Carrer Fraternitat 35
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would like to elucidate which data is absolutely necessary to work together and which voluntarily shared
data will enable you to get extra benefits. Your data is only asked for and saved, when you explicitly
have given your consent.
We will send you a mail if changes in the dataprotection terms occur. In case you do not agree with the
latest version you have the possibility to withdraw your acceptance.
1. Personal information that we need to deliver our services
In case you wish to use the services of Karma Response just as a mere source of information
without any registration, we will not need any personal data whatsoever from you. In case you want to
receive any specific service you would have to register. As a standard part of the registration we will
ask you the following information: your name, email address, your address and company.
2. Use of your necessary data
First and foremost we use your personal data to provide you with the applications and services rendered
by Karma Response. Once you have explicitly agreed to it, your personal data will only be
saved and used by Karma Response or by authorized partners of Karma Response.
Karma Response logs your permission to collect, save and use the data. In case the
rendering of services is tempory Karma Response will erase your data at the end of the
3. Collection and use of personal data
Personal data is only store, when you provide us with this information in order to e.g. draw a contract
with us, run an auction or want to register for personalized services. As part of rendering of
personalized services your registration data is used for publicity and market research purposes as well
as shared with third parties – granted we have your approval. We will inform you separately which third
parties we share your information with. This sharing also needs your explicit approval.
4. Extended data collection, storage and use
Once you give permission to Karma Response to obtain and store additional personal data in
order to give a personalized service, the company will store data not exceeding the absolutely necessary
minimum according to the service demanded and will use it accordingly. Some of the services offered by
Karma Response are realized with the help of partners. In order to work effectively it is
necessary to share your data with these partners in an anonymous form. This data is solely used by our
partners to go through with the rendering of the service. We will inform you if any other company other
than Karma Response stores or administers your data.
5. Type of data analysis
Karma Response analyses the behavior of its users. Karma Response may do this
by themselves or third parties. These analysis are made in order to permanently upgrade the services to
the client. All analyses will be carried out with anonymized data. No personal data will be used. We do
not hand on personal data to the advertisers such as who, when and where a user clicked on an offer.
If however you do not grant your consent to individual services , we may not be able to provide you with
the applications or services you have selected. To which applications and services this applies, you
will hear in separate form for each of the particular services. We point out that the use of our
services and applications can also be found with other providers and you have the opportunity to engage
Karma Response uses so called cookies. A cookie is a small piece of text data, that your
web-browser files in your temporary internet files, in order for a supplier to realize an offer over the
user function. Of course you got the option to block this cookie. Should you choose to deactivate this
cookie, you will not be able to use many of the functions from Karma Response
8. Use of Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”) Google
Analytics uses so called “cookies”, text files that are stored on your computer and which enable an
analysis of your use behavior on the website. The information generated by the cookie regarding your use
of the website (including your IP address) is transmitted and stored to a Google server in the USA.
Google will use this information to evaluate your use of the website, to compile reports on website
activity for website operators and to provide others with website and internet related services. Google
may also transfer this information to third parties within legal boundaries or where such third parties
process the information on Google’s behalf. Google will not associate your IP address with any other
browser, but we point out that you may not be able to use all features of this website in this case. By
using this site, you agree to the processing of data about you by Google in the manner described above
and for the aforementioned purpose.
9. Delete personal data
You have the rights to always revoke your consent to storage of your personal data in writing or
electronically. Furthermore, you can always revoke your consent to the collection and storage of other
voluntary data by Karma Response. Our postal address: Carrer Fraternitat 35, Planta Baja, 08012
Barcelona, Spain. Alternatively you can send us an email: firstname.lastname@example.org.
10. Data security
All Karma Response employees, who handle personal data, signed a non-disclosure agreement
compliant to the §5 of the Federal Law of Data-Security at the beginning of their time working for Karma
Response. The company Karma Response furthermore has implemented technical and
organizational security measures to prevent manipulation, destruction or loss of personal data.
11. Information about stored personal data
According to § § 19 and 34 BDSG (Federal Data Protection Act) we would be happy to give you free of
charge and in written form information about your stored personal data. Please use for your information
request, the prepared information request form.
Please be aware of when you fill in, by choice, personal information online (for example in chats or in
e-mail), there is always a risk that this information might be used by third parties. Which means you
might obtain news from undesired sources. Buying online, be cautious when filling in password and/or
1. For contracts between the Karma Response and
their customers, these terms and conditions apply exclusively. Terms and conditions of the customer are
hereby contradicted. Karma Response shall not recognize any conflicting or deviating conditions
of the customer, unless Karma Response has expressly agreed to them in writing.
2. These General Terms and Conditions apply to all contractual relationships, including all future
3. Karma Response is entitled to change these terms and conditions with effect for the future
business relationship with the customer after notification. The change will be considered approved if
the customer has not submitted a written objection to Karma Response within two weeks of
notification of the change. Karma Response will point this out in the announcement.
4. Karma Response markets online advertising on websites on the Internet or via e-mail marketing
through its network. Karma Response enables the entire process of planning, placing and
monitoring online advertising on online advertising space.
§2 offer & contract
1. Offers by Karma Response are always non-binding and subject to change.
2. Orders of the customer are binding. Karma Response may accept this within two weeks of
receipt, either in writing by an order confirmation, verbally or by commencement of performance.
3. Karma Response reserves the right to refuse orders without giving any reason or cancel
current campaigns. In the case of a rejection of an order or the termination of a campaign, the customer
has no claims for damages or any other claims against Karma Response.
4. Karma Response is entitled to make the delivery or delivery of advertising material dependent
on an advance payment and, if applicable, the settlement of outstanding invoices.
5. Unless otherwise agreed, no cancellation is possible for already booked campaigns.
6. Karma Response receives a commission from the customer for its services. The commission may
be based on the following remuneration models: a. Commission CPM: The customer pays Karma Response
a pre-determined amount per insertion or per e-mail of a promotional item that belongs to the
customer's campaign. In orders, the commission is stated in CPM (per 1,000 impressions).
b. Provision CPC: The customer pays Karma Response a pre-determined amount per click of a
visitor to a promotional material of the campaign from the customer.
c. Commission CPL / CPA: The customer pays Karma Response a pre-determined amount per user
action. Before concluding a contract with Karma Response, the customer determines what action a
visitor must take to ensure that the lead can be accepted as valid. An action may be e.g. enrolling in
the customer's newsletter, downloading software, completing and submitting a survey, or doing something
d. Commission CPO: The customer pays Karma Response a predetermined percentage of the revenue
generated by Karma Response. This is always the case when a visitor recruited by Karma Response
makes a purchase on the customer's website. The Karma Response commission is
then calculated according to the specified percentage of the net order value of the recruited customer.
e. Commission Fixed Price: The customer pays Karma Response a pre-determined fixed price.
f. There are also combinations of commission models possible. A subsequent change in the commission
amount is only possible by separate agreement between the customer and Karma Response in
individual cases and requires the written consent of Karma Response.
G. Commission type, amount of commission (price) and other conditions are listed in the offer.
§3 Carrying out the campaign
1. Karma Response takes over the delivery and distribution of the advertising material for all
campaigns alone and independently. Karma Response will deliver the advertising in its sole
discretion or may discontinue advertising and campaigns if they fail to achieve the desired result.
§4 Lead and Sale campaigns
1. When placing lead and sale campaigns, it is necessary to include a specific tracking code in the
customer's website. The tracking code must be installed in place of the website, from which the user
action is deemed to have been carried out.
2. The tracking code will be sent to the customer via e-mail and must not be changed. Furthermore, it is
not permitted to display the code only partially and in certain circumstances not to display it.
3. For the duration of the campaign and for 30 days beyond this, the customer must implement the named
code properly in his website and not remove it before this deadline. This is necessary for the sake of
4. Unless otherwise agreed in the offer, all leads or sales counted by Karma Response through
the tracking code are considered valid and must be provisioned. If the offer has been agreed that the
customer is entitled to validate the leads and sales, all invalid leads and sales must be canceled by
the 5th of the following month at the latest. Cancellations can only be made on the basis of OrderIDs
and only with a reason for cancellation. Karma Response must approve the conditions on when a
lead or sales is canceled before the campaign begins. If the leads are not canceled after expiration of
the deadline or if the reason for the cancellation is not comprehensible, the lead or sale is valid and
must be provisioned.
5. In the event of culpable violation of the provisions of §4 by the customer, he shall forfeit a
contractual penalty pursuant to §6 (6).
1. Relevant for the billing of the advertising measures are the systems of Karma Response.
2. Karma Response is entitled to invoice its compensation immediately after the conclusion of
the contract and to begin payment after receipt of the service.
3. Should Karma Response begin to perform without prior invoicing, Karma Response may
at any time submit an invoice for all or part of the performance and, if applicable, for the part to be
4. Unless otherwise agreed in the offer, the payment deadline is net, net 14 days.
§6 Warranty and liability, contractual penalty
1. Karma Response will operate within the scope of its technical capabilities. An assurance of
any kind cannot be given.
2. Karma Response is liable for damages by Karma Response or its legal representatives
or vicarious agents against contractual agreements or stipulations in these Terms and Conditions only in
cases of intent or gross negligence. This does not affect the liability of Karma Response for
damages resulting from injury to life, limb or health.
3. The liability of Karma Response is in each case limited in amount to the amount that is
measured for the period of the breach of contract according to the average monthly commissions of
customers within the last 6 months, as far as the damage does not result from the breach of essential
4. Karma Response assumes no liability for the websites marketed by Karma Response or
the advertisements switched by Karma Response. For the contents of the web pages the operator
of the respective website is alone responsible. For the contents of the advertisement the respective
customer is exclusively responsible. The fact that the mediation, switching and billing by Karma
does not give rise to any claims - even third parties - against Karma Response
or legal liabilities of Karma Response towards third parties.
5. The customer indemnifies Karma Response from any claims of third parties arising from
advertising through violations of copyright law, the law against unfair competition, the trademark law,
other fair competition and property laws or other protective regulations and applicable law asserted to
Karma Response. The customer will reimburse Karma Response for all damages and costs
(including reasonable legal costs).
6. If the customer culpably violates §4 of these General Terms and Conditions, a contractual penalty in
the amount of EUR 10,000, - per violation is agreed. The contractual penalty will not count towards any
damage suffered by Karma Response as a result of the breach of contract.
§7 Final provisions
1. Verbal collateral agreements are not met. Changes, additions and additions are only valid if they are
agreed in writing between the parties.
2. Should a provision of these Terms and Conditions be or become ineffective, this shall not affect the
validity of the Terms and Conditions otherwise. The parties are obliged to replace the ineffective
provision by an effective provision that comes closest to the economic purpose of the invalid provision.
The same applies in the case of an oversight.
3. For all claims, the place of jurisdiction is London. English law applies.
This translation is only to facilitate the understanding of the document, but has no legal value in a