Last updated: May 24, 2018
Welcome to loots!
loots provides a livestream monetization platform via loots.com (The “Site”) and related Internet Services (collectively, “The Service(s)”). The Service allows (“Users”) to send advertising-supported messages (“Sponsored Messages”) to broadcasters (“Streamer”). Sponsored Messages will appear on the livestream and the broadcaster will receive remuneration for providing the advertising space.
The Service is operated by fishwoodco GmbH, Sophienstrasse 32, 10178 Berlin, Germany, registered at HRB 172582 B District Court Berlin (Charlottenburg), email@example.com (“us”, “we”, or “our”).
We are processing Information for carrying out our commercial activities, in particular to pursue our Services, business activities as well as business communication including direct marketing.
We are collecting Information and may receive Information from our Streamers and Users as well as other third parties (e.g. business partners).
We are processing the following categories of Information for all visitors of our Site:
- Information about browser (type/version) and operating system used,
- the IP address,
- Websites from where visitors are directed to our Site (referral link),
- Access of Sites, use of Site functions, search queries and the frequency of pages visited,
- Websites accessed by visitors via our Sites (follow-up link),
- Date and time of access,
- Volume of data transmitted as well as
- Access status (file transmitted, file not found, etc.).
For Users, the following additional Information will be collected through registration (the “Registration Information”), processing our newsletter mails as well as during the use of our Services:
- Last name, first name,
- Contact information: address, email address, IP address, social media contact,
- Interest in specific services,
- Date and time of registration and newsletter processing,
- Websites accessed via our newsletter links,
- Sponsored Message communication
We may collect and process the following additional categories of Information regarding Streamers and contact persons of other business partners:
- Last name, first name,
- Contact information: address, email address social media contact, messenger contact
- Interest in specific services provided by us,
- Financial information,
Streamers and other business partners are contractually required to provide us these categories of Information. Without this Information, we are unable to provide our Services to the Streamer concerned.
Legal Basis & Legitimate Interest
If we are given consent to process Information, e.g. in the course of your registration, Article 6 (1) (a) of the EU General Data Protection Regulation ("GDPR") serves as legal basis.
Legal basis for the processing of Information to initiate or perform a contract to which you are a party, e.g. regarding a Streamer or business partner cooperating with us, is Article 6 (1) (b) GDPR.
If processing is required by us to meet our legal obligations, e.g. data preservation and documentation obligations, the processing is based on Article 6 (1) (c) GDPR.
Information will also be processed to assert our legitimate interests and that of third parties under Article 6 (1) (f) GDPR. Legitimate interests lie in the functionality of our and third parties’ IT systems including our Site appearance and the interchange with your device (, e.g. laptop, mobile phone) as well as carrying out our commercial activities including business communication and direct marketing.
Logs & Cookies
Every time our Site is accessed and every time a file on our Site is retrieved, our IT systems collect automated Information from the retrieving medium and store these in a log file on our server. The data stored in log files is evaluated exclusively for statistical purposes.
You may deactivate or limit the transfer of cookies through your Internet browser settings. You may delete previously stored cookies at any time. If cookies are deactivated, you may not be able to use all our Site functions to their fullest extent any longer.
Information will be deleted or blocked as soon as the processing or storage purpose no longer applies, especially after withdrawal of consent. Log files will be stored until deleted upon expiry of legal retention obligations, at the latest after one year. Storage beyond this period only occurs as long as and as far as it is designated by the EU or Member States legislation in Union Acts, Law, or other regulations, that we are subject to.
Disclosure of Information
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties may have access to your Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. As a rule, we do not transmit data to receiving parties outside of the European Economic Area (exceptions see below). Streamers will only receive aggregated or anonymized information.
For web analysis and conversion tracking we disclose Information retrieved from our Site to Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 in the USA. You may prevent the further collection and transfer of your Personal Information by Google. For this, Google Inc. provides the relevant information: https://tools.google.com/dlpage/gaoptout?hl=de.
Email Marketing Messages (“EMM”) are provided by an external email marketing service provider (“EMS”), a business partner that allows us to send out emails to registered persons. EMMs may contain tracking beacons, click through links or similar server technologies in order to track subscriber activities. We disclose Information about you towards our EMS Rocket Science Group LLC d/b/a MailChimp, 675 Ponce de Leon Avenue NE, Suite 5000, Atlanta, GA 30308 and Mailgun Technologies, Inc., 535 Mission St., San Francisco, CA 94105, both situated in the U.S.
We process payment transfers via PayPal Inc., 2211 North First Street San Jose, CA 95131, U.S.
So, data may be transmitted to servers in the U.S. and processed there. No adequacy decision covering the U.S. has been made by the European Commission within the meaning of Article 45 (1) GDPR. However, Google Inc., Rocket Science Group LLC and Mailgun Technologies, Inc. are certified under the EU-U.S. Privacy Shield, with the result that the transmission is permitted under Article 46 (2) (f) GDPR (through implementing decision (EU) 2016/1250 of the European Commission dated July 12, 2016.) PayPal Inc. has implemented corporate binding rules in accordance with Article 47 GDPR, allowing for the transfer of Information.
If fishwoodco GmbH is involved in a merger, acquisition or asset sale, your Information may be disclosed according to our justified interest (Article 6 (1) (f) GDPR). We will provide a notice before your Information is disclosed for such purpose.
We will disclose your Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
We do not otherwise initiate the disclosure of Information. However, if a User intends to disclose Information e.g. as part of a Sponsored Message, we will follow such User directive and provide the information intended for disclosure in connection with our Service. Thereby we have no influence if the User directs us to disclose Information to jurisdictions not providing for a data protection level adequate to EU data protection standards (e.g. the U.S: or China). Please follow the data protection notices of the relevant providers (streaming platform providers).
You are not subject to any decision based solely on automated processing, including profiling. We do not process specific categories of data. Please do not make any sensitive data available to us.
Data Protection Rights / Withdrawal of Consent
You have the right to access the respective personal data, as well as to correct, delete or limit the processing, and the right to object to the processing of these data. You can access and update certain information by accessing your profile via “Account > Personal Details.” You can also unsubscribe from emails by clicking the “unsubscribe” link they contain.
Please direct any Information requests to firstname.lastname@example.org. Beyond that, you have the right of complaint at a supervisory authority in the European Union.
You may withdraw your consent to process your Personal Information at any time by terminating your account via “Account > Settings”. Withdrawal of consent does not affect the legitimacy of processing that has taken place until we have received your withdrawal. Without a valid consent, you may no longer be able to participate in our electronic communications or receive further information from us, like our newsletters. Despite withdrawal of consent we may continue to process your Information on another legal basis for data processing (e.g. legitimate interest).