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Monday, Apr 12, 2021

Privacy Policy

This privacy policy was published on May 22nd, 2020.

  1. INTRODUCTION
  2. ABOUT THIS POLICY
  3. YOUR RIGHTS AND PREFERENCES
  4. CATEGORIES OF INFORMATION
  5. WHAT WE USE YOUR PERSONAL DATA FOR
    1. 5.1. Provide the Service
    2. 5.2. Interact with you regarding the Service
    3. 5.3. Communicate with you for marketing purposes
    4. 5.4. Analyze the use of our website
    5. 5.5. Ensure technical functionality and the security of the Service
    6. 5.6. Develop and improve the Service
    7. 5.7. Other purposes
  6. WHEN DO WE COLLECT PERSONAL DATA?
    1. 6.1. Signing-Up and Creating a User Account
    2. 6.2. Use the Service
    3. 6.3. Make a payment
    4. 6.4. Communicate with us
    5. 6.5. Participate in surveys or marketing activity
    6. 6.6. Information collected when using the App
  7. SHARING OF PERSONAL DATA
    1. 7.1. Service Providers
    2. 7.2. Publishers
    3. 7.3. Payment Service Providers
    4. 7.4. Other Sharing
  8. TRANSFER TO OTHER COUNTRIES
  9. COOKIES AND OTHER SIMILAR TECHNOLOGIES
  10. ANALYTICS
  11. LINKS TO OTHER WEBSITES
  12. KEEP YOUR PERSONAL DATA SAFE
  13. CHILDREN
  14. CHANGES TO THIS PRIVACY POLICY
  15. HOW TO CONTACT US

1. INTRODUCTION

Thanks for choosing Forum.eu!

Your privacy and the security of your personal data is, and will always be, enormously important to us. To ensure that you are fully aware of how we treat your data, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share it.

That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.

2. ABOUT THIS POLICY

This Policy sets out the essential details relating to your personal data relationship with Forum.eu and applies to all websites and web applications which link to this policy. Throughout the Privacy Policy we refer to the ‘Service’. This term is defined in our Terms and Conditions of Use and always refers to the Application or the Website or both.
Terms of Service

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

The aim of this Policy is to:

  • Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
  • Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Forum.eu Service; and
  • Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

Forum CTEP GmbH (referred to as either "Forum.eu", "the Company", "We", "Us" or "Our" in this Agreement) refers to Forum CTEP GmbH, Lobeckstrasse 30-35, 10969 Berlin and is a German entity. For the purpose of the GDPR, Forum CTEP GmbH is the data Controller.

We hope this helps you to understand our privacy commitments to you. Please read on for detailed information regarding when we collect personal data, how and why we use the personal data and your rights.

3. YOUR RIGHTS AND PREFERENCES

The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

  • Right of access - the right to be informed of, and request access to, the personal data we process about you;
  • Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • Right to erasure - the right to request that we delete your personal data;
  • Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
  • Right to object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
  • the right to object to your personal data being processed for direct marketing purposes;
  • Right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
  • Right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

You may exercise your rights of access, rectification, cancellation and opposition by contacting us, e.g. by writing an email to our support team ([email protected]). You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

4. CATEGORIES OF INFORMATION

The table below describes the personal data collected when you sign up for and use Forum.eu’s Service and provides an overview of the categories of information that we use and store about you:

Category of personal dataData
Account dataAccount-ID, e-mail address, country, status, creation date, subscription type.
Address dataName, address, zip, city, county, state, country
Profile dataName, e-mail address, birth year (optional), gender (optional)
Technical dataIP address, application version, operating system, unique device ID
Payment dataTransaction date, amount, VAT, subscription period, payment method
Mobile subscriber dataPhone number
User-generated dataArticles read, favourites, bookmarks, comments, personal website, comments
CommunicationContents of your communication?

5. WHAT WE USE YOUR PERSONAL DATA FOR

We collect and use personal information for the following reasons:

5.1. Provide the Service

We use your personal data to provide the Service, i.e. to give you access to Forum.eu’s website and application, to provide customized and personalized content, recommendations and features in the Service, to process your payment and to prevent or detect fraud. You need to provide the information that we request when you sign up for the Service as the information is necessary for the performance of the contract with you. If you do not provide the information requested, you cannot use the Service.

Personal DataLegal BasisStorage
  • Account data
  • Profile data
  • Address data
  • Mobile subscriber data
  • Payment data
  • User-generated data
  • Technical data
Performance of a contract, Article 6(1)(b) GDPR. The processing of your personal data is necessary in order to fulfil the terms for the Service.Your personal data is stored for this purpose as long as your user account is active and for a period of 12 months thereafter in order to satisfy our legitimate interest in promoting the Service.

5.2. Interact with you regarding the Service

We use your personal data to interact with you regarding the Service, e.g. notify you of updates to the Service or to respond to questions that you may have regarding the Service.

Personal DataLegal BasisStorage Period
  • Account data
  • Profile data
  • Address data
  • Communication
Performance of a contract, Article 6(1)(b) GDPR. The processing of your personal data is necessary in order to fulfil the terms for the Service.Your personal data is stored for this purpose as long as your user account is active.

5.3. Communicate with you for marketing purposes

We use your personal data to communicate with you for marketing and promotional purposes regarding offers from us and our business partners.

Personal DataLegal BasisStorage Period
  • Account data
  • Profile data
  • Address data
  • User-generated data
  • Technical data
Legitimate interest, Article 6(1)(f) GDPR. The processing of your personal data is necessary in order to satisfy our and our business partners' legitimate interest in communicating with you for marketing and promotional purposes.Your personal data is stored for this purpose as long as your user account is active.and for a period of 12 months thereafter in order to satisfy our legitimate interest in promoting the Service.

5.4. Analyze the use of our website

We use your personal data to analyze the use of our website, e.g. to collect visitor statistics.

Personal DataLegal BasisStorage Period
  • Technical data
Legitimate interest, Article 6(1)(f) GDPR. The processing of your personal data is necessary in order to satisfy our legitimate interest in analyzing how our website is used.Your personal data is stored for a period of 1 month for this purpose. Statistics and reports which do not include any personal data are stored until further notice or until deleted.

5.5. Ensure technical functionality and the security of the Service

We use your personal data to ensure the technical functionality and the security of the Service, e.g. security logging, error handling and backup of data.

Personal DataLegal BasisStorage Period
  • Account data
  • Address data
  • Profile data
  • User-generated data
  • Technical data
  • Mobile subscriber data
  • Payment data
  • Communication
Legitimate interest, Article 6(1)(f) GDPR. The processing of your personal data is necessary in order to satisfy our legitimate interest in ensuring the technical functionality and the security of the Service.Your personal data is stored for this purpose until your user account is deleted. Personal data in technical logs are stored for a period of 13 months from the date of the log event.

5.6. Develop and improve the Service

It is our aim to give you the best digital reading experience possible. We, therefore, use your personal data to develop and improve the Service, e.g. to develop new features for the Forum.eu application.

Personal DataLegal BasisStorage Period
  • Account data
  • Profile data
  • User-generated data
  • Technical data
  • Mobile subscriber data
Legitimate interest, Article 6(1)(f) GDPR. The processing of your personal data is necessary in order to satisfy our legitimate interest in developing and improving the Service.Your personal data is stored for this purpose for such a period as is necessary in order to anonymize the data, test features or functionality and deploy patches and other bug fixes.

5.7. Other purposes

We may also use your personal data to:

Manage and Defend Legal Claims

If necessary we may use your personal data to manage and defend legal claims, e.g. in connection with a dispute or a court proceeding.

Personal DataLegal BasisStorage Period
  • Account data
  • Address data
  • Profile data
  • User-generated data
  • Technical data
  • Mobile subscriber data
  • Payment data
  • Communication
Legitimate interest, Article 6(1)(f) GDPR. The processing of personal data is necessary in order to satisfy our legitimate interest in managing and defending legal claims.Your personal data is stored for this purpose for such a period as is necessary in order to manage or defend the legal claim.

Fulfil Legal Obligations

Finally, we use your personal data to fulfil legal obligations that we have, e.g. accounting requirements or obligations under data protection laws.

Personal DataLegal BasisStorage Period
  • Account data
  • Address data
  • Profile data
  • User generated data
  • Technical data
  • Mobile subscriber data
  • Payment data
  • Communication
Legal obligations, Article 6(1)(c) GDPR. The processing of personal data is necessary in order to fulfil legal obligations to which we are subject.Your personal data is stored for such a period as is necessary in order to fulfil a respective legal obligation. Accounting information is retained for 7 years calculated after the end of the calendar year the relevant financial year ended.

6. WHEN DO WE COLLECT PERSONAL DATA?

We collect personal data when you:

6.1. Signing-Up and Creating a User Account

When you sign up for the Service, we collect the personal data that you provide such as your email address, password and country in order to create your user account.

If you connect to the Service by using Facebook, you authorize us to collect your username and other information that may be available through your Facebook account, including your name, country, e-mail address, date of birth and gender. We only collect the information which you make available to us according to your Facebook privacy settings.

6.2. Use the Service

When you use and interact with the Service, we collect information about how the Service is accessed and used. For example, we collect information about your language preferences, the type of articles you have read and the interactions that you make with the Service, e.g. which articles you mark as favourites.

We also collect certain technical information, which includes e.g. URL information, your IP address, the type of device that you use to access the Service, your device's operating system and Forum.eu application version.

If you have signed up for the Service via one of our business partners, we collect information on whether payment has been made from the business partner.

6.3. Make a payment

We use payment service providers to process your payment. When you pay for a subscription, we collect your name, address and credit or debit card information (e.g. card type and expiration date) which are needed in order to process the payment. We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Apple Store In-App Payments: Their Privacy Policy can be viewed at
https://www.apple.com/legal/privacy/en-ww/

Google Play In-App Payments: Their Privacy Policy can be viewed at
https://www.google.com/policies/privacy/

Adyen: Their Privacy Policy can be viewed at
https://www.adyen.com/policies-and-disclaimer/privacy-policy

PayPal: Their Privacy Policy can be viewed at
https://www.paypal.com/webapps/mpp/ua/privacy-full

Chargebee: Their Privacy Policy can be viewed at
https://www.chargebee.com/docs/eu-gdpr.html

6.4. Communicate with us

We collect the information you provide when communicating with us, e.g. when contacting our customer support or interacting with us on social media platforms. This may include your name, e-mail address and your communication.

6.5. Participate in surveys or marketing activity

If you choose to participate in contests and surveys, we ask you for certain information in addition to what is stated above. This additional information may be combined with other information we have collected.

6.6. Information collected when using the App

Application means the software program provided by the Company downloaded by you on any electronic device (“Our Application”). While using our Application, in order to provide features of our Application, we may collect, with your prior permission Information regarding your location - We use this information to provide features of our Service, to improve and customize our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it might simply be stored on your device. You can enable or disable access to this information at any time, through your device settings.

7. SHARING OF PERSONAL DATA

We disclose personal information to certain recipients to facilitate the operation of the Service. These recipients are data controllers for their own use of your personal data unless we have stated otherwise.

7.1. Service Providers

We use service providers to operate the Service. They provide for example IT services (e.g. hosting), manage payments, and communication services (which allows us to send notifications and newsletters to you). Where a third-party service provider processes personal data on our behalf they act as data processors and we are responsible for the use of your personal data. They may not use your personal data for their own purposes and they are obligated to protect your personal data.

7.2. Publishers

The Service allows you to read articles in a digital format. In order to provide the Service, we collaborate with publishers that license this content to us (“Publishers”). We share usage data with Publishers in order to allow them to analyze the usage of their articles. Please read the Publisher's own privacy policy for information on how they use your usage data.

Personal DataLegal Basis for the Transfer
  • Account data (only name and physical address)
Legitimate interest, Article 6(1)(f) GDPR.The transfer is necessary in order to satisfy our legitimate interest in fulfilling our contractual commitments with the publishers and the publishers' legitimate interest in analyzing the readership of their articles.

7.3. Payment Service Providers

We use payment service providers to process payments.

Personal DataLegal Basis for the Transfer
  • Account data
Performance of a contract, Article 6(1)(b) GDPR. The transfer is necessary in order to handle the payment for your paid subscription.

Social Network Platforms

To promote the Service on social network platforms (e.g. Facebook, Twitter and LinkedIn), we share certain information with such social network platforms. The Service includes social features that allow you to share content with others.

Personal DataLegal Basis for the Transfer
  • Profile data
Legitimate interest, Article 6(1)(f) GDPR. The transfer is necessary in order to satisfy our legitimate interest of promoting the Service on social network platforms.

7.4. Other Sharing

In addition to the above, we may if necessary share your information with other recipients for the following purposes:

  • to allow a merger or an acquisition
  • to manage or defend a legal claim
  • to respond to lawful requests from authorities according to mandatory applicable laws.
PurposeLegal Basis for the Transfer
Allow a merger or an acquisitionLegitimate interest, Article 6(1)(f) GDPR.The transfer is necessary in order to satisfy our legitimate interest in allowing a merger or an acquisition of our business.
Manage or defend a legal claimPerformance of a contract, Article 6(1)(b) GDPR. The transfer is necessary in order to satisfy our legitimate interest in managing or defending legal claims.
Respond to lawful requestsLegal obligations, Article 6(1)(f) GDPR. The transfer is necessary in order to fulfil legal obligations to which we are subject.

8. TRANSFER TO OTHER COUNTRIES

We transfer and use the personal data that we collect in various countries in order to provide the Service. For example, we use service providers that might be located in other countries outside your home country. Personal data collected within the European Union (EU) and the European Economic Area (EEA) might in certain circumstances be transferred outside and used by our service providers outside the EU and EEA. In order to ensure that your personal data is always protected we ensure that there are adequate safeguards in place, e.g. data transfer agreements or, in case of transfer of personal data to the U.S., that the recipient is certified according to the EU-U.S. Privacy Shield framework. If you have questions or concerns, please contact us at [email protected].

9. COOKIES AND OTHER SIMILAR TECHNOLOGIES

We use cookies on our website and in the Service. Cookies are tidbits of information (usually text) a server sends to an application or browser, so the application or browser can return this information to the server upon a next visit. We use cookies as well as similar tracking technologies and analytics tools across our site forum.eu to collect information about you. This information can be used to improve the performance of the site, make advertising more relevant and enhance your user experience. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
TypeAdministered byPurpose
Session CookiesUsThese Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
Cookies Policy / Notice Acceptance Cookies
TypeAdministered byPurpose
Persistent CookiesUsThese Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
TypeAdministered byPurpose
Persistent CookiesUsThese Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
TypeAdministered byPurpose
Persistent CookiesThird-PartiesThese Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website. These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

10. ANALYTICS

We also may use third-party Service providers to monitor and analyze the use of our Service, including but not limited to:

Google Analytics

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 contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:
https://policies.google.com/privacy?hl=en

Mixpanel

Mixpanel is provided by Mixpanel Inc. You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page:
https://mixpanel.com/optout/. For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to You.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy:
https://mailchimp.com/legal/privacy/

GetResponse

GetResponse is an email marketing sending service provided by GetResponse.

For more information on the privacy practices of GetResponse, please visit their Privacy policy: https://www.getresponse.com/legal/privacy.html

Behavioral Remarketing

The Company uses remarketing services to advertise on third party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions:
https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page:
https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook:
https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA  http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada  http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe  http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

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 that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

12. KEEP YOUR PERSONAL DATA SAFE

We are committed to protecting our users’ personal data. We implement appropriate technical and organisation measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems. Your password protects your user account, so we encourage you to use a strong password that is unique to your Forum.eu account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Forum.eu Service.

13. CHILDREN

We do not knowingly collect information from children under the age of 14. If you are under 18 years old you must have your parents' or guardians' consent in order to use the Service. If it comes to our knowledge that we have collected Personal Data from a child under the age of 18, without the parents' or guardians' consent, we will take appropriate measures to delete the personal data provided. If you are a guardian or a parent and become aware that your child has provided personal data to us, please contact us at [email protected].

14. CHANGES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy. For example, we may decide to collect additional information or use for other purposes than those stated in the Privacy Policy. In such a case, we will notify you in advance in an appropriate way, e.g. by displaying a notice in the Service or by sending you an email and updating the last updated date at the top of this page.

15. HOW TO CONTACT US

Thank you for reading our policy! If you have any questions regarding this Privacy Policy, the Service or otherwise, please contact us at [email protected].

Forum CTEP GmbH
Lobeckstraße 30-35
10969 Berlin
Germany

Forum CTEP Gmbh is the data controller for the purpose of the personal data processed under this policy.

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