PRIVACY STATEMENT
VASCULAR VARIANTS (V.V.) APP
Privacy and Data protection is very important to us and we want you to feel secure when using our app.
Below we inform you in detail about the type, scope and purpose of the personal data collected, used and processed by us and clarify your rights as a data subject. We reserve the right to change the privacy statement at any time with effect for the future.
1. Name and address of the Controller
The Controller in terms of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:
53 N Studios UG (haftungsbeschränkt)
Diedrich-Speckmann-Weg 2
21682 Stade I Germany
tel: (+49)-1573-1412489
mail: info@53nstudios.com
2. Access data in server log files
If you use the search function of our app, access data is automatically stored in so-called server log files. This includes the date and time of the retrieval and, if applicable, the search term entered.
The temporary storage of the IP address by the system is necessary to enable the provision of the app and its contents to your end device. For this purpose, your IP address must remain stored for the duration of the session.
The legal basis for the temporary storage of your data and log files is Art. 6 para. 1 lit. b GDPR. This data is evaluated exclusively to ensure the permanent and trouble-free operation of the app and to improve the content of our app. An evaluation of your personal data for marketing purposes does not take place in this context.
The collection of data for the provision of the app and the storage of data in log files is necessary for the operation of our app. Consequently, there is no possibility of objection.
3. Use of cookies
In order to make the use of our app attractive and to enable the use of certain functions, we use so-called "cookies". These are small text files which are stored on your end device.
Cookies can contain a so-called cookie ID. It consists of a string of characters by which apps and servers can be assigned to a specific browser in which the respective cookie was stored.
The following data is stored and transmitted in the cookies: Language settings, search terms entered, frequency of page views, use of app functions, origin of the user, operating system used, terminal device used, browser used, resolution of the terminal device.
Your data collected on our app will be anonymized by technical precautions. Therefore, it is no longer possible to assign the data to you. The data will not be stored together with other personal data.
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. a GDPR.
The purpose of using technically necessary cookies is to simplify the use of our app for you (e.g. your settings are saved). The functions of our app cannot be provided without the use of cookies. This is necessary because we need to be able to verify that you have agreed to our App Terms of Use. Therefore, it is important that you are recognized as an app user in anonymous form. If cookies are not accepted or deactivated, the functionality of our app may be limited.
4. Google Firebase
To provide our app, we use the technology of Google Firebase, a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (hereinafter referred to as "Firebase"). Firebase is part of the Google Cloud platform and offers numerous services for developers. A list can be found here: https://firebase.google.com/terms/. Firebase is a real-time database that can be used to embed real-time information in apps. The user data is transferred anonymously to Firebase in order to use the database.
Some Firebase services process personal data. In most cases, the personal data is limited to so-called "instance IDs", which are time-stamped. These "instance IDs" assigned by Firebase are unique and thus allow different events or processes to be linked. This data does not constitute personally identifiable information for us, nor do we make any efforts to subsequently personalize it. We process this aggregated data to analyze and optimize usage patterns, especially to expand our database for unsuccessful searches or to evaluate crash reports.
The data is processed on the basis of Art. 6 Para. S. 1 lit. b GDPR, as the functions can only be guaranteed via Firebase.
The data processed by Firebase can be processed via servers outside Europe, e.g. from the USA. However, Firebase has voluntarily certified itself as a Google service under the US-EU data protection agreement "Privacy Shield" and has thus undertaken to comply with EU data protection regulations.: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI. Further information on data protection in connection with Google Firebase can be found at: https://www.firebase.com/terms/privacy-policy.html. Finally, we have concluded a contract with Google for order data processing in accordance with Art. 28 GDPR. In this contract, Google undertakes to protect the data of our users, to process it on our behalf in accordance with their data protection regulations and, in particular, not to pass it on to third parties.
For Firebase Analytics, Google uses the advertising ID of the end device in addition to the "instance ID" described above. In the device settings of your mobile device, you can restrict the use of the advertising ID by changing your menu settings as follows:
- For Android: Setting → Google → Ads → Reset Advertising ID
- For iOS: Settings → Privacy → Advertising → Restrict ad tracking
5. Google Analytics
We also use the analysis tool Google Analytics, a service of Google Inc. 1600, Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as "Google"). The information generated about your use of our app will generally be transmitted to and stored by Google on servers in the United States. In terms of the GDPR the USA is an insecure third country. Google is certified according to the so-called "Privacy Shield" (see above).
The legal basis for the processing of personal data is Art. 6 para. 1 lit. f GDPR.
Google Analytics uses methods that allow an analysis of the use of the app by you, in particular whether search queries were transmitted that did not yield any results.
We have activated IP anonymisation, which shortens the IP address prior to transmission within the Member States of the European Union or in other Contracting States to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. The anonymous IP address transmitted by your device as part of Google Analytics is not merged with other Google data.
Google will use this information on our behalf to evaluate the use of our app by users and to compile reports on search activities (e.g. if a term was not found) within this app.
These purposes also include our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Pseudonymous user profiles can be created from the processed data.
You can prevent the collection by Google of the data generated by the cookie and related to your use of our app (including your IP address) and the processing of this data by Google by proceeding as follows:
- For Android: On the search page of the app, click on the 3 points menu (⋮) → Manage Privacy Settings → Deactivate
- For iOS: On the search page of the app, click the + button → Manage Privacy Settings → Deactivate
The terms of use and privacy policy of Google and Google Analytics can be found here
https://www.google.de/policies/privacy/ or http://www.google.com/analytics/terms/.
6. Data security
We secure our app and other systems by numerous technical and organizational measures against loss, destruction, access, alteration or distribution of your data by unauthorized persons. Despite regular checks, however, complete protection against all dangers is not possible and cannot be provided by us. For this reason, you are free to transmit your personal data to us at any time by other means, for example by telephone or post.
7. Data Deletion and storage
Your personal data will be deleted or blocked as soon as the purpose of storage no longer applies or you withdraw your consent. In addition, your personal data may be stored if the European or national legislator has provided for this in EU ordinances, laws or other regulations to which the controller is subject. If the storage purpose ceases to apply, if you revoke your consent or if a storage period prescribed by the European directive and regulation giver or another competent legislator expires, the personal data will be blocked or deleted routinely and in accordance with the statutory provisions, unless there is a necessity for further storage of the data for the conclusion of a contract or fulfilment of a contract.
8. Right to access
You also have the right at any time to receive from us free information about the personal data stored about you and a copy of this information. You also have the right to receive the following information:
- the processing purposes,
- the categories of personal data to be processed,
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations,
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration,
- the existence of a right to the rectification or erasure of personal data concerning him or her or to the limitation of the processing by the controller or of a right to object to such processing,
- the existence of a right of appeal to a supervisory authority,
- if the personal data are not collected from the data subject: all available information on the origin of the data as well as,
- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject.
You also have a right to know whether personal data have been transferred to a third country or to an international organisation. If this is the case, you also have the right to obtain information on the appropriate guarantees in connection with the transfer
9. Right of rectification
You have the right to request the immediate rectification and/or completion of any inaccurate or incomplete personal data concerning you. We must carry out the rectification without delay.
10. Right to limit the processing
You have the right to demand that we restrict processing if one of the following conditions is met:
- The accuracy of the personal data is contested by the data subject for a period of time which enables the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject refuses to delete the personal data and instead requests that the use of the personal data be restricted.
- The controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the assertion, exercise or defense of legal rights.
- The data subject has lodged an objection to the processing pursuant to Art. 21 (1) GDPR and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the data subject.
If the processing of personal data concerning you has been restricted, such data - apart from their storage - may only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.
If the processing has been restricted in accordance with the above conditions, you will be informed by us before the restriction is lifted.
11. Right to erasure
You have the right to demand that we erase your personal data immediately if one of the following reasons applies and if processing is not necessary:
- The personal data has been collected for such purposes or processed in any other way for which it is no longer necessary.
- The data subject withdraws his consent on which the processing was based pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
- The data subject objects to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing pursuant to Art. 21 para. 2 GDPR.
- The personal data have been processed unlawfully.
- The deletion of the personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
- The personal data were collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.
If we have made the personal data public and we are obliged to delete the personal data as the person responsible pursuant to Art. 17 (1) GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other data controllers, insofar as the processing is not necessary.
The right to erasure does not exist insofar as processing is necessary:
- to exercise the right to freedom of expression and information;
- to fulfil a legal obligation which the processing requires under the law of the Union or of the Member States to which the controller is subject or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
- for archival purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the law referred to under section a) presumably makes it impossible or seriously impairs the attainment of the objectives of such processing, or
- to assert, exercise or defend legal claims.
12. Right to Information
If you have asserted the right to correction, deletion or limitation of processing against us, we are obliged to notify all recipients to whom the personal data concerning you have been disclosed of this correction or deletion or limitation of processing, unless this proves impossible or involves disproportionate effort.
You have the right to be informed of such recipients.
13. Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. You also have the right to transfer this data to another data controller without being hindered by us, provided that the processing is based on the consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task in the public interest or in the exercise of official authority which has been entrusted to us.
Furthermore, when exercising your right to data transferability pursuant to Art. 20 para. 1 GDPR, you have the right to obtain that the personal data be transferred directly by us to another responsible party, insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.
The right to data transfer does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority assigned to the person responsible.
14. Right of objection
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 letters e or f GDPR. This also applies to profiling based on these provisions.
In the event of objection, we will no longer process the personal data unless we can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.
If we process your personal data for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. This also applies to profiling as far as it is connected with such direct advertising. If you object to our processing for direct advertising purposes, we will no longer process your personal data for these purposes.
You also have the right to object to the processing of your personal data concerning you by us for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR for reasons arising from your particular situation, unless such processing is necessary to fulfil a task in the public interest.
You can contact us at any time to exercise your right to object. You are also free to exercise your right of objection through automated procedures using technical specifications in connection with the use of Information Society services, notwithstanding Directive 2002/58/EC.
15. Right to withdrawal your consent
You have the right to withdraw your consent to the processing of personal data at any time. The withdrawal of your consent does not affect the legality of the processing that took place due to your consent until your withdrawal your consent.
16. Right to automated decisions in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effect against you or which similarly significantly affects you, provided that the decision
- is not necessary for the conclusion or performance of a contract between you and us or
- is permitted by the laws of the Union or of the Member States to which we are subject and those laws contain adequate measures to safeguard your rights and freedoms and your legitimate interests, or
- with your explicit consent.
If the decision
- is necessary for the conclusion or performance of a contract between you and us or
- it takes place with your explicit consent,
we will take reasonable steps to protect your rights and freedoms and your legitimate interests, including, as a minimum, the right of us to obtain the intervention of any person in order to present our point of view and challenge the decision.
17. Existence of an automated decision-making process
We do not perform automatic decision making or profiling.
18. Right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the Member State where you reside, at your place of work or at the place where the alleged infringement shall be occurred, if you consider that the processing of your personal data in breach of the GDPR.
The supervisory authority to which the complaint was submitted will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR. The competent supervisory authority for us is: Landesbeauftragte für den Datenschutz Niedersachsen, Ms. Barbara Thiel, Prinzenstraße 5, 30159 Hannover.
Status as of October 2020