Privacy Policy wingu GmbH Application

 

I. General Information and Legislative Basis

The following statement informs you about what kind of personal data is collected by this app and for what purpose and to what extent this data is made available to third parties.

 

1. Responsible Party

wingu GmbH

c/o Mindspace

Rödingsmarkt 9

20459 Hamburg

hilfe<at>wingu.de

 

Geschäftsführung Hanz Geeratz & Michael Wolf

Registereintrag: Amtsgericht Hamburg - HRB 149417

 

2. Legislative Basis for Processing

The processing of personal data requires a legal basis, which we would like to present to you here. For the processing of personal data, for which we have obtained the data subject's consent, the legal basis is Article 6(1)(a) of the General EU Data Protection Regulation (GDPR). 

For the processing of personal data required for the performance of a contract to which the data subject is a party, GDPR Article 6(1)(b) serves as the legal basis. This also includes processing operations that are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, GDPR Article 6 paragraph 1 lit. c serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, GDPR Article 6(1)(f) serves as the legal basis for processing. The legitimate interest of our company lies in the execution of our business activities as well as in the analysis, optimization and maintenance of the security of our app offer.

 

II. Device Data, Hosting

Certain data is automatically stored. This is data which the device transmits to us within the framework of our legitimate interest in the analysis and for security reasons:
● Date and time our app was downloaded
● The transferred data volume and the access status (file transferred, file not found, etc.)
● IP address
● The operating system used
● Device type

As a rule, we cannot assign this data to specific persons. This data is not consolidated with other data sources. The data will be deleted within 7 days after a statistical analysis. Data for which further storage is required for evidence purposes are excluded from deletion until the respective incident has been clarified.

Furthermore we use hosting services. These are used to provide infrastructure and platform services, computing capacity, storage and database services, security services and technical maintenance services to maintain the operation of this app. Here we and/or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and users of this app on the basis of our legitimate interests in an efficient and secure provision of this app.

 

III. Contact and Consent (use of app functions)

Personal data that you yourself have provided in the context of enquiries and contacts will be collected, processed and stored exclusively for the processing of enquiries and, if necessary, for the handling of communication for any contractual relationships and other business relationships. Only if you have previously given your consent separately, your data will also be used for further purposes specified in the consent.

You can enable geolocalization to display location-related information, especially for the correct use of proximity technology. Your consent to geolocalization is indicated by the app ("To view location-related content, you must activate your location services"). If you have agreed to the geolocalisation, you can revoke this consent at any time via the general settings of your mobile phone.

By using push notifications, short messages can also be sent to you with an advertising nature. You give your consent to receive push notifications if you accept the relevant query of the app ("May wingu send you messages?"). Once you have given your consent, it can be configured or revoked via the general settings of your mobile device. Further promotional messages (newsletters) or telephone calls will only be made if you have expressly consented.

You can revoke your consent at any time with effect for the future. In the event of revocation, your data will be deleted immediately, unless there is a legal exception for further processing. Your data will be deleted when we have processed your request or the purpose of storage has ceased and there are no other conflicting legal exceptions. We can inform you at any time about the data stored about your person.

 

IV. Data Transferral to Third Parties

The personal data you provide will only be used internally to provide you with the functions of the app. Data will only be passed on to third parties if this is necessary within the scope of the functional scope, if we are legally obliged and/or authorised to do so in individual cases or if you have given your consent.

In some cases, we make use of the app of external service providers within the scope of our legitimate interests with regard to analysis, optimization and economic operation. This always presupposes that the third party providers of this content perceive the IP address of the users. 

If your data is to be used for other purposes, we will inform you in advance and only use the data if you have expressly given your consent in advance.

 

1. Google

We use the services of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google") within the scope of our legitimate interests in the analysis, optimization and economic operation of our app. Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt00000000001L5AAI&status=Active).

 

1.1 Google Analytics

We use Google Analytics as an analysis service. Google Analytics uses "cookies", which are text files placed on your device, to help the website analyze how users use the site. The information generated by the cookie about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Please note that we use Google Analytics with the extension "_anonymizeIp()" and therefore Google IP addresses in Member States within the European Union or in other signatory states to the Agreement on the European Economic Area are reduced prior to transmission in order to exclude any direct personal reference. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

On behalf of the provider, Google will use this information to evaluate your use, to compile reports on activities for the provider and to provide further services associated with the use. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

The purpose and scope of data collection and the further processing and use of the data by Google as well as your rights and setting options for the protection of your privacy can be found in the data protection information from Google at http://www.google.de/intl/de/policies/privacy/?hl=en and specifically for Google Analytics at https://www.google.com/policies/privacy/partners/?hl=en and at https://support.google.com/analytics/answer/6004245?hl=en. For Universal Analytics at https://support.google.com/analytics/answer/2838718?hl=en

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

The collection and storage of data by Google may be revoked for the respective terminal device at any time with future effect in connection with the use of this link: http://tools.google.com/dlpage/gaoptout?hl=en

You can also prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie is set which prevents the future collection of your data when you visit this website via this link:

<ahref="javascript:gaOptout()">GoogleAnalyticsdeaktivieren</a>

 

Attention: When you delete cookies on your device, it also means that the deactivation cookies will be deleted and must be placed when visiting our website again.

 

1.2 Google+

Our app uses the "+1″ button of the social network Google Plus. The button can be recognized by the sign "+1″ on a white or colored background. When you access a page of our app that contains such a button, your browser establishes a direct connection to Google's servers.

The content of the "+1″ button is transmitted by Google directly to your browser and integrated into the app. We therefore have no influence on the amount of data Google collects with the button. According to Google, no personal data is collected without a click on the button. According to Google, other data collected is for maintenance and troubleshooting purposes only. Only when members are logged in, such data, including the IP address, is collected, processed and stored in the USA.

For the purpose and scope of data collection and the further processing and use of the data by Google and your rights and setting options for the protection of your privacy, please refer to Google's data protection information on the "+1″ button: https://support.google.com/plus/answer/1319578 and https://developers.google.com/+/web/buttons-policy or in the FAQ: http://bit.ly/r3Qmer.

If you're a Google Plus member and don't want Google to use our app to collect information about you and link it to your membership information stored on Google, you'll need to log out of Google Plus before visiting our app.

 

1.3 YouTube

Our application allows customers to integrate videos from YouTube. These videos are stored on www.youtube.com and can be played directly in our app. YouTube uses cookies for data collection and statistical data evaluation. Among other things, YouTube uses cookies to collect reliable video statistics, to prevent fraud and to improve user-friendliness. The information generated by the cookie about your use of this website (including your IP address) will also be transmitted to and stored by Youtube servers in the United States.  Your IP address cannot be assigned unless you have signed in to YouTube or another Google service or are permanently signed in before you visit the site. If you do not want this, you must log out of your Youtube account and your other Google Accounts.

YouTube's embedded videos are used as permitted by YouTube, which all users must accept. If you see any copyright infringement, please report it directly to YouTube. We use embedded YouTube videos in advanced privacy mode. This means that YouTube does not store cookies for a user who displays a website with an embedded YouTube video player but does not click on the video to start playback. If you click on the YouTube video player, YouTube may store cookies on the user's computer. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or of how they are used by Youtube. For more information on YouTube's official privacy policy, please visit https://www.google.de/intl/de/policies/privacy/ and https://support.google.com/youtube/answer/171780?hl=en.

 

2. Facebook

We use services of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook") within the scope of our legitimate interests in the analysis, optimisation and economic operation of our online offer. Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law.
(https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

 

2.1 Facebook Plug-ins

Our app includes social plug-ins of the  Facebook social network. The plug-ins are identifiable with the Facebook logo or provided with the addition “Facebook Social Plug-In.” When you access content through our app that contains such a plug-in, your browser will automatically connect with Facebook’s servers in the USA. The content of the plug-in will be transmitted automatically to Facebook’s servers and subsequently embedded in the Facebook app. This means that personal data, such as your IP address, URL, date and time as well as other browser related data will be transmitted to Facebook and saved in the USA. Facebook Germany declares that only anonymised IP addresses are transmitted.

If you are logged into Facebook with your device, Facebook can connect your visit to your Facebook account. If you interact with a Facebook plug-in, i.e. use the “Like” button or comment, your browser will immediately transmit this activity to Facebook, which is subsequently saved and, depending on your Facebook settings, shared with your Facebook contacts. In case you do not want this to happen, please log out of your Facebook account on your device prior to using wingu.  

Facebook saves your data as user profiles and uses these profiles for advertising, market research and website designs for itself and other websites. In order to be able to do this, Facebook uses Cookies and similar technologies to show you advertisements on your Facebook account, as well as on other websites. This happens whether you have an account or not, and happens as soon as you have visited www.facebook.com. Facebook transmits your data to third parties as well.

wingu points out that we do not receive any information from Facebook concerning the transmitted content and data, nor how this data is used by Facebook. You can prevent the installation of Cookies by changing the internet settings of your browser to deny the placement of Cookies by third parties. However, this might mean that websites will no longer be able to function fully.

If you want to learn more about the purpose and scope of data collection and further processing and use of the data by Facebook, as well as your rights and options for privacy protection, please refer to the Facebook Privacy Notice at http://www.facebook.com/about/privacy/ and especially for social plug-ins from Facebook at https://en-gb.facebook.com/help/443483272359009/. Additionally you can change your privacy settings in your Facebook account settings.

 

3. Twitter

Our pages include functions of the Twitter service. These features are provided by Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter"). Twitter observes the principles of the EU-US Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active) and the Swiss-US Privacy Shield regarding the collection, use, transmission and storage of personal data from the European Union and Switzerland, according to its own statements.

When you access content through our app that contains such a plug-in, your browser will automatically connect with Twitter’s servers in the USA. The content of the plug-in will be transmitted to Twitter’s servers and subsequently embedded in the Twitter app. This means that personal data, such as your IP address, URL, date and time as well as other browser related log data will be transmitted to Twitter and saved in the USA. Twitter uses Cookies and similar technologies to display advertising and suggestions on Twitter services, regardless of whether you have a Twitter account and/or are logged in. The information transmitted by the cookies (including your IP address) is saved on a server in the USA.

Twitter only saves tailored content together with browser cookies or device IDs and separates it from other data, such as visited websites. After 10 days Twitter will either delete, remove the identification or gather the data. By using Twitter and the "Re-Tweet" feature, the pages you visit will be linked to your Twitter account and shared with other users. In this case data is also transferred to Twitter. In case you do not want this to happen, please log out of your Twitter account on the device you are using prior to using wingu. 

By using Twitter and the "Re-Tweet" function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter. If you do not want this, please log out of your Twitter account (before pressing the opt-in button).
We would like to point out that, as the provider of the pages, we are not aware of the content of the data transmitted or how it is used by Twitter. You may refuse the use of cookies by selecting the appropriate settings on your device, however please note that if you do this you may not be able to use the full functionality of this app. 

Further information can be found at https://support.twitter.com/articles/20171372-twitter-unterstutzt-die-option-do-not-track-nicht-verfolgen#.   For more information on Twitter's use of your data, please see Twitter's privacy policy at https://twitter.com/privacy?lang=en and https://support.twitter.com/articles/20171570-info-zu-mageschneiderten-vorschlagen#.
You can change your Twitter privacy settings in your account settings at http://twitter.com/account/settings

 

4. SurveyMonkey

Our application enables our customers to integrate surveys via SurveyMonkey, a service of SurveyMonkey Europe UC, 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland. The survey creator can decide whether to anonymize the survey or track respondents. If you choose to participate in a survey, please note that the survey creator may be able to track you. If you have any questions about your data, please contact the survey creator. For more information about SurveyMonkey's privacy policy, please visit: https://help.surveymonkey.com/articles/en_US/kb/Are-my-survey-responses-anonymous-and-secure

 

V. Rights of the Data Subject

You have a right to information about the personal data stored by us about you. According to the legal regulations you also have a right to correction of incorrect data, blocking, data transferability and deletion of your personal data. Send us an e-mail with the subject "Privacy".
You also have a right of appeal to a data protection supervisory authority if you believe that the processing of personal data concerning you violates the legal provisions.

If you have given your consent, you have the right to revoke your consent at any time. This does not affect the legality of the processing carried out on the basis of the consent until revocation.

You can object to the future processing of your personal data in accordance with the legal requirements at any time. The objection may be lodged in particular against processing for direct marketing purposes.

 

VI. Data Retention

We store personal data for the duration of the respective legal retention period or as long as the purpose of the collection exists. After expiry of the retention period, the data is routinely deleted, unless there is a need for the initiation of a contract or for performance of the contract. If the user's data are not deleted because they are necessary for other and legally permissible purposes, their processing is limited as far as possible. Accordingly, the data will be blocked as far as possible and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax reasons.

 

VII. Security Information

We make great efforts to process your personal data by taking all technical and organizational possibilities in such a way that the regulations of the data protection laws are observed and in order to protect the data.

 

 

This Privacy Policy has been translated by wingu GmbH for informational purposes. wingu GmbH uses the German original as a legal basis. The German original is made available by the law firm Sieling - Fachanwaltskanzlei für IT-Recht.