Privacy Policy

I. Preamble & definitions

1. Mandora Media adheres to EU General Data Protection Regulation ("GDPR") (679/2016 EU) on the protection of individuals with regard to the processing of personal data and on the free movement of such data..

We are informing you in this privacy policy about the nature, scope, and purpose of the personal data collected, used and processed by Mandora Media as well as your legal rights for protection of your personal data and its use.

Collection and processing of your personal data includes electronic processing and storage of your data. Personal data is used exclusively for internal use or for fulfilling contractual obligations and are only disclosed to third parties in the context of fulfilling contractual obligations. Sensitive data is submitted secured or encrypted within external processes.

2. Except where the context otherwise requires, the following principles will apply in interpreting the terms and words used in this privacy policy: :

• Words describing the masculine, feminine or neuter gender include any of them, and the singular includes the plural and vice versa.
• Clause or section headings are for ease of reference only and do not affect the meaning of this privacy policy.
• A reference to a party includes its executors, administrators, successors and authorised assignees.
• Words and expressions describing natural persons include partnerships, legal persons (e.g. incorporated companies), associations, governments, governmental and local authorities and agencies.

II. Privacy Policy

1. Nature of collected data

Contractual data
Mandora Media collects, processes and stores personal data, which you enter at the time of placing an order as well as data related to order and payment progress.

Customer data
Mandora Media collects, processes and stores, which you place on our server sytems, if you are using our services. This includes creation of backups on our systems.

Contact data
If your personal data includes communication data (like e.g. email address, phone number), you will agree that we are contacting you using the disclosed channels for fulfilment our contractual obligations or responding to your enquiries. You can revoke this consent at any time for the future of course.

Logfiles:
If you are using Mandora Media websites your computer automatically submits user connection data. User connection data is automatically stored in log files. This is particularly true in case you are placing an order, log in to CustomerCenter and also when you up- or download data. Logfiles are also created, when users visit your website, if this is served on our systems.
Following data is stored in automatically created log files:

• IP address of the used device from which services or websites are accessed
• user agent
• page requested
• HTTP status code
• bytes served
• referrer (previously visited web address)
• technical information about your operating system
• date and time data (timestamp)

Logfiles are also automatically created when establishing contact by email or phone. Depending on the means of communication you phone number or IP address respectively as well as further technical data will be submitted automatically.
Mandora Media stores IP addresses only as far as these are required for provision of our services or to comply to legal duties of documentation. Otherwise ip adresses are deleted or made anonymous.

Cookies
Mandora Media uses cookies on its websites. A cookie is a small piece of data sent from our website and stored on the you computer by your web browser while you are browsing. These cookies contain data, which can be retrieved when accessing Mandora Media's websites and thus allow a more efficient and convenient use of our web services.
Cookies serve optimisation of our services and allow the use of certain features. Processes like placing an order on our website or logging in to your customer account can only be completed by using cookies. Furthermore cookies are used to collect statistcal data about our websites, like e.g. the number of visitors.
Mandora Media uses session cookies and permanente cookies. Session cookies are deleted automatically when closing your web browser. Permanent cookies remain on your computer beyond that until their purpose is served and they are deleted then.
You can disable cookies anytime in your browser's settings. By disabling cookies in your browser you permanently refuse setting of cookies. Furthermore you can delete already set cookies in your browser or using other software. This is possible in all common browsers.
If you disable setting of cookies in your browser you may not be able to use all functions of our websites.

Pixel
Mandora Media uses pixels on its websites. Pixels are small graphics or picture elements on websites, which may be used for collecting connection data for statistical analysis.

Tracking tools
Mandora Media uses Matomo's web traffic tracking. When visiting our websites a unique web analytics cookie will be set on your device, which collects several statistical data for further analysis. Collected data is processed and stored exclusively on our own server systems and not on any external server systems ("cloud").
If you have disabled setting of cookies in your browser already, this unique web analytics cookie will no be set at all.

Google AdWords
Provider of Google Adwords services is Google Inc. If you are referred to our website from a Google ad a so called conversion cookie is set on your device. Conversion cookies are deleted automatically after 30 days are not used for identification. As long as a conversion cookie has not expired it may be used to detect if certain pages have been accessed on our website - like e.g. shopping cart of an online shop.
Using conversion cookies Mandora Media as well as Google can Mit dem Conversion-Cookie können sowohl Mandora Media als auch Google nachvollziehen, ob der Besucher über eine Google AdWords Anzeige auf unsere Website gelangt ist und einen Umsatz generiert haben.
Data retrieved from conversion cookies are used to measure success of relevant Google AdWords campaigns and thus to improve our future Google AdWords campaigns.
Neither Mandora Media nor other advertisers at Google receive data from Google, which could be used to identify visitors of our website. Mandora Media does not transfer personal data to Google. IP addresses collected on Mandora Medias website are submitted to Google only anonymised.
You can dissent to personalised ads from Google at
https://support.google.com/ads/answer/2662922?hl=en
At the mentioned website you can specify your preferences for personalised ads from Google. You will find further information as well as the current privacy policy of Google at https://policies.google.com/privacy?hl=en&gl=en.

Bing Universal Event Tracking (UET)
On our website data is collected and saved using the technologies of Bing Ads from which usage profiles are created using pseudonyms. This is a service of the Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. This service enables us to track the activities of users on our website if they accessed our website via advertisements from Bing Ads. If you access our website via an advertisement of this nature, a cookie is set on your computer. A Bing UET tag is integrated on our website. This is a code which, in combination with the cookie, saves some non-personal data about the usage of the website. This includes, among other things, the time spent on the website, which areas of the website were opened and via which advertisement the users accessed the website. No information about your identity is collected.
Information collected is transmitted to Microsoft servers in the USA and is stored there for a period of at most 180 days. You can prevent the collection of the data generated by the cookie with respect to your usage of the website as well as the processing of these data by deactivating the use of cookies. This may lead to a restricted functionality of the website.
Furthermore Microsoft can possibly track your usage behavior across several of your electronic devices using so-called Cross-Device Tracking and is thereby able to display personalized advertising on or in Microsoft web pages and apps. You can deactivate this behavior under https://account.microsoft.com/privacy/ad-settings. Further information about the analysis services of Bing can be found on the Bing Ads website ( https://help.bingads.microsoft.com/#apex/3/en/53056/0 ). Further information about data protection at Microsoft and Bing can be found in Microsoft’s data protection policy ( https://privacy.microsoft.com/privacystatement).

Data of applicants
Mandora Media processes personal data, which are submitted from the applicant during recruitment. This includes name, address, phone number and email addresses as well as any other personal data, which are mentioned in your application papers.

2. Legislative foundation of retrieved data

Mandora Media tretrieves and uses your personal data for processing your contract and rendering of your ordered services, for improving our websites and services as well as for customisation to your needs, for providing updates and upgrades, for provision of information concerning your used services as well as for creating bills and tracking of payment progress.
Legislation foundation for data processing, for which we acquire your consent is Art. 6 I lit. a GDPR. If processing of personal data is required for fulfilling a contract data processing is based on Art. 6 I lit. b GDPR. The same is true for processing data for pre-contractual measures like e.g. enquiries concerning our services or products. If Mandora Media underlies a legal duty, which requires processing of personal data - like e.g. fulfilling tax duties - data processing is based on Art. 6 I lit. c GDPR. Last but not least data processing may be based on Art. 6 I lit. f GDPR. This is true for data processing, which is not based on any of the before mentioned legal foundations, if processing of personal data is required for protection of legitimate interest of Mandora Media or of third parties, if the funamential rights and freedoms of the relevant person are not prevailing. Mandora Media is allowed to such data processing, as this is mentioned explicitely by European legislators. Legitimate interest is assumed usually, if the concerning person is customer of the part yresponsible.
If processing of personal data is based on Art. 6 I lit. f GDPR, then the legitimate interest of Mandora Media is constituted by performance of business operation.
Personal data of applicants is process acc. to Art. 88 GDPR in conjunction with § 26 BDSG (neu).

3. Categories of recipients

Registries and registrars
Mandora Media is obligend to submit certain personal data for registration of domain names to registries and / or registrars. These data is tored in the database of the relevant registry and is published in differeing extend in the whois service of the relevant registries. (Please see as well whois policy of relevant registries like e.g. www.denic.de or www.nic.at or other registry of relevant top level domains)

Data processors
Mandora Media submits different personal data as controller to its data processors within order-data processing. Mandora Media has ensured the safety of your personal data by concluding Data Processing Agreements with its data processors. Our data processors may be categorised as follows:

• Operation of services, service and mantainance of hard- and software
• Provision of services like e.g. payment providers, shipping providers, destruction of data storage media
• Insofar online payments are processed by payment provider WireCard Bank AG the privacy policy of WireCard Bank AG ensures safety of your payment data:
  https://www.wirecardbank.com/GDPR

Mandora Media discloses personal data to authorities and third parties only due to legal obligations or court order. Disclosure towards authorities due to legal obligations may be based on defence of risk or criminal prosecution. Personal data towards third parties is only disclosed, if this is required by law, as e.g. in case of infringement of intellectual property rights.

4. Submission of data in third countries

Registries
Mandora Media submits personal data to the relevant registry for top level domain name registration. This data submission is based on Art. 49 Abs. 1 lit. b GDPR.

5. Period of storage

Mandora Media is processing and storing data only as long as this is required to meet the purpose of storage or as long as it is required by law. Purpose of storage is usually met with termination of the contract of fulfillment of the contract.
You can update / delete data yourself, which you can store yourself in our systems while using our services. This data will be deleted automatically from our systems when your contract is terminated.
Copies in our backup systems will be deleted automatically with a certain delay due to technical reasons.
Processing of contractual data is limited at the time of termination of contract. contractual data is deleted after expiration of legal term of retaining data.
Data, which you have submitted as an applicant to Mandora Media will be deleted after max. 6 months.

6. Your rights

Right to information
You have the right to obtain information about your personal data stored in our systems at any time and at no cost or to retrieve a copy of already given information.

Right to correction
You have the right to correction of your personal data without undue delay. Furthermore you have the right to completion of incomplete personal data taking the reason for processing into account.

Right to deletion
You have the right to deletion of your personal data without undue delay in following cases and if processing of your data is not required:

• Your personal data was collected or processed for a purpose, for which these are not required any more.
• You are revoking your agreement, on which processing of your personal data was based and there is no other legal base for processing your data.
• You are objecting processing of your personal data according to Art. 21 Abs. 1 GDPR and no preceding legitimate reasons for processing exist or your are objecting processing of your personal data according to Art. 21 Abs. 2 GDPR.
• Your personal data was processed illegitimately.
• Deletion of your personal data is required for for compliance with a legal obligation in Union or Member State law to which Mandora Media is subject to.
• Your personal data was collected in relation to the offer of information society services referred to in Art. 8 Abs. 1 GDPR.

Right to restriction of processing
You have the right to obtain restriction of processing from Mandora Media if one of the following applies:

• You object to the accuracy of your personal data for a period enabling Mandora Media to verify the accuracy of your personal data.
• Porcessing of your personal data is illegitimate and you oppose deletion of your personal data and request restriction of use of your personal data instead.
• Mandora Media requires your personal data for for the purpose of processing no longer, but you require the data for establishment, exercise or defence of legal claims.
• You have objected to processing of your personal data acc. to Art. 21 Abs. 1 GDPR and verification is pending whether the legitimate grounds of Mandora Media override those of you.

Right to object
You have at any time the right to object to processing of your personal data for direct marketing purposes.
You have at any time the right to object to processing of your personal data, which were collected acc. to Art. 6 Abs. 1 lit. e or f GDPR.
Mandora Media will not process your personal data in such case any more, except Mandora Media verifies preceding legitimate reasons which override you interests, freedoms and rights
or processing your data is required for establishment, exercise or defence of legal claims.

Right to revocation of data protection consent
You have the right to revoke your consent to processing your personal data.

Right to data portability
You have the right to obtain your personal data collected from Mandora Media in a structured, commonly used and machine-readable format.
Furthermore you have the right to transfer these personal data to an other controller without interference from Mandora Media
if processing of your personal data is based on Art. 6 Abs. 1 lit. a GDPR or Art. 9 Abs. 2 lit. a GDPR
or on fulfilling a contract acc. to Art. 6 Abs. 1 lit. b GDPR and processing is executed by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Mandora Media.

Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority in the member state of your residence or your workplace or of the place of an assumed violation of your rights, if you are of the opinion that processing of your personal data infringes EU GDPR.

7. Automated individual decision-making - profiling

Mandora Media does neither use automated individual decision-making nor profiling.

8. Regulations for submitting personal data, requirement for conclusion of contract, consequences of not providing personal data

Submitting or providing personal data may be a legal requirement - e.g. by tax regulations - or be a requirement of contractual needs - e.g. data of contracting partner. Provision of your personal data to Mandora Media may be required for concluding the contract, which have to be processed by Mandora Media as a consequence of conclusion of the contract.
It is required, that you provide your personal data to Mandora Media in order to conclude a contract with Mandora Media.
If you do not provide your personal data in such case, the contract cannot be concluded.
Revoking your consent of processing your personal data leads to non-continuation of the contract or non-fulfilment of the contract. Please contact us before revoking your consent of processing your personal data, so that precise consequences of your revokation can be presented.

9. Contact data

Controller for the purposes of the GDPR:
Mandora Media GmbH
Internal Data protection office
Mühltalstrasse 38
DE-94032 Passau

For any questions or if you want to assert your legal rights please contact us at any time using our contact form at https://www.mandora.media/anfrage/ or directly by email to privacy@mandora.media.