Cookie Policy

Cookie Policy of Smart Agent GmbH (hereinafter „Smart Agent“, "us" or "we") for the websites and including all its subpages (hereinafter collectively referred to as the "Website") valid as of 01 June 2023.

An important piece of information to note initially:

You can, at any time in whole or part, revoke your consent as well as any other settings you set when visiting our Website and all its associated subpages via the consent management platform (hereinafter referred to as the "CMP Tool").

I. What data does Smart Agent process when I use the Website?

You may use the website or and all its associated subpages (hereinafter referred to as the "Website") without registering or actively providing personal data. Please refer to our data protection policy, or the data protection policies of the company web presences of our respective licence partners for further information.

In the event of a visit to the Website, we or our licence partners collect data about the end device you are using and your usage behaviour on our online services. This data is limited and cannot be assigned to an individual by us or our licence partners. This includes the following data when calling up a website:

  • Personal data transmitted by the user's internet browser each time they access the Website and stored as part of log files, also known as server log files. This data includes: the IP address (Internet Protocol address) of the accessing computer; the name of the accessed page; date and time of access; URL from which the user accesses the page; the volume of data transferred; status message for successful access; session ID number; 
  • Personal data in the form of location data (GPS data, so-called "Locate Me" function), which is transmitted by your Internet browser each time you have activated this setting on the browser by default or application-based.

II. Use of cookies and other tracking technologies

1. What are Cookies?

Like all other commercial websites, our Website also uses so-called cookies and other tracking technologies (hereinafter collectively referred to as "Cookies").

Cookies are small text files that are stored locally in the memory or on the hard drive of your computer or mobile device (hereinafter referred to as "end device"). Cookies fulfil various functions and can process data for many different purposes. Once the Cookies have been saved and the corresponding website is called up again, the user's browser sends back the content of the cookies and thus enables the recognition of the user on that particular website. Third-party technologies such as scripts, pixels and tags integrated by Smart Agent for advertising purposes may also set cookies on your end device. Certain cookies are automatically deleted at the end of the browser session (so-called session cookies), others are stored in the user's browser for a specified period of time and then delete themselves automatically (so-called temporary cookies). Others may be stored cookies permanently on the end device (permanent cookies). Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie by which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the visited Internet pages to distinguish the user's browser from other Internet browsers. Cookies cannot, in principle, identify you individually but rather enables the identification of your end device.

a. Types of Cookies

We make use of several different types of Cookies:

(i) So-called technically essential Cookies

Firstly, we use technically essential cookies to operate the Website. Technically essential Cookies are necessary for the functionality of the Website, without them the Website would not be operable or would only be operable to a limited extent. The user data collected through technically essential cookies are not used to create user profiles. This also includes temporary cookies (session cookies). These cookies do not collect any data from your computer and are automatically deleted as soon as you close your browser. 

Technically essential Cookies are also used by our Consent Management Platform hereinafter the "CMP Tool") to obtain your consent for the setting of cookies and the use of other tracking technologies.

Technically essential cookies are "essential" cookies in the context of the ePrivacy Directive 2002/58 EC and do not require consent. For the scope of application of the Federal Republic of Germany, the legal basis for their use is § 25 II TTDSG. If personal data is processed in this context, the legal basis is Art. 6 para. 1 p. 1 lit. f GDPR (legitimate interest).

(ii) So-called non-essential Cookies

Furthermore, some cookies have no technical necessity. Such cookies serve very different purposes, such as optimising the Website, creating user profiles and displaying interest-based advertising. As a general rule, it can be said that they are for analysis or marketing purposes.

If we use any of these cookies for analysis or marketing purposes, we process your data based on your consent pursuant to Art. 6 (1) sentence 1 lit. a) GDPR. This consent is given by you through the CMP Tool. Alternatively, Art. 6(1) sentence 1 lit. f) GDPR (legitimate interest) may also be the legal basis for such cookies for analysis or marketing purposes. Please refer to our CMP Tool for further details. Here we have listed in detail for which purposes we use Cookies for analysis or marketing purposes and the legal basis thereof. Further clarification can also be found below.

b. Managing Cookies in our CMP Tool

What Cookies are used when using the Website, if applicable by which service provider/partner (“vendors”) they are supplied, which of your data is processed in the process and whether you wish to consent to this, can be determined through the CMP Tool. The CMP Tool also includes further information about the cookies and tracking technologies used.

To enable you to make an informed decision, we use a cookie consent management procedure (the CMP Tool described above), which obtains your consent to the use of cookies, associated processing as disclosed within the procedure and respective vendors. This consent can be managed by you and if you wish, can also be revoked. The declaration of consent is stored to avoid a repeat request for consent and to be able to prove your consent in accordance with the obligatory legal requirements. The storage can take place on the associated server and/or in the form of a cookie (“opt-in cookie”) or with the help of comparable technologies, to be able to assign the consent to a user or their end device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to 12 months. A pseudonymous identifier of the user is created and together with the time of consent and information on the scope of consent (e.g. which categories of cookies and/or service providers) saved.

The CMP Tool enables you to filter and provide an overview of the various cookies, trackers and analysis tools and, if applicable, the vendors used by us. Furthermore, it enables you to select them according to their processing purpose and, if desired, to deactivate them generally or individually. However, you cannot deactivate technically essential cookies, trackers and analysis tools for the reasons described above.

As previously stated, you can use the Website free of cookies and other tracking mechanisms that are not technically essential, both from the outset and also subsequently. In this case, only the technically essential cookies, trackers and analysis tools that are necessary for the operability of the Website will remain.

Note on consent: Some of the services listed in the CMP Tool are set by our vendors or we transmit your data to these vendors. You can find more details in our CMP Tool.

Note on consent: Some of the services listed in the CMP Tool transmit data to the USA. The data processing and the protection of your data in the USA do not meet GDPR standards. The services/vendors are subject to US law and may therefore be required to hand over data to US authorities or US secret services. In particular, risks for you include the difficulty of asserting your rights, the lack of control over the further processing or transfer of your data and the aforementioned access by state authorities. You can also find more details in our CMP Tool.

To manage your cookie settings/opposition in this regard, please click on "Manage Cookie Settings" (accessible via the menu item at the bottom of the Website).

c. Management of Cookies via your browser

You can also deactivate the storage of cookies via your browser settings and delete already stored cookies in your browser at any time. However, please note that the Website or the online features may not function or may only function to a limited extent without cookies. We also recommend that you visit the website of, where you can obtain information and assistance in connection with web tracking mechanisms. A central objection option for various tools, in particular from US providers, is also available under the following link:

2. Summary of the purposes for which we set Cookies or also process personal data in the context of web tracking

a. For the provision of individual offers of our services or the services of our licence partners

If you have consented in accordance with Art. 6 (1) a of the GDPR, we may set cookies and/or process personal data such as your IP address or we may use unique identifiers (a unique identifier, or UID for short, is a unique identifier consisting of codes in the form of strings of numbers and letters) to inform you about our services. In doing so, we also take into account your preferences resulting from your usage behaviour on our Website.

In our CMP Tool you will find these Cookies under the following headings:

  • Select personalised ads
  • Select personalised content
  • Storage and access to geolocation information for targeted advertising purposes

b. Usage profiles based on statistical analysis for the needs-based design of the Website

We need statistical information about the use of the online services on the Website to make the Website or its contents more user-friendly and to conduct market research or a reach analysis. For this purpose, we use web analysis tools ("Tools"). Usage profiles are created with the help of analysis cookies or by evaluating your log files. The providers of these Tools process your data as processors in accordance with our instructions and not for their own purposes. The Tools either do not use the IP addresses of users at all or shorten them immediately after collection.

The legal basis may be your consent (if we process your personal data, the legal basis is Art. 6 para. 1 a) GDPR; if we use Cookies and do not process personal data, the legal basis is the ePrivacy Directive 2002/58 EC or, in the area of application of the Federal Republic of Germany, Section 25 II TTDSG). In addition, Smart Agent may also have an overriding legitimate interest in the design of the Website in line with demand and user habits and the statistical evaluation of the Website. The legal basis for data processing is then Art. 6 para. 1 f) GDPR.

For the aforementioned purposes, we use both our Cookies as well as Cookies of third-party providers on our Website and associated subpages, which are transmitted to your computer via your web browser. They enable our systems to distinguish your browser from others. On the one hand, we send so-called persistent cookies and on the other hand, we use so-called session cookies, with the help of which you receive a session ID for the duration of a visit to our pages, which enables us to distinguish you from other visitors to the Website.

In our CMP Tool you will find these Cookies under the following headings: 

  • Store and/or access information on a device
  • Measure content performance
  • Develop and improve products
  • Apply market research to generate audience insights
  • Measure ad performance
  • Selection of basic ads
  • Use precise geolocation data
  • Actively scan device characteristics for identification

You will also find the partners with whom we are cooperating in alphabetical order in our CMP Tool.

Some of the services listed in the CMP tool transmit data to the USA. The data processing and the protection of your data in the USA do not meet GDPR standards. The services are subject to US law and may therefore be required to hand over data to US authorities or US secret services. In particular, risks for you include the difficulty of asserting your rights, the lack of control over the further processing or transfer of your data and the aforementioned access by government agencies. Some providers, such as Google, may also process data for their own purposes. In these cases, data processing is based on your consent, cf. Art. 6 I lit. a GDPR.

You can also find more details in our CMP Tool (accessible via the menu item "Manage cookie settings" at the bottom of the Website).

3. Linking to social media pages

Our Website partly contains links to the most frequently used social media network sites (e.g. Facebook and X/Twitter). In this respect, it is not a matter of embedding social media plug-ins, but rather a linking in which personal data is not transmitted to the social media operators.

III. Disclosure of your personal data and transfer to non-EEA countries, if applicable

Please refer to the information within our CMP Tool to see to what extent we share personal data with our partners and whether these partners are based in non-EU countries.

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection.

Copies of the adequate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.

IV. Storage and deletion of data

Smart Agent will retain your personal data for the time necessary to achieve the purposes for which data is collected, including any retention period required by the applicable law (e.g. retention of accounting records). Please refer to our CMP Tool for further details on the storage period.

V. Privacy Policy

Our data protection information includes details of our responsibilities, our contact details and your rights within the scope of data processing.