Data Protection Notice

Last modified on 09/11/2017

four media network GmbH values the protection of your personal data and wants you to be familiar with how we collect, process and use information from and about you when you visit our websites, applications, or services (collectively, the "Service"). This Data Protection Notice details how we collect, process, and use personal data in compliance with applicable data protection law.

Unless detailed otherwise in this Data Protection Notice, the term "4MN" or "we" refers to four media network GmbH, Schanzenstrasse 23, 51063 Cologne, Germany, and we are also the data controller, meaning the legal entity responsible for compliance with applicable data protection law.

Any reference to # Group in this Data Protection Notice refers to companies affiliated with Turtle Entertainment GmbH based in Schanzen Strasse 23, 51063 Cologne, Germany and we will specify if and to which extent four media network GmbH or other # Group companies are involved in the processing and use of your personal data.

There are many different ways you can use the Service. If we give you the opportunity to publish information publicly on the Service - such as when you share content with other users, publicly display your profile information or participate in direct communication with other users – that information may be collected and used by us, so only share what you want to be public. When you create an account, the data that you provide to us is stored by and shared with us.

I. What is personal data?

The term "personal data" means any information relating to an identified or identifiable natural person. Information on the basis of which you cannot be identified, for example, the number of users visiting our website or comparably aggregated information, is not considered as "personal data".

II. What information do we collect?

II.1. User Provided Information
You may provide different information about yourself to us, such as your name, email address, postal mailing address, telephone number, credit card number, and billing information when you register for a Service or complete transactions on the Service, enter contests or sweepstakes, or otherwise use the features and functionality of the Service. You may also choose to include some or all of this information in an account that you created with the Service.

II.2. Automatically Collected Information:
When you access the Service or open one of our emails, we may automatically record and store certain information about your system by using cookies and other types of technologies. Cookies are small text files containing a string of alphanumeric characters that are sent to your browser.

Information we automatically collect may include Internet Protocol address ("IP Address"), a unique user ID, device type, device identifiers, browser types and language, referring and exit page addresses, platform type, version of software installed, system type, the content and pages that you access on the Service, the number of clicks made, the amount of time spent on pages, the dates and times that you visit the Service, and other similar information.

We will use this automatically collected information to:

II.2.a) Automatically update applications or comparable parts of the Service on your system

II.2.b) Remember your information so that you will not have to re-enter it during your visit or the next time you access the Service

II.2.c) Provide customized advertisements, content, and information

II.2.d) Monitor the effectiveness of marketing campaigns

II.2.e) Monitor and store aggregate site usage metrics such as total number of visitors and pages accessed and

II.2.f) Track your entries, submissions, and status in any promotions or other activities.

II.3. Precise Geolocation Information
When you use one of our mobile applications, we may use the GPS function (or other similar functions) of your mobile device to determine your current location as indicated by the GPS or similar function. Our mobile application will only access to GPS or similar function of your mobile device if you have explicitly agreed to such access, usually by means of confirmation during the mobile application installation process.

We will use such Precise Geolocation Information to tailor our Services to you, such as providing you with localized content or allowing you location sharing with others via our Services.

If you do not want us to use your location for the purposes specified above, you may turn off the location services for our mobile application in your account settings or your mobile phone settings. You may also turn off location-based functions within our mobile application.

II.4. Information from Other Sources:
We may obtain information about you from third parties and sources in addition to the user provided information and the automatically stored information, such as advertisers or social media networks for which you have approved our access to information (e.g., information from your Facebook account provided by the Facebook APIs). When you access the Service through social media networks or when you connect a Service to social media networks, the operator of the respective social media network will transfer information to us, and we will process and use such information in accordance with this Data Protection Notice.

We may also obtain information from third party services regarding your use of such services, including about your use of the content you choose to distribute through the Service. If we combine or associate information from other sources with information that we collect through the Service, we will treat the combined information in accordance with this Data Protection Notice.

III. How We Use Information

III.1. We use the information that you provide or that we collect from or about you to:

III.1.a) Operate, maintain, enhance, provide, create, and develop all of the features, functionality, and services (new or existing) found on the Service

III.1.b) Improve your experience with the Service by delivering content that we hope you will find relevant and interesting, including advertising and marketing messages

III.1.c) Allow you to comment on content, and participate in online games, contests, or rewards programs and

III.1.d) Understand the usage trends of our users.

III.2. We use your email address for administrative communications such as notifying you of major Service updates, for customer service purposes, or contacting you regarding any content that you have posted to or downloaded from the Service.

III.3. If you have declared your separate consent in receiving promotional information via email, we use your email address to send promotional materials or notifications to you related to the Service. If you want to stop receiving promotional emails, you can withdraw such consent at any time with effect for the future, for example, by going to your account settings once you have logged in to the Service or following the unsubscribe instructions at the bottom of each email.

If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.

IV. When We Disclose Information

IV.1. We do not share information that can identify you personally with third parties for their own marketing or promotional uses without your consent.

IV.2. We may, however, share your personal data for the following purposes:

IV.2.a) We may disclose your information to the extent necessary for the performance of an agreement with you, for example, to fulfil an order or process one of your transactions via the Service.

IV.2.b) We may disclose such information to service providers working on our behalf, such as, to: provide web site hosting, maintenance, and security services; fulfill orders; conduct data analyses and create reports; offer certain functionality; or assist us in improving the Service and creating new services and features. Our service providers' processing and use of your information are based on corresponding agreements to ensure that your information is processed on our behalf only for the purposes defined by us and subject to agreed technical and organizational measures to protect your information.

IV.2.c) If you connect to a third-party service (such as Facebook, Twitter, or another third-party application) through an icon or link on the Service or otherwise link your account with a third-party service, we may share information (such as your user name, the fact that your connection originated from the Service, and other relevant usage and diagnostic information) with such third party.With your consent, we may also send information about the content you watch or your activities on the Service to such third parties. The third party's use of your information will be subject to that service's privacy policy, and this Data Protection Notice will not apply.

IV.2.d) In compliance with the requirements under applicable law, we may make information available to other # Group companies.

IV.2.e) We may disclose user information in order to comply with our legal obligations.

V. Your Choices and Rights

V.1. You may decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality found on the Service.

V.2. You may update, correct, or delete certain information and establish preferences regarding your profile on the Service, visit the Settings Page, or contact It is also possible to disable your account from the Settings Page.

V.3. To access, review, correct, update, suppress, or otherwise limit our use of information you have previously provided directly to us, you may contact us (see our Contact Information below). In your request, please include your email address, name, address, and telephone number and specify clearly what information is relevant to your request. We will try to comply with your request as soon as reasonably practicable.

V.4. To protect your privacy and security, we may take steps to verify your identity before granting you access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

VI. Account Closure & Deletion

If you would like to close your account and delete your profile information, please go to your profile page. With other services, you may update or delete information tied to your account by accessing the "My Account" area of the service or by submitting a help ticket to that service.

VII. Analytics and Advertising Providers

VII.1. Google Analytics
The Service uses Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how you use the Service. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Our Service uses Google Analytics with a functionality for IP anonymization, so that Google will truncate/anonymize the last octet of the IP address within Member States of the European Union or other countries being parties to the Agreement on the European Economic Area. ?Only in exceptional cases is the full IP address sent to and shortsened by Google servers in the USA. Google will use this information on our behalf for the purpose of evaluating your use of the Service, of producing reports on Service activity and use to us as provider of the Service. Google will not link or otherwise associate your IP address with other data held by Google.

You may block the use of cookies by selecting the corresponding settings in your browser. However, please note that if you do this, you may not be able to use the full functionality of the Service. In addition, you can prevent Google's collection and use of Data (including your IP address) by downloading and installing the browser plug-in available at

VII.2. Advertising Providers
VII.2.a) We may allow advertisers, third-party advertising networks and third-party advertising service companies to deliver advertisements directly to you within the Service.

By delivering these advertisements directly to you, these companies can set their own cookies on your computer and trigger their own web beacons and other tracking technologies to measure the effectiveness of their advertisements and to collect and track information such as demographic information, inferred interests, aggregated information, and activity to assist them in personalizing the advertising content delivered to you.

We do not provide information that personally identifies you to these third-party ad servers or ad networks without your consent. However, please note that if an advertiser asks us to show an advertisement to a certain audience (for example, males age 15 to 18) or audience segment (for example, males age 15 to 18 who have participated in certain promotions) and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience that they were trying to reach.

VII.2.b) We cannot control the tracking technologies and activities of, those other advertisers, third-party advertising networks, or third-party advertising servers. You should consult the respective data protection notices / privacy policies of these advertisers, third-party advertising networks, or third-party advertising servers. For more information about third-party advertising networks and similar entities that use these technologies, see, and to opt-out of such ad networks' and services' advertising practices, go to the Network Advertising Initiative opt-out page, the Digital Advertising Alliance opt-out page, or the Your Online Choices page.

We do not control which companies participate in these opt-out programs or how these companies honor their opt-out choices.

VIII. Do Not Track

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the Network Advertising Initiative and the Digital Advertising Alliance opt-out links above. However, we do not recognize or respond to browser-initiated DNT signals, because the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

IX. Data Security

We use a variety of technical and organizational measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. However, no security precautions or systems can be completely secure. We cannot ensure or warrant the security of any information you transmit to us, and we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

X. Changes and Updates to this Data Protection Notice

We may change, modify, add, or remove portions of this Data Protection Notice at any time (for example, to reflect updates to the Services or to reflect changes in the law). If we change this Data Protection Notice, we will provide you notice of these changes, such as by sending an email or posting a notice on the Service.