Data protection

LAST UPDATE: April 2024

This Privacy Notice applies to the websites where it appears.
We take the protection and security of your personal data and compliance with data protection regulations very seriously. Personal data refers to any information relating to an identified or identifiable natural person. In this notice we will inform you about what data we collect and how we use it when you use our website and if you are a member of the Home Tester Club.
This data protection notice applies to the member states of the European Union, the United Kingdom and Switzerland.

1. CONTROLLER
We
The Brand Power Company GmbH
Landsberger Straße 284
80687 Munich
Email: dsb@hometesterclub.com
process your data as the controller.

2. DATA PROTECTION OFFICER
Our data protection officer is Mr Hannes Oenning, to be contacted by post at the above address (“FAO data protection officer”) or email: dsb@hometesterclub.com

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING OF YOUR PERSONAL DATA
We collect, process and use your personal data as described below in this privacy notice and in compliance with the relevant data protection laws.

a) Visit of the Home Tester Club website
If you only visit our website, i.e. if you do not contact us by email or via our contact form, we will only collect the personal data that your browser transfers to our server. If you wish to view our website, i.e. you wish to read product reviews without registering as a member, we will collect the following data, which are technically necessary for us so that we are able to display our website and ensure its stability and security:

IP address
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Respective data quantity transmitted
Website from which the request originates
Browser
Operating system and its interface
Language and version of the browser software

If you choose to communicate with us (e.g. via email or via our contact form), we may collect your email address and your first name and surname, as well as other data that you send us in case of communication, depending on the communication channel.
We use your data only for the purpose for which you have provided us with the data, e.g. to enable you to visit our website or to process your contact request.
To make visiting our website more attractive and to enable the use of certain functions, we also use so-called cookies. For details please refer to our Consent Management Platform which you can access here.
The legal basis for the processing of your personal data in connection with the visit of our website is our legitimate interest. This consists, on the one hand, of maintaining the functionality of our website and, on the other hand, of answering any enquiries you may send to us.

b) Registration as member of the Home Tester Club
If you become a member of our Home Tester Club, the data you provide us during registration and which are required for this purpose (“mandatory fields”) will be collected. This currently includes:

Name
Gender
Month and year of birth
Email address

In order to receive products to test you are required to provide your address. It is not a requirement to provide your address to create a Home Tester Club account. On a voluntary basis, you can provide us with your telephone number during registration.
When setting up your account, you will have to fill in further mandatory information. Examples of these are and further details are provided later in this policy:

Size of your household
Number and age of children
Your approximate annual income, with the option not to disclose

You also have the option, on a voluntary basis, to store a profile picture and create links to your social media accounts (Instagram and Facebook). In this context it is possible that we may receive further information from you.

When you link to your Facebook account, we receive your email address, your name, your date of birth (if you have provided it) and your Facebook user ID.
When you link to your Instagram account, we receive your Instagram user ID, your account name and information about the number of followers you have.

In both cases we will also receive any profile picture that you may have stored on your social media account.
To register you as a member we need your name and a valid email address without which, registration is not possible, as we need an individual email address for each member in order to be able to contact you personally as our contractual partner. In addition, we verify the accuracy of the email address you provided during registration as a member by sending you an email containing a link that you must confirm in order to complete your registration as a member (so-called “double opt-in”).
We require your address in order to be able to send you any product tests.
You must state your age since we only allow adults to become members.
Furthermore, your so-called socio-demographic data such as age, gender, household size, number of children and annual income class are absolutely necessary in order to determine representative participant groups for product tests.
Without specifying the above-mentioned mandatory data, a membership in the Home Tester Club is unfortunately not possible.
If we collect your telephone number in the course of registration, we will use it to clarify by telephone any queries we may have when delivering or submitting your evaluation. We may also use your telephone number to remind you to submit a review after you have participated in a product test.
You can add a profile picture to give your contributions a personal touch.
You can link your Facebook or Instagram account so that we have another channel through which we can communicate with you. For example, it is possible for us to remind you via the news function of your social media account to submit a review after you have participated in a product test. On the other hand, by linking to your social media accounts, we can identify members who are active on social media for our product tests. It also allows us to evaluate our product tests more thoroughly.

c) Application for a product test
If you choose to apply to participate in a product test as a Home Tester Club member, you will usually have to answer additional specific questions. These may be questions about your experience with the test product or similar products or your interests and habits regarding that type of product. These may also include questions about your lifestyle, socio-demographics or consumer behaviour. Depending on the product, we may also need to collect so-called sensitive data in individual cases, e.g. information on your health in connection with the corresponding test product. In this context, you will also be asked to confirm or update your address data.
We use and need this data to find out whether you fit the target group of the respective product test. Without answering these specific questions, you will not be able to successfully qualify for a product test.
For some product tests, the selection of participants is a two-stage process. In the first stage, we check whether you meet mandatory sociodemographic criteria via the answers that you submitted. Once an applicant has provided their voluntary details, an automated check will be carried out, i.e. without any of our Home Tester Club employees looking at the details, to see whether the applicant fulfils the specific requirements.
In the second stage, the final participants are selected for the product test from all applicants who have successfully completed the first stage. Selection, which may be automated, is determined according to a variety of factors, including but not limited to, your activity on Home Tester Club, your previous participation and completion of product tests, your answers to the sociodemographic.

d) Use of the Home Tester Club platform - What we do with information you provide
As a member you will provide a range of data, some containing data from which you could be identified and other data which is still associated with you but you can’t be identified from.
The following table outlines the data you may provide, how this data is used by Home Test Club, by our business partners and our basis for processing,

Registration:

Data provided: You provide a variety of data, including :Name Gender Month and year of birth Email address Size of your household Number and age of children Your approximate annual income, with the option not to disclose
Use by Home Tester Club: To create, manage and maintain your Home Tester Club account. If you have a public profile your first name and your town will be displayed with your reviews that you submit. If you have a private profile, only your first name will be displayed with the reviews that you submit. Your full address will be shown on your personal dashboard and is not displayed with your review or viewable by anyone on the Home Tester Club site. Home Tester Club employees can access this data to manage and maintain your account and for the purposes described below.
Use by our business partners: We may provide your address to our suppliers for the purpose of delivering products to you. In order to facilitate delivery we may also provide your email address. If any other use of your address is proposed we will seek specific consent for use.
Basis for processing: The basis for the processing of your personal data when registering as a Home Tester Club member is your interest in becoming a member of HTC and, after registration, your membership in line with our terms and conditions. The basis for the processing of personal data provided by you on a voluntary basis is the consent, expressed by your entering the data.

Uploading Profile Photo:

Data provided: As part of your Home Tester Club membership you can submit a profile photo, either directly on Home Tester Club or by attaching a social media account to your profile.
Use by Home Tester Club: Your profile photo will be displayed on the site next to written reviews, photo or video uploads you submit, or other activities you may conduct, such as entering a competition,
Use by our business partners: We do not provide your profile photo to our business partners.
Basis for processing: The basis for the processing of your personal data that may exist in your profile photo is your consent, expressed by your uploading of your profile photo or connection of your social media account,

Consideration for a product test:

Data provided: In order to participate in a product test you must register your interest by completing a questionnaire. The questionnaire will vary according to the product being tested but may ask socio-demographic questions to assist in our selection process.
Use by Home Tester Club: Your answers to this questionnaire will not be displayed on the site or available to other members, unless they are aggregated with other users’ responses.
Use by our business partners: The relevant business partners of the product test (eg the company providing the product or service being tested) will be able to view your answers to the questionnaire on an individual anonymised basis and in aggregate. This information will include the socio-demographic and profile data you have provided when you created your Home Tester Club account. Note, your full name, email, telephone, or address will not be shared as part of this processing.
Basis for processing: The basis for the processing of your personal data when applying to participate in one of our product tests is your explicit consent expressed by your registration for the product test. This will allow us to judge whether you are eligible for one of our product tests, i.e. whether you fit the defined target group.

Receiving your product to test & submission of your survey:

Data provided: Upon receiving a product to test, you will be requested to complete a survey following participation in a product test or project: If you take part in our product test surveys following participation in a product test, you will be asked additional general or specific questions, some of which are project-specific, usually about your experience with the tested product. The aim is to cumulate results to the experience with the specific product. Some product tests may request you provide sensitive data to Home Tester Club. This is to ensure the relevance of a product to you. If you are requested to provide Sensitive Data to Home Tester Club a notice will be provided to you in advance of providing that data. You are under no obligation to provide this data to Home Tester Club.
Use by Home Tester Club: Your answers to this questionnaire will not be displayed on this site or available to other members, unless they are aggregated with other users’ responses. We can use the survey results to generate reviews that are published either by ourselves or by our customers in aggregated form (e.g. “85% of 500 testers would recommend the product to others!”). In these cases, your identity will not be disclosed.
Use by our business partners: The relevant business partners of the product test (eg the company providing the product or service being tested) will be able to view your answers to the questionnaire on an anonymised individual basis and in aggregate. This information will include the socio-demographic data you have provided when you created your Home Tester Club account, the answers you provided on application for the product test, and your first name and suburb. Note, your full name, email, telephone, or address will not be shared as part of this processing. As part of registering for a product test you will be notified of the relevant category of our business partner or business partner with whom Home Tester Club is conducting the activity for.
Basis for processing: The basis for the processing of your personal data when participating in one of our product tests is your explicit consent expressed by your registration for the product test.

Completing a survey on Home Tester Club:

Data provided: As a Home Tester Club member, you can also participate in our surveys, which can be general surveys on general or specific topics and projects or product test surveys following participation in a product test or project: If you participate in one of our general surveys, you will be asked additional general or specific questions, for example about your interests and habits, your buying behaviour or your opinion on certain general or specific lifestyle topics. Some product tests may request you provide sensitive data to Home Tester Club. This is to ensure the relevance of a product to you. If you are requested to provide Sensitive Data to Home Tester Club a notice will be provided to you in advance of providing that data. You are under no obligation to provide this data to Home Tester Club .
Use by Home Tester Club: Your individual answers or participation in the survey will not be published. We may use all provided answers in aggregated form and publish them either by ourselves or by our business partners. The surveys will also be used to collect information that enables us to offer certain products to certain people and to get an impression of our community. This allows us to select and approach you for participation in specific projects.
Use by our business partners: The relevant business partners of the product test or the campaign may be able to view your anonymised individual answers to surveys. This information may also include the socio-demographic data you have provided when you created your Home Tester Club account. Note, your full name, email, telephone, or address will not be shared as part of this processing.
Basis for processing: The basis for the processing of your personal data when completing your survey is your explicit consent expressed by the completion of the survey.

Entering a competition on Home Tester Club:

Data provided: As a member, you can participate in competitions we organise from time to time. In this context, you may need to provide additional content, e.g. regarding your opinion or your experience in a product test (e.g. videos). Otherwise, you cannot participate in the competition.
Use by Home Tester Club: Your individual answers or participation in the survey will not be published. We may use all provided answers in aggregated form and publish them either by ourselves or by our business partners. The competitions will also be used to collect information that enables us to offer certain products to certain people and to get an impression of our community. This allows us to select and approach you for participation in specific projects.
Use by our business partners: Any relevant business partners associated with the competition may be able to view your answers to surveys with your first name. This information may also include the socio-demographic data you have provided when you created your Home Tester Club account.
Basis for processing: The basis for the processing of your personal data when entering the competition is our legitimate interests – that is, our interests to understand our members better are balanced with members’ interests to partake in such competitions.

Writing and publishing a review:

Data provided: You can directly submit a review on products on our site, or via a survey completed on our site. Please also note our Terms when providing Content. These specify, among other things, the scope of the rights of use for Content that you transmit to us and release for publication. If you add Content, our Terms will be provided to you as a link, so that you can view them.
Use by Home Tester Club: If you, as a member of the Home Tester Club, submit a review or participate in a product test, the data you submit to us in this context will be collected depending on whether you have chosen a “private profile” or a “public profile”.Private profile If you review a product or participate in a product test and then submit a review and have a “private profile”, the review will be published under your first name only and the date the review was submitted.Public profile If you review a product or participate in a product test and then submit a review and have a “public profile”, the review will be published under your member name and with your city/residence and your profile picture, if you have stored one. A public profile allows other members to see not only your first name, but also your city, your date of joining, all of your published reviews and your profile picture, if you have uploaded one. You can set up your profile to be private or public at any time in your member profile under “My Dashboard” – “Settings” – “Security”. We may use the review and your name and location to promote the Home Tester Club in mediums outside www.hometesterclub.com , including but not limited to social media, online, print or TV advertising and other platforms.
Use by our business partners: The relevant business partners associated with the product will be able to view your written reviews and your first name. This review may also be associated with the socio-demographic data you have provided when you created your Home Tester Club account, and, if relevant the, answers you provided on application for the product test. We may provide to our business partners your written review, first name or nickname and location. We may also provide information on the device you submitted your review on and other technical information for our partners to review the authenticity of your review. The relevant business partners may in turn use your review and the associated information to promote their product and brand, and in turn share that with their business partners. The relevant business partners associated with the product may use this information on mediums such as:Retail websites Brand websites Social media platforms Online advertising Printed advertising materials Advertising & marketing of their products and brands Any processing of personal data by our business partners will be subject to their own privacy policies and we recommend you make yourself familiar with those, where appropriate.
Basis for processing: The basis for the processing of your personal data when participating in one of our product tests is our legitimate interests as part of your membership of the community.

Submitting and publishing a video or photo review:

Data provided: You can directly submit a review on products on our site, or via a survey completed on our site. Please also note our Terms when providing Content. These specify, among other things, the scope of the rights of use for Content that you transmit to us and release for publication. If you add Content, our Terms will be provided to you as a link, so that you can view them.
Use by Home Tester Club: If you, as a member of the Home Tester Club, submit a video or photo, the data you submit to us in this context will be collected depending on whether you have chosen a “private profile” or a “public profile”.Private profile If you submit a video or photo review and have a “private profile”, the content will be published under your first name only and the date the content was submitted.Public profile If you submit a video or photo review and have a “public profile”, the content will be published under your member name and with your city/residence and your profile picture, if you have stored one. A public profile allows other members to see not only your first name, but also your city, your date of joining, all of your published reviews and your profile picture, if you have uploaded one. You can set up your profile to be private or public at any time in your member profile under “My Dashboard” – “Settings” – “Security”. We may use the video or photo content you provide to us to promote the Home Tester Club in mediums outside www.hometesterclub.com , including but not limited to social media, online, print or TV advertising and other platforms. For some healthcare clients we are required to share any information related to an adverse event related to their products. We will therefore analyse the contents of submitted reviews for healthcare related products to identify any reviews that may contain information related to an adverse event.
Use by our business partners: The relevant business partners associated with the product will be able to view your photo or video review and your first name. This photo or video review may also be associated with the socio-demographic data you have provided when you created your Home Tester Club account, and, if relevant, the answers you provided on application for the product test. We may provide to the relevant business partners your photo or video review, first name or nickname and location. We will obtain your consent for this when you upload a photo or video to our site. We may also provide information on the device you submitted your review on and other technical information for our partners to review the authenticity of your review. Our business partners may in turn use your photo or video review and the associated information to promote their product and brand, and in turn share that with their business partners. The relevant business partners will use this information on mediums such as:Retail websites Brand websites Social media platforms Online advertising Printed advertising materials Advertising & marketing of their products and brands Any processing of personal data by our business partners will be subject to their own privacy policies and we recommend you make yourself familiar with those, where appropriate. If we identify information related to an adverse event, we will disclose your anonymous review to the relevant business partner who is linked to the product. If our business partner wants to investigate the adverse event report further, we may share your contact details with them so they can contact you directly to gather more details.
Basis for processing: The basis for the processing of your personal data when submitting a video or photo review is your explicit consent expressed by your submission of the content.

Use of campaign hashtags:

Data provided: Regardless of whether your social media profiles have been linked or not, you can still use so-called “campaign hashtags”. By using the campaign hashtag, you agree that such posts can be shared.
Use by Home Tester Club: If you do use a campaign hashtag, we will be alerted to your post and can repost it on our website or our social media channels. Depending on the content of your post, your identity may be disclosed, for example, if you use your real name as the name of your social media profile, or if you are visible in your post yourself.
Use by our business partners: Our customers may do the same as the treatment by Home Tester Club. Depending on the content of your post, your identity may be disclosed, for example, if you use your real name as the name of your social media profile, or if you are visible in your post yourself.
Basis for processing: The basis for the processing of your personal data when using the Home Tester Club is your consent given through the platform which you have posted with the campaign hashtags

Use of the “hometesterclub” hashtag:

Data provided: If you use the “hometesterclub” hashtag, your posts can be published automatically on our website, if you have a public profile. By adding the “hometesterclub” (or local market derivatives of), hashtag, you agree that such posts can be used.
Use by Home Tester Club: If you do use the relevant hometesterclub hashtag, we will be alerted to your post and can repost it on our website or our social media channels. Depending on the content of your post, your identity may be disclosed, for example, if you use your real name as the name of your social media profile, or if you are visible in your post yourself.
Use by our business partners: Our business partners are not permitted to use
Basis for processing: The basis for the processing of your personal data when using the Home Tester Club is your consent given through the platform which you have posted with the campaign hashtags.,

4. TRANSFER OF DATA TO THIRD PARTIES
Your data will of course be treated confidentially. If necessary, we use service providers who are strictly bound by instructions to support us, e.g. with logistics and fulfilment (i.e. dispatch of products for product testing), EDP or the archiving and destruction of documents, and with whom separate contracts for data processing have been concluded in order to guarantee the secure and legally compliant handling of your data. In this context, service providers are only granted access to your personal data to the extent necessary to provide the respective service. Your data will not be transferred to third parties unless we are legally obliged to do so (e.g. in the event of an inquiry from an authority or court), or we have a legal basis for doing so as outlined in the table above or you have given us your consent to do so in individual cases.

5. TRANSFER TO A THIRD COUNTRY
We may exchange information and personal data within the The Brand Power Company, i.e. in a so-called third-country transfer. We have adopted so-called EU standard contractual clauses in order to ensure an adequate level of data protection in accordance with the provisions of the General Data Protection Regulation (GDPR). Transfer of data is subject to appropriate security measures, including encryption.

6. RETENTION PERIOD
Your data will be stored as long as they are necessary for the fulfilment of the purpose for which they were collected, and no legal retention obligations oppose their erasure.
Your data as a Home Tester Club member will be stored as long as your member profile exists or the post you have commented, reviewed or published is available on the platform. You can cancel your membership in the Home Tester Club at any time by deleting your account in your member profile under “My Dashboard” – “Settings” – “Security”.
If you are requested to provide Sensitive Data to Home Tester Club a notice will be provided to you in advance of providing that data. You are under no obligation to provide this data to Home Tester Club. Sensitive Data that you have provided will be stored for a period of six months.
If you have entered data after registration when using the platform, the data will remain stored for as long as your Home Tester Club account exists. Of course, you can anonymise your posts (e.g. photos, videos, reviews) at any time in your member profile under “My Dashboard” – “My Uploads” or “My Dashboard” – “My Reviews”, or you can delete your account. All personal data related to your account will be truncated. Furthermore, your first name or nickname will be used in connection with your posts – your first name or nickname will not disclose your identity after your other membership data have been erased.

7. YOUR RIGHTS
With regard to your personal data, you have the following rights towards us:

Right of access,
Right of rectification or erasure,
Right to restriction of processing,
Right to object to the processing, insofar as we process your data due to legitimate interests
Right to data portability

You also have the right to withdraw any consent you may have given to the processing of your personal data with effect for the future, without affecting the lawfulness of processing based on consent before its withdrawal. If you are affected by automated processing based on your express consent by disclosure of your data, you have the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.
Furthermore, you have the right to lodge a complaint with a data protection supervisory authority in the member state of your habitual residence, place of work or place of the alleged infringement about the processing of your personal data by us.
In order to exercise the above rights and for further questions on the subject of data protection, please refer to the contact data mentioned under Section 1 or contact our data protection officer.

8. SECURITY
We have taken various technical and organisational measures to ensure that the data collected and processed by us is protected against unauthorised access, loss, destruction and manipulation. It goes without saying that legal requirements for data protection are observed. However, we would like to point out that no data transfer over the Internet is one hundred percent secure.

9. LINKS TO OTHER WEBSITES
For your convenience, this website may contain links to other websites. This privacy policy does not apply to those other websites. We recommend that you read the respective data protection notices to obtain information on data collection and data processing.

10. UPDATES
We reserve the right to change or adapt this privacy policy. We therefore ask you to check it occasionally to ensure that you know the latest version whenever you access the website.

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