Last updated: October 15, 2019
Tips.gg website thanks to the visitor of the website (hereinafter: User) for visiting and for the Users interest in its services. The protection of the Users personal data during his visit to the website is an important concern for Tips.gg. Tips.gg has therefore created data protection notices in which it explains the handling of the Users personal data according to art. 12, 13 and 21 of the General Data Protection Regulation (GDPR). If the User has registered on Tips.gg, Tips.gg will inform the User via email of any changes.
Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes information such as the civil name, address, telephone number and date of birth.
I. Data Controller according to GDPR
- E-Mail: email@example.com
II. Purposes and Legal Bases of the Data Processing
1. Informational Use of the Website
The User can visit the Website without providing any personal information. If the User uses the Website for informational purposes only, i.e. does not log in, register or otherwise provides Tips.gg with information about himself, Tips.gg does not collect any personal data, with the exception of the data that the User’s browser transmits to enable the User to visit the Website as well as information that is transmitted to Tips.gg through cookies used for statistical analysis of the use of the Website.
a. Technical Provision of the Website
For the purpose of the technical provision of the Website, it is necessary that Tips.gg processes certain automatically transmitted information about the User, so that the User’s browser can display the Website and the User can use the Website. This information is automatically collected for each visit of the Website and stored in our server log files. This information refers to the computer system of the requesting computer. The following information is collected thereby:
- Browser type / -version (e.g.: Firefox 62.0.1 (64 Bit));
- Browser language (e.g.: English);
- Operating system (e.g.: Windows 10);
- Internal resolution of the browser window;
- Screen resolution;
- Java on / off;
- Cookies on / off;
- Color depth;
- Time of access;
- Mobile network information.
The following information is stored in the cookies and transferred to Tips.gg:
- alphanumeric identification information that is related to a user’s identification.
The User’s information, collected by Tips.gg through the aforementioned cookies, will not be used by Tips.gg to create user profiles or to evaluate the Users browsing behavior.
Tips.gg processes the Users personal data for the technical provision of the Website on the basis of the following legal bases:
- for the fulfillment of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, provided the Users visit of the Website to obtain information about our products or com (online) trainings; and
- to protect Tips.gg legitimate interests pursuant to Art. 6 para. 1 letter f GDPR in order to make the Website technically available to the User. Tips.gg’s legitimate interest is to offer the User an appealing, technically functioning and user-friendly website and maintain information security regarding cyber risks and prevent cyber risks for third parties from emanating from our website.
b. Statistical Analysis of Website Usage and Range Increase
For the purpose of statistical analysis of the use of the Website, Tips.gg uses Google Analytics and thus cookies, which enable an analysis of the Users browsing behavior. This enables Tips.gg to improve the quality of the Website and its content. Tips.gg learns how the Website is used and can thus continuously optimize its offer.
The information obtained in the context of the statistical analysis of the Website will not be merged with the User’s other data collected in the context of the Website.
Tips.gg processes the Users personal data for statistical analysis of the use of the Website on the basis of the following legal bases:
- If the User has given Tips.gg its consent, pursuant to Art. 6 para. 1 lit. a GDPR
The Website uses Google Analytics, a web analysis service of Google Inc. Google Analytics uses so-called “cookies”: text files placed on the User’s computer, enabling an analysis of the use of the Website by the User. The information generated by the cookie about the Users use of the Website is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on Tips.gg’s website, Google will shorten the Users IP address within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On Tips.gg’s behalf, Google will use this information to evaluate the User’s use of the Website, to compile reports on website activities and to provide the website’s operator with other services relating to the website and internet use. The IP address transmitted by the Users browser in the context of Google Analytics is not merged with other Google data.
On the Website, Tips.gg uses Google Analytics with the extension “_anonymizeIp()”. This arranges for IP addresses to be further processed in abridged form, a direct relation to a person can be ruled out.
Tips.gg uses Google Analytics exclusively with the consent of the User. The User may revoke a consent once given by
- preventing the storage of cookies by setting his browser software accordingly; however, Tips.gg points out to the User, that in this case, the User may not be able to use all functions of our website in full;
- downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en or
- clicking this link to prevent future collection by Google Analytics on Tips.gg website. An opt-out cookie is stored in the User’s browser. However, the User should note that he must activate the opt-out cookie in every browser he uses on all end devices and must also reactivate it if necessary once all cookies in a browser have been deleted.
c. Social Links
The Website includes links to services such as Google, Facebook, Twitter, Twitch and YouTube. After clicking on the link you will be redirected to the page of the respective provider, i.e. only after clicking on the link, User information will be transferred to the respective provider. For information on the handling of your data when using the Websites of other providers, please check the respective data protection information of these providers.
2. Active Use of the Website
In addition to the merely informational use of our website, the User can also actively use the Website e.g. to register as a registered user, to register and tag his business or to contact Tips.gg. In addition to the above-mentioned processing of the Users personal data for merely informational purposes, Tips.gg will also process other personal data that Tips.gg requires from the User to process the User’s order or to process and respond to the Users inquiry.
a. User Requests and Requests for Consultation
In order to process and answer the Users inquiries to Tips.gg, e.g. via the contact form or Tips.gg’s e-mail address, Tips.gg processes the Users personal data provided by him in this context. In any case, this includes the Users first and last name and e-mail address in order to send an answer, as well as the other information that the User sends to Tips.gg in the context of his message. It is up to the User to make his own decision as to whether and which information he provides in this way.
Tips.gg processes the Users personal data in order to respond to the Users inquiries on the basis of the following legal bases:
- to protect com’s legitimate interests pursuant to Art. 6 para. 1 lit f GDPR; Tips.gg’s legitimate interest is to answer customer inquiries appropriately.
b. Sending of application documents
Tips.gg processes the Users personal data with regard to his application, provided that he makes this data available to Tips.gg. The application documents may contain special categories of personal data.
According to Art. 9 DSGVO, special categories of personal data are data, which reveal racial and ethnic origin, political opinion, religious (e.g. information on religion/confession) or ideological beliefs or trade union membership, as well as the processing of biometric data for unique identification (e.g. photos), health data (e.g. information on the degree of disability) or data on sexual life or orientation. If the User’s CV contains special categories of personal data, Tips.gg does not collect them on purpose. Tips.gg explicitly asks the User not to send such data.
Moreover, if the User contacts Tips.gg via e-mail, Tips.gg processes the data the User may send to Tips.gg. Below, Tips.gg informs the User about the purpose as well as the legal basis of such data processing.
In case the User sends Tips.gg his application, Tips.gg will process the data collected in order to execute the application process. According to Art. 88 para 1 DSGVO in conjunction with Art. 26 para 1 sentence 1 BDSG-new, data processing is permitted, among other things, for the decision on the establishment of an employment relationship. Usually, the applicant data includes the following information: first and last name, if applicable academic degree, date, and place of birth, contact data (address, e-mail, telephone and/or mobile phone number), application documents (cover letter, CV, certificates), language skills, abilities.
Within legal requirements, Tips.gg bases its decisions during the application process on the personal data the User provides Tips.gg. For example, Tips.gg uses the Users professional qualifications in order to decide whether to consider him on the shortlist or to have an interview with him to get a personal impression in order to make a decision whether Tips.gg is offering the User the job he applied for.
Tips.gg processes the Users personal data on the basis of the following legal requirements:
- Data processing for the decision on the establishment of an employment relationship, Art. 88 para. 1 DSGVO in conjunction with Art. 26 para 1 sentence 1 BDSG-new
Tips.gg processes the Users special personal data on the basis of the following legal requirements:
- Pursuant to Art. 9 para 1 DSGVO based on the Users approval according to Art. 88 para 1 DSGVO in conjunction with Art. 26 para 3 sentence 2 BDSG-new
If the User – as part of his application documents – voluntarily and contrary to Tips.gg’s explicit request, sends Tips.gg special categories of personal data pursuant to Art. 9 para. 1 DSGVO (e.g. his photo or details of his religion/confession), Tips.gg will store such data on the basis of his consent pursuant to Art. 88 para. 1 DSGVO in conjunction with Art. 26 para 3 sentence 2 BDSG-new. This also applies, if the User provides Tips.gg with further special personal data in the course of the application process.
By voluntarily submitting this data and by accepting this data protection declaration, the User agrees to the storage of this special personal data within the application process. Tips.gg does not take this special personal data into account when making a selection decision unless it is required by law to do so. It is possible, for example, that people with disabilities may receive preferential treatment in some job advertisements in accordance with applicable laws. In these cases, the information is always voluntary and is provided with the Users explicit consent, which the User declares by voluntarily submitting this data and accepting this data protection declaration.
If the User has subscribed to Tips.gg’s newsletter, Tips.gg collects and uses the Users personal data (first name, last name, email address) to send information about the services Tips.gg offers and the products displayed on the Website by email on a regular basis.
For the subscription to the newsletter, Tips.gg uses the so-called double opt-in procedure, i.e. the registration is not complete until the User has confirmed his registration by clicking on the link contained in a confirmation e-mail sent to him for this purpose. If the User does not confirm the subscription, his subscription to the newsletter will automatically be deleted from Tips.gg’s database.
The User can unsubscribe from the newsletter at any time with future effect. Therefore the User has to send an email to firstname.lastname@example.org.
The legal basis for the collection of the Users’s personal data is Art. 6 para. 1 lit. a GDPR; Tips.gg will process the User’s data with the User’s consent.
d. Registration and User Account
The User can create a user account to use other services which are only accessible for registered Users. For this purpose, the User has to register.
The User must enter his e-mail address, a password of his choice and a username of his choice. In addition, the User has to enter the following data:
- First and Last name
- Date of birth
Tips.gg uses the so-called double opt-in procedure for registration, i.e. the registration is not complete until the User has confirmed his registration by clicking on the link contained in a confirmation e-mail sent to him for this purpose. If the User does not confirm the registration, his registration will automatically be deleted from Tips.gg’s database. The indication of the e-mail address is obligatory in order to be able to assign the User to the data contained in Tips.gg’s customer database.
After successful registration, the User can perform certain activities through his user account, such as changing his data, etc.
Tips.gg processes the Users data for the above purposes on the basis of the following legal bases:
- for the performance of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, provided that the User registers to use the user account and the services offered in this context; and
- to safeguard com’s legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, in order to make the portal technically available to the User. Tips.gg’s legitimate interest is to be able to provide the User with an appealing, technically functioning and user-friendly portal.
e. Law Enforcement
Tips.gg processes the Users personal data in order to assert Tips.gg’s rights and enforce Tips.gg’s legal claims. Tips.gg also process the Users personal data in order to be able to defend itself against legal claims. Finally, Tips.gg processes the Users personal data to the extent necessary to defend against or prosecute criminal offenses.
Tips.gg processes the User’s data for the above purposes on the basis of the following legal bases:
- to protect com’s legitimate interests pursuant to Art. 6 para 1 lit. f GDPR, insofar as Tips.gg asserts legal claims or defends itself in legal disputes or Tips.gg prevents or clarifies criminal offenses.
Some sections of the Website contain links to third-party websites. These websites are subject to their own data protection principles. Tips.gg is not responsible for their operation, including data handling. If the User sends information to or through such third-party sites, the User should review the privacy statements of those sites before submitting information that may be associated with him.
V. Categories of Recipients
Firstly, only Tips.gg’s employees will have access to the Users personal data. In addition, Tips.gg shares the Users personal data with other recipients who provide services to Tips.gg in connection with the Website, insofar as this is legally permitted or prescribed. Tips.gg limits the transfer of the Users personal data to what is necessary. In some cases, Tips.gg’s service providers receive the Users personal data as contract data processors and are then strictly bound by Tips.gg’s instructions when handling the Users personal data. In some cases, the recipients act independently with the Users data, which Tips.gg transmits to them.
Below, Tips.gg describes the categories of recipients of the Users personal data:
- External service providers for sending invoices by post,
- IT service providers who administrate, provide and host Tips.gg’s website,
- Collection companies and legal advisors in asserting Tips.gg’s claims,
- Possibly further categories of recipients.
Additionally, Tips.gg may share the Users personal data within the global Tips.gg family of companies, e.g. with Tips.gg subsidiaries. Such data may be used by each Tips.gg entity for internal business and operational purposes as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorized by you.
VI. Transfer into Third countries
Tips.gg operates his business on a global scale. Therefore the Users personal data may be transferred to recipients outside the European Union. In these cases, the recipients are either situated in a country for which an adequacy decision by the Commission exists, or Tips.gg has entered into standard data protection clauses adopted by the Commission or adopted by a supervisory authority and approved by the Commission. The Users can ask the Data Protection Officer of Tips.gg to provide him with a copy of the respective standard data protection clauses.
VII. Duration of Storage
1. Informational Use of the Website
When using the Website for information purposes only, Tips.gg stores the Users personal data on its servers exclusively for the duration of the Users visit to the Website. After the User has left the Website, the personal data will be deleted immediately.
Cookies installed by Tips.gg are usually also deleted after leaving the Website. However, this does not apply to Google Analytics. These remain stored for the duration of 24 months. Tips.gg also has the option to delete installed cookies itself at any time.
2. Active Use of the Website
If the User actively uses the Website, Tips.gg initially stores his personal data for the duration of responding to the Users inquiry or for the duration of the Users business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
Cookies installed by Tips.gg are usually also deleted after leaving the Website by using the log-out link from the Website. However, if a User leaves the Website without logging off, this does not apply to login_code, keep_login, and Google Analytics. Login_code remains stored for the duration of 31 days, keep_login remains stored for the duration of 21 days and Google Analytics remains stored for 26 months. Tips.gg also has the option to delete installed cookies itself at any time.
In addition, Tips.gg will store the Users personal data until any legal claims arising from the relationship with the User becomes time-barred, in order to use them as evidence if necessary. The limitation period is generally between 12 and 36 months, but can also be up to 30 years.
Upon expiry of the limitation period, Tips.gg deletes the Users personal data, unless there is a legal obligation to store such data, for example from the German Commercial Code (sec. 238, 257 para. 4 HGB) or from the Tax Code (sec. 147 para. 3, 4 AO). These retention obligations can last from two to ten years.
VIII. Users Rights as Data Subject
Under the legal provisions the User is entitled to the following rights as a data subject, which the User can assert against Tips.gg:
- Right to information: The User is entitled to request confirmation from Tips.gg at any time within the scope of Art. 15 GDPR as to whether Tips.gg is processing personal data relating to the User; If this is the case, the User is also entitled under Art. 15 GDPR to receive information about such personal data as well as other specific information (inter alia, processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.
- Right to correction: According to Art. 16 GDPR, the User is entitled to demand correction of the personal data stored about him if it is inaccurate or incorrect.
- Right to deletion: The User is entitled, under the conditions of Art. 17 GDPR, to request from Tips.gg the deletion of personal data relating to the User without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defense of legal claims.
- Right to the limitation of processing: Under the conditions of Art. 18 GDPR the User is entitled to request from Tips.gg the limitation of the processing of your personal data.
- Right to data transferability: The User is entitled, under the conditions of Art. 20 GDPR, to request from Tips.gg the provision of the personal data relating to the User that he has submitted to Tips.gg in a structured, current and machine-readable format.
- The right of revocation: The User has the right to revoke his consent to the processing of personal data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.
- Right to the objection: The User is entitled to object to the processing of his personal data under the conditions of Art. 21 GDPR, meaning that Tips.gg has to terminate the processing of his personal data. The right of objection exists only within the limits provided for in Art. 21 GDPR. In addition, Tips.gg’s interests may prevent the processing from being terminated, so that Tips.gg is entitled to process his personal data despite the Users objection.
- Right of appeal to a supervisory authority: The User is entitled to file a complaint with a supervisory authority, in particular in the Member State of his place of residence, work or suspected infringement, under the conditions laid down in Article 77 GDPR, if the User believes that the processing of personal data concerning him infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy.
However, Tips.gg recommends that the User always addresses a complaint to Tips.gg’s email first.
IX. The scope of the Users obligations to provide Data
Generally, the User is not obliged to provide Tips.gg with his personal data. However, if he does not provide this information, Tips.gg will not be able to make the Website available to the User, answer his questions and enter into a contract with him. Personal data which Tips.gg does not necessarily require for the above-mentioned processing purposes are marked as voluntary information by a ” if applicable ” or another symbol.
X. Automated Decision Making/Profiling
Tips.gg does not use automated decision making or profiling (an automated analysis of the Users personal circumstances).
Information about the Users right of objection Art. 21 GDPR
- The User has the right to object at any time to the processing of his data on the basis of Art. 6 para. 1 f GDPR (data processing on the basis of a balance of interests) or Art. 6 para. 1 e GDPR (data processing in the public interest), if there are reasons for this arising from his particular situation. This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 GDPR.
If the User objects, Tips.gg will no longer process the Users personal data, unless Tips.gg can prove compelling and applicable reasons for the processing, which outweigh the Users interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
- Tips.gg also process the Users personal data in individual cases for direct marketing purposes. If the User does not wish to receive advertising, he has the right to object to it at any time; this also applies to profiling, insofar as it is associated with such direct advertising. Tips.gg will take this contradiction into account in the future.
Tips.gg will no longer process the Users data for direct marketing purposes if the User objects to the processing for these purposes.
Last updated: October 15, 2019