2. Processing of Personal Data and Transfer to Third Parties

When you use our website, certain personal data about your device (computer, mobile phone, tablet, etc.) is automatically collected. This includes the IP address your device is using at the time, date and time, browser, device operating system, and pages visited. This occurs for data security purposes, to optimize our services, and to improve our website. The processing of this personal data is always based on Article 6, Paragraph 1, Sentence 1, Letter f) of the General Data Protection Regulation (GDPR). The protection of our website and the optimization of our services constitute legitimate interests on our part.

If you contact us (e.g., via the contact information we provide), we will only process the personal data that you have provided, which is necessary to process and respond to your inquiry.

We rely on service providers to enable the data processing operations detailed in this Data Protection Statement, such as hosting and maintaining the website.

Cookies

To make our services attractive and enable the use of certain features, we use cookies, which are small text files stored on your device. Some of the cookies we use are deleted after the browser session ends (session cookies). Other cookies remain on your device and allow us to recognize your browser upon your next visit (persistent cookies). You can configure your browser to notify you when cookies are being used and decide whether to accept them, only accept cookies in certain cases, or generally reject cookies. More information can be found in your web browser’s help section. If you do not accept cookies, the functionality of our website may be limited. By accepting our “Cookie Banner,” you consent to the processing of your personal data via cookies. This personal data is processed based on Article 6, Paragraph 1, Sentence 1, Letter a) of the GDPR. Below, we provide specific details about the cookies used.

We use Adobe Analytics, a service of Adobe Systems Software Ireland Limited (4-6 Riverwalk Citywest Business Campus, Dublin 24, Republic of Ireland; “Adobe”). This service uses cookies stored on your device to allow the analysis of your website usage. The information generated by the cookie regarding your website usage (including your IP address) is transferred to Adobe servers in Ireland, anonymized, and then transferred in an anonymized form to servers in the United States for processing and storage. Adobe uses this information to evaluate your website usage, compile reports on website activity for the website operator, and provide other services related to website and internet usage. If required by law or if third parties process data on behalf of Adobe, this information may be transferred to third parties as necessary. Your IP address will never be associated with other Adobe data. You can prevent the installation of cookies by adjusting your browser settings. However, please note that if you do so, you may not be able to fully utilize all the functions of the website. By using the website, you consent to the processing of your collected data in the manner described above and for the purpose outlined. You can cancel Adobe’s data collection at any time with future effect. More information on this can be found at: http://www.adobe.com/privacy/opt-out.html

We also use Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics also uses cookies. The information generated by the cookies about your website usage is generally transferred to a Google server in the United States, where it is stored. However, before this transfer, Google shortens your IP address within the member states of the European Union or in other states that are parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the United States and shortened there. On behalf of the website operator, Google uses this information to evaluate your website usage, compile reports on website activity, and provide other services related to website and internet usage. The IP address transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can prevent the storage of cookies by making the appropriate settings in your browser software. You can also prevent Google from collecting the data generated by the cookies and related to your use of the website (including your IP address) and processing your personal data. To do this, download and install the browser add-on at: https://tools.google.com/dlpage/gaoptout?hl=en

DISH also uses third-party advertising cookies for advertising purposes. These cookies allow us to tailor the ads displayed in your browser to your interests based on your browsing behavior. We use the following advertising cookies:

a) DISH uses Facebook Pixel, a tool operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025 (USA), or, if you reside in the EU, by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 (Ireland) (“Facebook”), on its website for the analysis, optimization, and commercial activities of the website. Facebook Pixel allows Facebook to determine visitors to our website as a target group for displaying Facebook ads. Therefore, DISH uses Facebook Pixel to show Facebook ads only to users who have shown interest in the DISH website. Facebook Pixel also helps track the effectiveness of Facebook ads for statistical and market research purposes, observing whether users were redirected to our website after clicking on a Facebook ad (known as “Conversion” or “User Interaction”). In this case, the legal basis for processing is Article 6, Paragraph 1, Sentence 1, Letter a) of the GDPR. Facebook uses Facebook Pixel directly when you visit our website, and a cookie may be set on your device. If you then log into Facebook or visit Facebook while logged in, your visit to our website will be recorded in your profile. The data collected about you is anonymous to us, and we do not receive any information about the identity of the users. However, Facebook stores and processes the data so that a connection to the respective user profile is possible. This allows user profiles to be created from the processed data. Facebook processes the data according to Facebook’s privacy policy. For more information on how Facebook Pixel works and how Facebook ads are displayed, please review Facebook’s privacy policy at: https://www.facebook.com/policy . You have the right to object to Facebook Pixel’s collection and use of your data for displaying Facebook ads. To configure the types of ads you see on Facebook, you can go to the page provided by Facebook and follow the instructions for configuring ad settings based on your usage: https://www.facebook.com/adpreferences/ad_settings . The settings are platform-independent, meaning they can be applied to all devices, such as desktop computers or mobile devices. You can also opt out of the use of cookies for tracking and advertising purposes through the Network Advertising Initiative’s opt-out page http://optout.networkadvertising.org or through the U.S. website http://www.aboutads.info/choices or the European website http://www.youronlinechoices.com/uk/your-ad-choices/ . You can manage your privacy settings through the Onsite button on our website.

We take technical precautions to pseudonymize the data collected about you through analytics and/or advertising cookies. After pseudonymization, it is no longer possible to directly assign the data to that user.

By clicking “Accept” on our “cookie banner,” you consent to the processing of your personal data via analytics and advertising cookies for the purposes mentioned. In this case, the processing of this personal data is based on Article 6, Paragraph 1, Sentence 1, Letter a) of the GDPR.

Provision of Personal Data and Retention Periods

Providing your personal data is voluntary. You are not legally required to provide us with your personal data. If you do not wish to provide it, the only consequence will be that you will be unable to use our services. The personal data you provide via our website is only stored until the purpose for which it was processed has been fulfilled. Retention periods may be adjusted based on legitimate interests on our part (e.g., ensuring data security or preventing misuse). Personal data that we are required to retain due to contractual or regulatory obligations will be blocked.

Your rights

To exercise the rights granted to you under the GDPR, such as:

• obtaining information about the processing of your personal data and a copy of this data (Art. 15 GDPR);
• rectifying and completing your personal data when it is incorrect or incomplete (Art. 16 GDPR);
• deleting your personal data, and if it has been made public, requesting that other responsible parties be notified of the deletion request (Art. 17 GDPR);
• restricting the processing of your personal data (Art. 18 GDPR);
• accessing data portability (so that your data is provided in a structured, standard, and machine-readable format) and the right to transfer that data to another responsible party without hindrance from us (Art. 20 GDPR);
• withdrawing any consent given; the withdrawal does not affect the legality of processing carried out based on consent prior to the withdrawal (Art. 7 GDPR); and
• objecting to the processing of your personal data (Art. 21 GDPR),

you can contact us at any time using the contact information provided in Section 1. Additionally, you have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your data is not in line with the GDPR (Art. 77 GDPR).

Version Date: May 2018 / AG