Data protection declaration

Unless stated otherwise below, the provision of your personal data is neither legally nor contractually obligatory, nor required for conclusion of a contract. You are not obliged to provide your data. Not providing it will have no consequences. This only applies as long as the processing procedures below do not state otherwise. “Personal data” is any information relating to an identified or identifiable natural person.

Server log files

You can use our websites without submitting personal data. Every time our website is accessed, user data is transferred to us or our web hosts/IT service providers by your internet browser and stored in server log files. This stored data includes for example the name of the site called up, date and time of the request, the IP address, amount of data transferred and the provider making the request. The processing is carried out on the basis of Article 6(1) f) GDPR due to our legitimate interests in ensuring the smooth operation of our website as well as improving our services. Your data may be transferred to third countries outside the European Union for which an adequacy decision has been made by the EU Commission.

Contact

Responsible person/Data protection officer

Contact us at any time. The person responsible for data processing is: FLEX Capital Management GmbH Münzstr. 21 10178 Berlin Telefon: 030 55668-127 E-mail: kontakt@flex.capital You can contact our data protection officers directly at: HB E-Commerce Rechtsanwaltsgesellschaft mbH Kohlgartenstraße 11-13 04315 Leipzig Telefon: 0341 92659-205 E-Mail: flexcapital@datenschutz.hb-ecommerce.eu

Proactive contact of the customer by e-mail

If you make contact with us proactively via email, we shall collect your personal data (name, email address, message text) only to the extent provided by you. The purpose of the data processing is to handle and respond to your contact request. If the initial contact serves to implement pre-contractual measures (e.g. consultation in the case of purchase interest, order creation) or concerns an agreement already concluded between you and us, this data processing takes place on the basis of Article 6(1)(b) GDPR. If the initial contact occurs for other reasons, this data processing takes place on the basis of Article 6(1)(f) GDPR for the purposes of our overriding, legitimate interest in handling and responding to your request. In this case, on grounds relating to your particular situation, you have the right to object at any time to this processing of personal data concerning you and carried out on the basis of Article 6(1)(f) GDPR. We will only use your email address to process your request. Your data will subsequently be deleted in compliance with statutory retention periods, unless you have agreed to further processing and use.

Collection and processing when using the contact form

When using the application form, we collect your personal data only to the extent provided by you. This includes your contact details (e.g., name, e-mail address, telephone number), details of your professional qualifications and training, details of further professional training and performance-specific evidence.

The purpose of this data processing is to contact you and to decide on the establishment of an employment relationship with you. The provision of the data is necessary to carry out the application procedure. The processing of your personal data takes place on the basis of Art. 6 para. 1(b) GDPR in conjunction with Art. 26 para. 1 Federal Data Protection Act (BDSG) for the implementation of pre-contractual measures (undergoing the application procedure as an initiation of the employment contract).
If you have given us permission to process personal data for inclusion in our pool of applicants, e.g., by checking a checkbox, the processing takes place on the basis of Art. 6 para. 1(a) GDPR. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of your consent until the revocation.

If specific categories of personal data within the meaning of Art. 9 para. 1 of the GDPR are requested from the applicants, such as information on the degree of severe disability, this is carried out on the basis of Art. 9 para. 2(b) GDPR, so that we can exercise the rights arising from labor law and the social security and social protection legislation and fulfill our obligations in this regard.

We will store your personal data as long as this is necessary for the decision about your application. Your data will then be deleted after six months at the latest, provided that you have not consented to further processing and use. If an employment relationship is established following the application procedure, the data provided will be further processed and then transferred to the personnel file for the purposes of implementing the employment relationship pursuant to Art. 6 para. 1 (b) GDPR in conjunction with Art. 26 Para. 1 of the Federal Data Protection Act (BDSG).

Collection and processing when using the application form

We process the data that you have provided to us in connection with your application in order to assess the establishment of an employment relationship. This includes your contact information (such as name, email address, phone number), details of your professional qualifications and education, information about professional training, and performance-related evidence. The data processing serves the purpose of contacting you and deciding on the establishment of an employment relationship with you. The provision of data is necessary to conduct the application process. The processing of your personal data is based on Article 6(1)(b) of the GDPR in conjunction with § 26(1) of the BDSG for the performance of pre-contractual measures (the application process as a prelude to an employment contract). If you have given us consent to process your data for inclusion in our applicant pool, the legality of this processing is based on your consent (Article 6(1)(a) of the GDPR). Consent granted can be revoked at any time. Please note that the revocation only applies to future processing. Processing that occurred before the revocation is not affected by it. If special categories of personal data as defined in Article 9(1) of the GDPR are requested from applicants as part of the application process, such as information about the degree of disability, this is done on the basis of Article 9(2)(b) of the GDPR so that we can exercise the rights arising from labor law and social security and social protection law and fulfill our related obligations. We will store your personal data for as long as necessary to make a decision about your application. Your data will be deleted no later than six months after you have not consented to further processing and use. If an employment relationship is established following the application process, the provided data will be further processed based on Article 6(1)(b) of the GDPR in conjunction with § 26(1) of the BDSG for the purposes of employment relationship management and subsequently transferred to the personnel file. In case you have consented to further storage of your personal data in our applicant pool, we will retain your data and delete it no later than two years after the expiration of such consent. For this purpose, we use the “Personio” tool provided by Personio SE & Co. KG (Seidlstraße 3, 80335 Munich) as part of order processing. When applying through our website, cookies may also be used. Cookies enable the recognition of your browser. The use of cookies or similar technologies is done with your consent based on § 25(1) of the TTDSG in conjunction with Article 6(1)(a) of the GDPR. The processing of your personal data is carried out with your consent based on Article 6(1)(a) of the GDPR. You can revoke your consent at any time without affecting the legality of processing carried out based on the consent before the revocation. For further information on data processing by Personio, please refer to https://www.personio.de/datenschutzerklaerung/ and https://www.personio.de/datenschutz/.

Advertising

Use of your email address for mailing of newsletters

We use your email address outside of contractual processing exclusively to send you a newsletter for our own marketing purposes, if you have explicitly agreed to this. The processing will be carried out on the basis of art. 6 (1) lit. a GDPR with your consent. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. You can unsubscribe from the newsletter at any time using the relevant link in the newsletter or by contacting us. Your email address will then be removed from the distributor.

Use of your email address for mailing of direct marketing

We use your email address, which we obtained in the course of selling a good or service, for the electronic transmission of marketing for our own goods or services which are similar to those you have already purchased from us, unless you have objected to this use. You must provide your email address in order to conclude a contract. Failure to provide it will prevent the conclusion of any contract. The processing will be carried out on the basis of art. 6 (1) lit. f GDPR due to our justified interest in direct marketing. You can object to this use of your email address at any time by contacting us. You will find the contact details for exercising your right to object in our imprint. You can also use the link provided in the marketing email. This will not involve any costs other than transmission costs at basic tariffs.

Use of Brevo (Sendinblue)

We use the service of Sendinblue GmbH (Köpenicker Straße 126, 10179 Berlin, Germany; “Sendinblue”) for newsletter distribution as part of order processing. We pass the information you provide during the newsletter registration process (e-mail address, first and last name, if applicable) on to Sendinblue. The data processing serves the purpose of sending the newsletter and its statistical evaluation. In order to evaluate newsletter campaigns, the distributed e-mail newsletters contain a 1×1 pixel graphic (tracking pixel) and/or a tracking link. This allows us to determine whether you have opened the newsletter and whether you have clicked on any integrated links. In this context, your personal data such as e.g. IP address, browser type and device and time of opening can be collected. User profiles under a pseudonym can be created from this data. The data collected will not be used to identify you personally. The data collected is only used for statistical evaluation to improve newsletter campaigns. Your personal data is transferred in accordance with Art. 6 para. 1 lit. f GDPR arising from our overriding legitimate interest of a targeted advertising-effective and user-friendly newsletter system. For reasons that arise from your particular situation, you have the right to object to this processing of your personal data at any time. You can find more information and the SendinBlue privacy policy at: https://de.sendinblue.com/legal/privacypolicy/.

Cookies

Our website uses cookies. Cookies are small text files which are saved in a user’s internet browser or by the user’s internet browser on their computer system. When a user calls up a website, a cookie may be saved on the user’s operating system. This cookie contains a characteristic character string which allows the browser to be clearly identified when the website is called up again. Cookies will be stored on your computer. You therefore have full control over the use of cookies. By choosing corresponding technical settings in your internet browser, you can be notified before the setting of cookies and you can decide whether to accept this setting in each individual case as well as prevent the storage of cookies and transmission of the data they contain. Cookies which have already been saved may be deleted at any time. We would, however, like to point out that this may prevent you from making full use of all the functions of this website. Using the links below, you can find out how to manage cookies (or deactivate them, among other things) in major browsers: Chrome Browser: https://support.google.com/accounts/answer/61416?hl=en Microsoft Edge: https://support.microsoft.com/de-de/microsoft-edge/cookies-in-microsoft-edge-lB6schen-63947406-40ac-c3b8-57b9-2a946a29ae09 Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Safari: https://support.apple.com/de-de/guide/safari/manage-cookies-and-website-data-sfri11471/mac

technically necessary cookies

Insofar as no other information is given in the data protection declaration below we use only these technically necessary cookies cookies to make our offering more user-friendly, effective and secure. Cookies also allow our systems to recognise your browser after a page change and to offer you services. Some functions of our website cannot be offered without the use of cookies. These services require the browser to be recognised again after a page change. The use of cookies or comparable technologies is carried out on the basis of Art. 25 para. 2 TTDSG. Processing is carried out on the basis of art. 6 (1) lit. f GDPR due to our largely justified interest in ensuring the optimal functionality of the website as well as a user-friendly and effective design of our range of services. You have the right to veto this processing of your personal data according to art. 6 (1) lit. f GDPR, for reasons relating to your personal situation.

Use of CookieFirst

On our website, we use the CookieFirst consent management tool from Digital Data Solutions B.V. (Plantage Middenlaan 42a, 1018 DH, Amsterdam; “CookieFirst”). The tool enables you to give your consent to data processing via the website, in particular to set cookies, as well as to make use of your right of revocation for consents already given. The data processing serves the purpose of obtaining and documenting necessary consents to data processing and thus to comply with legal obligations. Cookies may be used for this purpose. The information that may be collected and transmitted to CookieFirst includes: uniquely identifiable ID, date and time of consent, opt-in and opt-out information. This data will not be passed on to any other third parties. The data processing is carried out on the basis of Article 6 para. 1 lit. c GDPR to comply with a legal obligation. For more information about data protection at CookFirst, please visit: https://cookiefirst.com/legal/privacy-policy/

Advertising tracking

Use of the Google Analytics

Our website uses the web analysis service Google Analytics from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”). The processing of data serves to analyse this website and its visitors and for marketing and advertising purposes. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity and to provide other services to the website operator relating to website and internet use. In this process the following information, inter alia, can be collected: IP address, date and time of the website access, click path, information on the browser and the device you are using, the pages visited, referrer URL (website via which you accessed our website), location data, purchasing activities. The IP address transmitted from your browser within the scope of Google Analytics is not associated with any other data held by Google. Google Analytics uses technology such as cookies, web storage in the browser and tracking pixels which enable an analysis of your use of the website. The information generated by these regarding your use of this website is usually transferred to a Google server in the USA and stored there. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Google has certified itself in accordance with the TADPF and has thus undertaken to comply with European data protection principles. Both Google and the US government authorities have access to your data. Google may combine your data with other data, such as your search history, personal accounts, usage data from other devices and any other information Google has about you. IP anonymisation is activated on this website. Google uses this to shorten your IP address beforehand within Member States of the European Union or in other signatories to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. You can find more detailed information on the terms and conditions of use and data protection at https://www.google.com/analytics/terms/de.html and/or at https://www.google.de/intl/de/policies/ and at https://policies.google.com/technologies/cookies?hl=de.

Use of the LinkedIn Insight tag

On our website, we use the LinkedIn Insight tag from LinkedIn Ireland Unlimited Company (Attn: Legal Dept., Wilton Plaza, Wilton Place, Dublin 2, Ireland; “LinkedIn”) for conversion tracking (visitor activity analysis) and retargeting (playing personalised advertisements). The LinkedIn Insight tag places a unique LinkedIn browser cookie (conversion cookie) in your browser and allows the following information to be collected for that cookie: metadata such as IP address, time stamp and page events (e.g. page views). These cookies have a limited validity. If you visit certain pages on our site and the cookie has not expired, we and LinkedIn may recognise that you have clicked the ad and been directed to that page. The LinkedIn Insight tag also allows LinkedIn to collect information about visits to our website, including URL, referrer URL, IP address, device and browser characteristics (user agent), and time stamps. This data is transmitted to LinkedIn, encrypted, IP addresses are truncated, and the direct IDs of LinkedIn members are removed within seven days to pseudonymise the data. This remaining pseudonymised data is then deleted by LinkedIn within 90 days. LinkedIn does not share any personally identifiable information with us, but only provides aggregate reports about the site’s target group and ad performance. LinkedIn members can control the use of their personal information for promotional purposes in their account settings. The information collected using the conversion cookie serves the purpose of producing conversion statistics. This allows us to find out the total number of users who have clicked our adverts and were forwarded to a page equipped with a conversion tracking tag. Your data may be transmitted to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). LinkedIn is not certified under the TAPF. The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. For more information about cookies and LinkedIn’s privacy policy, please visit: https://www.linkedin.com/legal/cookie-policy and https://www.linkedin.com/legal/privacy-policy.

Use of Outfunnel

On our website, we use the service “Outfunnel” provided by Outfunnel OÜ (Harju County, Tallinn, Põhja-Tallinn Valgevase 13, 10414, Estonia, “Outfunnel”). The data processing serves the purpose of analyzing this website and its visitors, as well as for marketing and advertising purposes, managing marketing campaigns, and for the purpose of sending newsletters and their statistical evaluation. Outfunnel uses technologies such as cookies. When visitors access our website, a cookie is placed in the web browser, and the tracking code sends information about the visitor’s web activities to Outfunnel. Outfunnel also tracks the opening of emails, clicks on hyperlinks contained therein, and other email activities. The following information may be collected and transmitted to Outfunnel, among other things: page visits, the timing of each page visit, IP address, referrer (source, medium), user ID. The use of cookies or similar technologies is carried out with your consent based on § 25(1) sentence 1 of the TTDSG in conjunction with Article 6(1)(a) of the General Data Protection Regulation (DSGVO). The processing of your personal data is done with your consent based on Article 6(1)(a) of the DSGVO. You can revoke your consent at any time, without affecting the lawfulness of the processing carried out based on your consent before the revocation. The processing of your personal data regarding the use of Outfunnel as a newsletter provider is based on Article 6(1)(f) of the DSGVO, stemming from our predominant legitimate interest in a targeted, effective, and user-friendly newsletter system. You have the right to object to the processing of your personal data concerning you at any time for reasons arising from your particular situation. For further information on data protection and Outfunnel’s privacy policy, please refer to the following links: Privacy Policy: https://outfunnel.com/privacy/ Data Processing Agreement: https://outfunnel.com/data-processing-agreement/

Plug-ins

Use of the Google Tag Manager

Our website uses the Google Tag Manager from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”). This application manages JavaScript tags and HTML tags which are used in particular to implement tracking and analysis tools. The data processing serves to facilitate the needs-based design and optimisation of our website. The Google Tag Manager itself neither stores cookies nor processes personal data. It does, however, enable the triggering of further tags which may collect and process personal data. You can find more detailed information on the terms and conditions of use and data protection at https://www.google.com/intl/de/tagmanager/use-policy.html

Use of social plug-ins

Our website uses social network plug-ins. The integration of social plug-ins and the data processing associated with this serves the purpose of optimising the advertising for our products. The integration of social plug-ins involves a connection between your computer and the servers of the service provider of the social network which then instructs your web browser to display the plug-in on that web page, provided you have expressly consented to this. In this process, both your IP address as well as the information on which web pages you have visited will be transmitted to the provider’s servers. This happens regardless of whether you are registered with or logged into the social network. The information is transferred even if users are not registered or logged in. Should you be connected simultaneously with one or more of your social network accounts, the collected information may also be assigned to your corresponding profiles. When using the plug-in functions (e.g. by pressing the appropriate button), this information will also be assigned to your user account. You can therefore prevent this assignment by logging yourself out before visiting our website and before activating the button for your social media accounts. The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. The following social networks are integrated in our website through social plug-ins. You can find more detailed information on the scope and purpose of collection and use of the data and your associated rights and options for protecting your privacy in the provider’s privacy policy via the link. Instagram by Meta Platforms Ireland Limited (4 Grand Canal Square, Dublin 2, Ireland): https://help.instagram.com/155833707900388 Your data may be transmitted to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Meta has certified itself in accordance with the TADPF and has thus undertaken to comply with European data protection principles. LinkedIn by LinkedIn Corporation (2029 Stierlin Court, Mountain View, CA 94043, USA) https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy Your data may be transmitted to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). LinkedIn is not certified under the TADPF.

Use of Facebook Connect

Our website uses the single sign-on function Facebook Connect from Meta Platforms Ireland Ltd. (Grand Canal Harbour, Dublin, D02, Ireland; “Facebook”). Meta Platforms Ireland and we are jointly responsible for the collection of your data and the transfer of this data to Facebook when the service is integrated. The basis for this is an agreement between us and Meta Platforms Ireland on the joint processing of personal data, in which the respective responsibilities are defined. The agreement is available at https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible in particular for the fulfilment of the information obligations in accordance with Art. 13, 14 GDPR, for compliance with the security requirements of Art. 32 GDPR with regard to the correct technical implementation and configuration of the service, and for compliance with the obligations in accordance with Art. 33, 34 GDPR, insofar as a violation of the protection of personal data affects our obligations under the agreement on joint processing. Meta Platforms Ireland is responsible for enabling the rights of the data subject in accordance with articles 15-20 of the GDPR, for complying with the security requirements of article 32 of the GDPR with regard to the security of the service, and for complying with the obligations of articles 33, 34 of the GDPR, insofar as a breach of personal data protection concerns Meta Platforms Ireland’s obligations under the joint processing agreement. This function enables website visitors to log on to the website via their already existing Facebook account. The processing of data serves the purpose of verification during registration, personalisation and for interest-related advertising. To offer this function on the website a connection to the Facebook servers is established. Cookies are used for this purpose. In this process the following information, inter alia, can be collected and transmitted to Facebook: IP address, browser information, referrer URL (website via which you accessed our website), location data. This happens regardless of whether you are registered with or logged into the social network. The information is transferred even if users are not registered or logged in. Should you be connected simultaneously with one or more of your social network accounts, the collected information may also be assigned to your corresponding profiles. You can therefore prevent this assignment by logging yourself out before visiting our website and before activating the button for your social media accounts. Your data may be transmitted to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Meta has certified itself in accordance with the TADPF and has thus undertaken to comply with European data protection principles. When using the single sign-on function the Facebook profile of the website visitor is connected with a customer account for this website. In this case we receive personal data of the user through Facebook, as stated in the login process. This can include the following information, inter alia: Name, address, public profile information (e,g, name profile picture, age, gender), email address, friends list, “Likes” information. The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. You can find more detailed information on the terms and conditions of use and data protection at https://www.facebook.com/about/privacy/.

Use of YouTube

Our website uses the function for embedding YouTube videos by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “YouTube”). YouTube is a company affiliated with Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). This feature shows YouTube videos in an iFrame on the website. The option “advanced privacy mode” is enabled here. This prevents YouTube from storing information on visitors to the website. It is only if you watch a video that information is transmitted to and stored by YouTube. Your data may be transmitted to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). YouTube has certified itself in accordance with the TADPF and has thus undertaken to comply with European data protection principles. The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. Further information on the data collected and used by YouTube and Google and your associated rights and options for protecting your privacy can be found in YouTube’s privacy policy (https://www.youtube.com/t/privacy).

Rights of persons affected and storage duration

Duration of storage

After contractual processing has been completed, the data is initially stored for the duration of the warranty period, then in accordance with the retention periods prescribed by law, especially tax and commercial law, and then deleted after the period has elapsed, unless you have agreed to further processing and use.

Rights of the affected person

If the legal requirements are fulfilled, you have the following rights according to art. 15 to 20 GDPR: Right to information, correction, deletion, restriction of processing, data portability. You also have a right of objection against processing based on art. 6 (1) GDPR, and to processing for the purposes of direct marketing, according to art. 21 (1) GDPR.

Right to complain to the regulatory authority

You have the right to complain to the regulatory authority according to art. 77 GDPR if you believe that your data is not being processed legally.

You can lodge a complaint with, among others, the supervisory authority responsible for us, which you may reach at the following contact details:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59-61
10555 Berlin
Telefon: 030/13 88 9-0
Telefax: 030/21 55 050
E-Mail: mailbox@datenschutz-berlin.de

Right to object

If the data processing outlined here is based on our legitimate interests in accordance with Article 6(1)f) GDPR, you have the right for reasons arising from your particular situation to object at any time to the processing of your data with future effect.
If the objection is successful, we will no longer process the personal data, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests or rights and freedoms, or the processing is intended for the assertion, exercise or defence of legal claims.

If personal data is being processed for the purposes of direct advertising, you can object to this at any time by notifying us. If the objection is successful, we will no longer process the personal data for the purposes of direct advertising.