This Privacy Policy applies to the "OWAPro" technology created, used, and offered by Hurra Communications GmbH (“hurra.com”) and its affiliates. Our technology (including tracking, tag management, web analytics, and web controlling) is used as hurra.com's services on behalf of our clients or by our clients themselves.
When our technology is used for our own website and our own marketing campaigns, hurra.com is a controller in accordance with GDPR.
Hurra Communications GmbH
Lautenschlagerstraße 23a
70173 Stuttgart
Germany
CEO: René Schweier
When our technology is used by and on behalf of our clients, these clients are controllers. In this case, hurra.com is a processor in accordance with Article 28 GDPR.
The following personal data categories are processed using OWAPro technology:
* Processed data depends on the settings, commissioned agency services, or OWAPro services in use.
By default, IP addresses are automatically anonymized by OWAPro and processed only anonymously . Therefore, we erase the last octet (3 digits) of an IP address before we send it to our storage. As a result, a personal reference is no longer accessible. However, hurra.com clients can change this setting themselves in the OWAPro settings or ask hurra.com to do it on their behalf.
Email addresses are exclusively processed in an anonymized form in OWAPro, with the use of a hashing algorithm.
With cross-device tracking, our clients generate or send users pseudonyms to us. The pseudonym is usually generated on the base of a login (e.g., username or email address) by a cryptographic hash algorithm on the client's web server and by the client themselves. By definition, the generated pseudonyms cannot be decrypted so the process is irreversible.
OWAPro collects only pseudonymized personal data, which hurra.com cannot use to identify any person.
hurra.com collects data in the following ways:
Our technology is used by and/or on behalf of our clients for the following purposes:
Our purpose is to prepare a cost-benefit analysis of our clients' online marketing campaigns through analyzing user traffic to and on our clients' websites. The kind of data we collect and process depends on the particular implementation of the conversion tracking – which is adjusted to the needs of our clients and their online marketing goals.
This section refers to the following situations described in the next section: 1, 2, 3, 4, 5, and 8.
We collect and process data concerned with user (i.e., your) behavior on our client's website, and we send only your profile ID to our advertising partners. Thanks to information on your experience on our client's website, advertising partners can show you ads which are better suited to your preferences. This section refers to the following situations described in the next section: 6, 7, and 8.
We collect data on user (i.e., your) behavior on our client's website, and send it directly to third-party advertising partners through their marketing tags. Third-party advertising partners use this data to create your user profile (containing basic information valuable for online marketing), which helps our clients to optimize their online marketing strategies.
This section refers to the last situation (9th) described in the next section.
The Data Processing Agreement, which we enter with our client, is always our legal basis for data processing. The application of the justified legal basis for processing any data is the controller's (our client's) responsibility. Data processing performed by hurra.com and its affiliates is limited by the law. The possible legal bases include: the controller's legitimate interest, or user (i.e., your) consent, either explicit or implicit. Our recommendations to which situations those legal bases should be applied are listed below.
Our client's legitimate interest, if not outweighed by your interests or fundamental rights and freedoms, applies to:
Your consent applies to:
For the EU users, data collection, processing, and storage takes place exclusively in our data centers in Frankfurt (Germany) and/or Kraków (Poland).
For the users from outside the EU, data collection and processing as well as temporary storage are possible if the data has been transmitted to one of our data centers in the EU. There is no permanent data storage outside the EU.
Hurra Communications GmbH, based in Germany, processes data on behalf of their clients as a digital marketing agency in accordance with the Data Processing Agreement. For that purpose, GmbH cooperates closely with its sub-processor Hurra Communications Sp. z o.o., based in Poland, which is a marketing technology software house. The legal basis for processing personal data by Sp. z o.o. is the Data Processing Agreement between Hurra Communications GmbH and Hurra Communications Sp. z o.o.
If our clients use our OWAPro Tag Manager, data can be passed on to third parties such as Google, Criteo, or Facebook. It is possible that data will also be transmitted to the USA. You can find out which third-party services are used for a specific client in our client's privacy policy.
If your data is shared with a third-party advertising partner, it is done for the purpose of ad performance optimization as well as for creation of user (i.e., your) profile, which aim is to show you ads that are better suited to your preferences on that third-party advertising partner's websites.
If your profile is created by a third-party advertising partner, it is created based on either data collected by us during your visits to our client's website, or a combined set of data on your visits to our client's website and data collected about you by third-party advertising partners.
Your profile, along with campaign targeting settings, determine which ads will be displayed to you on websites which belong to third-party advertising partners, or to their ad network.
Personal data is deleted or anonymized after 18 months. Anonymized data is stored over the duration of the contract concluded between us (hurra.com) and our clients, and after the contract has expired.
As hurra.com, we use "cookies" and similar technologies to assess the effectiveness of various advertising strategies of our advertising partners. These technologies allow us to measure the advertising reach and effectiveness of online advertising campaigns and websites.
In some cases, we use cookies to create profiles of visitors to our clients' websites. These profiles are created solely based on data collected from these particular websites. Identifiers of such profiles (without any details about these profiles) are passed on to our advertising partners who then use these identifiers to show users well-matched marketing messages and ads.
We also use cookies to save your set of preferences in Consent Management Tool – a feature which is a part of our tag management solution.
Cookies are used to enable the recognition of an internet browser during a re-visit. These cookies may store unique online identifiers ("cookie ID") and other non-personal information on your device.
Cookies are stored by the web browser on your computer in the form of small text files and are limited to a size of 4 KB per domain. Cookies are plain text files that cannot be used to store or run malicious or executable programs.
We store information about the server that has set the cookie, a name of the cookie and its lifetime, and, depending on the purpose of the cookie, various other non-personal data.
By default, cookies can be read by the web servers that have prompted the web browser to save a cookie. At hurra.com, these are web servers of the hurra.com domain. With the use of a JavaScript code, it is possible to save and read cookies belonging to the domain of a first-party advertising service – the domain that you are visiting.
Cookies lifetime depends on each cookie's purpose. Exact information about the different types of cookies, their purpose, lifespan, and data they store can be found below.
Third-party advertising partners, such as Google AdWords or DoubleClick, may also store cookies in your browser for remarketing and display advertising purposes. These cookies belong to third-party domains (i.e., a third-party advertising partner's tracking code can be embedded on a website you are visiting, thus making your browser save cookies from these third-party domains). These third-party cookies are accessible to advertising partners on different websites, hence they can be used to create a user (i.e., your) profile based on information collected about you from domains belonging to different advertisers and advertising partners. The goal is to learn more about your product preferences to show you better suited ads. Likewise, other third-party tracking technologies can be integrated with OWAPro Tag Manager on our client's request or implemented by our client themselves, and these technologies can also set cookies.
In accordance with Art. 21 Para. 2 GDPR, you have the right to object to the processing of personal data for direct marketing.
That is why, we provide our clients with a client-specific opt-out mechanism which allows users (i.e., you) to object to future data processing on our client's website through hurra.com. The opt-out mechanism is client-specific and thus only applies to the website of a specific client.
You can opt-out of data collection and processing by hurra.com services on our client's website at any time. OWAPro may also already be configured to comply with the "Do Not Track" setting of your browser, which means that you have already objected to data collection and processing.
The opt-out mechanism is based on a cookie named "__coo". Please note, that we can apply our opt-out mechanism as long as this cookie is present. If you delete that cookie yourself, we have no possibility to stop our technology from tracking you. The opt-out mechanism is bound to the device and the browser used for deactivation; i.e., the ones that were used while setting the opt-out option. To stop our technology from processing of personal data shared on other browsers and devices, the opt-out option must be set on those browsers and devices as well.
Yes, if DNT has been activated by our clients through OWAPro. Do-Not-Track (DNT) is a setting that becomes active in your browser. For some browsers this option is enabled by default. If this setting is activated through OWAPro by our client, we comply with DNT and treat is as an Opt-Out option, which means that you are no longer tracked by the hurra.com technology.
Please contact the owners of the website that directed you to this privacy policy. You may need to provide some additional or personal information to process your request or ensure identification.
Technical progress, changes in the law or in our internal processes require adjustments to this privacy policy. We reserve the right to make changes to this privacy policy. Notifications depend on the data controller (our clients) so please follow information provided by them.
Date of this Privacy Policy: 02.05.2018
Updated: 25.05.2018
Updated: 20.10.2021