Last change: 15.07.2022
1. General information
The controller responsible for data collection and processing is:
Virtual Minds GmbH
D-79106 Freiburg im Breisgau
You can reach our data protection officer at
Attorney Daniel Raimer
Kanzlei Daniel Raimer
Phone: 0211 4167 4600
3. Information relating to the collection and processing of data through our products
3.1 What kind of products do we offer?
We enable our customers to participate in third party auctions for ad spaces and to display advertisement content on Websites. We provide the necessary interfaces and technologies to participate as efficiently as possible in these auctions. Our clients are mostly businesses that would like to advertise their products and services in digital media, for example websites or mobile apps. Therefore, we also offer our customers the possibility to display target group-specific or user-oriented advertising. The advertisers decide which ads are displayed to which user based on the interests and preferences of the users.
3.2 How do we collect data?
Cookies allow us to recognize your device when you visit other digital resources, which also include one of our products, by assigning a random number to your device.
The Cookies we use can only be read and used by us. The same applies to other providers with comparable or supplementary services to ours. When cooperating with these providers, it is advantageous if all parties involved agree on which user or device certain information refers to. For this reason we match our cookies with those of our partners.
With regard to Cookies, you have a wide range of options, which we explain in more detail under section 4.
3.3 What data does Virtual Minds collect?
We collect and use the following data about you:
- Information about your Internet connection: We collect data on which provider you use, how fast your connection is, and how high the latency is.
- Information about your browser: We collect information about which browser you use, its version, the language set in the browser, and information about how your browser handles cookies.
- Information about your device: In this regard, we collect information about the operating system used, language settings, the brand of your device, device identification numbers, mobile operating system manufacturer advertising identifiers (IDFA or AAID) and the IP address of the device.
- Information about the website/app you visit: The content of the website/app, the type and nature of the web page, the domain of the web page or name of the app, technical information about the web page including referral URL (i.e. the URL of the web page from which you were referred to a web page) and the date and time of the visit.
- Information about your behaviour on websites: This includes information about the content you viewed, how long you viewed it, and which apps you used.
- Information about advertising materials: We record which adverts you have been shown, whether you have clicked on them or visited the advertiser’s website or downloaded their app.
- Information about your decisions: We also receive information on whether you have been informed about processing activities or whether you have consented to them. We also receive information on whether you have partially or completely objected to the processing and/or whether you would like your Cookie to no longer be used in the future.
- Location information: If you are viewing digital content or advertising on a mobile device, we can collect your exact location if you have enabled the appropriate feature on your mobile phone. Regardless of whether you are using a mobile device or a stationary device, we can obtain your approximate location or postcode area.
Our products allow the exchange of data with other publishers, advertisers or third parties to make ads more relevant.
Additionally to the website operators and the businesses acting on their behalf, advertisers may have additional information about you themselves, or may purchase this information from so-called data management platforms. This data was previously collected about you and you were informed about its collection. We use this information to assess whether ads are relevant to you.
We do not collect your name, e-mail address or any other information that could be used to directly identify you.
3.4 What this policy does not cover
If you would like to receive more detailed information on the other companies engaged by the website operator and their processing, please contact them directly. If the website operator already supports the IAB TCF 2.0 (see section 3.11 below), you can also obtain much of this information via the CMP used by the website operator (see also section 3.11 below).
3.5 What this policy does not cover
We use the data described above for the following purposes:
3.6 To whom may Virtual Minds pass on your information?
3.6.1 Virtual Minds passes on an ID to partner companies that provide additional information about users or market such information for third parties. In both cases this additional data has been collected from you beforehand. If such additional information about you is available, we will check whether it is legally permissible to pass it on to us. If this is the case, we can use this additional data to make a more informed decision on whether or not to display ads to you and hence whether to bid on an advertising space. We further pass data on to companies that analyse the effectiveness of our advertising efforts. The data will only be passed on if we have received the relevant consent or if we can invoke our legitimate interests. Further, Virtual Minds may share information related to advertising inventory that attracted a committed interest of our clients with such clients. Such data may include personal data. Our clients may only use such data in connection with our platform and must not disclose the data to third parties.
Virtual Minds is a service provider, so we work with partners when processing data. This also includes those partners on whose websites or mobile applications we collect data through the cookies described above. With some of these partners, we are joint controllers within the meaning of data protection law (Art. 26 DSGVO). This joint responsibility generally relates to the collection and transmission of data to us. A current list of those partners with whom we are jointly responsible is available on request.
We and our partners have divided certain tasks and activities among each other within the framework of joint responsibility. The division is as follows:
Virtual Minds provides the partner with a technical solution (here tag) which the partner integrates on its offers. This tag enables the collection of the data described in more detail above. Virtual Minds also supports the partner, in particular in the processing of inquiries from affected parties..
Each of the parties shall in particular ensure that the necessary data security is given. Both we and our partner will fulfil our reporting and notification obligations individually, but will support and inform us to the extent necessary.
You can exercise your rights described below as a data subject [Ref.: 3.10] both towards us and towards our partner. We and our partner are liable for any processing that does not comply with the provisions of the GDPR in accordance with Art. 82 GDPR.
Do you have any further questions on the subject of joint responsibility? We would be happy to provide you with further information on our cooperation with certain partners.
3.6.2 We may also disclose your information to governmental authorities, courts or third parties if such disclosure is necessary or appropriate to enforce or defend our claims, interests or rights, or to protect the vital interests of the data subject or another individual.
3.6.3 We may also disclose your information to an acquirer or potential acquirer of our business or parts of our business to the extent that your information is related to the part to be acquired and to the extent necessary to enable the acquirer or potential acquirer to evaluate our business or the part of our business in question. In the event of an acquisition, we may also transfer your data to the acquirer.
3.7 On what legal basis does Virtual Minds process your data? ?
Virtual Minds always complies with the applicable data protection laws and regulations when processing your data. For some processing operations, our legitimate interests form the basis for the processing.
Other processing operations require your consent. Our respective customers make sure that you have given such consent before we process your data and of course we verify this. Of course, you have the possibility to change your mind and to withdraw your consent, we explain how to do this under section 4.
3.8 How long do we store your data?
We do not store personal data for longer than is necessary for the purpose for which it was collected, unless we are entitled or obliged by law to continue to store it. Information that is not stored in connection with the cookie ID assigned to your device is regularly deleted by us after three days.
The third party Cookies we use are generally valid for up to 180 days, after which time they and the data associated with them are deleted. If the Cookie on your device is recognized by us again within this period, the runtime is extended again by 30 days. The information associated with the Cookie can be stored for up to 24 months in agreement with our customers. Such data that we have received from a data management platform (see above) will be deleted after 30 days regardless of the Cookie’s duration.
3.9 Transfer of your data abroad
Virtual Minds and its servers are located in Germany. However, some of our Partners and Customers are located outside of the European Union. If we transfer your data to a Partner or a Customer who is based outside of the European Union, we will ensure that data is processed with an appropriate level of protection. To this end, we make use of legally provided and permissible measures, such as an adequacy decision by the European Commission (cf. Art. 45 para. 1 GDPR) for the third country concerned; the use of the European standard contractual clauses (cf. Art. 46 para. 2 c) GDPR) or other effective safeguards provided for in the GDPR.
Standard contractual clauses for the transfer of personal data from the European Union to third countries
3.10 Your rights
It is important to us that you do not lose control over how we handle your data. Under the General ´Data Protection Regulation (“GDPR”), you have the following rights towards us:
3.11 What is the IAB Transparency and Consent Framework (IAB TCF)? ?
We participate in the IAB TCF. The IAB TCF is a common standard for dealing with transparency obligations and obtaining consent in connection with online advertising. The companies organised in the IAB TCF undertake to comply with standards that go beyond the GDPR. Virtual Minds is registered as a so-called vendor under the IAB TCF. Further information about the IAB TCF can also be obtained from the following link: https://iabeurope.eu/tcf-2-0/. We recommend all our customers to also register with the IAB TCF. If you use a service from a company that is already registered as a Publisher in the IAB TCF, you will benefit as the IAB TCF offers you transparency and control over the use of your personal data.
On a technical level, the latest version of the IAB TCF (currently version 2.0) allows each participating company to understand which processing activities are permissible in individual cases based on the user’s choice.
For you as a user, the IAB TCF means a highly granular freedom of choice. Of course, you can still either agree or disagree with the use of your data in general. In addition, you can precisely understand who will receive your data and for what purposes. Of course, you are free to exclude individual recipients or to limit the purposes for which your data is used individually. Limiting the purposes is only excluded in exceptional cases, such as security-relevant processing activities.
We recommend that you consider the various options available to you under the IAB TCF in order to make a decision that best suits your interests. You will receive more information on these options and how to implement them in the following section.
3.11 Switzerland: country-specific regulations
In addition to the above provisions, the following applies to Switzerland:
- All references to the GDPR are replaced by the corresponding provisions of the Swiss Federal Data Protection Act, as amended.
- Personal data is processed in Germany, France, the Netherlands, Norway, Lithuania, the UK and the USA. If we also share your personal data with partners in the third countries UK or USA, we will safeguard this transfer by concluding standard contractual clauses with the data recipients to the extent required by law.
- For Switzerland, the following supervisory authority is responsible: FDPIC: https://www.edoeb.admin.ch/edoeb/de/home/deredoeb/kontakt.html
4. Your choices
It is particularly important to us to enable you to make an informed decision about the use of your data. To this end, we would like to explain the options available to you at a glance. Should you have any questions, especially regarding the options we ourselves offer, please contact us at firstname.lastname@example.org.
However, generally speaking, the following applies: If you delete the cookies stored on your device or update the Mobile Advertising ID (MAID) of your device, all previous choices will be lost. You will then have the opportunity to choose again as soon as a cookie is set again.
Finally, it should be noted that these choices do not mean that you will no longer be displayed ads. However, the ads that are still displayed may be less relevant to you.
4.1 Using the CMP or the settings on the website
As described above, your data is collected when you visit websites or use apps. Those websites that participate in the IAB TCF especially offer you detailed possibilities to influence the processing of your data. For this purpose, these websites usually make use of a third-party provider, a so-called CMP (Consent Management Platform). This CMP clearly shows you your options when you visit a site. The CMP will allow you to generally agree to or reject the processing of your data. However, the CMP also allows you to make more minute choices. If you so wish, you can decide on each purpose and recipient separately. The CMP recognizes you by means of the Cookie. This does not apply if you have deleted the Cookie in the meantime or if it has been deleted due to time lapse. After you have made your choice in the CMP, the CMP will then ensure that this information is forwarded.
Since we and the publishers (website operators) want to offer you the greatest possible freedom of choice, these options are available to you on each individual website and generally only apply to that individual website. We understand that your choice may be different depending on the website operator.
4.2 Use of our opt-out possibility
Independently of the website operators, you can also object directly with us regarding the processing of your data by us. This option is also bound to the Cookie. You can make these settings under the following link: Opt-Out
Your advantage: This choice then applies to all our services for all our customers. However, it only applies to our processing activities and has no effect beyond that. Other contractual partners of the Publisher and its partners are not covered by this choice.
4.3 Deletion or blocking of Cookie IDs
While we have defined the term “Cookie” broadly elsewhere in this document, here we mean the cookie in the technical sense. These explanations therefore only apply if you use a browser and cannot be applied to the use of apps. In addition, these explanations refer to third-party cookies, (i.e. those that do not originate from the website operator).
Many browsers already offer you the possibility to handle cookies automatically. They often offer the following options:
- Cookie blocking
- Automated deletion of cookies at a certain time (e.g. after closing the browser).
- Manual deletion at a desired time
The browser you are using may offer additional or different possibilities. In order to make it as easy as possible for you to use these functions, we have put together links to the corresponding instructions or assistance pages of the most frequently used browsers:
- Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
- Chrome: https://support.google.com/accounts/answer/32050
- Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
However, as mentioned above, deleting cookies results in a new cookie being set the next time you visit a website, for which previous choices do not apply. If you want to prevent this completely, you may wish to block the cookies.
4.4 Mobile Advertising ID (MAID)
Unlike those in websites, advertisements displayed in programs (apps) on mobile phones use the so-called MAID to identify the device. This MAID is a unique identifier that is stored on your device and linked by apps. Its use and purpose is otherwise equivalent to a Cookie.
If you wish to object to our use of the MAID, you can do so by clicking on the following link: Opt-Out. The app you are using will also provide you with appropriate options. Where these options can be found and how they are designed can vary from app to app.
If you would like to make more fundamental changes with regard to the MAID, there are two main options available to you. You can renew the MAID or block it completely.
For devices running the Apple operating system, you can find this information under preferences, then under privacy, then under advertising. There you have the possibility to limit or reset Ad-Tracking.
If you have a device running the Android operating system, you can usually find these settings under “Settings”, then under “Google” and then “Advertising”.
We are aware that many of the concepts explained here are complicated. Some important answers can therefore be found in the following FAQ:
5.1 Does Virtual Minds know who I am?
No. Although we make some assumptions about your person, we do not know any directly identifying information about you. We do not know your name, e-mail address, postal address or telephone number. We are also not interested in finding out about them.
5.2 What about my IP address?
We know your IP address, but we only use it in its unabridged form to send your device the ads, or to enable others to do so. Otherwise, we use your IP address only in a highly abbreviated form, which is no longer sufficient to identify you or your device directly.
Just as a side note, let us be clear that it is theoretically possible to identify you by your IP address. However, this is an extremely complex process which, if at all, is only possible in cooperation with your internet service provider (ISP). However, your ISP will only disclose the relevant information on the basis of a court decision. It is therefore not possible for us to identify you by your IP address.
5.3 You say you “personalize” advertising, but then you must know more about me!
The personalization is based on probabilistic assumptions and is therefore only a probability value. The assumptions may or may not apply to you. Often the segments formed are so vague that they apply to a large number of people. For example, if we estimate that you could be between 20 and 28 years old.
5.4 Which cookies are stored on my device, can anyone read these cookies?
A cookie can only be read by the person who set it. This way ADITION can only read its own cookies. The same applies to the website operators. You can easily find out which cookies are stored on your device. You can find this information in the settings of the browser you are using. There you will also find the options for deleting the cookies described in section 4.3.
5.5 I do not want to be shown online advertising, is it enough to block/delete cookies?
5.6 Why is there online advertising at all and what is the benefit of personalized advertising online?
Many providers make their services available to the user free of charge. At the same time these providers often have high costs, relating to employees, the operation of the website and other expenses.
One of the few options available to website operators to finance their services is the possibility of displaying ads. This enables a free, diverse range of services on the Internet that are accessible to everyone, regardless of the financial position of the individual user.
The website operator as well as the advertisers have an interest in showing you the most relevant advertising. As such, the website operator does not want the ads to be perceived as annoying. This is not the case if, for example, the ad is relevant to the user and he does not encounter it too often. For both purposes, however, the companies involved must be able to distinguish one user from another. The Cookies already described serve this purpose.
At the same time, it is important to all parties involved that you have the most precise options possible available to you to determine how your data will be used for advertising purposes. We firmly believe that the acceptance of online advertising depends crucially on you, the recipient, being able to understand and influence the processes behind it.
5.7 Many players are involved in the description. What do these companies do?
Online advertising is a complex industry with many players. But it can be presented in a simple way: There are companies that act on the side of the providers of websites and other digital content and help them to market the advertising inventory, and there are companies that help advertisers to target the ads as accurately as possible.
Content providers usually do not have the technical means to offer and market the advertising inventory themselves, so they work together with an SSP (Supply Side Platform). This supply side platform recognises when a user visits the site and an advertising space is available. At that moment it sends out a corresponding offer.
This offer is received by the DSPs (Demand Side Platform). These DSPs work for advertisers (directly or through an agency). They determine whether the advertising space is interesting to the advertiser. If it is, they place a bid, should several actors place a bid, the highest bidder wins.
All parties involved benefit from having additional information about the users who are currently visiting digital content. Some advertisers therefore collect information about users on their own websites (e.g. when you visit a webshop). This information can in turn be used by both SSPs and DSPs to determine which user should be advertised to.
Of course, this presentation is a little simplified, but it reflects the basic relationships and functions of the individual participants.