The protection of your privacy is extremely important to us. This data protection declaration provides information on how and for what purpose we process personal data and explains the rights to which you are entitled. We are aware of how important personal data is to our users and we uphold all European data protection provisions.
1. Contact & data protection officer
In relation to the General Data Protection Regulation (GDPR), the organization responsible is:
550 Grand Street
New York, NY 10002
Our Data Protection Officer can be contacted at email@example.com or our postal address with the addition of “data protection”.
2. Your rights
You have the following rights with respect to us regarding the personal data relating to you:
- Right to information
- Right to correction or deletion
- Right to restriction of processing
- Right to refuse processing Right to data transferability
- In addition, you have the right to complain to a data protection supervisory authority regarding our processing of your personal data.
3. Processing by external service providers
In some cases, we avail of external service providers to process your data. We select and commission these carefully, they are bound by our instructions and inspected on a regular basis.
4. Gathering of personal data while visiting our website
In the case of use of the website for purely informational purposes, if you do not – for instance, using our search function – provide us with information in any other way, we gather only the personal data which your browser transmits to our server. If you wish to view our website, we gather the following data, which we technically require in order to show you our website and to guarantee stability and security. The legal basis for the temporary storage of the data is Art. 6 Para. 1 lit. f of the General Data Protection Regulation.
- IP address
- Date and time of enquiry
- Difference between time zone and Greenwich Mean Time (GMT)
- Content of the request (specific webpage)
- Access status / HTTP status code
- Respectively transferred data quantity
- Website from which the request comes
- Operating system and its surface
- Language and version of the browser software.
The data are saved in the logfiles of our system. This data can never be connected to other personal data of our users. The data are deleted once they are no longer required to achieve the purpose of your gathering. In the event that the data are saved in log files, this occurs at the most seven days later.
It is possible to save the data for longer than this. In this case, the users’ IP addresses are deleted or anonymized so that they can no longer be associated with the visiting client.
In addition, while you are using our website, cookies are saved on your computer. See below and section 4 in this regard.
We gather anonymous data in order to identify and gather errors and problems in Trickle products and services. These data include data in connection with program crashes. We use several third-party providers for the gathering of error logs. During the use of the Trickle’s website, various pieces of personal data that are necessary for the performance are saved on the technical infrastructure of the third-party supplier a limited period of time in encrypted form.
Cookies are small text files which are saved on your hard drive assigned to the browser you have used and through which the location which the cookie sets (here by us) accrues specific pieces of information. Cookies cannot execute any programs or transmit viruses to your computer. They serve to make Trickle more user-friendly and more effective in general.
We set one or several persistent cookies in order to save the user’s settings and to make our website more user-friendly, to analyze user behavior and as necessary carry out web analytics (see below in this regard) or A/B testing (see below also). The legal basis for the processing of personal data using cookies is Art. 6 Para. 1 lit. f of the General Data Protection Regulation.
Persistent cookies are automatically deleted after a specified length of time, which may differ from one cookie to another. You may delete the cookies in the security settings of your browser at any time. You may configure your browser setting the way you want it and e.g. refuse the acceptance of third-party cookies or all cookies. Cookies that have already been saved may be deleted at any time. This can also be done automatically. Please note that you may not be able to use all functions of this website within the full scope if you deactivate cookies for our website.
7. Special forms of use of the Trickle website
Trickle search is a search which is supported by third-party suppliers. If a search is carried out with Trickle, data are transferred to Bing. Bing is operated by: Microsoft Ireland Operations Ltd, Carmanhall Road, Sandyford Industrial Estate, Dublin 18, Ireland (referred to below as: Bing). This is done in order to display search results and to prevent fraudulent activities. The following data are transferred to Bing during a search enquiry: IP address, user agent string, search term, country and language settings, filter settings for adult content, active search filter settings (e.g. filter search results by date).
Trickle also assigns a “Bing Client ID” in order to improve the quality of the search results. This value is a user-specific ID which enables Bing to deliver more relevant search results also based on previous searches. The ID is saved in the Trickle cookie and retrieved during future visits. In both cases, the legal basis for the processing of these data is Art. 6 Para. 1 S. 1 lit. f of the General Data Protection Regulation.
However, you have full control over the use of this “Client ID”. If “Do not track” is activated in your browser, the Client ID is automatically deactivated and neither saved nor sent. The Client ID and personalized search results can also be switched off specifically in the Trickle search settings.
Microsoft/Bing is certified under the “Privacy Shield” US-EU data protection agreement and undertakes to uphold the EU data protection provisions. For information on data protection at Bing, go to: https://privacy.microsoft.com/privacystatement
b. Contact form and help pages
We use the “Wordpress” platform to handle your enquiries. In an enquiry, the data you provide are saved and processed in order to answer your questions. At the same time, we gather certain pieces of statistical information via cookies in order to improve the contact and enquiry function and use your data to prevent any potential misuse of this function. In this context, the data are not forwarded to third parties. The data arising in this context are deleted after their storage is no longer necessary or restricted if legal storage obligations exist.
The following pieces of your data are saved:
- The email address to which we should send the reply to your question.
- The question itself as well as the associated correspondence and the times at which the messages were sent and received
- Technical information regarding browser and operating system as well as the type of device used in order to ensure that the information is presented correctly
- Your IP address
The processing of your personal data for the use of our inquiry and contact function is carried out on the basis of your consent.
c. Web analytics
We employ third party companies and individuals to facilitate our Website (“Service Providers”), to provide our Website on our behalf, to perform Website-related services or to assist us in analyzing how our Website is used. These third-parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
d. Online advertising
Advertising on Trickle
At Trickle, advertisements (ads) are shown beside or above the search results. If you click on these ads, we earn commission. We use this to pursue the interest in generating income which goes towards covering our ongoing costs and sharing revenue with the non-profits we work with. These ads are provided by advertising networks.
We work with the Bing Ad Network. During the search and simple display of an ad, no data are transferred to this advertising network (only to Bing, see above). The following data, among others, are only sent to the advertising network when you click on an ad: the search term, your IP address, place, date and time of the search inquiry and the browser configuration.
Trickle also assigns a Bing “Client ID” in order to improve the quality of the adverts. This value is a user-specific ID, which is saved in the Trickle cookie and retrieved during future visits.
This enables Bing to display more relevant adverts from Bing or third-party suppliers from the Bing ad network for you, based in part on prior searches. The legal basis for the data processing referred to Art. 6 Para. 1 S. 1 lit. f of the General Data Protection Regulation.
If “Do not track” is activated in your browser, the Client ID is automatically deactivated and neither saved nor sent. The Client ID and personalized adverts can also be specifically switched off in the Trickle search settings.
For further details on the data processing of the Bing Ad Network, go to: https://privacy.microsoft.com/privacystatement
Monitoring the success of advertisements via Trickle on third-party provider platforms
We use several offerings of third-party providers Google, Facebook and Amazon, in order to call attention to ourselves with the help of advertising tools on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. By doing so, we pursue the interest in showing you advertising, which is of interest to you, we can shape our website in a way which is more interesting for you and we can achieve a fair calculation of advertising costs.
In some places, but never on search pages, Trickle allows third-party providers to set cookies in order to check the success of Trickle advertising campaigns.
Based on the marketing tools used, your browser automatically forms a direct connection with the third-party provider’s server. We do not have any influence on the scope and the further use of the data which are gathered by the third-party provider. Therefore, we inform you in accordance with what we know: Due to their involvement, the third-party provider receives the information that you visited the relevant website of our internet presence or clicked on one of our adverts.
If you are registered for one of the third-party providers’ services, it may assign the visit to your account. Even if you are not registered or you have not logged in, it is possible that the provider may find out your IP address and other identifying characteristics and save them.
The legal basis for this processing of your data is Art. 6 Para. 1 lit. f of the General Data Protection Regulation. You may prevent the participation in this tracking process in various ways:
- You may configure your browser setting the way you want it and refuse the acceptance of third-party cookies or deactivate cookies in general.
- By deactivating the interest-related adverts of the provider, which are part of the self-regulation campaign “About ads”, via the link http://www.aboutads.info/choices
- By deactivating the function “Facebook Custom Audiences” for logged-in users at https://www.facebook.com/settings/?tab=ads#_
For further information on data protection in third-party suppliers which we commission to measure the success of our advertising measures, go to:
- Google: http://www.google.com/intl/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, visit the website of the Network Advertising Initiative (NAI) at: http://www.networkadvertising.org. Google has undertaken to uphold the EU-US Privacy Shield. https://www.privacyshield.gov/EU-US-Framework
- Facebook: https://www.facebook.com/about/privacy. Facebook has undertaken to uphold the EU-US Privacy Shield.
- Amazon: http://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401 and at: http://www.amazon.de/gp/BIT/InternetBasedAds Amazon has undertaken to uphold the EU-US Privacy Shield. https://www.privacyshield.gov/EU-US-Framework
We do not integrate tracking scripts or pixels into Trickle search pages. Therefore, search data are never shared with third-party providers who are not directly connected with the provision of the search service.
7. Refusal or withdrawal of the consent to processing of your data
If you have granted your consent to the processing of your data, you can withdraw this at any time. Such a withdrawal influences the permissibility of processing of your personal data, on the basis that you have stated this to us.
Insofar as we support the processing of your personal data on a balancing of interests in accordance with Art. 6 Para. 1 lit. f of the General Data Protection Regulation, you may at any time refuse the processing of data about you for reasons which arise from your specific situation. In the event of a refusal, we will inspect the matter and will stop or adjust the data processing, unless we can provide compelling and legitimate grounds for the processing which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
Of course, you may refuse the processing of your personal data for advertising purposes at any time. No justification is required to do so. This also applies to profiling if it is connected with such direct advertising.
To assert a refusal or a withdrawal of consent, please contact our Data Protection Officer at firstname.lastname@example.org.