tagm.tchibo.de
Weighted across nine legal categories. Lower is worse.
Executive summary
This document is a privacy policy for Exactag GmbH, a third-party analytics and advertising tracking service deployed across numerous European retail and media websites. It provides strong GDPR-compliant transparency regarding data collection purposes, legal bases, and retention periods, but lacks traditional terms of service elements like account management, liability limitations, or dispute resolution clauses. Consumers should review the linked consent banners on individual client sites to exercise granular control over their tracking preferences.
Category breakdown
7 of the nine categories are not addressed by this document, so they are left out rather than scored.
Acceptance of Terms & Scope
Contract formation and service boundaries
The document does not use traditional clickwrap acceptance but relies on GDPR/TTDSG consent mechanisms and the IAB Transparency & Consent Framework. Scope is narrowly defined to reach measurement and cost optimization on behalf of client websites.
Key findings
- Relies on IAB TCF Vendor ID 312 for consent management
- Distinguishes between consent-based user-level and anonymous group-level collection
- No explicit 'I agree' button or browsewrap language described
Evidence from the document
Data collection is carried out in two fundamentally different ways and on two different legal bases: a. User-level Data Collection If the user has given his or her consent in accordance with Art. 6(1)(1) lit. a of the GDPR...
Recommendations
- Add a clear statement that continued browsing constitutes acceptance of the privacy policy where applicable, or provide a direct link to a full Terms of Service if one exists separately.
Data Privacy
Data collection, usage, and protection
Highly transparent regarding GDPR/TTDSG compliance, IAB TCF integration, specific data points collected, and clear retention schedules. Provides functional opt-out mechanisms but retains cross-device and journey data for up to 36 months.
Key findings
- Explicit legal bases cited (GDPR Art 6, TTDSG §25)
- Granular purpose limits aligned with IAB Europe standards
- Clear retention caps and functional opt-out cookie/link provided
Evidence from the document
Journey information... Maximum 36 months from collection;
To ensure exclusion from user-level data collection, a cookie can be set in your browser as an alternative to missing consent in the privacy settings.
Recommendations
- Shorten the maximum journey information retention period to align with data minimization principles, and clarify how users can request deletion of cross-device links.
Ex-TerCo provides automated analysis of legal documents for informational purposes. This is not legal advice. Terms can change at any time.