Data Privacy Policy of Silnap.com
(Version 03.03.2020)
This Data Privacy Policy informs you about the kind, scope and purpose of the gathering and use of your personal data on the website
www.silnap.com (hereinafter referred to as the “Website”) by SILNAP AG (hereinafter referred to as “We” or “Us”). By using the website or our offer of streaming subscriptions and contents (hereinafter referred as the “Services”), you consent to the following terms. The Data Privacy Policy applies to all offers of SILNAP AG.
1. General information about data protection
Your rights
We take the privacy of your personal data seriously. We process personal data only to the required extent, treat them as confidential and in accordance with the legal data protection regulations and this Data Privacy Policy. Within the scope of the legal regulations, you have the right to obtain a confirmation on request about what personal data has been stored about you. In addition, you have the right to demand the correction of incorrect data, the restriction of the processing of processed data, and erasure of your data. If you have given us your formal consent to the data processing, you can revoke it at any time by sending a formless message by email. Moreover, you also have the right to lodge complaint with the competent data protection supervisory authority.
The data controller and EU representative for the processing under this Data Privacy Policy is:
Data controller:
SILNAP AG
Seefeldstrasse 303
8008 Zurich
EU representative:
Silnap AG
Friedrichstraße 171
10117 Berlin
Germany
If you have questions regarding data processing on our website, please contact:
SILNAP AG
Data Protection Officer
Seefeldstrasse 303
8008 Zurich
datenschutz@silnap.com
2. Gathering and use of personal data
Depending on your relationship with us, we process different kinds of personal data about you for different purposes.
Below is a list of the gathered personal data and of how we use them.
Visit to our website
When you access our website and use our Service, information is sent automatically from the browser that is used on your end device to the server of our website. This information is stored temporarily in a so-called logfile.
The following information is gathered in the process without any action by you and stored until its automatic deletion:
- IP address of the requesting computerdate and time of the access
- date and time of access
- information about the type of subscription
- information about the interaction with the service
(search queries, streaming history)
- name and URL of the retrieved file
- website from which the access was made (referrer URL)
- browser type and browser version, and further information
transmitted by the browser such as the operating system of your
computer, the name of your access provider, your geographical
origin, language settings, etc.
These data are gathered for the following purposes:
- ensuring that a connection with the website is established without
problems
- ensuring easy use of our website
- analysis of system security and stability
The legal basis for this data processing is our overriding private interests in accordance with Art. 13 (1) DSG [Data Protection Law] or Art. 6 (1), sent. 1 lit. f) GDPR.
Account and usage data
This relates to the personal data that are gathered by us and made available by your, respectively, to register with our Service and to be able to use it (hereinafter “Account Data”). This data is processed in addition to the data that are gathered when you visit our website.
The Account Data includes, in particular:
- last name, first name
- email address
- postal address, if applicable
- information about the type of offer
- information about the interaction with the service (search queries,
streaming history, etc.)
Some data are indispensable for the creation of an account. Depending on the type of Service you subscribe, the kind and scope of the data gathered by Us may be subject to change.
These data are gathered for the following purposes:
- check of identity
- fraud prevention
- provision and customisation of your subscription
- ensuring the security of your account
- development, provision and optimisation of the website
This data processing takes place on the basis of contractual or pre-contractual measures pursuant to Art. 13 (2) lit. a) DSG or Art. 6 (1), sent. 1 lit. b) GDPR.
Payment data
The Service is paid for via PayPal (Europe) S.a.r.l. et Cie, S.C.A. (hereinafter referred to as “PayPal”) or with a credit card. These data are the personal data provided by you in order to register for a subscription that is subject to payment or to purchase content. This includes in particular:
- last name and first name
- date of birth
- credit card information (including name, card number, security code
CVV, and date of expiry)
- PayPal account number
Some data are indispensable for the creation of an account. Depending on the type of Service you subscribe, the kind and scope of the data gathered by Us may be subject to change.
These data are gathered for the following purposes:
- facilitating payment transactions
- fraud prevention
- provision and customisation of your subscription
This data processing takes place on the basis of contractual or pre-contractual measures pursuant to Art. 13 (2) lit. a) DSG or Art. 6 (1), sent. 1 lit. b) GDPR.
Newsletter
You have the possibility to subscribe to our newsletter in which we inform you about important news relating to our offer.
To obtain your consent to our newsletter mailing, we use the so-called double opt-in procedure, meaning we will email a newsletter to you only if you have also expressly confirm this to us beforehand. You will receive a confirmation email in which you are asked to click on the link contained in the email.
The following personal data will be used to send advertising to you:
- email address
- on a voluntary basis: first and last names
These data are gathered for the following purposes:
- Project announcements
- Software updates
- News from silnap.com
- Internal purposes (e.g. data analysis)
This data processing takes place on the basis of contractual or pre-contractual measures pursuant to Art. 13 (2) lit. a) DSG or Art. 6 (1), sent. 1 lit. b) GDPR.
Contact form
For queries of any kind, we offer you the option to contact us by means of a form that is provided on our website. The following information has to be provided for this purpose:
- your valid email address
- first and last names
- company name (voluntary)
These data will be processed for the following purposes:
- contacting
- consulting
- identification
This data processing takes place on the basis of contractual or pre-contractual measures pursuant to Art. 13 (2) lit. a) DSG or Art. 6 (1), sent. 1 lit. b) GDPR.
User profile for ASMRtists
ASMRtists can create a user profile on our Website, in the course of which personal data are gathered about you. In this process, the following data will be gathered about you:
- user name
- profile picture (avartar) if applicable
- personal description and information about your person
- email address
These data are gathered for the purpose of verifying the artist’s identify, as information for subscribers, and for identification of the producer on rendition. This Data Privacy Policy serves as an addition to the contractual agreements with the artists.
This data processing takes place on the basis of contractual or pre-contractual measures pursuant to Art. 13 (2) lit. a) DSG or Art. 6 (1), sent. 1 lit. b) GDPR.
3. Storage and deletion of data
We keep your personal data for as long as we deem this necessary or appropriate for compliance with the applicable laws, or for as long as the data are needed for the purposes for which they were gathered.
We will delete your personal data as soon as they are no longer needed and, in any case, after the expiration of the legally prescribed maximum retention period.
4. Links
We can display contents that refer to the Websites of third parties. We are neither able to check the data privacy policies or contents of these websites nor be held responsible for them. Consequently, if you click on a link or an ad of third parties, please notice that you will be leaving the Website and Service of Silnap.com. The personal data that you enter in subsequence will no longer be subject to this policy.
On visits to our social media profiles, the respective operators gather personal data about you. The gathered data pertain to, e.g. your IP address and further information that is available on your PC in the form of cookies.
If you click on the respective social media button, you will be redirected to the website of the provider. When you click on the social media button, the provider will receive information about your IP address and that you have visited our Website.
You can get more information about the providers at:
- Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour,
Dublin 2, Ireland:
https://www.facebook.com/privacy/explanation
- Instagram: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal
Harbour Dublin 2, Ireland:
https://help.instagram.com/519522125107875
- Twitter International Company, One Cumberland Place, Fenian Street,
Dublin 2, Ireland:
https://twitter.com/de/privacy
In respect of the data that are gathered by third parties from our profiles in social media in accordance with this Data Privacy Policy, the third party and We are deemed joint data controllers. We are not responsible for the further processing steps carried out by the respective operator of the network and reject any liability.
5. Cookies and other technologies
The Services offered by us use cookies. A cookie is a small file that is sent from a web server to your device to gather information about your browser behaviour. These cookies provide Us with information about the use of our Website, information to identify your device (device ID, IP address, browser type) and with the URL of the visited website.
Certain cookies are required for the functioning of the website. These cookies are used on our website, in particular for the following functions:
- to recognise you as a logged in user
- to store certain settings chosen by you
- to identify any occurring errors
- to compile statistics of how our website is used
In the process, we use the following cookies:
Technically required cookies
Type |
Cookie |
Duration |
Purpose |
|
required |
crsftoken |
End of the session |
Protection against CSRF attacks |
|
required |
Django_language |
1 year |
Basic language setting |
|
required |
sessionid |
End of the session |
Identifies the current user. It is used for tracking the session and authenticating the request. |
The data processed by technically required cookies serve to protect our legitimate interest pursuant to Art. 13 (1) DSG or Art. 6 (1), sent. 1 lit. f) GDPR.
Cookies not required for technical reasons:
Type |
Cookie |
Duration |
Purpose |
|
permanent |
_ga |
2 years |
Google Analytics: Registers a unique ID that is used to gene- |
|
permanent |
_gid |
1 day |
Google Analytics: Registers a unique ID that is used to gene- |
|
permanent |
_gat_gtag_UA 138143018_1 |
1 minute |
Google Analytics: This is a log cookie to analyse the user behaviour on our website. |
|
permanent |
_gat UA 138143018-1 |
1 minute |
Google Analytics: This is a log cookie to analyse the user behaviour on our website. |
The data processing by means of cookies that are not required for technical reasons is based on your consent pursuant to Art. 13 (1) DSG or Art. 6 (1), sent. 1 lit. a) GDPR.
Google Analytics
To improve our offer on the website, we use Google Analytics, a web analysis service of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”).
Google Analytics uses cookies. The information generated by the cookies is transmitted to a server of Google in the USA and stored on servers there. Google uses the information to analyse your use of the Website, to compile reports for the operators regarding the activity on the Website, and to perform further services relating to the activity on the Website and the use of the internet. Google observes the data protection regulations of the “Swiss-US Privacy Shield” Framework and therefore offers an adequate data protection standard. You can find out more at http://www.google.com/intl/de/analytics/privacyoverview.html, in particular also regarding the possibility to deactivate Google Analytics at http://tools.google.com/dlpage/gaoptout?hl=de.
The data processing by Analytics is based on your consent pursuant to Art. 13 (1) DSG or Art. 6 (1), sent. 1 lit. a) GDPR.
Settings
Most web browsers are configured by default to automatically accept cookies. If you do not want that our Website stores cookies on your device, you can configure your browser so that you will receive a warning before certain cookies are stored. You can also adjust your settings so that your browser will reject most of our cookies or that it rejects or completely deactivates only certain cookies.
If you want that technically required cookies are used:
Accept
Reject
You can also revoke your consent to cookies by deleting the already stored cookies. To do so, see the instructions of the search engine operator:
- Internet Explorer: https://support.microsoft.com/en-
in/help/278835/how-to-delete-cookie-files-in-internet-explorer
- Google Chrome: https://support.google.com/chrome/answer/95647?
co=GENIE.Platform%3DDesktop&hl=en
- Safari: https://support.apple.com/kb/ph21411?locale=en_US
Find more about this at www.allaboutcookies.org.
Please notice that certain functions of the Website might possibly no longer be available to you if you restrict or deactivate cookies.
6. Disclosure to third parties
Personal data that are gathered inside of the European Union and Switzerland can be transferred to third parties, who are outside of the European Union or Switzerland. Your personal data will not be disclosed in third countries that do not have an appropriate data protection standard, unless this Data Privacy Policy provides for an exception. We ensure that the transmission of data takes place in a secure manner at all times and in accordance with the respectively applicable data protection laws. We moreover ensure that appropriate technical and organisational measures are in place in such a case.
We neither sell nor pass on personal data to third parties for marketing purposes.
7. Service providers
We pass on personal data to service providers, which are specialised in the processing of information, administration and maintenance of customer data, performance of customer service or the implementation of surveys on customer satisfaction.
The personal data are processed by service providers only upon a prior contractual assurance that the service providers comply with the requirements of data protection laws.
We use Vimeo for replaying videos on our Website. Vimeo is operated by Vimeo, LLC with headquarters in 555 West 18th Street, New York, New York 10011.
The access to Vimeo and the videos takes place via our account and no personal data of you are forwarded to Vimeo.
8. Children
This Service is not intended for persons under the age of 16. If you are under the age of 16, please do not use this Service and do not transfer any personal data to us.
9. Protection of personal data
Your password protects your account and payment data. We therefore recommend that you use the most secure password possible, which is valid exclusively for this Account Data. It should never be passed on to third parties. In addition, access to your computer and browser should be protected by means of a password. Please sign out after each use of our Services.
10. Changes to this Data Privacy Policy
We reserve the right to change this Data Privacy Policy at any time. The respectively current version of the Data Privacy Policy is published at https://www.silnap.com/privacy/.
Should we make major changes, we will inform you clearly of them, either by sending you an email or displaying a message within the Service used by you. Please always read such a message carefully.
11. Place of jurisdiction and applicable law
Swiss substantive law applies to the exclusion of the Swiss Federal Law on Private International Law (IPRG). The place of jurisdiction is Zurich.
Status: May 2020