Streetspotr GmbH (hereinafter referred to as “Streetspotr” or “we” (and affiliated pronouns, such as “us” and “our”) is the operator of the websites streetspotr.com, app.streetspotr.com, all sub-sites or national sites as well as the affiliated mobile applications (“apps). As such, Streetspotr GmbH is theData Controller(responsible party) of the personal data of users (hereinafter referred to as “you” (and affiliated pronouns, such as “your”), “members” or “Data Subject(s)”) of the websites and apps as defined in the General Data Protection Regulation (GDPR).

As the Data Controller, we protect your privacy and your personal data. We collect, process and use your personal data in compliance with the content of this Data Protection Policy and the applicable data protection regulations, in particular the GDPR. These data protection regulations govern our collection, processing and use of personal data affiliated with you. Hence, we ask you to carefully read the following stipulations.

If you consent to our Data Protection Declaration, you permit Streetspotr GmbH to collect, process and use your personal data for the defined purposes.

Our contact information can be found on our website under “Information Required By Law” or in Section 9 of this Declaration.

Please find the name and contact information of our Data Protection Officer below:

DataCo GmbH

Dachauer Str. 65
80335 München
Germany

Tel.: +49 089-41207033
E-mail: info@dataguard.de

1. Hosting and Handling of Data During Website Visits

1.1. The streetspotr.com and app.streetspotr.com websites as well as all national sites and sub-sites are operated on servers on the AWS Cloud. Operated by Amazon Web Services, Inc., P.O. Box 81226, Seattle, WA 98108-1226, USA, the AWS Cloud is part of Amazon’s Web Services.” Amazon Web Services, Inc. has joined the “EU-US Privacy Shield Program,” which enables the compliant transfer of personal data from Data Controllers in the EU to Data Controllers (or processors) in the United States. The legal basis for hosting services is Art. 6 Section 1lit. f GDPR. We have executed a contract data processing agreement pursuant to Art. 28 GDPR with our hosting service provider.

1.2. You have the option to visit our website without providing personal information. This excludes the (access) data your Internet browser communicates to us, e.g.

• The name of your Internet service provider
• The data and time you accessed our website
• Your browser type
• Browser settings
• Utilized operating system
• The last page you visited
• Your IP address.

Additional personal data will be collected only if you voluntarily share such data with us, for instance when you register, submit a project inquiry or subscribe to our newsletter.

1.3. Description and Legal Basis

Data are also stored in our system’s log files. These data are never stored with any other personal data of the user.

The legal basis for the temporary storage of these data and the log files is Art. 6 Section 1 lit. f GDPR.

1.4. Data Processing Purpose

The temporary storage of the IP address by the system is necessary to make it possible to display the website to the user’s computer.

Log files are stored to ensure that the website works properly. The data also help us optimize the website and to safeguard the security of our information technology systems. Data analyses for marketing purposes are not conducted in conjunction with the aforementioned. Our legitimate interestsin processing the data pursuant to Art. 6 Sect. 1 lit. f GDPR are inherent in these purposes.

1.5. Storage Time

The data are eradicatedas soon as they are no longer required to attain the collection purpose. If data are recorded to provide access to the website, this purpose is attained as soon as the respective session ends. If the data are stored in log files, the purpose shall be attained no later than seven days after they have been collected. It is possible that they will be stored for a period that exceeds this time. In such cases, the users’ IP addresses will be deleted or modified in such a manner that it is no longer possible to identify the accessing client.

1.6. Objection and Elimination Option

For the provision of access to the website, it is absolutely necessary to record the data. Moreover, for the operation of the website, it is mandatory to store the data in log files. Consequently, the user does not have any options to objective to these activities.

2. Cookies and Tracking

2.1. How Cookies Work

The website uses cookies to make the use of the website as convenient as possible for you.

Cookies are small text files that are stored on your computer while you visit our website. Some of them are deleted as soon as you leave our website (session cookies). Others remain on your computer so that your computer will be recognized when you visit the site in the future (these are called permanent cookies).

2.2. Google Analytics

This website and the Streetspotr apps use Google Analytics, which is a service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA = “Google”). This is a web analysis service that tracks the generation, collection and analysis of data with regard to the user patterns of website visitors. Among the patterns tracked by the service are data that make it possible to determine the website from which a user navigates to another website, which sub-pages the user accessed, how frequently the user has accessed which sub-pages and how much time a user spent reviewing any sub-page. Principally, the use of this service also makes it possible to allocate user patterns across multiple devices to a user ID pseudonym and, as a result, to analyze the activities of a user across several devices (cross-device tracking)/ We have not activated the user ID, so that it is not possible to implement cross-device tracking in conjunction with our use of Google Analytics.

Within the scope of our use of this service, we use the tag “_gat.anonymizeIp,” which results in the abbreviation of your IP address by Google within member states of the European Union or other countries who have ratified the Agreement on the European Economic Area. The complete IP address is transferred to a Google server in the United States and abbreviated there only in exceptional cases.

The purpose of this service is to analyze the visitor streams on our website. Google uses the gathered data and information e.g. to provide to us the results in conjunction with a report that tracks the activities on our website, so that we can make available additional services related to the use of our website. This also establishes legitimate grounds for our interest in processing the data.

The legal basis for the use of Google Analytics is Art. 6 Sect. 1 lit. f GDPR.

After 14 months, the data we have sent are automatically eradicated. The eradication of data that have reached their retention expiration dates is automatically performed once a month.

Google Analytics uses “cookies.” The information concerning your use of the website (including your IP address) generated by the cookie is transferred to one of Google’s servers in the United States, where it is stored. Please see the explanations provided above concerning the use of “cookies.” If you would like to reject cookies, you have the option to adjust your browser settings. Moreover, you can prevent the recording of data generated by the cookie and of data related to the use of the website (incl. your IP address) and the transmission of the former to Google as well as the processing of these data by Google by downloading and installing a program fromhttps://tools.google.com/dlpage/gaoptout?hl=de%22%20target=%22_blank

As an alternative, or, in particular if you are using mobile end devices, you may file an objection by using the following link: Opt Out Google Analytics.

More detailed information about Google’s current Data Privacy Policies may be accessed under

https://www.google.com/analytics/terms/de.html and https://policies.google.com/?hl=de.

2.3. Google Adwords

For web analysis purposes, this website uses conversion tracking, which is part of the advertising program “Google AdWords.” This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google AdWords is a tool that enables us to promote our product portfolio on third party websites. Through conversion tracking, we can determine how frequently users access these promotions. The purpose of this is to generate interest in our website among users.

Google AdWords conversion tracking uses Cookies, which are usually valid for 30 days and do not identify individual users. As far as the functions of cookies are concerned, reference is hereby made to our earlier explanations. The archived cookie allows us as well as Google to determine that the user has clicked on an AdWords promotion and was redirected to our website. It is not possible to trace the used cookies via the websites of AdWords customers.

The generated results make it possible to compiled statistics, based on which Google AdWords conversion tracking customers can determine how many users have clicked on their ads and were subsequently redirected to their websites. Technical precautions convert the generated user data into pseudonyms. Consequently, it is no longer possible to allocate the data to the accessing user.

The legal basis for the use of Google AdWords conversion tracking is Art. 6 Section 1lit. f GDPR.

The purpose of the use of Google AdWords conversion tracking is the placement of targeted advertising and, as a result, to improve the quality of our website and its content, as well as the constant optimization of our website presentation of products and services.

If you would like to reject Google AdWords conversion tracking, you have the option to change your browser settings accordingly.

To permanently deactivatethe cookie for Google AdWords conversion tracking, download and install a program for your Internet browser under https://tools.google.com/dlpage/gaoptout?hl=de%22%20target=_blank. More detailed information about Google’s current Data Privacy Policies may be accessed under http://www.google.de/policies/privacy/.

2.4. HockeyApp

We use the software analysis tool HockeyApp to improve, eliminate errors and analyze weaknesses of our apps. HockeyApp is beta test platform operated by the Microsoft Corporation, which makes it possible to analyze app error functions. The Data Privacy Policy of HockeyApp is available for review at https://hockeyapp.net/privacy/. If our app should crash, you have the option to send a crash report to HockeyApp. The report will include the date and time of the crash, the affected software module, the used operating system and language as well as the device type and IP address. Crash reports are not sent to HockeyApp until you have given your specific consent.Some of the information included in the crash report may be processed in the United States. If you consent to the transmission, you automatically also consent to the transfer of the aforementioned data to the United States.

2.5. UserVoice

Our apps use the UserVoice software, which is provided and operated by UserVoice Inc. (121 2nd St, Fl 4, San Francisco, CA 94105, USA). It collects user feedback. By sending feedback to us via UserVoice (for instance by making entries into the contact form), you consent to the storage of data (such as your IP address, name and other data you voluntarily provide) on our behalf on UserVoice Inc. servers. UserVoice is a member of the EU-US Privacy Shield, i.e. a special data privacy compact between the European Union and the United States. More details and information about UserVoice’s specific data privacy policies can be found at https://www.uservoice.com/privacy.

2.6. Facebook Pixel

For web analysis purposes, this website uses the “Facebook Pixel” program, which is part of the social network “Facebook.” This service is provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). This program makes it possible to track whether you have clicked on an ad on “Facebook” while you are on the social network. The results of these analyses are used to generate statistics, which enable us to determine how many users have clicked on an ad and have been redirected to our websites. The user data we receive as a result of these analyses are anonymous. We have not activated the function called “enhanced comparison function.” However, Facebook will store the data, which means that Facebook will be able to link the data to your Facebook user profile. There is also a possibility that Facebook may use the data for its own advertising purposes. The legal basis for the user of “Facebook Pixel” is Art. 6 Section 1 lit. f GDPR.

We use “Facebook Pixel” for the purpose of posting targeted advertising and, as a result, boost the quality of our website as well as its content and to constantly optimize our products and services.

More information regarding Facebook’s data privacy policies can be reviewed at https://www.facebook.com/about/privacy/.

2.7. MailChimp

We distribute our customer newsletter via “MailChimp,” a newsletter mailing platform provided by the Rocket Science Group, LLC (675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA).

The e-mail addresses of our newsletter subscribers, as well as additional data described herein, are stored on MailChimp’s servers in the United States. MailChip uses this information to send and analyze the newsletters on our behalf. Based on information provided by MailChimp, the company may also use these data to optimize or improve its own services, e.g. to technically optimize its distribution and the display of the newsletters. It may also use the information for business purposes to determine the location of subscribers (countries). However, MailChimp does not use our newsletter subscriber data to contact them directly or share the data with third parties.

MailChimp’s data privacy policy may be reviewed here: https://mailchimp.com/legal/privacy

Our newsletters contain a so-called “web-beacon,” i.e. a pixel-sized file, which is accessed by MailChimp’s server when the newsletter is opened. In conjunction with this access, initially, technical details, such as browser and system data, as well as your IP address and the time of access are collected. This information is used to make technical improvements to the services based on technical data or target groups as well as their reading patterns and their access locations (which can be determined with the assistance of the IP address) or the access times.

The statistical information gathered also includes whether the newsletter was actually opened and when this happened. The clicked links are tracked as well. While it is possible to allocate this information to individual newsletter subscribers for technical reasons, it is neither our, nor MailChimp’s objective to monitor individual users. Instead, the purpose of these analyses is to get to know our user’s reading habits and to adapt our content to their interests or to send out different content that matches our users’ interests.

2.8. LinkedIn Conversion Tracking

We use the re-targeting tool LinkedIn conversion tracking of LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”). For this purpose, we have integrated the LinkedIn Insight Tag on our websites. It enables LinkedIn to generate statistics using pseudonymous data about your website visit and the use of our site. Based on the aforementioned, the company is able to provide us with pertinent aggregated statistics. The information is also used to make it possible for us to tailor our offers and recommendations to your interests. The related information is stored in a cookie. You can prevent the storage of cookies by setting up your browser accordingly. More information can be found in LinkedIn’s data privacy policy at https://www.linkedin.com/legal/privacy-policy.

2.9. YouTube Videos

This website uses the “YouTube” video platform embedding tool that allows users to see and play videos posted on this specific platform. Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) is the operator of “YouTube.” Whenever you start a video, “YouTube” deploys a cookie to collect user behavior information with the aim of improving the user friendliness of the platform and to also prevent any misuse. If you do not want the social media plug-in to allocate data to your “YouTube” account, you must log out of your respective account while you are visiting our website. However, Google will store and analyze your data even if you are not logged into your “YouTube” account. The legal basis for the analysis is Art. 6 Section 1 lit. f GDPR. The purpose of the analysis is market research and the needs-adequate design of the website, as well as, if applicable, the display of customized advertising. You have the option to object to the creation of a user profile by Google. If you access a page that contains this plug-in, your web browser will establish a connection with Google’s “DoubleClick” network. Consequently, the operator of the website that contains such a plug-in cannot influence the type and scope of the data Google collects based on this plug-in. To review the type and scope of data collection, visit: https://www.google.de/intl/de/policies/privacy.

3. Collection and Use of Personal Information

The following data are transferred and stored on the Streetspotr server when you visit our websites or use our apps:

3.1. In our apps

3.1.1. Automatically collected data

When you download the app, certain essential information is transferred by the app store you have chosen to acquire the app (e.g. Google Play or Apple App Store). In particular your user name, e-mail address, the customer number linked to your account, the time of the download, payment information and the individual identification number of the device, may be processed. These data are exclusively processed by the respective app store and the process is not under our control.

In conjunction with your use of our app, we automatically collect certain data, which are required for the use of the app. This includes the internal device ID, your operating system version and the time of access.

These data are automatically transferred to us, but not stored, to (1) make available to you the service and its affiliated functions; (2) improve the functions and service features of the app and (3) prevent and eradicate misuse and error functions. There are legitimate reasons for these types of data processing: (1) such processing is necessary for the fulfillment of the contract between you, the Data Subject and us, the Data Controller, pursuant to Art. 6 Sect. 1 lit. b) GDPR so that the app can be used, or (2) Because we have a legitimate interest in guaranteeing the functions and error-free operation of the app and in the ability to offer a market and interest compliant service, which outweighs, in this case, your rights and interests to protect your personal data as defined in Art. 6 Sect. 1 lit. f) GDPR.

3.1.2. Data collected after the registration and while using the apps

• E-mail
• ZIP code
• Date of birth
• Gender
• Town you live in
• Education / vocational training
• Smartphone manufacturer/model
• GPS location (only if your home location is defined and if you accept and administrate a micro job)
• VAT ID (if available)
• Address (for the disbursement of remuneration)
• PayPal address (for the disbursement of remuneration)
• If assignments that require different qualifications, alternating additional data, such as household income

3.1.3. Registration via Facebook Connect

To register, you will be redirected to the Facebook page to register with your user data.
Due to the linkage, we will automatically receive the following information from Facebook Inc.:

• Facebook ID
• First and last name
• E-mail
• Date of birth
• Gender

We will store and process your transferred data on our page for registration purposes.

3.1.4. When you upload a micro job:

• Smartphone manufacturer/model
• Upload time and location
• Image upload time and location
• Assignment-relevant information (text, image, video)

3.2. Use of functions of your smartphone

Depending on the selected mode, our app will access functions of your smartphone, such as your microphone and voice recognition (to enter information), your camera (for assignment-related photography), your GPS receiver (to obtain geo-coordinates to determine your distance from assignments).
Principally, your smartphone’s functions will only be accessed if you initiate it, for instance by activating the voice recognition tool to enter information, or if you enter your location to find out your distance from an assignment. You can deactivate the app’s access by changing your device settings for the different functions. However, if you do this, you will no longer be able to use the respective functions for the Streetspotr app.

3.3. Submission of an inquiry on our websites as the customer

If you would like to work with us as a business partner, we will collect the following personal information to contact you:

• Contact name
• Company name
• Phone number
• E-mail
• ZIP code
• Country
• Inquiry details

3.4. Profiles in the app

Moreover, we will set up profiles for our respective members, which contain data comprising the required member information submitted during the registration process (first name, last name, e-mail address, date of birth, education/professional training, gender) as well as the voluntary information shared during registration (hometown, profile picture) as well as the data available from our in-house evaluation system. These data are used to make the matching micro jobs available to the respective members. If a member is a registered business, this member’s VAT ID will also be stored.

3.5. Data use

We will use the data you provide to us only for the purposes they have been provided or will use and share them only if you have consented to their use or sharing. We collect and transfer personal data with government institutions and agencies only within the scope of mandatory national legislation. We have committed all of our employees to non-disclosure agreements and to banking secrecy and data privacy. Data will only be used for the administration of contractual relationships, in particular the processing and disbursement of compensation for micro jobs (e.g. the issuance of credit notes, interactions with members, etc.). When we handle personal data, we comply with all statutory provisions, in particular the GDPR. The collection, processing and use of data occurs in consistent compliance with all data protection law principles.

3.6. Special use of information in conjunction with the activation of Instant Spot Alerts

Notifications we call “Instant Spot Alerts” aim to provide information on micro jobs in the immediate proximity of the member’s current location although the app is not open at the time. To be able to do this, the smartphone’s operating system verifies the location. The following data are transferred to our servers when the Instant Spot Alerts feature is in use:

• Current location so that micro jobs in the immediate vicinity can be loaded
• Micro job ID when a micro job is opened

Streetspotr never compiles movement profiles of its members. It is possible to individually activate or deactivate Instant Spot Alerts at all times. The Instant Spot Alerts opt-in or opt-out occurs the first time the app is used.

3.7. Newsletter distribution

During the registration process on our websites or in our apps, we offer what we call a double-opt-in process for subscriptions to our newsletter. We will only send you our newsletter if we are permitted to do so by applicable laws or if you sign up for a subscription. You have the option to revoke your consent to the newsletter subscription at any time, which will apply to all future mailings. If law permits the distribution, you can object to the receipt of the newsletter. You can do so in particular, by activating the respective link in every e-mail we send to you.

3.8. Personal data storage time

We store your personal data only for the reasonably necessary period of time to meet the requirements we have collected this information for and to comply with any applicable laws.

4. Payout via PayPal

Compensation will be disbursed through PayPal’s mass payment API. To do this, we automatically send your PayPal e-mail address and the payment amount to PayPal to enable the transfer of this amount.

5. How Secure is My Information

To protect the security of your data during transfer, we used Secure Sockets Layer Software (SSL). This software encrypts the information you send.

6. Disclosures

You have the right to at any time receive information on your personal data as defined in Art. 15 GDPR. To obtain such information, you can send us a request via postal services or via e-mail addressed to support@streetspotr.com. In addition, based on the stipulations in applicable laws, you are entitled to the rectification, blockageand eradication of such personal data. To request such actions, please reach out to the contact address provided below.

7. Data Sharing with Third Parties

We principally do not share any personal data with third parties. We specifically do not sell any data we are entrusted with for advertising purposes. Any sharing of data occurs only if absolutely necessary, e.g. with our service providers that need such data for the processing of orders, purchases and payments (e.g. the contracted financial institution that handles payments). In these cases the scope of the transferred data is limited to the absolute minimum. In some isolated cases, we will need your personal data to ship merchandise and orders. However, if we do this, we will first obtain your express consent, which you may revoke at any time.

When processing a survey of our service providers, we may potentially share the following information:

• User ID
• Country
• Date of birth
• Gender
• ZIP code
• Skin color
• Language
• Annual household income
• Level of education
• Employment status
• Industry
• Title within the company and position
• Business travel
• Your company’s employees
• Children
• Civil status
• Homeownership
• Possession of cellphones (model, brand, carrier)
• Entertainment electronics ownership
• Pets in household
• Vehicle ownership (model, brand, year)
• Household products buying patterns

Neither first nor last names will be shared with the service provider; hence, the survey will be anonymous. The party that orders the survey will be the owner of the survey results.

8. Changes to the Data Protection Declaration

We will always keep this Data Protection up-to-date. Hence, we reserve the right to make changes to it from time to time and to update these changes when collecting, processing or using your data. The latest version of the Data Protection Declaration will always be accessible for review in the apps and on the websites.

9. Data Controller

The Data Controller as defined in the Bundesdatenschutzgesetz (German Federal Data Protection Act) is the Streetspotr GmbH, Emilienstraße 9, 90489 Nürnberg, Germany.

Last updated: October 2019