Privacy Policy UT 9200 Com App

Preamble

We, Hermann Sewerin GmbH, Robert-Bosch-Straße 3, D-33334 Gütersloh, in our capacity as the operator of the App, are the party responsible for processing the personal data of the App's users. Our contact details can be found in the App's imprint, and the contact persons for questions regarding the processing of personal data are named directly in this privacy policy.

We take the protection of your private sphere and of your private data very seriously. We register, store and use your personal data only in conformity with the contents of this Privacy Policy and the applicable data protection law, in particular of the General Data Protection Regulation (GDPR) and the national data protection regulations.

With this data protection policy, we inform you to what extent and for what purposes personal data is processed in connection with the use of the App.

Personal Data

Personal data are information on an identified or identifiable natural person. This includes all information about your identity, such as your name, e-mail address or postal address. Information that cannot be associated with your identity (such as statistical data on the number of Users of the App, for example), on the other hand, shall not be considered as being personal data.

Basically, you may use our App without disclosing your identity and without providing personal data. We will then only collect general information about the visit to our App. For some of the services offered, however, personal data is collected from you. Subsequently, this data will then only be processed by us for the purposes of using this App, particularly to provide the requested information. When collecting personal data, it is only mandatory to provide the data that is absolutely necessary. In addition, further information may be required, in which case it is voluntary. We point out in each particular case whether the information to be provided is mandatory or voluntary. We will then provide information on the specific details in the relevant section of this Privacy Policy.

Automated decision-making based on your personal data will not take place in connection with the use of our App.

Processing of Personal Data

Your data will be stored by us on specially protected servers within the European Union. These data are protected by technical and organisational measures against loss, destruction, access, modification, or distribution of your data by unauthorised persons. Only a few authorised persons are allowed to get access to your data. These are responsible for the technical, commercial, or editorial support of the servers. However, despite regular checks, complete protection against all hazards is not possible.

Processing of personal data to third parties

As a basic rule, we use your personal data only to provide the services you have requested. To the extent as external service providers are engaged by us within the framework of the provision of services, their access to the data shall also take place exclusively for the purposes of the provision of services. Through technical and organisational measures, we ensure compliance with data protection requirements and also oblige our external service providers to do so.

Furthermore, we will not transfer the data to any third parties without your express consent, in particular not for advertising purposes. Your personal data will only be transferred if you yourself have consented to the data being passed on or if we are entitled or obliged to do so on the basis of statutory provisions and/or official or court orders. This may, in particular, involve the provision of information for the purposes of criminal prosecution, the prevention of danger or the enforcement of intellectual property rights.

To the extent as we should transfer your personal data ourselves or through any service providers to countries outside the European Union, we will comply with the special provisions of Art. 44 et seq. GDPR and will also oblige our service providers to comply with these regulations. We will therefore only transfer your data to countries outside the European Union subject to the level of protection guaranteed by the GDPR. This level of protection is ensured in particular by an adequacy decision of the EU Commission or by appropriate guarantees pursuant to Art. 46 GDPR.

Legal Data for Data Processing

To the extent as we should obtain consent for the processing of your personal data, Art. 6 para. 1 lit. a) GDPR shall be the legal basis for data processing.

To the extent as we should process your personal data because this is necessary for the fulfilment of a contract or agreement, or within the scope of a relationship with you similar to any such contract or agreement, Art. 6 para. 1 lit. b) GDPR shall constitute the legal basis for said data processing.

To the extent as we should obtain consent for the processing of your personal data, Art. 6 para. 1 lit. a) GDPR shall be the legal basis for data processing.

Furthermore, Art. 6 (1) f) DSGVO can be considered as being the legal basis for data processing if the processing of your personal data is necessary to safeguard a legitimate interest of our company or of a third party and your interests, fundamental rights and freedoms do not require the protection of personal data.

In the context of this privacy policy, we will always indicate the legal basis on which we base the processing of your personal data.

Deletion of Data and Period of Data Storage

We always delete or block your personal data as a basic rule when the purpose for storing is no longer applicable. However, storage may take place beyond this if this is provided for by legal requirements to which we are subject, for example about statutory storage and documentation obligations. In any such case, we will delete or block your personal data after the end of the applicable requirements.

Use of our App

Certain information will already be processed automatically as soon as you use the App. The specific personal data processed by ourselves is as follows:

Information raised during the download

When you download our App, certain required information is transmitted to the corresponding app store, in particular Google or Apple. The User’s name, the e-mail address, the customer number of your account, the time of the download, payment information and the individual device identification number can be processed. Processing of this data is carried out exclusively by the corresponding App Store and is beyond our control.

Information that is collected automatically

In the course of your using of the App, we will automatically collect certain data that is required for the use of the App. Particularly, these include: internal device ID, version of your operating system, time of access, location data.

This data is automatically transmitted to us, but is not stored, (1) to provide you with the Service and related features; (2) to improve the features and functionality of the App; and (3) to prevent and remedy misuse and malfunction. This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the person concerned and ourselves pursuant to Art. 6 (1) lit. b) GDPR for the use of the App or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the App and in being able to offer a service that is in line with the market and interests, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) lit. f) GDPR.

Use of the App

The App also requires the following authorizations:

Bluetooth: This is needed so that the App can establish a connection to the tracking device.

Photos and Media: This authorisation is needed to be able to save and send the measurements.

The processing and use of user data is mad to provide the service. This data processing is justified by the fact that the processing is necessary for the fulfilment of the contract between you as the person concerned and ourselves pursuant to Art. 6 (1) lit. b) GDPR for the use of the App and you consent to this by using the function and releasing the camera pursuant to Art. 6 (1) lit. a GDPR.

Your Rights and Contact

We attach much importance to explaining the processing of your personal data as transparently as possible and to informing you about the rights to which you are entitled. If you wish to receive more information or to exercise the rights to which you are entitled, you may contact us at any time so that we can deal with your request.

Rights of Individuals Affected

You have extensive rights about the processing of your personal data. Firstly, you have a comprehensive right to information and, if necessary, you can demand the correction and/or deletion or blocking of your personal data. You may also request a restriction of the processing of data and have the right to object. With respect to the data provided to us by yourself you shall also have a right to data portability.

If you wish to assert any of your rights and / or wish to receive more detailed information about this possibility, please contact our administrators. Alternatively, you may also contact our data protection officer.

Cancellation of the Consent and Objection

Once you have given your consent, you can freely revoke it at any time with effect for the future. Any such revocation of the consent shall not affect the lawfulness of the processing carried out based on the consent until the revocation. The contact persons responsible for this are also our administrators and our data protection officer.

If processing of your personal data is not based on consent but on another legal basis, you can object to this data processing. Your objection will lead to a review and, if necessary, termination of the data processing. You will be informed about the result of the review and - if the data processing is nevertheless to be continued - you will receive more detailed information from us as to why the data processing is permissible.

Data Protection Officer and Contact

We have appointed an internal data protection officer who supports us in data protection issues and whom you can also contact directly. If you have any questions concerning our way of handling of personal data or if you should need further information on data protection issues, please do not hesitate to contact our data protection officer:

datenschutz@sewerin.com

Complaints

If you believe that the processing of your personal data by us is not in accordance with this privacy policy or the applicable data protection regulations, you shall have the right to file a complaint with the supervisory authority. You may also file a complaint with our data protection officer. The Data Protection Officer will then review the issue and inform you about the outcome of the review.

Links to other Websites

Links to other Websites

Our App can contain links to other Websites These links are usually characterized as such. We have no influence on the extent to which the applicable data protection regulations are observed on the linked websites. Therefore, we recommend that you also seek information on the corresponding data protection declarations of other websites.

Amendments to this Privacy Policy

The status of this data protection declaration is indicated by the date (below). We reserve the right to change this data protection policy at any time with effect for the future. A change is made in particular in the event of technical adjustments to the App or changes to the data protection requirements. The current version of the Privacy Policy can always be accessed directly through the App. Therefore, we recommend you to seek information on modifications of this Privacy Policy on a regular basis.

Rev. of this Privacy Policy May 2023