Privacy Policy and Legal Disclaimer

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Limitation of liability for internal content

The content of our website has been compiled with meticulous care and to the best of our knowledge. However, we cannot assume any liability for the up-to-dateness, completeness or accuracy of any of the pages.

Pursuant to section 7, para. 1 of the TMG (Telemediengesetz – Tele Media Act by German law), we as service providers are liable for our own content on these pages in accordance with general laws. However, pursuant to sections 8 to 10 of the TMG, we as service providers are not under obligation to monitor external information provided or stored on our website. Once we have become aware of a specific infringement of the law, we will immediately remove the content in question. Any liability concerning this matter can only be assumed from the point in time at which the infringement becomes known to us.

Limitation of liability for external links

Our website contains links to the websites of third parties („external links“). As the content of these websites is not under our control, we cannot assume any liability for such external content. In all cases, the provider of information of the linked websites is liable for the content and accuracy of the information provided. At the point in time when the links were placed, no infringements of the law were recognisable to us. As soon as an infringement of the law becomes known to us, we will immediately remove the link in question.


The content and works published on this website are governed by the copyright laws of Germany. Any duplication, processing, distribution or any form of utilisation beyond the scope of copyright law shall require the prior written consent of the author or authors in question.

Data protection

A visit to our website can result in the storage on our server of information about the access (date, time, page accessed). This does not represent any analysis of personal data (e.g., name, address or e-mail address). If personal data are collected, this only occurs – to the extent possible – with the prior consent of the user of the website. Any forwarding of the data to third parties without the express consent of the user shall not take place.

We would like to expressly point out that the transmission of data via the Internet (e.g., by e-mail) can offer security vulnerabilities. It is therefore impossible to safeguard the data completely against access by third parties. We cannot assume any liability for damages arising as a result of such security vulnerabilities.

The use by third parties of all published contact details for the purpose of advertising is expressly excluded. We reserve the right to take legal steps in the case of the unsolicited sending of advertising information; e.g., by means of spam mail.

General Information

SmileToVote® (“we”, “us” or “our”) is committed to protecting your privacy. This Privacy policy has been created to answer any questions you may have regarding data collection and protection policies.

Our Privacy Policy explains how we collect, use, and protect information about you or associated with you through your use of the Site, purchase of commercially available data and our research activities, and your choices about the collection and use of your information. We will not use or share your information with anyone except as described in this Privacy Policy.

By using the Site or voluntarily submitting information directly or indirectly you agree that this Privacy Policy and our Terms and Conditions will apply. We may amend this Privacy Policy without notice, and your continued use of the Site or participation in our research activities will confirm your agreement to the new terms. We keep our privacy policy under regular review and we will place any updates on this webpage. This privacy policy was last updated on February 21th, 2017.

What data is the Site collecting?

We may collect two types of information from Site users: personal information and aggregated data or log files. All users of the Site remain anonymous unless they choose to give us their personal information.

We will collect personal information only if you submit it voluntarily, which may include:

your name
your e-mail address
your postal address
your phone and mobile number
your geographical location
your demographic information

Aggregate data and log files may include, among other information, IP addresses and domains, web traffic, type and information of device employed to access the Site, and interactions with advertisements.

What about SmileToVote®’s data file?

We may collect information about you from a variety of third party data vendors, all of which are compliant with applicable data privacy laws in their respective jurisdictions. We also collect information when you voluntarily complete one of our surveys that are conducted, upon SmileToVote® instruction, via a third party online survey provider or market research company.
What about cookies?

Cookies are small data files stored on your computer’s hard drive that help us first and foremost automatically provide you with personalized content which you requested. Cookies are harmless files that cannot access or affect other files or damage your computer. Although most browsers’ default settings accept cookies, you can customize your browser settings to refuse cookies or to warn you when cookies are detected. We may use our own and third party cookies to automate user-facing processes on the Site and we reserve the right to combine this information with other information.

How does SmileToVote® use my information?

We may use your information to

provide, maintain, improve, and customize the features and functionality of the Site;
gain insight to the behavior of target audiences;
contact you directly or indirectly for marketing or research purposes; and
to contact you with updates, messages, notices, including any notice required by law, or other information.

Which third parties have access to my information?

For the above purposes, we may share your information with third parties, under the same restrictions set out by this Privacy Policy. The classes of recipients of personal data to whom your data may be disclosed are the following:


Political campaigns
Independent expenditure groups
Non-profit organizations
Commercial entities

Service providers

Digital marketing platforms
Mail vendors
Call centers
Research partners
Affiliated data processors
Legal counsel

We may also disclose your information to any relevant third party if are convinced that we have to do so to

comply with legal process, respect the law or meet national security requirements; or
enforce this policy, take precautions against liability and defend ourselves against claims; or
exercise or protect the rights, property, or personal safety of our users, us, or others.

We may disclose your personal information to any member of our group, which means our subsidiaries, as well as our ultimate holding company and its subsidiaries.

We may also disclose your personal information to third parties:

in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
if SmileToVote® or substantially all of its assets are acquired by a third party, in which case personal data held by it about its registered supporters will be one of the transferred assets.

What about my children’s privacy and security?

The Site will normally not include content that is reasonably considered unsuitable for children. However, we encourage parents to spend time with their children online and to be fully familiar with the sites their children visit. Further, we do not knowingly collect or solicit personal information from any persons under the age of 18 or knowingly allow them to submit their personal information. If you become aware that we may have collected personal information from a person under the age of 18 without parental consent, please contact us using the details from our contact us page and we will remove the information from our files.

What measures does SmileToVote® take to protect my information?

We are aware of the need for user privacy and risks associated with use of the Internet, so access to user information is monitored and restricted to specific individuals with appropriate login credentials. All of the information we collect or record is restricted to designated sites. Only employees who need the information to perform a specific job are granted access to personally identifiable information.

Although we do our best to protect your personal information, the transmission of your data is outside our control and any such transmission is at your own risk. However, we will try to protect all personal information collected through this website in accordance with strict data protection standards.

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by using the Site and submitting your personal information, you acknowledge our processing of personal data in this way.

We will retain your information for a reasonable period or for as long as is required by law.

Data we may collect on EU citizens will remain within the EU, will be stored on our secure server and will be handled by analysts operating within the EU.

What about other websites accessible through the Site?

We may advertise on behalf of third parties on the Site, but we are not responsible for the practices employed by web sites or pages not under our control and we do not endorse any of these web sites or pages, their services, products or content. Please read over the rules and policies of third party websites before using them.

What about user-generated content and social media?

We will try to monitor the user content of our Site to the extent reasonably possible to ensure a positive experience for our users. Removal of any user-generated content may happen at our sole discretion for any reason, or no reason whatsoever.

However, we cannot guarantee the privacy and safety of any message board or any form of social media-type features included in the Site. By using these features you understand that you are responsible for such use and for any information you may disclose.

Can I access, remove or amend my information?

You have the right to request a copy of the information that we hold about you. If you want to access your data, please use the following form: Our compliance team will assess these requests on a case-by- case basis. We make a small charge for this service. If access to your data is granted, we will want to make sure that your personal information is accurate and up to date and you may ask us to correct or remove personal information you think is inaccurate.

We reserve the right to withhold any research data, data derived from our predictive modelling, confidential data acquired through third parties, or any other data at our disposal that is essential to our business to the degree permissible under applicable law. Please be aware that we may require you to co-operate with our security checks before we disclose information to you.

How can I get in touch with you about my information?

In compliance with the Privacy Shield Principles, SmileToVote® commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SmileToVote® at We will respond to any submission within 45 days, or earlier if so required by applicable law.

SmileToVote® has further committed to cooperate with EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) in particular ( with regard to unresolved Privacy Shield complaints. If we do not respond to your complaint within the timeframe provided by law or regulation, or in a satisfactory manner, please contact the UK ICO or another EU DPA for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

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