Last updated: February 2022
This Privacy Policy shall apply to the Jodel websites https://jodel.com/, https://jodel-app.com/ and https://share.jodel.com and every URL or Subdomain that contains or ends with https://jodel.com/ (these websites together also the “Website” or as “Services”). You can find the privacy policy for the app in the following links:
Regarding the Services The Jodel Venture GmbH, Wilhelmstraße 118, 10963 Berlin (“Jodel”, “we”, “us” or “our”) is the controller within the meaning of the General Data Protection Regulation (“GDPR”).
The Jodel Venture GmbH
Wilhelmstraße 118
10963 Berlin Germany
Telefon: 0157- 322 687 22
Email: [email protected]
This privacy policy shall inform you on how we collect, process and use (“Use”) your Personal Data in connection with the Services.
By using our website, access to information (e.g. IP address) or storage of information (e.g. cookies) in your terminal equipment may occur. This access or storage may involve further processing of personal data pursuant to the GDPR.
In cases where such access to information or such storage of information is strictly necessary for the technically error-free delivery of our services, this is done on the basis of § 25 para. 1 s. 1, para. 2 no. 2 TTDSG.
In cases where such a process serves other purposes (e.g. the needs-based design of our website), this will only be carried out on the basis of § 25 para. 1 TTDSG with your consent pursuant to Art. 6 para. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future.
For more information on the processing of your personal data and the relevant legal basis in this context, please refer to the following sections on the specific processing activities on our website.
a. Regarding the Website: if you visit the Website your browser automatically transfers certain data so that it can access the Website, in particular: the IP address, the date and time of the request, the browser type, the operating system, the language and version of the browser software. Such data is processed, in particular, as without such data the Website cannot be accessed.
b. On the one hand, your data is collected when you provide it to us. This may be data that you enter into a contact form, for example. This data is used to contact you via the given information. The use of our website is usually possible without providing personal data. As far as personal data (e.g. name or e-mail addresses) is collected on our pages, this is always done on a voluntary basis as far as possible. This data will not be passed on to third parties without your express consent. If you would like to receive the content offered on the website, we need an e-mail address from you. Further data will not be collected. We use these data exclusively for sending the requested information and do not pass them on to third parties.
c. If you provide to us information on the Website via a request form contained on the Website or on another way then we will process your data in order to answer your respective (information) requests.
d. We might disclose your Personal Data where such disclosure is required by law (for example, upon request of a court or of law enforcement authorities).
a. We also analyze data of usage to better understand user preferences through user actions. Next to our own analytics we also use the following tools:
aa. Google Analytics
The Website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyze how you use the Website. The information generated by the cookie about your use of the Website will normally be transmitted to and stored by Google on servers in the United States. Google will use this information on behalf of the operator of the Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services for the Website operator relating to Website activity and internet usage. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use all functions of the Website. You can also opt-out from the storage by Google of the data that is created by the cookie and is related to the use of the Website (including your IP address) and the processing of such data by Google by downloading and installing the Google Analytics opt-out Browser add-on available under https://tools.google.com/dlpage/gaoptout?hl=en. For further information on Google Analytics please refer to: http://www.google.com/analytics/terms/gb.html, https://support.google.com/analytics/answer/6004245?hl=en, http://www.google.de/intl/en-GB/policies/privacy/.
Since a transfer of personal data to the U.S. takes place, further appropriate safeguards are required to ensure the level of data protection under the GDPR. To guarantee this, we have concluded standard contractual clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the U.S. to process the data according to the level of protection in Europe. In cases in which this cannot be guaranteed even by this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the U.S.
The data will be deleted as soon as it is no longer necessary for the purpose for which it was collected.
bb. LinkedIn Analytics/Insight Tag
We use conversion tracking technology on our website as well as the retargeting feature of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
This allows us to serve personalized ads to visitors to our website on LinkedIn. For this purpose, a cookie, LinkedIn Insight tag, is set in your browser with a validity of 120 days. This cookie enables LinkedIn to recognize you if you visit this website and are simultaneously logged in to your LinkedIn account. LinkedIn uses this data to generate anonymous reports on ad performance and website interaction information. The information generated by the cookie is usually transferred to a server in the USA and stored there.
The legal basis for the processing is your consent according to Art. 6 para. 1 (a) GDPR. Since a transfer of personal data to the USA takes place, further protective mechanisms are required to ensure the right level of data protection. For this, we have signed Standard Data Protection Contractual Clauses with the Provider in accordance with Art. 46, para. 2 © GDPR. These require the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even by this contractual extension, we will endeavour to obtain additional regulations and commitments from the recipient in the USA.
You may opt-out of LinkedIn Insight conversion tracking and interest-based personalized advertising by following this link: https://www. linkedin. com/psettings/guest-controls/retargeting-opt-out. For more information about LinkedIn’s privacy policy, please visit https://www. linkedin. com/legal/privacy-policy.
cc. branch.io
We use the tool branch.io of Branch Metrics, Inc. 1400 Seaport Blvd, Building B, 2nd Floor, Redwood City, CA 94063, USA (“Branch Metrics”) with regard to the App. branch.io is a real-time database, which we are using for real-time data exchange and data storage. branch.io also allows for analyzing anonymized behavioral data, in particular the analyzing of active users and activity events (e.g. posts, replies, votes). We also use branch.io to analyse more complex use cases of the app which we otherwise would not be able to understand (connection between sharing content and engagement, what is the source of users registering into the app) so that we can further optimise the app and identify real users and bots. Certain (anonymized) user data might be sent to Branch Metrics. For further information regarding branch.io please refer to https://branch.io/policies/#privacy.
Since a transfer of personal data to the U.S. takes place, further appropriate safeguards are required to ensure the level of data protection under the GDPR. To guarantee this, we have concluded standard contractual clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the U.S. to process the data according to the level of protection in Europe. In cases in which this cannot be guaranteed even by this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the U.S.
The data will be deleted as soon as it is no longer necessary for the purpose for which it was collected.
dd. If you decide to deactivate (some of) the tools described in this section 3 (to the extent this is possible), please note that certain features and functionalities of the Services might not work or might not be accessible to you.
b. The legal basis for the processing of the data described in paragraph 3 is Art. 6 (1), paragraph 1, letter a DSGVO given consent. We use and such data for analyzing the respective data (i) to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services, (ii) to help personalize your user experience, (iii) to recognize user patterns in order to protect the App against bots, abusive members and abusive content, and (iv) to provide you with certain features of the Services (without us using such data some of the functionalities of the Services might not work or might not be accessible (this applies, in particular, to the tools mentioned above in sections 3.b, aa, bb, cc, dd; with regard to item (iv) such processing of data is also based on Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures)).
c. In order to comply with existing youth protection laws, some content is only accessible after successful age verification. The data submitted during the verification process is stored in the browser’s local storage and is checked each time protected content is visited.
If you write to us via the contact form, your details from the enquiry form or your e-mail will be stored by us for the purpose of processing the enquiry and in case you have follow-up questions. An e-mail address is required for contact purposes. Under no circumstances will we share these data without your consent. The legal basis for processing the data is our legitimate interest in replying to your request. We use the Zendesk tool to reply to your request. Zendesk is software by Zendesk, Inc, 1019 Market Street San Francisco, CA 94103, a US company. Zendesk processes your data on our behalf only. Your data will be deleted after the final processing of your request, unless there are legal obligations to keep records. You can object to the processing of your personal data at any time in accordance with Art. 6 (1) lit. f GDPR.
Since a transfer of personal data to the U.S. takes place, further appropriate safeguards are required to ensure the level of data protection under the GDPR. To guarantee this, we have concluded standard contractual clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the U.S. to process the data according to the level of protection in Europe. In cases in which this cannot be guaranteed even by this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the U.S.
For more information about Zendesk’s data processing, please visit Zendesk’s Privacy Policy at www.zendesk.de/company/customers-partners/privacy-policy/ and the EU Data Protection page www.zendesk.de/company/customers-partners/eu-data-protection/.
We partly use service providers who process Personal Data on behalf of us to operate the technical platform for the Services. These service providers process the data exclusively according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).
Unless no shorter storage period is indicated in this privacy policy, we, in general, store Personal Data as long (i) as required for the provision of the Services to you, and/or (ii) as it is necessary with regard to the contractual relationship with you, thereafter only if and to the extent that we are obliged to do so by mandatory statutory retention obligations. If we no longer require the respective Personal Data for the purposes described above, such Personal Data will only be stored during the respective legal retention period and not processed for other purposes.
You have the following rights regarding your personal data:
You have the right to request information about your personal data processed by us in accordance with Art. 15 GDPR.
The right to immediately request the correction of incorrect or complete personal data stored by us in accordance with Art. 16 GDPR.
You have the right to have your personal data erased in according with Art. 17 GDPR. According to this provision, your right to have your data erased may be excluded due to a conflicting interest.
You have the right to have the processing of personal data concerning you limited in accordance with Art. 18 GDPR.
You have the right to withdraw your given consent to the processing of your personal data at any time according to Art. 7 para. 3 GDPR.
The right to receive your personal data that you have provided to us in a structured, current and machine-readable format or to request its transfer to another person responsible in accordance with Art. 20 GDPR.
The right to complain to a supervisory authority pursuant to Art. 77 GDPR. As a rule, you can contact the supervisory authority of the federal state in which we have our registered office or, if applicable, that of your usual place of work or usual residence.
Right of objection If your personal data is processed by us on the basis of legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, insofar as this is for reasons resulting from your particular situation. If the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right of objection without the requirement to indicate a special situation.
You can contact us, for example, via the address indicated above in section 1., via [email protected] and/or by using the contact info contained in the App or on the Website.
For all questions regarding data protection at Jodel (including the assertion of your rights further describe above under section 6.), you can also contact Jodel’s Data Protection Officer directly. The contact details of the data protection officer are:
PROLIANCE GmbH
www.datenschutzexperte.de
Leopoldstr. 21
80802 München
[email protected]
We place great importance on the security of all Personal Data associated with the use of our Services. We have security measures in place to attempt to protect against the loss, misuse and alteration of Personal Data under our control. Our security and privacy policies are periodically reviewed and enhanced as we consider it appropriate and only authorised personnel have access to Personal Data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
We have taken additional extensive security precautions relating to our Services and their use. However, you should bear in mind that in spite of such security measures, submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our Services whilst it is in transit over the internet.
Here you will find our Transparency Report (in German for now, from January 2020), which we prepared to let you know how our moderation system and cooperation with legal authorities works, what were the biggest challenges in the last few months and what is coming in the future.
Since Jodel started we have always deeply respected our user’s right to privacy while at the same time granting the right to free uncensored speech. Additionally, for the last weeks, we have been working hard on making sure that our internal processes are in line with the new GDPR law. That is why you can be sure that this topic is especially important for us.