Capture Media AG

Data protection declaration and disclaimer

Client: vlot AG

Capture Media AG (hereinafter “Capture”) respects the privacy and personal rights of users. Responsible handling of personal data is an important concern for the company. The following text explains what data Capture processes, where the data is stored and what rights users have.

1. About Us

Capture is a Swiss company based in Zurich. Capture develops and operates tracking solutions for the analysis and optimization of digital offers and advertising campaigns. Furthermore, Capture also sells its own campaign solutions to national and international business customers.
Capture’s business customers have an economic interest in improving their digital offerings based on measured usage, thus offering users an optimized user experience. Business customers can also optimize the efficiency of their advertising campaigns and media purchasing.

2. Data-processing activities

2.1. Anonymous measurements

Capture’s tracking is basically anonymous. This means that Capture cannot assign the collected data to a specific person. The following tracking events and engagements can be measured if a business customer integrates the Capture tracking script into the digital presence (all events and engagements can be displayed per campaign, per publisher (website, app etc.), per channel (social, search, newsletter etc.) and per advertising medium (e.g. advertising banner, text ad etc.)):

– Timestamp, Ad-Impressions, Clicks, Clients and Unique Clients, Sessions, Visit duration, URL visited, Scroll depths, Text and image visibility, Hovers, Video engagements (Clicks, Play, Play duration, Visibility), Audio engagements (Clicks, Play, Play duration, Visibility), Onpage-Clicks, Clickouts, filled out form fields.
– Various key figures such as click rates, engagement rates, play rates and similar values are derived from the measured engagements and events. Business customers can set up their own key figures derived from the measured values.
– In addition to engagements and events, different technical values are measured and stored: country, region, city, approximate position of the Internet connection point, user agent (operation system (type, version, subversion)), device (type, brand, model), browser (type, version, subversion), referrer, IP address (anonymized).

Measures to make tracking data anonymous before the data is stored:

– A user’s IP address provides at least a theoretical way of identifying a specific person. For this reason, Capture does not store the IP address in an identifiable way, but creates a random code from the IP address. Therefore, business customers, employees or partners of Capture do not have access to the IP address of a user.
– To ensure that no conclusions can be drawn about a specific person via geo localization, Capture only saves the geo information down to city/town level. Information that allows more accurate localization is not stored.

3. Storage of data

All data is stored at AWS in Ireland (Amazon Web Services).

Amazon Web Services Ireland Limited
One Burlington Plaza
Burlington Road
Dublin 4

4. Data security

Capture has implemented numerous technical and organisational measures for the processing of personal data. The aim is to ensure that this data is protected as good as possible. However, Internet-based data transmissions can have security gaps, which is why absolute protection cannot be guaranteed.

4.1. Access control – The business buildings of Capture and the AWS data centers are protected against unauthorized access (security locks, batch, alarm).
4.2. Access control – Capture stores all data in encrypted form.
4.3. Transfer control – When personal data is transferred, the sender and recipient of the data are logged (persons, time).
4.4. Input control – Changes to the settings of Capture’s technology that can affect personal data are logged.
4.5. Order control – Orders are summarized internally in a briefing at Capture. Specific reference is made to contractual obligations with the employee responsible.
4.6. Availability Control – Capture backs up all data several times a day. Internal processes define the fastest possible recovery of data in the event of an interruption.
4.7. Guarantee of the earmarking/separation requirement – Personal data generated about/for a business customer will be used exclusively for the purpose described. Capture does not use personal data for purposes other than those agreed by the user at the time the form was submitted.

5. Data transfer

Depending on the situation, the data must be passed on to third parties. Partially for the performance of the contract or for order processing. The data will be passed on to the following company:

vlot AG
Hardturmstrasse 133
8005 Zurich
(Purpose: Performance of contract)

6. Data deletion

Anonymous data is stored without time limit. Personal data is stored for 25 months. After this time has elapsed, personal data will be deleted automatically. Users have the right to request the deletion of their personal data before the end of this period (see 7.4. right to delete the data).

7. User rights

7.1. The right to be informed

Users have the right to know which data Capture has stored about them as a person. On request, Capture sends these data to the corresponding user. The user must sufficiently prove that he/she is the person he/she claims to be.

7.2. The right of rectification

Users have the right to correct personal data stored about them. A correction must be checked individually.

7.3. Right to object to data processing

Users may object to the processing of their data. In the event of an objection, the processing process is interrupted. In specific cases, no objection may be raised to the processing of the data, for example when the data must be used for evidential purposes.

7.4. Right to delete the data

Users have the right to have their personal data deleted. The user must sufficiently prove that he/she is the person he/she claims to be. If the data cannot be deleted, the user has the right to block the data.

7.5. Right to be forgotten

If information about a user has been published, for example when naming a winner in a competition, the user has the right to have this data deleted after a certain period of time.

7.6. Right to data portability

Users have the right to request the disclosure of their personal data in a machine-readable format in order to be able to port this personal data to a third party system.

7.7. Right of appeal to supervisory authorities

Users have the right to complain to the responsible data protection authorities about unauthorised data processing.

8. Opt-out possibility

Users have the possibility to opt-out from the anonymous measurements of Capture for this website. If a user has unsubscribed, Capture stores a DO-NOT-TRACK cookie in the user agent of the user. This cookie is technically necessary to identify users who do not wish to be tracked. If a user has unsubscribed, Capture does not store any data about the user’s usage behavior. If a user deletes the cookies or uses another browser or another device, the process must be repeated.

Opt-out: vlot Engagement

Users also have the option of re-entering anonymous tracking. In this way, users help the operator of the website to improve the service.

9. Third party tracking integration

Third party tracking tools are integrated into this website.

9.1. Publisher tracking for advertising campaigns

Legitimate interest: Economic interests (optimization of the web presence and media purchasing)
Depending on the campaign, various publisher tracking systems can be integrated into the website to optimize media purchasing during an advertising campaign. These trackings are only integrated for the duration of an advertising campaign and are then removed again. These trackings give the publisher the opportunity to optimize the campaign on the basis of anonymous performance values. Personal data will not be passed on to publishers.

10. Contact

10.1. Address and contact information

Capture Media AG
Löwenstrasse 3
8001 Zurich
Registration number: CHE-429.589.107

10.2. Data Protection Officer

If you have any questions or comments regarding data protection, please contact the data protection officer of Capture Media AG:

Mr. Sandro Albin