Thank you for your interest in our website. The protection of your privacy is very important to us. In the following we will inform you in detail about how we handle your data. BrandTURBO GmbH is the responsible party in terms of the Data Protection Ordinance and other national data protection laws of the member states as well as other data protection regulations.
brandTURBO GmbH ("we", "us", "our" etc.), Strassburger Str. 55, 10405 Berlin, +49 (0)30 83797979, operates the website member.app, MEMBER Mobile Applications and New Tab Extensions for partners (hereinafter referred to as "service").
This site contains information about the way in which we collect, use and disclose data when you use our service and the options available to you in connection with this data.
The service is the website member.app operated by the BrandTURBO GmbH and the Mobile Applications and New Tab Extension Platform described on it.
· Non-personal product usage data
Non-personal product usage data is data that is collected in the course of using the service or within the service infrastructure itself that does not permit direct association with any specific individual (for example, aggregate counting of product openings).
Cookies are small files that are stored on your device (computer or mobile device).
· Data controller
The data controller is a natural or legal person who determines (either alone or together with other persons) the purposes for which and the way in which data are or will be processed.
· Data Processor (or Service Provider)
A data processor (or service provider) is a natural or legal person who processes data on behalf of the data controller.
We may use the services of different service providers to process your data in a more efficient way.
· Data subject (or user)
A data subject is a living individual who uses our service and is the subject of personal data.
II. Collection and Use of Data
We collect various types of information for a variety of purposes to improve the service we provide to you.
Types of information collected:
1. Personal data
In order to provide access to our platform and its services, we may collect several categories of Personal Data about you, for different purposes, legal bases for processing and different retention periods. We offer a summary of all this information in the table below.
|Purpose of the Processing||Personal Data Processed||Legal Ground for the Processing||Retention Period|
|Account creation and User identification - Account management||Mandatory profile data (phone number)||Performance of the contract between You and brandTURBO||Duration of the use of the services increased by 3 years after the last connection to the service or until the request for removal|
|Optional profile data (name, images)||Consent||Duration of the use of the services increased by 3 years after the last connection to the service or until the withdrawal of consent|
|Proper functioning of the Platform and its Services||Data related to your activity on brandTURBO, Communications with brandTURBO, Data related to devices and equipment used||Legitimate interests of the Data Controller||2 years from collection date|
|Data sent by your phone's camera and photos stored on your phone, Geolocation Data||Consent||Duration of the use of the services increased by 3 years after the last connection or until the withdrawal of consent|
|Administrative management of the Platform, complaints and reports from Users, Moderation of content in accordance with our ToU||Content Data, Communications with brandTURBO||Legitimate interests of the Data Controller||Duration of the use of the services + applicable statutory limitation|
|Moderation of content in accordance with the law (prevention of illegal activities, fraud, cyber harassment, ...)||Content Data, Data about your activity on brandTURBO||Compliance with our legal obligations||1 year from collection for metadata 5 years (statutory limitation) for data retained for dispute prevention purposes|
|Connection with other Users||Contact data from your smartphone||Consent||Duration of use of services or until withdrawal of consent|
2. Non-personal product usage data
We may also collect usage data that cannot be associated with any particular individual each time you visit our service or access our service through or from a mobile device ("Usage Data").
This usage data may include an anonymized Internet Protocol (IP) address of your computer, your browser type, your browser version, the features you use within our service, the time and date of your visit, your country, the total time spent in our service, and other diagnostic data.
You can decide in the settings of your browser whether you wish to reject all cookies or only accept certain cookies. However, if you refuse to accept cookies, you may not be able to use parts of our service.
Examples of cookies used by us:
· Preference cookies. We use preference cookies to store your preferences and various settings.
· Security Cookies. We use security cookies for security purposes.
III. Use of Data
We at BrandTURBO GmbH use the collected data for various purposes, for example to
· to provide you with our service and to maintain it;
· to inform you about changes regarding our service;
· to enable you to participate in the interactive parts of our service if you wish;
· provide customer service;
· collect aggregate usage data to help us improve our service;
· monitor the use of our service;
· identify, prevent and correct technical problems;
IV. Legal basis for the processing of data in accordance with the Basic Data Protection Regulation (DSGVO)
We at BrandTURBO GmbH may process your data for the following reasons:
· We need to fulfil a contract we have entered into with you.
· You have given us your consent for this.
· The processing serves our legitimate interests, and these are not subordinate to your rights.
· The processing serves to comply with the statutory provisions.
V. Retention of Data
BrandTURBO GmbH will also retain data for internal analysis purposes. Data is usually kept for shorter periods of time, unless it is used to strengthen our security measures or to improve the functionality of our service or unless we are legally obliged to keep it for a longer period of time.
VI. Transfer of Data
Data generated by you, may be transferred to - and stored on - computers located outside your home state, province, country or other jurisdiction and may be subject to privacy laws that differ from the privacy laws in your jurisdiction.
If you are located outside of Germany and decide to submit data to us, you should note that we will transfer your data to Germany and process it there.
VII. Disclosure of Data
1. Disclosure for Law Enforcement Purposes
Under certain circumstances, BrandTURBO GmbH may be obliged to disclose data within the scope of a legal obligation or as a result of a court or official request.
2. Legal Requirements
BrandTURBO GmbH may disclose data under certain circumstances, if it is of the opinion that this is necessary in order to achieve the following objectives in accordance with the principles of good faith:
· to fulfil a legal obligation
· to protect and defend the rights or property of BrandTURBO GmbH
· to prevent or investigate possible misconduct in relation to the service
· to protect the personal safety of users of the service or the public
· to avoid liability claims
VIII. Data Security
The security of your data is important to us. However, please remember that there are no transmission methods over the Internet and no electronic storage media that are 100% secure. Although we make every effort to implement commercially acceptable measures to protect data, we cannot guarantee absolute security.
IX. Service Provider
We may engage third party companies and individuals ("Service Providers") to provide support services to facilitate the provision of our Service, to provide services on our behalf, to provide services related to our Service, or to provide support services to analyze the manner in which our Service is used.
These third parties may access information only to the extent necessary to perform the aforementioned tasks on our behalf and may not disclose or use it for any other purpose.
We may commission third party service providers to display advertising. This helps us to support and further provide our service.
2. Landing Pages
X. Links to other websites
Our service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to the website of the third party in question. We strongly encourage you to review the privacy policies of each website you visit.
We have no control over, and accept no liability for, the content, privacy policies and practices of third party websites or services.
XI. protection of the data of minors
Our service is not directly aimed at persons under 18 years of age ("children"), although it is possible for persons under 18 years of age to purchase our services. Please read our ToS (link) carefully.
XIII Your rights under the Basic Data Protection Regulation (DSGVO)
If your residence is within the European Economic Area (EEA), you have certain data protection rights. BrandTURBO GmbH endeavours to implement reasonable measures that allow you to correct, amend, delete or restrict the use of that data.
If you would like to find out what data we have stored about you and if you wish to have your data deleted from our system, please contact us.
You can choose to delete content and close your account through our application.
Under certain circumstances you have the following data protection rights:
· The right to access the data we have stored about you and to update or delete it. As far as this is possible in each case, you can access your data directly in the section with your account settings and update or request their deletion. If it is not possible for you to carry out these actions yourself, please contact us so that we can help you.
· The right of rectification. You have the right to correct your data if it is incorrect or incomplete.
· The right to object. You have the right to object to the processing of your data by us.
· The right to be limited. You have the right to limit the processing of your data by us.
· The right to data portability. You have the right to request that we provide you with a copy of the data we hold about you in a structured, machine-readable and standard format.
· The right to withdraw consent. You also have the right to withdraw your consent at any time in cases where BrandTURBO GmbH has relied on your consent to process your data.
Please note that we may verify your identity before processing such requests.
You have the right to lodge a complaint with a data protection authority regarding the collection and use of your data. For further information, please contact your local data protection authority within the European Economic Area (EEA).
By e-mail: info (@) member (dot) app