Data protection Skandika Training Data

1. General Information

This privacy policy informs you about the nature, scope, and purpose of the processing of personal data within our Skandika Training Data App and the functions and content associated herewith. Our privacy policy is intended to be simple and understandable for everyone. In this data protection declaration, the official terms of the Data Protection Regulation (DSGVO, in German) are generally used. The official definitions are explained in Article 4 DSGVO (in German).

1.1. Who is responsible for data processing?

Skandika GmbH
Wilhelm-Beckmann-Straße 19, 45307 Essen
+49 201 219601-40
app@skandika.com

1.2. Contact details for the data protection officer

PROLIANCE GmbH / www.datenschutzexperte.de
Datenschutzbeauftragter
Leopoldstr. 21
80802 München
datenschutzbeauftragter@datenschutzexperte.de

When contacting the data protection officer, please state the company to which your enquiry relates. Please refrain from enclosing sensitive information, such as a copy of ID cards.

2. Data collection in the context of app use

We take the protection of your data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

Our app offers you the possibility to use your own smartphone or tablet as a modern training computer. The transfer of training data takes place via a Bluetooth connection in real time, without having to use an outdated training computer.

When you download our app, register, or log in to and use the app, various personal data is processed.

Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

2.1. Access to and storage of information in terminal equipment

By using our app, information may be accessed (e.g., IP address) or stored (e.g., cookies) in your terminal equipment. This access or storage may involve further processing of personal data within the scope of the DSGVO.

In cases where such access to information or such storage of information is absolutely necessary for the technically error-free provision of our services, this is done on the basis of Section 25 (1) s.1, (2) no. 2 TTDSG (in German).

In cases where such a process serves other purposes (e.g., the needs-based design of our app), this will only be carried out on the basis of Section 25 (1) TTDSG with your consent in accordance with Article 6 (1) (a) DSGVO. The consent can be revoked at any time for the future. The provisions of the DSGVO and the Federal Data Protection Act (BDSG, in German) apply to the processing of your personal data.

For further information on the processing of your personal data and the relevant legal provisions in this context, please refer to the following sections on the specific processing activities in our app.

2.2. Information collected when downloading the app

When downloading the app, certain required information is transmitted to the app store which you have selected (Google Play Store, Apple App Store). In particular, the following may be processed: username, e-mail address, customer number of your account, time of the download, payment information, and individual device identification number. We have no influence on this data collection and are not responsible for it. The contract is made with the respective provider of the shop and is handled in accordance with their terms and conditions of business and use as well as their data protection provisions. When you use the stores, we only process the reviews you have published for our app with any associated data, and only receive anonymous statistics via the stores, e.g., on download figures, deinstallation, and crashes.

2.3. Hosting

This app is hosted by an external service provider (host) in Germany. Personal data collected in the app is stored on our host’s servers. We have signed an order processing contract with the host in accordance with the requirements of Article 28 DSGVO, in which the host is obligated to protect the data of our customers and not to pass them on to third parties.

2.4. Data processing when using the app

When you use the app, we automatically collect certain data that is required for the provision and use of the app. The following data is processed for this purpose: Time of access, IP address, content of access.

This data is automatically transmitted to us in order to provide you with the service and any associated functions and to prevent and resolve misuse and malfunctions.

This data processing is carried out on the basis of our legitimate interest, as defined in Article 6 (1) (f) DSGVO, in ensuring the functionality and fault-free operation of the app, as well as the fulfilment of the contract with the user for the use of the app, as defined in Article 6 (1) (a) DSGVO.

2.5. Technical features of the app

The app requires the following authorisation for the full use of our services:

  • Internet access: This is required in order to transfer your entries.
  • Push notification: This is required in order to send you targeted push messages to remind you to train.
  • Bluetooth connection: This is required in order to connect the app to the respective training device.

At the latest, authorisation to access the above functions is explicitly requested when the device is used for the first time and may be confirmed or rejected.

If you have granted individual authorisations, the associated processing of your data is based on your consent in accordance with Article 6 (1) (a) DSGVO. You may revoke your consent for the future at any time. Any authorisation granted can normally be cancelled at any time in the device settings (however, this depends on the device and the operating system, over which we have no influence). The legality of the data processing already carried out remains unaffected by the cancellation. Please note that authorisations that have not been granted may restrict the use of the app.

2.6. Contact by e-mail or telephone

When you send us enquiries by e-mail or telephone, the information you provide in your e-mail, including any personal data you enter there, is stored by us for the purpose of processing the enquiry and for the event of follow-up questions. Under no circumstances will we pass on this data without your consent. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Article 6 (1) (f) DSGVO and, if applicable, Article 6 (1) (b) DSGVO if your request is aimed at concluding a contract.

Your data will be deleted after your request has been processed, provided that there are no legal obligations to retain data. You may object to the processing of your personal data at any time in the case of Article 6 (1) (f) DSGVO.

2.7. Feedback Form

When you send us enquiries via the contact form or e-mail, your details from the enquiry form or your e-mail, including any personal data you provide there, will be stored by us for the purpose of processing the enquiry and for the event of follow-up enquiries. The specification of an e-mail address is necessary in order to contact you. Under no circumstances will we pass on this data without your consent. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Article 6 (1) (f) DSGVO and, if applicable, Article 6 (1) (b) DSGVO if your request is aimed at improving the functionalities provided in the contract.

Your data will be deleted after your request has been processed, provided that there are no legal obligations to retain data. You may object to the processing of your personal data at any time in the case of Article 6 (1) (f) DSGVO.

3. Data disclosure and recipients

Your personal data will not be transferred to third parties unless

  • we have explicitly pointed this out in the description of the respective data processing,
  • you have given your express consent in accordance with Article 6 (1) s.1 (a) DSGVO,
  • the disclosure is necessary for the enforcement, execution, or protection of legal claims in accordance with Article 6 (1) s.1 (f) DSGVO and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
  • a legal obligation for the disclosure exists in accordance with Article 6 (1) s.1 (c) DSGVO, and
  • this is necessary for the fulfilment of contractual agreements with you in accordance with Article. 6 (1) s.1 (b) DSGVO

Furthermore, we use third-party service providers for the processing of our services. These have been carefully selected and commissioned in writing and we have signed order processing agreements with them where necessary, in accordance with Article 28 DSGVO. They are bound by our instructions, and we monitor them on a regular basis. They provide services in app hosting, analysis tools, and the maintenance and care of our IT systems, among other things. The service providers will not pass this data on to third parties.

4. Use of Google Firebase

We use the Google Firebase developer platform and related services and features provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Firebase is a platform for developers of applications (“apps”) for mobile devices and websites. Google Firebase offers a variety of features, which are described on the following overview page: https://firebase.google.com/products/.

Among other things, these functions involve app storage, including personal information about app users, such as content they create or information about their interaction with the apps (so-called “cloud computing”). Google Firebase also provides interfaces that enable interaction between app users and other services, e.g., authentication via services such as Facebook, Twitter or via an e-mail/password combination.

The evaluation of user interactions and the performance of the app is achieved with the help of the analytics services “Crashlytics” and “Google Analytics”. Google Firebase was developed to record how users interact with an app. It records such things as when the app is first opened, when it is uninstalled, when it is updated, when it crashes, and how often the app is used. Based on this information, further interests of the users, such as certain functions of the apps or certain topics, may also be recorded. This also allows the creation of user profiles, which can be used as a basis for presenting advertising messages tailored to the users, for example.

Google Firebase and the users’ personal data processed by Google Firebase may also be used in conjunction with other Google services, such as Google marketing services (in this case, device-related information such as “Android Advertising ID” and “Advertising Identifier for iOS” is also processed in order to identify the users’ mobile devices).

We use Google Firebase on the basis of your consent in accordance with Article 6 (1) (a) DSGVO. This serves the analysis, optimisation, security, and economic operation of our application.

We have concluded a so-called order processing agreement with Google for our use of Google Firebase, which stipulates that Google is obliged to protect the data of our website users and not to pass it on to third parties.

Since personal data is transferred to the USA, further appropriate safeguards are required to ensure the level of data protection under the DSGVO. To ensure this, we have concluded standard contractual clauses with the provider in accordance with Article 46 (2) (c) DSGVO. These oblige the recipient of the data in the USA to process the data in accordance with the European level of protection. In cases where this cannot be guaranteed even through this contractual extension, we endeavour to obtain additional regulations and assurances from the recipient in the USA.

For more information on Google’s use of data for marketing purposes, please see the overview page: https://www.google.com/policies/technologies/ads. Google’s privacy policy can be found at https://www.google.com/policies/privacy.

If users wish to opt out of interest-based advertising by Google’s marketing services, they can do so using the opt-out and opt-in choices provided by Google: http://www.google.com/ads/preferences. For more information about Google Firebase, please visit: https://firebase.google.com.

5. Use of Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

The purpose of reCAPTCHA is to check whether data entry on our website (e.g., in a contact form) is made by a human or by an automated programme. For this purpose, reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information, e.g.

  • IP address
  • How long the visitor stays on the website
  • Mouse movements made by the user

The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run exclusively in the background. Website visitors are not informed that an analysis is taking place. The data processing is based on Article 6 (1) (f) DSGVO. We have a legitimate interest in protecting our website from abusive automated cyber espionage and from unwanted automated mailings (spam).

Since personal data is transferred to the USA, further appropriate safeguards are required to ensure the level of data protection under the DSGVO. To ensure this, we have concluded standard contractual clauses with the provider in accordance with Article 46 (2) (c) DSGVO. These oblige the recipient of the data in the USA to process the data in accordance with the European level of protection. In cases where this cannot be guaranteed even through this contractual extension, we endeavour to obtain additional regulations and assurances from the recipient in the USA.

We do not store any personal data from the use of reCAPTCHA. In general, personal data of the person concerned will be deleted or blocked as soon as the purpose of the storage no longer applies.

Further information on Google reCAPTCHA and Google’s data protection declaration can be found under the following links:
https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/v3beta.html

6. Duration of the storage of personal data

The duration of the storage of personal data is determined by the relevant statutory retention periods (e.g., from German commercial law and tax law). After expiry of the respective period, the corresponding data is routinely deleted. If data is required to fulfil or initiate a contract or if we have a legitimate interest in continuing to store it, the data will be deleted when it is no longer required for these purposes, or you have exercised your right of revocation or objection.


7. 
Your rights

In the following, you will find information on which rights the applicable data protection law grants you towards the controller with regard to the processing of your personal data:

The right to request information about your personal data processed by us in accordance with Article 15 DSGVO. In particular, you may request information about the processing purposes, the type of personal data, the types of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details. 

 

The right to request the immediate correction of inaccurate or incomplete personal data stored by us in accordance with Article 16 DSGVO.

The right to request the deletion of your personal data stored by us in accordance with Article 17 DSGVO, unless further processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the enforcement, execution, or defence of legal claims.

The right to request the restriction of the processing of your personal data in accordance with Article 18 DSGVO, insofar as you dispute the accuracy of the data, the processing is unlawful, but you object to its deletion and we no longer require the data, but you need it for the enforcement, execution, or defence of legal claims or you have objected to the processing in accordance with Article 21 DSGVO.

The right, in accordance with Article 20 DSGVO, to receive personal data that you have provided to us in a structured, established, and machine-readable format or to request that it be transferred to another controller.

The right to complain to a supervisory authority in accordance with Article 77 DSGVO. As a rule, you may contact the supervisory authority of the federal state where our registered office is located or, if applicable, that of your usual place of residence or workplace.

The right to revoke consent given in accordance with Article 7 (3) DSGVO: You have the right to revoke your consent to the processing of data for the future at any time. In the event of revocation, we will immediately delete the data concerned unless further processing can be justified on a legal basis for processing without consent. The legality of the data processing already carried out remains unaffected by the revocation.

8. Right of objection

Insofar as your personal data is processed by us on the basis of legitimate interests in accordance with Article 6 (1) s.1 (f) DSGVO, you have the right to object to the processing of your personal data in accordance with Article 21 DSGVO, insofar as this is done on grounds arising from your particular situation. Insofar as the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right of objection without the requirement to specify a particular situation.

If you would like to exercise your right of revocation or objection, an e-mail to app@skandika.com is sufficient.

9. Legal obligations

The provision of personal data for a decision on the conclusion of a contract, the fulfilment of a contract or for the implementation of pre-contractual measures is voluntary. However, we can only make the decision in the context of contractual measures if you provide the personal data that is required for the conclusion of the contract, the performance of the contract or pre-contractual measures.

10. Automated decision making / profiling

Automated decision-making or profiling in accordance with Article 22 DSGVO does not take place.

11. Changes and updates to this privacy policy

We reserve the right to amend or update this data protection declaration, if necessary, in compliance with the applicable data protection regulations. This enables us to bring it in line with current legal requirements, considering changes to our services, such as the introduction of new services. The most current version applies to your website visit.

This data protection declaration was last updated on 22.02.2022.