- Details of the Controller
- Information on the Types of Data Processed and Their Origin
- Processing Purposes & Legal Bases
- To Whom do we Transmit Your Data?
- Transmission to Countries Outside the EU or the EEA
- How long will my data be stored?
- Information on The Voluntary Nature of the Information
- Information About Your Rights
- Information About Your Right of Objection
We have always taken the protection of your personal data very seriously and take appropriate organisational, contractual and technical measures to protect your data from unauthorised or unlawful processing and against accidental loss, destruction or damage.
- 1 1. Details of the Controller
- 2 2. Information on the Types of Data Processed and Their Origin
- 3 Processing Purposes & Legal Bases
- 4 To Whom do we Transmit Your Data?
- 5 Cookies
- 6 Affiliate Systems
- 7 Public authorities
- 8 5. Transmission to Countries Outside the EU or the EEA
- 9 6. How Long Will My Data Be Stored?
- 10 7. Information on The Voluntary Nature of the Information
- 11 8. Information About Your Rights
- 12 9.Information About Your Right of Objection
Responsible for data processing is Ideawise Limited, Room 604, Alliance Building, 133 Connaught Road, Central Hong Kong, Hong Kong. Its representative is SmH ServiceCenter.de GmbH, P.O. Box: 20 04 34, 13514 Berlin.
Ideawise Limited is also meant when the terms “we” or “us” are used below. You can contact our data protection officer at:
Please note that we are a company based outside the European Economic Area (“EEA”). As far as you use our service and data is processed, these data are transferred to a so-called “third country”. Details can be found in section 5 below.
If we provide the Service for your use, we process personal data from various sources. This is data that we collect automatically – for example when you visit a website – as well as other data that you have additionally provided to us.
a. Types of Data That We Automatically Collect
When you visit our website, you submit technical information to our servers. In any case, this data is recorded every time you visit our website:
Each time a page is accessed, access data is stored in a file, the so-called server log. The following data is stored:
The time, the status of your website visit (status means in this case whether the visit of the website was successful or not) as well as the request that your browser has made to the server to open the page, the amount of data transferred and the website from which you came to the requested page (referrer), and the product and version information of the browser used (user agent).
b. Types of Data You Transmit to Us
In addition to the data we receive from all website visitors, we also process additional data if user make this available, depending on how they use the Service. For instance, if you make use of a commenting functionality or when sending a message via a contact form, this type of data will then also be processed. When you contact Customer Service, written communications between you and our service team staff and notes on such transactions are stored so that we can provide uninterrupted customer service when the communication thread is followed up by other members of our service team.
We process your data exclusively for the following defined purposes:
- To allow you and other users to use the Service and to ensure its functionality
- To display advertising tailored to your interests (including participation in prize competitions and sweepstakes)
- To continuously improve the service offer and to correct errors
- To detect and prevent fraud attempts
- To ensure the protection of minors
- To disclose your personal data to third parties if we are legally obliged to do so
- To assert legal claims and to defend against legal disputes
- To ensure IT security and operation of our systems
In doing so, we rely on various legal bases in accordance with the so-called General Data Protection Regulation, a European Union legal framework for the standardisation of data protection law (“GDPR” for short). We refer in detail to the following legal bases:
When you visit the website, you agree to our cookie guidelines and to the processing of your IP address in a cookie bar. If you have given your consent to the processing of personal data for specific purposes, this consent ensures the legality of such processing.
Accordingly, if we process your data, it is because you expressly allowed us to do so. Your consent is therefore the most important legal basis for the processing of your personal data by us. If you provide us with information about your sexual orientation or preferences, we will process this data principally on the basis of your consent.
Safeguarding legitimate interests
Legal requirements or public interest
In addition, we are legally obliged to provide certain information to criminal prosecution in individual cases upon request.
We treat your personal data with care and confidentiality and will only pass them on to third parties to the extent described below and not beyond.
a. To other users:
As our Services are blogging platforms, it is in the nature of things that we transmit your comments and other communication you conduct publicly or with other users to these corresponding users of the Services at your request and on your behalf.
b. To Group Companies:
We transfer data to our affiliated companies, which form a group with us, within the framework of strict protection requirements. This is the case, for example, when you make a customer service request. We will then forward this request to SmH Servicecenter.de GmbH, a service company associated with us, and our Community Management and Marketing team at Playamedia S.L. receive the information they need to ensure the accuracy, lawfulness, security and functionality of the Services.
c. To Third Parties & Cookies
In addition, we transmit data to external service providers that enable us to provide the Services. These include hosting providers and providers of analytics platforms. We require these service providers to comply with strict rules to ensure the security of your data when processing personal data on our behalf. Such processing is generally based on contractual regulations. When we state – further below – that there is ‘no adequate level of data protection’, it means that there is no adequacy decision by the European Commission – in these cases, however, we regulate the processing on the basis of other guarantees, such as Data Processing Agreements or standard data protection clauses.
We use our own cookies (so-called “first-party cookies”) to analyze web traffic, tailor services, content and ads to your needs and interests, measure the effectiveness of advertising campaigns and promote confidence in and security of the service. In addition, we use first-party cookies to distinguish the various users from each other and, in conjunction with the log files of our web server, to calculate the total number of people who visit the service. The web usage data collected in this way helps us to receive the necessary feedback to continuously improve the service.
Users can prevent the acceptance of first-party cookies by configuring their browser settings so that they do not accept cookies at all. However, if this setting is made, you may not be able to use certain current or future elements of our Service.
Google LLC is a privacy shield certified provider from the USA. Google Analytics is used to analyse the behaviour of users of our services. With the help of Google Captcha we determine with certain actions whether the visitor is a human being or a machine. For information on Google Adwords, please refer to the information about Affiliate Systems further below. YouTube videos are embedded in our service in “enhanced privacy mode”. While no YouTube cookies are set by this particularly data protection-friendly type of embedding, calling up the pages nevertheless leads to a connection with YouTube and the DoubleClick network. A click on the video can trigger further data processing processes over which we no longer have any control. Here you find a resource to opt-out of Google Cookies. (https://tools.google.com/dlpage/gaoptout?hl=en)
This storage service (processing in the USA and Europe, Privacy-Shield certified) is used by us to store encrypted backups.
Cookies set by the Wordfence Security plugin are used to protect the site against malicious attacks. Wordfence only uses data about your visit and does not store personally identifiable information and therefore does not require user consent.
We use the following affiliate systems to win new customers for our community. We measure success on the basis of registrations and sales. We use: Adcell, Adwords together with the Google Tag Manager and Hasoffers.
Hasoffers/TUNE: We use Hasoffer’s affiliate program, a service of TUNE, Inc.. This service places tracking cookies. As soon as you click on an advertisement with the partner link, a cookie is set. In addition, the ads contain so-called tracking pixels. The information generated by cookies and tracking pixels on the use of this website (including the IP address and delivery of advertising formats) are transmitted to a server of TUNE, Inc. and stored there. Among other things, TUNE Inc. / Hasoffers recognize that the partner link on our website has been clicked. This data can not be aggregated with other stored data. For more information on how Hasoffers processes data see https://www.hasoffers.com/privacy-policy/.
Google Adwords: We also use Google Adwords together with the Google Tag Manager to promote our website in Google’s search results and third-party sites. For this purpose, Google sets a remarketing cookie that contains a pseudonymous CookieID and information about the use of our website. This way, we can show you interest-based advertising. You can disable the cookie using the link here: https://tools.google.com/dlpage/gaoptout?hl=en
We transmit data to authorities in the event of a legal obligation based on a request for information from the respective authority.
All servers of the Service are located in the EEA, hence initially your data does not leave the EEA technically, but the technical provision and processing of the data for the operation of the service takes place in the European Union.
However, when you submit data to us, it will be legally transferred to a country outside the EEA, as we have our registered office in the People’s Republic of China. In addition, our development company is also based in China, from where it has technical access to the servers in the European Union. According to the GDPR, China is a so-called “third country” in which an adequate level of data protection cannot be guaranteed in principle; there is no corresponding decision on adequacy and there are also no specific guarantees to compensate for this deficit. However, we have concluded strict Data Processing Agreements and standard contractual clauses that work towards a secure level of data protection. What do we mean with the information about China? It means that we may have to transmit data to government agencies there under less stringent conditions than is the case within the EEA. The legal hurdles to the protection of personal data in China are thus generally regarded as lower from a European point of view, as would also be the case for processing in Australia, Russia or India, for example. Until 17.05.2018 (= preparation of this document) there has not been a single case of disclosure of Data to Chinese authorities, also because as a former British colony, Hong Kong continues to enjoy a special status until at least 2047, despite belonging to the People’s Republic of China. In preparation towards GDPR, we have committed ourselves to full transparency in accordance with the GDPR and are therefore happy to comply with this legal requirement and our voluntary commitment, although this transparent approach may at first unsettle some users.
6. How Long Will My Data Be Stored?
We process and store your personal data as long as it is necessary for the fulfilment of our contractual or legal obligations. Therefore, we store the data only as long as our contractual relationship with you exists and also after termination only, as far as the laws of the Federal Republic of Germany and the People’s Republic of China require this. If the data are no longer necessary for the fulfilment of such obligations, they will be regularly and promptly deleted, unless their further processing is necessary for the protection of legitimate interests or for the preservation of evidence within the framework of statute of limitations.
7. Information on The Voluntary Nature of the Information
You are not required by law to provide us with the above information. In principle, the relationship that you have entered into with us by agreeing to the Cookie Banner or by giving any other consent does not give rise to any obligation to provide this personal data. However, the transmission of automatically collected data is a basic prerequisite for using our Services. Furthermore, you may not be able to use the Services, or only to a limited extent, if you do not provide us with certain data or object to their use.
8. Information About Your Rights
You can assert the following rights:
- Your right to access to information under Article 15 GDPR,
- Your right to rectification under Article 16 GDPR,
- Your right to erasure under Article 17 GDPR,
- Your right to restriction of processing under Article 18 GDPR and
- Your right to data portability under Article 20 GDPR.
If you have any questions in this regard, please contact our customer service at:
You can revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent issued to us prior to the validity of the GDPR, i.e. before 25 May 2018. However, this revocation will then only be effective for the future. Processing that took place before the revocation is not affected by this.
In addition, you have a right of appeal to the competent data protection supervisory authority.