funnelgorithm

Privacy Policy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data on funnelgorithm.com. Preliminary draft, awaiting legal review.

1. Controller

The controller within the meaning of the GDPR is:

Lutz Nahrgang
Wiesenweg 3
8723 Kobenz, Austria
E-mail: datenschutz@funnelgorithm.com

2. What is Funnelgorithm?

Funnelgorithm is a technical infrastructure platform that provides analytics, tracking and account management services in the background for the connected property operators (including morehits4u.com, ptc-wall.com, aidzap.com, mein-ppc.com, unirotator.com).

The domain funnelgorithm.com is not directly used by end users. All end user interactions occur through the respective property (e.g. morehits4u.com), whose own privacy policy you should review before use.

3. Data Processed and Legal Bases

3.1 Server log files

Each time this website is accessed, the following information is automatically stored in the server log:

  • IP address of the requesting device
  • Date and time of the request
  • URL accessed
  • Data volume transferred, HTTP status code
  • User agent (browser type and version)
  • Referrer (previously visited page)

Purpose: ensuring smooth operation, error analysis, IT security.
Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in a secure and functional web service).
Retention: as a rule 14 days, then automatic deletion or anonymisation; longer only in the case of security incidents for the purpose of clarification.

3.2 API access (property operators only)

Connected property operators access our services via an authenticated API (HTTP header X-FG-Key). We log these accesses:

  • ID of the API key used (not the plaintext key itself)
  • Endpoint accessed and HTTP method
  • Response status code and duration
  • Number of records transferred

Purpose: operational monitoring, rate limiting, abuse detection, error analysis.
Legal basis: Art. 6 (1) (b) GDPR (performance of the contract with the property operator) and (f) (legitimate interest in IT security).

3.3 Central user account (data processing on behalf)

Funnelgorithm maintains a central account and balance ledger for users of the connected properties. Depending on the use case we process:

  • a unique internal identifier (UUID)
  • the external user ID passed by the property operator
  • optional: e-mail address, preferred language, time zone
  • balance and transaction history (amounts, timestamps, origin)

The controller of this data is generally the respective property operator (e.g. morehits4u.com) who collected the user's data. Funnelgorithm processes it on their behalf as a processor within the meaning of Art. 28 GDPR. Data subject rights (see section 5) should preferably be exercised against the property operator; we forward requests accordingly.
Legal basis: Art. 6 (1) (b) GDPR (performance of the contract between property operator and user), Art. 28 GDPR (processing on behalf).
Retention: as long as the property operator maintains the user's account; upon deletion by the property operator, the central account is also deleted within 30 days (accounting-relevant data may be retained longer as required by law).

3.4 Tracking and analytics data (data processing on behalf)

When you visit one of the connected properties, the Funnelgorithm tracker script may be loaded there. Depending on the configuration by the property operator, this collects technical characteristics for visitor recognition, session duration and events (e.g. page views, clicks, conversions). Please refer to the privacy policy of the respective property for details.

The controller of the collection is the property operator; Funnelgorithm processes the data on their behalf.
Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in reach measurement and service optimisation) or Art. 6 (1) (a) GDPR (consent), depending on the implementation at the respective property.

4. Recipients, Sharing, Third Countries

Your data is processed exclusively:

  • by us and internal technical systems
  • by our hosting provider Hetzner Online GmbH (based in Germany; servers in the EU) as a processor
  • between Funnelgorithm and the respective connected property, within the framework of the data processing agreement in place between the two

No transfer to third countries outside the EEA takes place at this time.

5. Your Rights as a Data Subject

Under the GDPR you have the following rights:

  • Access to the data processed about you (Art. 15)
  • Rectification of inaccurate data (Art. 16)
  • Erasure of your data, unless a legal retention obligation applies (Art. 17)
  • Restriction of processing (Art. 18)
  • Data portability (Art. 20)
  • Objection to processing, particularly to processing based on legitimate interest (Art. 21)
  • Withdrawal of consent with effect for the future (Art. 7 (3))

For data processed on behalf of a property (account and tracking data), please contact the respective property operator directly; otherwise we will forward your request.

Please direct requests to: datenschutz@funnelgorithm.com

6. Right to Lodge a Complaint with the Supervisory Authority

You have the right to lodge a complaint with the competent data protection supervisory authority. In Austria this is the Austrian Data Protection Authority (Barichgasse 40-42, 1030 Vienna).

7. Cookies

Funnelgorithm.com itself does not set cookies for analytics or marketing purposes. See the Cookie Policy for details.

8. Currency and Changes

We reserve the right to adapt this privacy policy in order to keep it in line with current legal requirements. The version available at the time of your visit applies.

As of: July 2026

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