2. General principles

We process personal data only to the extent necessary to provide our websites and services, or where you have given your consent.

Legal bases, depending on the processing activity, are your consent under Art. 6(1)(a) GDPR, which you may withdraw at any time; the performance of a contract or pre-contractual measures under Art. 6(1)(b) GDPR; or our legitimate interest under Art. 6(1)(f) GDPR, where your rights and freedoms do not override it. For each individual processing activity we state the applicable basis.

Encryption: Both websites are served over HTTPS. Data in transit is encrypted.

No automated decision-making: We do not use profiling or automated individual decision-making within the meaning of Art. 22 GDPR.

Data-minimising integration: On butter-bei-die-ads.de, fonts and graphics are served from our own server. Without your consent, the site establishes no connection to any third-party server.

3. Hosting

3.1 Netlify (butter-bei-die-ads.de)

The website butter-bei-die-ads.de is hosted by:

Netlify, Inc., 512 2nd Street, Suite 200, San Francisco, CA 94107, USA

When you access the site, Netlify processes technically necessary connection data (see section 4). Netlify delivers content via a global server network, which means data may also be transferred to the USA.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in secure and performant delivery.

Transfer to third countries: Netlify is certified under the EU-US Data Privacy Framework. Standard contractual clauses pursuant to Art. 46(2)(c) GDPR are additionally in place. A data processing agreement pursuant to Art. 28 GDPR exists.

Privacy policy: https://www.netlify.com/privacy/

3.2 Framer (noble-advertising.com)

The website noble-advertising.com is built and hosted with:

Framer B.V., Rozengracht 207B, 1016 LZ Amsterdam, Netherlands
Chamber of Commerce (KvK) registration number: 59920637

When you access the site, Framer processes technically necessary connection data (see section 4). Framer uses Amazon Web Services servers as a sub-processor for delivery, which may involve processing outside the EU.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in secure and performant provision.

Processing agreement: A contract pursuant to Art. 28 GDPR exists. Framer is a provider established in the EU.

Transfer to third countries: Where data reaches third countries via sub-processors, this takes place on the basis of standard contractual clauses pursuant to Art. 46(2)(c) GDPR.

Framer Analytics: Framer additionally collects anonymised page-view statistics ("events.framer.com"). According to the provider, no cookies are set and no personal profiles are created in the process.

Privacy policy: https://www.framer.com/legal/privacy-statement/
Data processing agreement: https://www.framer.com/legal/dpa/

3.3 Bunny CDN

We use a content delivery network to serve image files and media, operated by:

BunnyWay d.o.o., Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia

When these files are retrieved, your IP address is transmitted to Bunny so that the content can be delivered to your browser. Bunny operates servers both inside and outside the EU.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in fast delivery.

Processing agreement: A contract pursuant to Art. 28 GDPR exists. Bunny is a provider established in the EU.

Privacy policy: https://bunny.net/privacy

4. Server log files

When you access our websites, the hosting provider automatically collects information transmitted by your browser:

• IP address
• Date and time of access
• Page or file requested
• Referrer URL (previously visited page)
• Browser type and version
• Operating system
• Volume of data transferred

This data is not merged with other data sources and serves technical provision, error analysis and defence against attacks.

Legal basis: Art. 6(1)(f) GDPR.

Retention period: As a rule [ANZAHL] days, then automatically deleted. In the event of security-relevant incidents, longer, until the matter is resolved.

5. Cookies and similar technologies

We use cookies and comparable storage technologies.

Technically necessary storage

On butter-bei-die-ads.de we store two items locally in your browser:

• Under the key "bbda-consent" we remember your decision as to whether tracking may be used. This entry is stored permanently until you delete it via your browser settings.

• Under the key "bbda-kampagne" we remember the campaign parameters of the address you arrived on, that is, information about which advertisement or link brought you to us. This entry is deleted as soon as you close the browser tab.

This data does not leave your browser. The campaign parameters are the one exception: if you sign up for the newsletter, they are transmitted together with your email address (see section 6).

Legal basis: § 25(2)(2) TTDSG (German Telecommunications-Telemedia Data Protection Act) — storage is strictly necessary so that we can respect your privacy decision. Without it, we would have to ask you again on every visit.

Cookies requiring consent

All technologies beyond the above — in particular the Meta Pixel and Google Analytics — are only set after you have given your consent in the cookie banner.

Legal basis: § 25(1) TTDSG in conjunction with Art. 6(1)(a) GDPR.

Withdrawal: You may withdraw your consent at any time by deleting the stored website data in your browser settings. The banner will then appear again on your next visit. Withdrawal does not affect the lawfulness of processing carried out up to that point.

6. Newsletter "Butter bei die Ads"

What we collect

When you sign up, we collect:

• your email address (mandatory)
• time of sign-up
• origin data: the previously visited page (referrer) as well as campaign parameters from the URL you arrived on ("utm_source", "utm_medium", "utm_campaign", "utm_term", "utm_content", "utm_id") and click identifiers from advertising platforms ("fbclid", "gclid", "ttclid", "msclkid")

We use the origin data exclusively in aggregated form, to understand which channels sign-ups come from.

Double opt-in

After signing up, you will receive an email containing a confirmation link. Only after you click this link will we add you to our mailing list. This ensures that nobody can sign up someone else's address. If you do not confirm, we delete the sign-up data after [ANZAHL] days.

Legal basis and withdrawal

Legal basis: Art. 6(1)(a) GDPR — your consent.

You may unsubscribe at any time using the link at the end of every email, or by writing to info@noble-advertising.com. After unsubscribing, we remove your data from the mailing list. We retain the sign-up record (email address, timestamp, IP address of confirmation) for up to three years in order to demonstrate consent in the event of a dispute (Art. 6(1)(f) GDPR).

Performance measurement

Our newsletters contain tracking pixels and individualised links. This allows us to see whether and when an email was opened and which links were clicked. We use this to improve content and send times.

This analysis forms part of the consent you give when signing up. If you withdraw consent, measurement ends. You can additionally prevent open tracking by disabling automatic image loading in your email client.

6.1 Make.com (data forwarding)

Your sign-up data is transmitted via webhook to the following service, which forwards it to our newsletter system:

Celonis SE (Make), Theresienstrasse 6, 80333 Munich, Germany
(Make.com is operated by Celonis; server location of the instance we use: EU)

Legal basis: Art. 6(1)(a) GDPR. A data processing agreement pursuant to Art. 28 GDPR exists.

Privacy policy: https://www.make.com/en/privacy-notice

6.2 beehiiv (newsletter delivery)

Delivery is handled by:

beehiiv Inc., 228 Park Ave S, PMB 96181, New York, NY 10003, USA

Your email address and origin data are stored there. beehiiv additionally processes open and click data (see performance measurement).

Legal basis: Art. 6(1)(a) GDPR.

Transfer to the USA: The transfer is based on standard contractual clauses pursuant to Art. 46(2)(c) GDPR. A data processing agreement pursuant to Art. 28 GDPR exists.

Note on risk: In the USA, authorities may under certain conditions access data without European legal remedies being available against this. By giving your consent, you expressly agree to the transfer (Art. 49(1)(a) GDPR).

Privacy policy: https://www.beehiiv.com/privacy

6.3 Kit (formerly ConvertKit)

For part of our email communication we use:

Kit (ConvertKit LLC), 750 Cross Pointe Rd, Suite N, Columbus, OH 43230, USA

Processed data: email address, name (if provided), sign-up time, and open and click data.

Legal basis: Art. 6(1)(a) GDPR.

Transfer to the USA: Standard contractual clauses pursuant to Art. 46(2)(c) GDPR; a data processing agreement pursuant to Art. 28 GDPR exists. The risk note in section 6.2 applies.

Privacy policy: https://kit.com/privacy

7. Meta Pixel (Facebook Pixel)

On butter-bei-die-ads.de, noble-advertising.com and simple-advertiser.com we use the Meta Pixel, operated by:

Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland

What the pixel does

The pixel is a piece of JavaScript that transmits a "PageView" event to Meta when the page loads. The following are processed:

• your IP address
• browser and device information
• the page accessed
• where applicable, a Facebook identifier, if you are logged in to Facebook or Instagram

We use the pixel to measure the effectiveness of our advertising and to build audiences for future campaigns. Meta provides us only with aggregated reports, not data on individual people.

Consent required

The pixel is only loaded after you have consented in the cookie banner. Without consent, no transmission to Meta takes place.

Legal basis: § 25(1) TTDSG in conjunction with Art. 6(1)(a) GDPR.

Joint controllership

For the collection and transmission of data we are joint controllers with Meta (Art. 26 GDPR). The corresponding agreement is available here:
https://www.facebook.com/legal/controller_addendum

Meta is solely responsible for any further processing it carries out.

Transfer to third countries

Meta may transfer data to the USA. This is based on standard contractual clauses pursuant to Art. 46(2)(c) GDPR. The risk note in section 6.2 applies.

Objection

In addition to withdrawing consent via the cookie banner, you can object directly with Meta:
• Ad settings: https://www.facebook.com/settings?tab=ads
• EDAA opt-out: https://www.youronlinechoices.com/uk/your-ad-choices

Privacy policy: https://www.facebook.com/privacy/policy

8. Google services

8.1 Google Analytics

On Butter-bei-die-ads.de, noble-advertising.com and simple-advertiser.com we use Google Analytics 4, operated by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Google Analytics uses cookies and similar technologies to analyse how the website is used. Data collected includes pages viewed, time on site, approximate location, device and browser, and the origin of visitors.

IP anonymisation: In Google Analytics 4, IP addresses are truncated by default and not stored.

Consent required: Analytics is only loaded after you have consented in the cookie banner.

Legal basis: § 25(1) TTDSG in conjunction with Art. 6(1)(a) GDPR.

Transfer to third countries: Google LLC is certified under the EU-US Data Privacy Framework. Standard contractual clauses are additionally in place. A data processing agreement pursuant to Art. 28 GDPR exists.

Retention period: [ANZAHL] months, then automatically deleted.

Objection: Browser add-on to opt out: https://tools.google.com/dlpage/gaoptout

Privacy policy: https://policies.google.com/privacy

8.2 Google Tag Manager

We use Google Tag Manager to manage website tags. Tag Manager itself stores no personal data; it only controls the loading of other services. It may, however, record your IP address and transmit it to Google.

Tag Manager only loads services for which you have given consent.

Legal basis: Art. 6(1)(f) GDPR for Tag Manager itself; for the services it loads, your respective consent.

8.3 Fonts

The font "DM Sans" used on butter-bei-die-ads.de is served from our own server. There is no connection to Google Fonts or any other external provider, and no data is transmitted to third parties in the process.

On noble-advertising.com, fonts are embedded via Google Fonts, operated by Google Ireland Limited (address above). When you access the site, your IP address is transmitted to Google so that the font files can be delivered to your browser. Without this transmission the font cannot be loaded.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in a consistent presentation.

Transfer to third countries: Google LLC is certified under the EU-US Data Privacy Framework; standard contractual clauses are additionally in place.

Further information: https://developers.google.com/fonts/faq

8a. Further services on noble-advertising.com

Payhip (sale of digital products)

For selling digital products we embed:

Payhip Ltd., 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

When the page loads, a Payhip script is retrieved, which transmits your IP address to Payhip. In the event of a purchase, Payhip additionally processes the order and payment data you provide.

Legal basis: Art. 6(1)(b) GDPR for purchase processing, otherwise Art. 6(1)(f) GDPR.

Transfer to third countries: An adequacy decision by the EU Commission exists for the United Kingdom, so no additional safeguards are required.

Privacy policy: https://payhip.com/privacy

Leadsy (visitor identification)

WebsitePolicies (cookie banner)

The consent banner on noble-advertising.com is provided by:

WebsitePolicies LLC, 1201 N. Orange St., Suite 7160, Wilmington, DE 19801, USA

The banner stores your consent decision locally in your browser. When the script loads, your IP address is transmitted to the provider.

Legal basis: Art. 6(1)(c) in conjunction with (f) GDPR — obtaining and documenting consent is a legal requirement.

Transfer to third countries: Standard contractual clauses pursuant to Art. 46(2)(c) GDPR. The risk note in section 6.2 applies.

9. Contacting us

If you contact us by email or via a form, we process the data you provide (name, email address, message content, any attachments) in order to handle your enquiry.

Legal basis: Art. 6(1)(b) GDPR for contract-related enquiries, otherwise Art. 6(1)(f) GDPR.

Retention period: Until your enquiry has been conclusively dealt with. Statutory retention obligations — in particular under commercial and tax law — remain unaffected.

10. Your rights

You have the following rights at any time:

• Right of access (Art. 15 GDPR). You may find out which data we process about you. The first copy is provided free of charge.

• Right to rectification (Art. 16 GDPR). You may request that we correct inaccurate data and complete incomplete data.

• Right to erasure (Art. 17 GDPR). You may request the deletion of your data, provided no statutory retention obligation applies.

• Right to restriction of processing (Art. 18 GDPR). You may request that we temporarily suspend the processing of your data.

• Right to data portability (Art. 20 GDPR). You may request that we provide your data in a commonly used, machine-readable format, or transmit it to another organisation.

• Right to object (Art. 21 GDPR). You may object to processing that we base on a legitimate interest.

• Right to withdraw consent (Art. 7(3) GDPR). You may withdraw consent you have given at any time with effect for the future. This does not affect the lawfulness of processing carried out up to that point.

For any of these, a message to info@noble-advertising.com is sufficient. We will respond within one month. In justified cases this period may be extended by two months — we will inform you if that happens.

Right to lodge a complaint

Independently of the above, you may lodge a complaint with a data protection supervisory authority, in particular in the EU Member State of your residence, place of work or the place of the alleged infringement (Art. 77 GDPR).

A list of German supervisory authorities is available at:
https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html

For authorities in other EU Member States:
https://edpb.europa.eu/about-edpb/about-edpb/members_en

11. Children and young people

Our offerings are directed at businesses and persons aged 16 and over. We do not knowingly collect data from children under the age of 16. Should such data have been transmitted to us without the consent of a parent or guardian, we will delete it promptly upon becoming aware. Please contact info@noble-advertising.com in such a case.

12. Changes to this policy

We update this privacy policy when our services or the legal situation change. The version published on this page applies at any given time. The date at the top indicates the current version.

For material changes affecting consent-based processing, we will obtain your consent again.