Last updated: 2019-09-03
Rspective collects information through its websites on voucherjet.com (the “Websites”) in several places. This includes also sub-sites of the Website which you might reach by accessing the websites of one of our “Clients” which might contain a link to the Website or embed the Website into the Client’s own web-page.
In the company, the data protection officer can be contacted at this address email@example.com.
The Personal Data will be handled by Rspective in strict confidence according to the applicable legal provisions. The Personal Data will only be collected, processed and used for the purpose of providing our Websites functions, unless you expressly consent to other uses. The Personal Data is collected, used and processed electronically. No persons under the age of 18 will be actively marketed to, nor will they be knowingly asked to provide personal information.
Personal Data of Users may be transferred for processing to (recipients of personal data): Rspective’s accounting firm, the provider of hosting for the Website, the company providing technical support for the Website, the payment provider, the companies providing the CRM systems. The personal data collected by Rspective may also be disclosed to: competent state authorities upon their request on the basis of relevant provisions of law or other persons and entities—in the cases prescribed in the provisions of law. The entity processing Users’ personal data on the basis of the Transfer Agreement will process Clients’ personal data from the effective date of GDPR through another entity only upon prior consent of Rspective.
Please be aware that, where you reach our Website through the website of one of our Clients, we are not the data controller but only our Client’s data processor (“Processor”). For you this means that our Client, not Rspective is responsible for the data processing. Rspective will not determine the purposes and means of the processing. This will, instead, be done by the Client. Rspective will process all data solely on the documented instructions from the Client within the Framework of a so-called “Data Processing Agreement”. Our Data Processing Agreement governs our processing of any information obtained as a result of the customer or service provider relationship. You can read our commitment to customers and service providers, and our fair information practices in the Data Processing Addendum.
Our legal basis
Please be aware that the below legal bases will only be applicable where we process your Personal Data as a so-called “data controller” under the GDPR. Where a Client is using our Services to process your Personal Data on behalf of the Client, please refer exclusively to the Client’s privacy information to learn more about the Client’s legal basis for the processing.
Our legal basis for the processing of your Personal Data is your consent which you have
granted to us by checking the respective checkbox when providing your Registration Data
(Art. 6 (1) lit. b) GDPR).
PLEASE BE AWARE: Rspective will be processing and using the Personal Data for a duration of 2 years from the date of their initial collection. The Personal Data are deleted upon the lapse of the said period, unless their further processing is necessary on the basis of another legal basis.
You consent to the use of my Personal Data by Rspective for the purposes of market researches and sending me a newsletter for Rspectives own services and promotions. Any market research will rely solely on aggregated non-identifiable data based on broad demographic information and will not identify you as a person. We will never combine your Personal Data with data collected from third-party sources.
You can withdraw these consents and opt-out of having information collected by or submitted to Google Analytics, Woopra, Help Scout at any time by opting out at firstname.lastname@example.org.
We process your Registration Data also to fulfil our contractual relationship with you as a User (Article 6 (1) lit. b) GDPR)
In accordance with Article 6 (1) lit. f) GDPR, there are also cases where we are entitled to process your data without your consent because it is necessary to protect our legitimate interests (or the interests of third parties). In this respect, the purposes described below, for which we process your data, also represent legitimate interests. This means that we may process the Usage Data necessary to guarantee the security of our IT systems or the operation, functionality or improvement of our Websites without your consent.
In addition, we are legally obliged to process certain data in individual cases in order to
provide information to law enforcement authorities or tax authorities. We are also subject
to statutory storage obligations for business letters under commercial and tax law. In this
case, the legal basis will be Article 6 (1) lit. c). GDPR
Use of personal data
Rspective will only transfer or process Personal Data to third parties if this is required for statutory or legal reasons and/or if this is required in order to offer and implement services of Rspective to you and/or if Rspective has your explicit consent to do so.
Rspective will collect, process and use your Personal Data for the purpose of identifying,
delimiting and removing malfunctions and errors to provide User with a great overall
experience interacting with Rspective and when using the Website. Rspective may also
collect, process and use Personal Data that is necessary to uncover any unlawful use of the
VoucherJet systems and services. In accordance with prevailing legal provisions, Rspective
may provide information to criminal prosecution authorities and courts for prosecution
purposes. Apart from this, Rspective will not pass on your Personal Data without your
explicit prior consent. We may use your Personal Data for the following
- To operate, maintain, and improve our Websites, products, and services.
- To process and deliver contest entries and rewards.
- To respond to comments and questions and provide customer service.
- To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
- To link or combine user information with other personal information.
- To protect, investigate, and deter against fraudulent, unauthorized, or.
Personal data of the Website Users will be processed in the form of profiling on the basis of the number of sessions on Users’ pages. This means that we use your Personal Data to provide you with a personalized Website based on your personal preferences and interests, and to provide you with customized offers based on your previous behavior. However, we will never process and analyse your personal data within the framework of this user profile in such a way that this enables us to identify you as a person or leads to an automated decision which is legally valid for you or which similarly significantly affects you.
The User may file an objection to profiling by sending an email at email@example.com
aware that we do share aggregated,
anonymized information with our Clients to provide them with insights on the success of their
campaigns conducted through our Services. We will share such information with our Clients
exclusively in a non-identifiable aggregated manner.
Use of web analytic services
The following web analytic services are used to improve the user experience of our
- Google Analytics, a service for the marketing analysis of this website provided by Google Inc.,
- Woopra, an advanced analytics service provided by Woopra, Inc.,
- Help Scout, a customer support and ticketing software provided by Help Scout, Inc.
Rspective may send you a newsletter with information regarding its services or other promotional material. You may cancel the order at any time and free of charge by using the link in the newsletter or by sending an email at firstname.lastname@example.org
Consent to use of personal data
1. Push and Brain GmbH & Co KG, Löwenstraße 32, 20251 Hamburg, Germany will be collecting, processing and using of the personal data, i.e. first name, last name, email address, IP address and company name (“Personal Data”) through 2 years by “Rspective” period of 2 years and are deleted upon the lapse of the said period, unless their further processing is necessary on the basis of another legal basis.
2. I further consent to the use of my Personal Data by Rspective for the purposes of market researches and sending me a newsletter.
3. I can withdraw these consents and opt-out of having information collected by or submitted to Google Analytics, Woopra, Help Scout at any time by opting out at email@example.com.
VoucherJet allows its customers to integrate their uploaded promotions and end user data above into their web and mobile applications. This happens through an application programming interface (API) that delivers data stored on Rspective’s servers into these web and mobile applications.
The software development kits (SDK) provided by VoucherJet are optionally embedded in such applications and solely facilitate developers to request and work with promotions from Rspective’s servers. The APIs and SDKs may be used by Users to collect personal data of end users (e.g. tracking user on customer website or profile information).
In providing VoucherJet’s Service, VoucherJet provides tools to permit our customers to collect information about their end users on their site or service, which may include personal information or data about our customers’ end users as well as non-personally identifiable information or data about our customers’ end users, such as actions and activities on the User site, click data, referrer and exit page data, and other behavioral tracking data (all of which we call “Customer Data”). Rspective’s users may link personally identifiable data to the non-personally identifiable tracking data collected by Service. Customer Data is owned and controlled by Rspective’s Users, and any Customer Data that we maintain or process VoucherJet considers to be strictly confidential. VoucherJet collects and processes Customer Data solely on behalf of our Users, and in accordance with agreements with the applicable Users. VoucherJet does not use or disclose Customer Data except as authorized and required by our Users and provided for in our agreements with Rspective’s Users.
VoucherJet logs the originating IP address of an end user to avoid fraudulent use (e.g. denial of service attack).
Upon request, Rspective shall provide you with the information on the stored Personal Data relating to your person, free of charge and without delay. The information can be provided electronically, if desired. You shall also have the right to control the processing of the personal data referring to you included in Rspective’s data sets, in particular to remove the collected personal data referring to you both from the system belonging to Rspective and from bases of entities which have co-operated with Rspective, to restrict the processing of data and the right to portability of the personal data collected by Rspective and referring to you, in this to receive them in a structured form, to file a complaint to the supervising body if you find that your data are processed in violation of the law, and to lodge legal remedies before a court against the supervising body and the entity committing the violations.
Rspective additionally applies within the Website all necessary technical measures as specified in Articles 25, 30, 32–34, 35–39 of GDPR, providing for enhanced protection and security of the processing of Clients’ personal data.
The use of the Website proceeds in secure https connection. The communication between a User’s device and the servers is encoded by means of the SSL protocol. In the case of logging through external platforms facebook.com or google.com and twitter.com the level of security is prescribed by https://facebook.com/privacy/explanation and https://privacy.google.com/your-security.html, https://twitter.com/en/privacy.
Cookies & Web-tracking
You may enable the storing of Third-Party Cookies on your device at any time in line with the instructions of the browser producer. Failure to enable the Third-Party Cookies shall not cause lack of availability of the Website, in its entirety or in part, for you.
As you navigate the Rspective’s Websites, Rspective may also process Usage Data through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Rspective’s Websites (such as the Web pages viewed and the links clicked).
Use of log files
Rspective uses log files to process Usage Data. However, none of the information stored in our log files, including but not limited to IP addresses, is linked to personally identifiable information.
At Rspective we collect aggregate traffic statistics, internet protocol addresses, browser types, and internet service providers (ISP) using log files. Traffic statistics include, but are not limited to: referring/exit pages, date/time stamp, clicking patterns and click through rates. These data are used to streamline the User experience, improve the products and services provided to Users on the Rspective Website. All of this information is only used in the aggregate.
Your rights under the GDPR
You can assert the following rights against Rspective within the framework of the GDPR with
regard to your personal data:
Your right of access and copy pursuant to Article 15 GDPR
Your right to rectification pursuant to Article 16 GDP
Your right to erasure pursuant to Article 17 GDPR
Your right to restriction of processing pursuant to Article 18 GDPR
Your right to data portability pursuant to Article 20 GDPR.
You also have the right to appeal to the competent data protection supervisory authority either at the place where you reside or at our seat of business.
In addition to your right to withdraw your consent at any time and your right to object
to any data processing conducted for the purpose of direct marketing you can also object to any
processing conducted on the basis of Article 6 (1) lit. f) for reasons arising from your
We do not transmit your Personal Data to any third parties located in countries outside the EEA without implementing appropriate safeguards. Where your Personal Data are, for technical reasons, transferred to a country outside the EEA (a so-called "Third Country"), in all cases, we will ensure that an adequate level of data protection is guaranteed at all times. We make sure that the data recipients are either certified according to the so-called "EU Privacy Shield" (as is currently the case with Google or Woopra, for example) or that the so-called EU standard contract clauses are included in our contracts with these providers in order to guarantee at all times the security of the processing and an appropriate level of data protection.
Should you have further questions concerning the Data Privacy Provisions, please do not hesitate to contact us at firstname.lastname@example.org
Push and Brain GmbH & Co KG
20251 Hamburg, Germany
Data Protection Officer: A. Heerens
Email address: email@example.com