Privacy policy

This privacy policy describes the data processing activities carried out by the following subsidiaries of Goldbach Group AG:

• Goldbach Media AG
• Swiss Radioworld AG
• Goldbach Audience AG
• dreifive (Switzerland) AG, dreifive AG and dreifive GmbH
• Goldbach Manufaktur AG
• Goldbach Pemium Publishing AG
• Goldbach Germany GmbH
• Goldbach Austria GmbH

(hereinafter all collectively referred to as "Goldbach") as part of the provision of their services. Goldbach Group AG, based in Küsnacht, Switzerland, is a sub-holding company of TX Group AG, based in Zurich. Goldbach is a technology-based media service provider whose customers include both advertisers and operators of media channels such as TV broadcasters (including ConnectedTV and HbbTV applications), online platforms (websites and mobile apps), (online) radio stations, DooH and print media (collectively "publishers"). We offer innovative products and services that enable advertisers to better reach their target audience and publishers to promote, grow and monetize their online platforms through the sale of ads.

Note: This privacy policy describes the data processing operations of Goldbach in the context of its above-mentioned services. For the data processing operations that take place when you visit the Goldbach website, i.e. Goldbach.com, or when you contact the companies of the Goldbach Group, please consult the privacy policy of Goldbach Group AG.

The protection of personal data is of particular concern to Goldbach. We believe that safe, secure and respectful practices in handling consumer information are fundamental to the success of our business and the growth and viability of the Internet as a whole. We are a member of IAB-Europe, the trade association of the European digital and interactive marketing industry ("IAB").

The Goldbach Group is a registered member of the IAB Transparency and Consent Framework 2.2 (Vendor ID 580) and adheres to its guidelines. The IAB TCF 2.2 is an industry standard that enables all digital market participants (publishers, advertisers, technology service providers, etc.) to inform end users about the processing of their personal data and to give them the opportunity to consent to or object to this. You will find a Consent Management Platform at all operators of online platforms that participate in the framework: A control interface, usually in the form of a cookie or privacy center, within which you can make your data protection settings. These settings are taken into account by all participants in the framework, including the companies of the Goldbach Group.

Goldbach processes your personal data (hereinafter "data") on the basis of the legal provisions of the Swiss Federal Act on Data Protection of September 25, 2020, SR 231.1 (hereinafter "DPA") and, where applicable, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter "GDPR").

In the following, we provide you with an overview of the most important aspects of data processing in the context of our services, offers and products. We will inform you about your rights and explain what decisions you can make in relation to the collection of your data. You will then find a contact point to which you can turn if you have any questions or concerns regarding data protection.

Goldbach delivers advertisements (e.g. banners, video spots) from hundreds of advertisers on a variety of media channels (websites, mobile apps, DooH screens, HbbTV applications) (hereinafter referred to as "Goldbach services"). A list of the websites and apps on which Goldbach delivers advertisements is available here.

As part of the Goldbach Services, Goldbach uses - on its own responsibility and independently of the website operator - innovative target group products that enable Goldbach to reach its target audience more precisely and to promote websites and apps by selling ads. These target group products can also be created through the use of data that Goldbach collects and processes.

2.1 Cookies - definition and purpose

Goldbach uses so-called cookies for the purpose of creating these target group products. These are small text files that are stored on the hard disk of the end device of a visitor to a website or app (hereinafter referred to as "user") with the help of the browser and are stored there for data collection purposes. When you as a user visit one of the websites or apps of the Goldbach network, the automated systems of their service providers (e.g. ad servers, data management platforms) collect usage data with the help of cookies in relation to the visit to this website and apps or by means of third-party cookies also beyond the specific domian. Information can be written in these text files that can be read again at a later time.

Some cookies remain stored on your end device until you as the user delete them. For example, you enable Goldbach to recognize your browser on your next visit. Other cookies are only stored for the duration of your visit to a website.

If you do not want data to be collected using cookies, you can set up your browser so that it informs you about the setting of cookies and you only allow this in individual cases. You can find out more about this in section 2.1.3 "Handling cookies".

2.1.1 Third party cookies or cookies from our service providers

Third-party cookies are cookies that originate from a domain other than that of the website. Third-party cookies are usually used by technology providers or advertising networks. For example, as some online or mobile advertisers ("advertisers") and website and app operators ("publishers") do not want to run campaigns on just one domain or website, third party cookies enable them to recognize users on different domains and store information in the third party cookie. For example, if a user visits a website, a third-party cookie is placed on the user's computer by the advertising network that provides the ad. With the help of the cookie, user data such as page visits and length of stay can be tracked. If the user later visits another website on which there is an ad from the same advertising network, the same cookie is used despite the different website - because it is the same third-party provider. In this way, the advertising network can track a user across domains and deliver targeted advertising.

Goldbach uses technologies from service providers or their sub-service providers that contain cookies to optimize the provision of its services. These are third party cookies.

Our most important service provider is Goldbach neXT AG, a subsidiary of the Goldbach Group, which in turn uses third-party technology providers that use third-party cookies on behalf of Goldbach. You can find more information on this in Goldbach neXT's privacy policy.

Insofar as its service providers process personal data on behalf of Goldbach (including Goldbach neXT), they have each concluded an order processing contract with Goldbach. Such a contract guarantees that the provider will only process the personal data transmitted to it in accordance with Goldbach's instructions and not for its own purposes, and that it will take suitable technical and organizational measures to ensure the legally compliant protection of your data. The providers' own privacy policies can be found in the links above. Please note: Cookies are used on the websites of the aforementioned providers and therefore personal data is processed by the providers and, where applicable, by their partners and service providers.

In addition, advertising customers may also store third-party cookies on users' end devices via the advertising spaces provided in the Goldbach network. In this case, the advertising clients contractually undertake to participate in the IAB Transparency and Consent Framework (see section 1) and to comply with all data protection regulations, whereby you will be specifically responsible to the user for their data processing.

2.1.2 First party cookies

First party cookies are cookies that are linked to a specific domain (e.g. website). Only this domain can write information to the cookie and read it again at a later time. First party cookies are mainly used to provide the user with a better and faster surfing experience on a website, as, for example, certain user preferences are stored in the cookie and do not have to be re-entered by the user on each visit.

First party cookies are also used on Goldbach.com. For more information, please refer to the Goldbach Group's privacy policy.

2.1.3 Your handling of cookies

You can change the settings of your web browser and block all cookies. However, as cookies are widely used, blocking cookies in your web browser may restrict your use of various websites.

You will find a Consent Management Platform on all operators of online platforms that participate in the IAB Transparency and Consent Framework - including this website: A control interface, usually in the form of a (cookie) banner, in which you can make your privacy settings. Here you can allow or prohibit the use of cookies for various purposes. If we use cookies on an online platform that you use, you will find us in the Consent Management Platform there. The settings you make there will be taken into account by all participants in the framework, including Goldbach.

Please note that the storage of your data protection settings made in this way may be based on cookie technology (this may vary depending on the operator of the online portal). For users of multiple computers or browsers, this means that you must deactivate the receipt of cookies on each computer or for each browser. Even if users change computers or delete cookies from your computer, you must repeat the deactivation process.

2.2 API interface

An API interface is a programming interface that allows software to communicate with other software. Similar to cookies, this is a technology that can be used to collect usage data and is usually used in conjunction with apps. Specifically, this means that information about the use of a mobile or HbbTV app, for example, can be transmitted via such an interface to our service providers, who process the information for the above-mentioned purposes on our behalf.

You can generally consent to or object to the collection of data via the API interface within the corresponding application (mobile, HbbTV apps, etc.), depending on the legal basis of the processing (see section 4). Similar to cookies, this is done on a consent management platform that complies with the IAB TCF standards.

3.1 Data that we process about you as a contractual partner, interested party and enquirer

We collect your personal data when you contact us, e.g. as an interested party, enquirer or contractual partner. This is particularly the case if you are interested in our products, make inquiries, request quotations or contact us by email or telephone, as well as if you have an existing business relationship with us. We process the following personal data for the initiation and fulfillment of contracts and for the purposes of customer contact:

• Personal identification data
  e.g. first and last name, address, date of birth, nationality, e-mail address, telephone number
• Company data
  e.g. sector and commercial register data

• Order and payment data
  e.g. product details; means of payment; customer number

3.2 Data that we collect about you as an end user of online platforms marketed by Goldbach

In the course of offering its services and products, Goldbach does not process any personal information that directly identifies you as an end user (such as names, residential addresses, e-mail addresses). The identification of end users is not necessary for the purposes of data collection and is not sought in the sense of the principle of data minimization. Instead, user information (see next section) is linked to pseudonymized data points such as IP addresses or device identification numbers. These cannot be assigned to an individual person without additional great effort. IP addresses are pseudonymized immediately after collection (e.g. by deleting the last 8 bits). This means that only a rough determination of the user's location (at zip code level) is possible.

The usage data collected by Goldbach from end users includes information such as websites visited, date and time at which websites or apps were viewed, interactions between content and ads, location data (only with explicit consent). The technologies used to collect this data include cookies or similar technologies, which are deleted after a certain period of time (see section 7 below).

In addition to the collected usage behavior of end users, Goldbach enriches the data pool with characteristics estimated by them or their service providers in order to derive interest profiles. These essentially include segment identifiers such as football fan, smart shopper, adventure traveler or similar. Under no circumstances does Goldbach determine probabilities for "sensitive" characteristics such as creditworthiness, susceptibility to illness, political orientation or similar for individual persons.

3.3 Where does the data processed by Goldbach come from?

Goldbach collects and processes your data as described in section 3.2 when you interact with online platforms - e.g. a website, a mobile or HbbTV app - that are marketed by Goldbach.

We always treat personal data in accordance with the strict provisions of the applicable data protection regulations (namely the GDPR and the DSG). We only collect and store personal or usage-related data if

• your corresponding consent has been given or
• this is necessary for the fulfillment of a contractual or legal obligation or
• we have an overriding legitimate interest in processing your personal data.
• Data collection after consent

Where required by law, Goldbach will ask for your consent when processing your data. If you have given Goldbach your consent to process your data (for example via a Consent Management Platform in the IAB Transparency and Consent Framework, see section 1), this processing will be based on your consent. You can withdraw your consent at any time.

• Data collection for the fulfillment of our contractual obligations

In order to fulfill any contracts with you, we must process your data. This also applies to pre-contractual information and contacts that you make to us as part of an inquiry. The purposes of data processing depend primarily on the respective service or product. For example, we need your address, your telephone number or your e-mail address to be able to contact you in order to perform the contractual relationship.

In addition to this Privacy Policy, you can find details on the respective purposes of data processing in the contract documents, our General Terms and Conditions and the product and service descriptions.

• Data collection to fulfill our legal obligations

The processing of your data may be necessary due to legal obligations to which we are subject (in particular for the storage of business letters and contract documents). Such obligations may arise, for example, from the Swiss Code of Obligations (OR) or tax law.

• Data collection to safeguard overriding legitimate interests

Goldbach may process your data if this is necessary to safeguard its legitimate interests, unless the interests of the user outweigh these or consent is required under applicable law. A legitimate interest of Goldbach may, for example, lie in the customization of the advertisements that users of the online platforms of the Goldbach network see. The user benefits from the better coordinated advertising placements and the resulting increase in the general quality of advertising. The processing helps advertisers to play out campaigns to the appropriate target groups. We also have a legitimate interest in processing your data for our own marketing purposes, for customer retention or for legally permissible direct advertising by means of newsletters. In addition, we have a legitimate interest in processing your data in the context of (potential) legal prosecution and for purposes related to the accounting and auditing obligations of the companies within the Goldbach Group.

Your data will be transmitted to the following recipients:

• Service providers and partners used by Goldbach, such as the providers under section 2.1.1 insofar as they require your data to fulfill their respective tasks. These service providers are contractually obliged to treat your data confidentially and to process it only to the extent necessary for the provision of services. In particular, you are not authorized to process the data received beyond the provision of their services for your own purposes. In this respect, your data remains within the sphere of Goldbach. A list of the current service providers of the Goldbach Group companies can be found here.
• Within the Goldbach Group and its parent company TX Group AG, those employees and departments receive your data that need it to fulfill the respective contractual and legal obligations, as well as the legitimate interests mentioned above.
• In the case of data transfers outside the Goldbach Group and the TX Group, it is particularly important to us that the protection of your data is guaranteed. As a rule, such a transfer does not take place or takes place under the strictest conditions. For example, we may have to pass on personal data to public bodies and authorities on request because we are legally obliged to do so. In addition, data may only be passed on in aggregated, anonymized form - so that no conclusions can be drawn about an individual person - or in such a way that you always retain control over the processing of your data (e.g. via the Consent Management Platform in the IAB). via the Consent Management Platform in the IAB Transparency and Consent Framework).
• Finally, it is possible for an advertising client of Goldbach to equip its advertising material with additional tags that enable it to collect data at the time of delivery of this advertising material. However, this is not a transfer of data collected by Goldbach. The advertiser is responsible for this data collection and Goldbach cannot influence the use of such tags, nor is it involved in their technically successful implementation. Should this be the case, such an advertising client will be listed in the Consent Management Platform of the publisher on whose website the advertisement is placed and you can object to this data collection. As a rule, Goldbach only works with advertisers who are registered in the IAB Transparency and Consent Framework.

We and our service providers have technical and organizational security procedures in place to protect the security of your personal data and to protect your session data and personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access.

Goldbach does not store your data for longer than is necessary for the respective processing purposes.

We store your personal data for a maximum period until the end of the contractual relationship with you or as long as our legitimate interest in processing exists. The latter is the case, for example, if legal claims can be asserted from the contractual relationship or as long as statutory retention and documentation obligations exist. Reasons for this may be, for example

• The fulfillment of retention obligations under company and tax law: in particular under the Code of Obligations and tax law.
• The preservation of evidence for legal disputes within the framework of statutory limitation periods.

Temporary or permanent cookies remain stored on your computer or mobile device for between one month and ten years, depending on the type of cookie, and are automatically deactivated after the programmed time has expired. However, we only process the information resulting from the cookies for a maximum of 90 days. Depending on the decision of the website operator, providers other than Goldbach may also use cookies on the basis of consent. The deletion of data within the meaning of section 14.2 below can be requested at any time via [email protected].

In order to fulfill our contracts and for our business relationships as well as for processing and responding to contact requests, we require the following personal data from you:

• Data needed for the establishment and execution of a business relationship or contact request (e.g.: name, address, telephone number or e-mail address)
• Data that is necessary for the fulfillment of the associated contractual obligations

Without this personal data, we are generally unable to enter into or perform a contractual relationship with you.

If you do not want Goldbach to collect your data using cookies, you can set this accordingly in the Consent Management Platform of the Goldbach website and the online platforms in the Goldbach partner network. However, this may restrict the functionality of the websites or apps in question.

To enable Goldbach to create and continuously optimize services and products (target group products), the technical possibility of automated profiling is used, in particular to analyze or predict aspects relating to personal preferences, interests, behavior, location or change of location.

In some cases, Goldbach processes your data in order to evaluate certain personal aspects (profiling). This applies, for example, in the following cases:

• Through targeted marketing, Goldbach only wants to make you offers that are tailored to your needs.
• In order to assess the interests of users of its websites and apps, Goldbach uses characteristics derived from cookie data. This involves calculating the probability with which a user corresponds to a certain category of interest. This calculation is based on statistical methods. The calculated interests support Goldbach in the allocation of its services and products.

You acknowledge that your data processed by Goldbach may be processed outside the country in which you reside. Goldbach assures its contractual partners and all users from whom data is collected that the data will only be processed in countries in which an equivalent level of data protection as in Switzerland or the EU is guaranteed.

If data is processed by service providers (contract processors) outside the EEA, Goldbach ensures that the company concerned provides adequate protection for your data (e.g. by means of Binding Corporate Rules) or that it is obliged to do so, e.g. by means of Standard Contractual Clauses (SCC) of the EU Commission. If these precautions do not lead to sufficient protection of the data, additional measures are taken. Where possible and necessary, an alternative service provider is used.

Data collected by us on our own behalf or on behalf of our customers may be stored and processed in any country in which the Goldbach Group has subsidiaries, branches, agents or customer facilities. The user acknowledges and accepts that information provided by the user may be transferred outside the country in which the user resides and to all companies belonging to the parent company of Goldbach, i.e. the Goldbach Group and the parent company of the Goldbach Group, i.e. TX Group AG. Goldbach assures its customers and all users from whom data is collected that the data will only be processed in countries where an equivalent level of data protection as in Switzerland or the EU is guaranteed. If data is processed by a company in another country, the data transfer will take place in accordance with the criteria set out in section 10.

If another company acquires all or substantially all of our company's assets through a consolidation, merger, asset purchase or other transaction, we reserve the right to transfer all data (including personal data) in our possession or under our control to the acquiring party.

We reserve the right to make changes to this Privacy Policy by posting an updated version on this page. The date on which the current privacy policy was published is always indicated at the top of this page. Any changes to this Privacy Policy will be made in accordance with the applicable (data protection) laws.

Goldbach tries to answer your questions and concerns as quickly as possible. However, it can sometimes take up to a month before you receive an answer. If we need longer than a month, we will of course let you know in advance.

In some cases, Goldbach cannot or may not provide any information. If this is permitted by law, Goldbach will always inform you promptly of the reason for the refusal. You have the right to lodge a complaint (see below).

14.1 Right to access, information and rectification

You can request information about your data processed by Goldbach. If your data is incomplete, you can request that it be completed. If your data is not (or no longer) accurate, you can request that it be corrected. If Goldbach has passed on your data to third parties, Goldbach will inform these third parties of your correction if this is required by law.

14.2 Right to erasure of your personal data

You can request the immediate deletion of your data if:

• your data is no longer required for the purposes for which it was collected,
• you withdraw your consent and there is no other legal basis for processing by Goldbach
• you object to the processing and there are no overriding legitimate grounds for processing
• your data has been processed unlawfully,
• your data must be deleted in order to comply with legal requirements or
• your data was collected in relation to information society services (e.g. advertising offers) aimed at children (within the meaning of Art. 8 GDPR).

14.3 Right to restriction of the processing of your personal data

You have the right to request a restriction (comparable to a block) on the processing of your data if

• the accuracy of your data is disputed by you for the period required by Goldbach to verify the accuracy
• the processing is not lawful and you request a restriction of use instead of erasure,
• Goldbach no longer needs your data for the purposes of processing, but you need it to assert, exercise or defend against legal claims, or
• you have lodged an objection as long as it is not yet clear whether your interests prevail.

14.4 Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interest or for the performance of a task carried out in the public interest; this also applies to profiling. Goldbach will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

The Goldbach Group is a registered member of the IAB Transparency and Consent Framework 2.0 (Vendor ID 580) and adheres to the guidelines specified for this. The IAB TCF 2.0 is an industry standard that enables all digital market participants (publishers, advertisers, technology service providers, etc.) to inform end users about the processing of their personal data and to give them the opportunity to consent or object to it. You will find a Consent Management Platform at all operators of online platforms that participate in the framework: A control interface, usually in the form of a cookie or privacy center, within which you can make your data protection settings. If we process your data, you will find us in the Consent Management Platform of the websites, mobile and HbbTV apps etc. you use. The settings you make there will be taken into account by all participants in the framework, including the companies of the Goldbach Group.

If personal data is processed for the purpose of direct marketing (via newsletter or telephone), you have the right to object at any time to the processing of your personal data for the purpose of such marketing. You will find the contact details below.

If you have any questions, concerns or comments regarding the processing of your personal data by Goldbach, please contact us by e-mail or post:

Goldbach Austria GmbH
Laimgrubengasse 14
1060 Vienna
Austria
[email protected]

If you contact us using the form on the website or by email, the data you provide will be stored by us for six months for the purpose of processing your inquiry and in the event of follow-up questions. We will not pass on this data without your consent.

Company data protection officer:
ePrivacy GmbH
Burchardstrasse 14
20095 Hamburg
Germany
www.eprivacy.eu