This service (hereinafter “App”) is provided by Rissland Marketing UG, Kurfürsten-Anlage 52, 69115 Heidelberg, Germany, represented by its managing director Alexander Rissland (hereinafter “we” or “us”) as the responsible party within the meaning of the applicable data protection law. With our app, we enable interaction between users and advertising companies (hereinafter referred to as partner companies). Our services include:
Certain information is already processed automatically when you use the app. We have listed exactly which personal data is processed for you below:
As part of your use of the App, we automatically collect certain data that is necessary for the use of the App. This includes:
Internal device ID, version of your operating system, time of access, IP address.
This data is automatically transmitted to us, but not stored, (1) to provide you with the Service and related features; (2) to improve the functions and performance features of the App; and (3) to prevent and remedy misuse and malfunctions. This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) (b) DSGVO for the use of the App, and / or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the App and in being able to offer a service that is in line with the market and interests, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) (f) DSGVO.
When you create a user account or register, we use your access data (email address and password) to grant you access to your user account and to manage it (“mandatory data”). Mandatory data within the scope of registration are required for the conclusion of the user contract. If you do not provide this information, you will not be able to create a user account.
This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) (b) DSGVO for the use of the app, and / or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the app, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) (f) DSGVO.
You may create a user account (hereinafter also referred to as “Profile”) on our Services in order to access the Smatched Services and your Features. In order to do so, you must log in to one of our social media partners with one of your accounts. In the process, our social media partners (Facebook, Instagram, Google, Apple, Twitter, TikTok) transmit personal data such as your email address to us and we process this data to create a user account and store it in our information technology systems. Your IP address and the time of registration are also stored.
When you log in to your profile, Smatched places cookies on your terminal device to enable you to remain logged in – even if you have to reload the app in the meantime. By creating the profile, you can use the functions of Smatched.
The processing operations associated with the creation and completion of a profile serve the purpose of being able to allocate future usage operations and to be able to access the entire range of Smatched services. Directly connected with this is, for example, checking whether you are suitable for surveys that we receive from the marketplaces. In order to participate in surveys, you must meet the criteria requested for the specific survey. We check whether you meet the criteria either by requesting you (if we have not yet requested the survey criteria from you), or automatically (if we have already requested the survey criteria from you) after receipt of the survey by comparing the criteria with the personal details you have provided. The processing of your data thus serves the execution of the contract, is thus purpose-bound and necessary according to Art. 6 para. 1 lit. b DSGVO.
The storage of IP address and time of registration is necessary to ensure the security of our information technology systems. This is also our legitimate interest, which is why the processing is also lawful according to Art. 6 Para. 1 lit. f DSGVO.
The personal data entered by you will be stored until the time of deletion of your profile at Smatched, beyond that only as long as the processing is necessary for any contract fulfilment.
We do not intend to pass on your data to third parties. All checks on the requested criteria in a survey are carried out by us on our servers.
Within the framework of the app, you can carry out, manage and edit various activities. As part of the activities, we store certain information about you and your user and surfing behaviour. The most important functions of the app include that
We store your activities, such as survey results, in order to transmit them anonymously as statistical evaluation data to partner companies after the end of a campaign. These partner companies in turn use this data for marketing and analysis purposes.
In addition, we integrate third-party advertisements and videos within the app via the “Google Admob” advertising network and the “YouTube” video portal of the Irish company Google Ireland Limited. You can find more details on data processing in this respect under point 2 of this notice.
The app also requires the following authorizations:
Internet access: This is required to store your entries on our servers, to evaluate and check your interactions and to prevent misuse.
The processing and use of usage data is carried out to provide the service. This data processing is justified by the fact that the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) lit. b) DSGVO for the use of the app. Data processing for advertising purposes is a main service in this respect. In addition, we have a legitimate interest in the data processing within the meaning of Art. 6 para. 1 lit. f DSGVO. Since you are free to use our app and we also provide detailed information about data processing, our legitimate interest outweighs your rights and freedoms.
PaymentWe offer various payment methods, some via payment service providers such as PayPal, to process the payment of credits that you receive through participation in surveys in or via our app. Processed data in this context are usage data, connection data, master data, payment data, contact data or also contract data. The legal basis for the use of the payment service providers results from Art. 6 para. 1 lit. b DSGVO, as well as from our legitimate interests according to Art. 6 para. 1 lit. f) DSGVO to enable a user-friendly and uncomplicated payment processing. However, please note: Personal data may also be passed on by the online payment service provider to service providers, subcontractors or other affiliated companies, insofar as this is necessary for the fulfilment of the contractual obligations arising from your order or the personal data is to be processed on your behalf. We have signed an order processing agreement with each of the payment service providers to ensure that the security of the processing of your data is guaranteed at all times.
The recipient is the respective service provider, such as: PayPal (Europe) S.à.r.l. & Cie. S.C.A. A transfer of data to a third country may take place. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Furthermore, the data will be deleted if you revoke your consent or request the deletion of the personal data.
The payment service providers are in detail:
It is possible to process the payment process with the online payment service PayPal. PayPal enables online payments to be made to third parties. The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg. If you choose PayPal as your payment method, your data required for the payment process will be automatically transmitted to PayPal. This regularly involves the following data:
If you make a payment with PayPal, please check that you are responsible for paying taxes according to the laws in your country/region.
You can also exchange the credits you receive for taking surveys in or through our app for vouchers from our partners, such as StarBucks, Amazon, Zalando, iTunes, Spotify, etc. If you decide to do this, we will not pass on any of your personal data to our partners. We have interfaces to the Amazon API and Wunschgutschein API.
Our app is for marketing purposes and is ad-supported. As we use Google AdMob and YouTube to display personalised ads and partner videos within the app, you consent to the transfer of your personal data such as the advertising ID of your device, the IP address, your location data, your interactions with advertisers’ ads via cookies or cookie-like technologies (so-called mobile identifiers, e.g. Google AdMob and YouTube). mobile identifier, e.g. Web Beacon, IDFA, GAID) to Google Ireland Limited, Ireland, as the provider of Google AdMob and YouTube, as well as to the Google partner companies named below (hereinafter referred to as advertising partners) for the purpose of generating and displaying personalised advertising.
In the case of Google AdMob, conversion statistics are created for AdWords customers (advertising partners) who have opted for conversion tracking via cookie-like technologies (so-called mobile identifiers). Mobile identifiers are stored on your end device and enable the storage of information with which your surfing behaviour can be tracked. The advertising partners thus learn the total number of users who clicked on their ad and were redirected to a page marked with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.
When clicking on a partner video, we use the YouTube service. We use the extended data protection mode, which, according to the provider, only starts storing user information when the video(s) is/are played. If the playback of embedded YouTube videos is started, Google uses “YouTube” cookies or mobile identifiers to collect information about user behaviour. According to information from “Youtube”, these are used, among other things, to collect video statistics, to improve user-friendliness and to prevent abusive behaviour. If you are logged in to Google, your data is directly assigned to your account when you click on a video.
We have no influence on the data processing by Google after clicking on a partner video / an advertisement. The data processing is then the sole responsibility of Google Ireland Limited.
Details of what data Google collects and how it is processed can be found here:
YouTube and other Google services: https://policies.google.com/privacy
The Application furthermore uses AWIN. Awin is a specialized affiliate marketing platform. It connects advertisers with a network of publishers. Awins positions itself as a trusted third party between advertisers and publishers providing account management, strategy and technology. In the process of doing so it is gathering data and thus needs the consent to cookies.
Details about what data is collected by Awin and how it is processed can be found here:
In this respect, we would like to point out once again in all clarity that the purpose of our service / our app is the evaluation of your surfing behavior by processing your data in order to use this data for the purpose of online marketing in so-called advertising networks. “Online marketing” includes, in particular, the referral of the user of the app to advertising partners of us and the interaction with advertising materials and surveys provided by advertising partners in the app and through links. Your data will not only be evaluated and used by us, but also by third parties such as Google Ireland Limited, Lucid Holdings LLC. and our advertising partners.
If you want to disable personalized advertising on your mobile device, you can disable interest-based advertising when using Android smartphones (Google Setting => Setting => Google => Display => Disable interest-based advertising).
In this case, however, certain features of our app will no longer be usable. The same applies to deactivating the operation of Lucid.
If you do not wish to be associated with your YouTube profile, you must log out before clicking on the video. You also have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.
You can revoke your consent at any time with effect for the future by sending a short email to firstname.lastname@example.org. In this case, however, participation in campaigns (surveys, videos, news, etc.) and the receipt of rewards are no longer possible.
We would like to point out that rewards are only due once a certain number of “Smatches” points has been reached. If the user revokes his/her consent to data processing before reaching this number of points, the premium can no longer be distributed.
The legal basis for the forwarding and transfer of data is – in addition to the legal bases mentioned below – your consent, Art. 6 para. 1 lit. a) DSGVO.
In addition to the cases explicitly mentioned in this data protection declaration, your personal data will only be passed on without your express prior consent if this is permitted or required by law. A technical transfer may also take place if and to the extent that this is necessary for the operation of our app or for other reasons for the establishment, implementation or processing of your user relationship with us. This may be the case, for example, if we host the app with an external service provider. If this is not a case of commissioned processing, the transfer is based on Art. 6 para. 1 lit. b) DSGVO.
2.2.1 As a matter of principle, we do not pass on to third parties the personal data that you provide when registering.
2.2.2 The data that we receive from you when you redeem / order a premium (first name, surname, address) will only be passed on to the company delivering the premium for the purpose of sending the premium. This transfer of your data is justified by the fact that (1) the transfer of the data is necessary for the fulfilment of the contract between you as the data subject and us in accordance with Art. 6 Para. 1 lit. b) DSGVO for the use of the app, as we would otherwise not be able to send you the rewards. (2) We also have a legitimate interest within the meaning of Art. 6 (1) (f) DSGVO in sending you the rewards by way of a so-called drop shipment (i.e. directly from the manufacturer of the rewards, e.g. from the brewery). In this respect, your rights and freedoms do not outweigh our legitimate interests in the delivery of the rewards.
2.2.3 Irrespective of your consent referred to in section 2.2, we also disclose your personal data, such as your advertising ID, to our advertising partners and the aforementioned third parties on the basis of a legitimate interest within the meaning of Article 6(1)(f) and on the basis of the user agreement concluded with us pursuant to Article 6(1)(b) of the Data Protection Regulation. Since we offer our app free of charge, we have a legitimate interest in using marketing tools such as Google AdMob. This interest also outweighs the interests of the user, as it is up to each user whether they want to use our app and participate in promotions, surveys, games, etc.
2.2.5 We rely on the following third party companies and external service providers to provide our service:
Transport and logistics companies, such as DHL, etc.
technical support: Antony Konstantinidis,
Google Ireland Limited, Ireland. (Google AdMob / YouTube)
Any disclosure of personal data is justified by the fact that (1) this is either necessary for the implementation of the user relationship, Art. 6 para. 1 lit. b) or (2) we have a legitimate interest in the data processing, Art. 6 para. 1 lit. f) or we have carefully selected our third-party companies and external service providers as processors within the framework of Art. 28 para. 1 DSGVO, regularly checked them and contractually obliged them to process all personal data exclusively in accordance with our instructions.
Any disclosure of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances as required and that your rights and interests in the protection of your personal data within the meaning of Article 6 (1) (f) of the Data Protection Regulation are not overridden.
VPNAPIOur app uses VPNAPI to prevent users who attempt to access the app using VPNs from disguising their IP address and mistakenly receiving surveys from another country.
Smatched uses Sentry to send error messages from the backend and thus quickly identify and fix bugs, etc.
Twillio is a cloud communication platform that can be used to serve channels such as SMS, telephony, video, WhatsApp and more. Smatched uses Twillio’s two-factor authentication via SMS, which asks for the user’s mobile number for authentication purposes and to prevent the use of multiple accounts.
Our App uses AppsFlyer, an attribution service provided by AppsFlyer Ltd, 14 Maskit St., POB 12371 Herzliya, Israel (“AppsFlyer”). We have entered into a commissioned processing agreement with AppsFlyer for the use of AppsFlyer (Article 28(3) of the GDPR)
AppsFlyer processes personal data on our behalf in order to create aggregated user profiles about the interaction with our advertising materials. The information obtained in this way enables us to measure the success of our app marketing campaigns and optimise our app. In addition, AppsFlyer enables us to ensure the security and defence against fraud by advertising networks.
The following data is transmitted to Appsflyer: Your device’s IP address and associated location data, the campaign source and associated targeting, and various smatched events after the app is installed.
However, by activating the IP anonymisation “IP Masking”, your IP address is shortened beforehand by AppsFlyer.
The recipient of the data in this context is AppsFlyer Ltd, 14 Maskit St, POB 12371 Herzliya, Israel. The European Commission has determined by decision that an adequate level of protection for personal data is ensured in Israel (Art. 45 GDPR).
Further information on data protection at Appsflyer can be found at the following link https://www.appsflyer.com/privacy-policy/.
You have the option to revoke your consent to data processing at any time. A revocation has no influence on the effectiveness of the previous data processing. If you do not want AppsFlyer to collect and process data, you can download an opt-out cookie via the following link: https://www.appsflyer.com/optout.
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Furthermore, the data will be deleted if you withdraw your consent or request the deletion of personal data.
If you delete your cookies, you will also have to download the opt-out cookie again.
In addition, you will be redirected to third parties who are responsible for data processing when you click on or download third-party content. This content is marked as third-party content. It may be external links in messages, apps from third parties, tasks from third parties, etc..
You are leaving our app.
We use so-called cookie technology in our app. Cookies are small text files that are sent from our server to your smartphone when you use the app and are stored there for later retrieval. We use both so-called session cookies (also referred to as temporary cookies) and cookies that are stored for a longer period of time (also referred to as persistent cookies).
You delete the cookies by deleting the smatched app from your smartphone.
As explained in section 2, Google also uses cookie-like technologies. If you do not want to allow tracking, you must either revoke your consent or delete our app.
Processing of your personal data for purposes other than those described will only take place if permitted by law or if you have consented to the changed purpose of the data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you about these other purposes prior to further processing and provide you with all other relevant information.
We will delete or anonymise your personal data as soon as it is no longer necessary for the purposes for which we collected or used it in accordance with the above paragraphs. As a rule, we store your personal data for the duration of the usage or contractual relationship via the app plus a period of 7 days, during which we keep backup copies after deletion, unless this data is required for longer for criminal prosecution or to secure, assert or enforce legal claims.
You have the right to ask us to correct personal data relating to you without delay if it is inaccurate. To do so, please contact us at the addresses below.
You have the right to ask us to correct your personal data immediately if it is inaccurate. To do so, please contact us at the addresses below.
You have the right to demand that we restrict processing in accordance with Art. 18 DSGVO. This right exists in particular if the accuracy of the personal data is disputed between the user and us, for the duration that the verification of the accuracy requires, as well as in the event that the user requests restricted processing instead of erasure in the case of an existing right to erasure; furthermore, in the event that the data is no longer necessary for the purposes pursued by us, but the user requires it for the assertion, exercise or defence of legal claims, as well as if the successful exercise of an objection is still disputed between us and the user. To exercise your right to restrict processing, please contact us at the contact addresses below.
You have the right to receive from us the personal data relating to you that you have provided to us in a structured, commonly used, machine-readable format in accordance with Article 20 of the GDPR. To exercise your right to data portability, please contact us at the addresses below.
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out, inter alia, on the basis of Article 6(1)(e) or (f) DSGVO, in accordance with Article 21 DSGVO. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the purpose of asserting, exercising or defending legal claims. In the event of objection, you will no longer be able to use the app.
If you have given us consent to data processing, you can revoke this at any time with effect for the future via the menu item “Profile” => “Settings” => “Revoke consent” or our contact details given in the imprint. The use of the app is no longer possible after the revocation.
You also have the right to complain to the relevant supervisory authority. You can find a list of supervisory authorities here:
If you have any questions or comments about our handling of your personal data, or if you wish to exercise your rights as a data subject, please contact Rissland Marketing UG (hb), Mr Alexander Rissland at the following contact details: Kurfürsten-Anlage 52 in 69115 Heidelberg, Email: email@example.com
In order to protect your data from manipulation, loss and unauthorised access by third parties, for example, we use technical and organisational measures to ensure an appropriate level of protection for your personal data. These measures include the use of firewalls and antivirus programs as well as manual security precautions. We continuously review and improve our security measures in line with the current state of the art. In addition, in accordance with the principle of “data protection by default”, the strictest privacy settings are preset when you first register.
Status: 28th of July 2022
Smatched – Unleash your data’s value