Privacy policy

Kjero.com and other websites operated by kjero (hereinafter “Kjero.com”) are offered and operated by Kjero GmbH (hereinafter “Kjero”).

The protection of your personal data is of particular concern to us. We have therefore always processed your data exclusively on the basis of the statutory provisions (GDPR). In these data protection regulations we inform you about the most important aspects of data processing within the framework of the websites operated by us. These data protection regulations apply to:

• the use of all Kjero online services (content, product reviews, promotions, cashbacks and other offers and services) on Kjero.com, any sub-pages of Kjero.com Community or third party sites that have included Kjero services from Kjero.com.
• using Kjero.com without a registered user account, registering a user account, registering, applying for and/or participating in Kjero Promotions, and using Kjero Services.

If you have any questions about data protection, you can contact us anytime at [email protected].

1. legal bases for data collection

Where the legal basis for the collection of data is not specifically mentioned, the following shall apply:

The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfil our services and carry out contractual measures as well as answer inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.

2. Your rights

You are basically entitled to the rights to information, correction, deletion, restriction, data transferability, revocation and opposition. To make use of your right to information, correction, deletion, restriction, data transferability, revocation or opposition, please contact us at [email protected]. Our employees are at your disposal for questions and information at any time!

You also have the right, pursuant to Art. 77 GDPR, to submit a complaint to the competent supervisory authority. In Austria, this is the data protection authority.

3. How long do we store data

Unless otherwise stated, data collected about you will be stored for the duration of your Kjero account. You can delete this data at any time by deleting your user account.

If the data are not deleted because they are required for other legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes or made anonymous. This applies, for example, to data that must be stored for tax reasons.

3. What data do we collect?

3.1. e-mail addresses:

When you register on Kjero.com you give us your e-mail address. This is done in a double opt-in process. After registration you will receive an email asking you to confirm your email address. If you do not confirm your email address within 7 days, all data you entered during registration will be deleted automatically.

Your email address will be used to enable you to sign up with your Kjero account, to inform you about new Kjero Membership promotions, and to send you emails as part of a promotion.

3.2. personal details and profile pictures

When you register on Kjero.com, you provide various information about yourself.

We use your name as part of your address when sending test packages. Your name will also be used in abbreviated form (Erika Musterfrau becomes Erika M.) as the display name for public content you create on Kjero.com.

We ask for your age and gender in order to check compliance with our participation regulations (minimum age), to personalize our appearance towards you and in anonymous form for the evaluation of action results.

3.3. postal address

With many Kjero promotions you have the possibility to get a test package. So of course we need to know where to send the package 😉 . We also use your postal address to invite you to Kjero promotions in certain countries/regions and to evaluate the results of promotions anonymously for specific regions.

3.4 The Kjero survey

In the course of applying for Kjero promotions we ask you to fill out the Kjero survey. It includes questions about household, shopping habits, interests and social media use.

As you may have noticed, Kjero.com has promotions for various product groups. Not everyone is interested in all product groups and not every product is suitable for every person. We use the data from the Kjero survey only to send you invitations to promotions that suit you. In addition, at the end of the promotion, we create anonymous evaluations of the results of the promotion based on this information (e.g. “People who are interested in sweets find the taste of the product too sweet”).

3.5. application and other surveys

To be selected to participate in Kjero actions you must complete the application survey. Before and during an action, there may also be other surveys where participation is voluntary.

In these surveys, your attitude and knowledge about the respective product as well as any other information relevant to the campaign will be queried. We use this information to select participants for promotions and for the anonymous evaluation of the results of a specific promotion.

3.6. bills and bank details

For some Kjero promotions you buy the test product yourself and get the purchase price refunded. In order to make this refund possible, you must provide us with the receipt of your purchase and your bank details. To process the refund, your bank account details will be handed over to a bank commissioned by us.

3.7. content created by you

On Kjero.com you have the possibility to create your own content in text and image form (e.g. comments, stories, pictures). Depending on the action format, they may be visible to the public and in this case will remain visible even after you have deleted your user account from your account settings.

We use these contents in the course of actions to answer questions and to run sweepstakes. We also reserve the right to use your content for other purposes and to pass it on to the respective promotional partner. Further information can be found in the Terms of Use and Conditions of Participation.

3.8. e-mails

As part of your Kjero.com membership, we will send email to you. To technically implement this process, we rely on the services of MailChimp (more information and point 5.2). Your e-mail address and any other data contained in the e-mails (content of the e-mail, e.g. the first name in the salutation) will be passed on to MailChimp. E-mails sent to you will be stored by MailChimp for 30 days to enable us to troubleshoot, quality control and user support.

If you send us email or respond to an email we send to you, that email will be rejected by servers hosted by Google Inc. (more information and item 5.3) will be received and stored.

3.9. Cookies

Cookies are small files that allow you to store specific information on your browser. On the one hand, they serve the user-friendliness of websites and thus the users (e.g. storage of login data). On the other hand, they serve to collect statistical data on website usage and to be able to analyse it in order to improve the service. You can influence the use of cookies. Most browsers have an option that restricts or completely prevents the storage of cookies. However, please note that for technical reasons, participation in Kjero promotions without cookies is not possible.

3.10. Your usage behavior on Kjero.com:

We store information about your use of Kjero.com to improve our services and monitor the quality of our services. The legal basis for their use is our legitimate interest in the analysis, optimization, and cost-effective operation of our platforms. For this purpose, we store access data (IP address in anonymous form, browser used) in the form of log files and use the web analysis tool Google Universal Analytics (more information under point 5.3). We store this data for 14 months.

3.11. Social media plugins and embeds

We use social plugins (Facebook Like Button, Twitter Tweet Button) and social embeds (embedded Instagram images, Youtube videos) on our platforms. We use these to enable our users to exchange information on social media platforms and to invite other users to actions. They also help us to better understand the results of an action.

The legal basis for their use is our legitimate interest in the analysis, optimisation and economic operation of our platforms.

When you access a page on Kjero.com that contains such a plugin or embed, your browser establishes a direct connection with the servers of its operator. The content of the plugin is transmitted directly to your browser by its operator and integrated into the website by the latter. We therefore have no influence on the amount of data that the operator collects from your browser with the help of this plugin and therefore inform you according to our current knowledge:

When these plugins or embeds are called, your browser transmits your IP address to the operator. This will also allow the operator to know that you have accessed the relevant page on Kjero.com. If you interact with the plugin/embed, e.g. press the Like button, the corresponding information will be transmitted directly from your browser to the operator and stored there. If you have an account with one of these operators and do not want them to collect data about you via social plugins or embeds and link it to your account stored with them, you must log out of the operator before visiting Kjero.com.

We use the social plugins of the following providers:

• Facebook (more information under point 5.5.). According to Facebook, only one anonymous IP address is stored in Germany.
• Twitter (for more information see point 5.4.)
• Youtube (for more information see point 5.3.)
• Instagram (for more information see point 5.6.)

3.12. Online advertising tools

We use advertising tools from various providers on Kjero.com. These tools enable us to measure and improve the success of our advertising campaigns on Kjero.com.

The legal basis for the use of advertising tools and their pixels is our legitimate interest in the analysis, optimization and economic operation of our platforms.

The use of these providers usually includes the use of so-called pixels. These pixels enable the advertiser to see whether you are visiting a specific target page after you have seen an ad. When loading such pixels, your browser transmits your IP address to the operator.

We use tools from the following vendors:

• Google Adwords (more information under point 5.3.)
• Facebook (more information at point 5.5.)

4. order processor

If we disclose data to other persons and companies (contract processors or third parties) in the context of our processing, transfer them to them or otherwise grant them access to the data, this will only take place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as logistics providers, pursuant to Art. 6 Para. 1 lit. b GDPR for contract performance is necessary), you have consented, a legal obligation or on the basis of our legitimate interests (e.g. when using web hosting, etc.).

If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

5. processing outside the European Union or the European Economic Area

If we process data in a third country outside the European Union or the European Economic Area or if this occurs in the context of the use of third party services or disclosure or transmission of data to third parties, this will only occur if it occurs to fulfill our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Art. 44 ff. of the German Data Protection Act are met. GDPR. I.e. the processing takes place e.g. on the basis of special guarantees, like the officially recognized statement of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or observance of officially recognized special contractual obligations (so-called “standard contract clauses”).

Below is a list of the service providers we use that may process data outside the European Union or the European Economic Area:

5.1. Cloudflare

We use the Content Delivery Network (CDN) Cloudflare, which is operated by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA, to provide the content. Cloudflare optimizes loading times for users of Kjero services and protects Kjero servers from attacks.

To enable this performance, access to Kjero.com is routed through the Cloudflare network. Cloudflare automatically selects the nearest data center to the user. Since Cloudflare over 20 computer centers within the European Union operates is usually ensured that inquiries are worked on only by computer centers within the European Union. The Logdatein provided thereby is deleted according to Cloudflare within 4 hours (https://blog.cloudflare.com/what-cloudflare-logs/).

We trust in the reliability and IT and data security of Cloudflare. Cloudflare is certified under the Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).

5.2. MailChimp

Emails are sent via “MailChimp”, an e-mail dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

The e-mail addresses of our registered users, as well as their other data described in the context of this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate e-mails on our behalf. MailChimp may also use this information to optimize or improve its own services, e.g. to technically optimize the sending and display of e-mails or for economic purposes, to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them or pass them on to third parties.

We trust in the reliability and IT and data security of MailChimp. MailChimp is “Privacy Shield” certified (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG) . Furthermore, we have concluded a “Data Processing Agreement” with MailChimp. This is a contract in which MailChimp undertakes to protect the data of our users, to process it on our behalf in accordance with their data protection regulations and, in particular, not to pass it on to third parties. You can view the privacy policy of MailChimp here: http://mailchimp.com/legal/privacy/.

Statistical survey and analysis:

E-Mails contain a so-called “web-beacon”, i.e. a pixel-sized file which is retrieved from the MailChimp server when the e-mail is opened. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected. This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times.

The statistical surveys also include determining whether the e-mails are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual e-mail recipients, but it is neither our nor MailChimp’s aim to monitor individual users. The evaluations serve us much more to anonymously recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

5.3. Google

We use various services of Google LLC (“Google”) 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google is certified under the Privacy Shield Agreement (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

5.4. Google Analytics

Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transferred to a Google server in the USA and stored there.

We only use Google Analytics with IP anonymization enabled. The IP address transmitted by the user’s browser is not merged with other Google data.

You can prevent cookies from being saved by changing the settings in your browser. You can also prevent Google from collecting the data generated by the cookie and related to your online offer and Google from processing this data by installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

https://policies.google.com/technologies/ads) as well as in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Personal data will be automatically deleted or anonymized after 14 months.

5.3.1. Google AdWords

We use Google AdWords and its conversion tracking. Google Adwords stores a cookie in your browser (“conversion cookie”) if you have come to kjero.com via a Google ad. We and Google can use these cookies to recognize that you clicked on an ad and were redirected to kjero.com. This allows us to measure and improve the success of our promotions.

http://optout.networkadvertising.org/) and the U.S. website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

5.3.2 Google Fonts

We embed fonts via “Google Fonts”, which is a service of Google LLC.

5.3.3. YouTube

We integrate videos of the platform “YouTube”, which is a platform of Google LLC.

5.4 Twitter

We use social plugins (“Plugins”) of the social network twitter.com, which is operated by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (“Twitter”). The plugins can be recognized by one of the Twitter logos (white bird on light blue background and the terms “tweet”). The list and the appearance of the Twitter Social Plugins can be seen here: https://dev.twitter.com/web/overview.

https://twitter.com/privacy?lang=en.

Purpose and scope of the data collection and the further processing and use of the data by Twitter as well as the related rights and setting options for the protection of privacy can be found in this Twitter privacy notice: https://twitter.com/privacy?lang=en.

5.5. Facebook

We use social plugins and advertising tools from the Facebook network operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).

Facebook is certified under the Privacy Shield Agreement (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

5.5.1. Social plugins

We use social plugins from Facebook. The plugins are recognizable by one of the Facebook logos (white “f” on a blue tile, the terms “like”, “like” or a “thumb up” sign). The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and settings to protect the privacy of users, you can find these in Facebook’s privacy policy: https://www.facebook.com/about/privacy/. Other settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads.

5.5.2 Facebook Pixel and Custom Audiences

The so-called “Facebook pixel” is used on Kjero.com. With the help of Facebook pixels, we can measure and improve the success of advertisements.

Using the pixel, Facebook is able to identify Kjero.com visitors as the target audience for displaying ads. Accordingly, we use the pixel to display Facebook ads placed by us only to Facebook users who have shown an interest in Kjero.com or who have certain characteristics (e.g., interests in certain topics or products) (custom audiences). These custom audiences can be used to create lookalike audiences, which are similar to the Facebook user profiles of the custom audiences as an advertising target group, but can no longer be traced back to them. We use these Lookalike Audiences and may share them with our customers without disclosing any personal information. With the help of Pixel, Custom Audiences and Lookalike Audiences, we want to make sure that our ads and those of our customers are in line with the potential interest of the users and do not appear annoying.

Facebook processes the data in accordance with the Facebook Data Usage Policy. Accordingly, general notes on the presentation of Facebook ads in Facebook’s data usage policy: https://www.facebook.com/policy.php. Specific information and details about Facebook pixels and how they work can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.

Facebook processes the data in accordance with the Facebook Data Usage Policy. Accordingly, general notes on the presentation of Facebook ads in Facebook’s data usage policy: https://www.facebook.com/policy.php. Specific information and details about Facebook pixels and how they work can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.

You may opt out of Facebook pixel capture and use of your information to display Facebook ads. To control what types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions on how to set up usage-based ads: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

http://optout.networkadvertising.org/) and the U.S. website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

5.6. instagram

We use social plugins and embeds of the social network Instragram, which is operated by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA (“Instragram”). Instagram Inc. is a subsidiary of Facebook. The plugins and embeds are recognizable by one of the Instagram logos and/or the letters “Instagram” (square stylized camera on different colored backgrounds).

The purpose and scope of the data collection and the further processing and use of the data by Instagram and the related rights and privacy settings of users, you can find in Instragram’s Privacy Policy: http://instagram.com/about/legal/privacy/.

5.7. how to reach us

You can reach us at the following contact details:

Kjero GmbH
Bozner Platz 1/9
6020 Innsbruck
Austria
43 (0) 512 328 308
E-mail: [email protected]

State of data protection regulations: May 2018