Privacy Policy for the Crash Sensor System
Preamble
The Crash Sensor System (hereinafter System) is the system consisting of the interaction of Crash Sensor and the Crash Sensor App (hereinafter App).
The Crash Sensor System and the Crash Sensor App are provided by the
MTS MarkenTechnikService
GmbH & Co. KG
Carl-Benz Street 2
76761 Rülzheim - Germany
Telephone: +49 (0) 7272-9801-100
(hereinafter "we" or "us") as the responsible party within the meaning of the applicable data protection law.
The app is available for download as a Google Android or Apple iOS version and must be connected to the crash sensor of the respective user via Bluetooth in order to forward any messages.
Users (hereinafter "you" or "your") are the persons who have installed the Crash Sensor App on their mobile device and/or use the Crash Sensor System.
When using the app, we process personal data of the user. Personal data means any information relating to an identified or identifiable natural person.
Because the protection of your privacy is important to us, we would like to inform you with the following information about which personal data we process when you use the app and how we handle this data. In addition, we inform you about the legal basis for the processing of your data.
You can access this privacy statement at any time under the menu item Privacy statement of the app.
1. Information on the processing of your data
Certain information is already processed automatically as soon as you use the app. We have listed exactly which personal data is processed for you below:
1.1 Information collected during the download.
When you download the app, certain required information is transmitted to the app store you have selected (e.g., Google Play or Apple App Store); in particular, the user name, the e-mail address, the customer number of your account, the time of the download, payment information, and the individual device identification number may be processed. The processing of this data is carried out exclusively by the respective App Store and is beyond our control.
1.2 Information collected during first use
During your first use of the app or registration, the following information of the user will be requested:
- Username
- Phone number
- Emergency contacts to be informed when the crash sensor is triggered (name of contact person and phone number).
This data is stored in the terminal device and transmitted to us in order to provide you with the service and the associated functions.
This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as a data subject and us pursuant to Art. 6 (1) lit. b) DSGVO for the use of the app, or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the app (Art. 6 (1) lit. f) DSGVO).
1.3 Information that is collected automatically
As part of your use of the App, we automatically collect certain data that is necessary for the use of the App. This includes:
- IP address and time of access
- Requesting server (so-called user agent)
- ID of the end device (so-called UUID)
- Type, version of the operating system and language of the end device.
This data is automatically transmitted to us and stored by us (1) to provide you with the Service and related features; (2) to improve the functions and performance features of the App; and (3) to prevent and remedy misuse and malfunctions.
This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as a data subject and us pursuant to Art. 6 (1) lit. b) DSGVO for the use of the App, or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the App (Art. 6 (1) lit. f) DSGVO).
1.4 Use of the app
When using the app, we collect the following data in anonymous form, which is required for the use of the app or the functions offered.
These are, as far as provided e.g. via connected devices:
- Current location when the crash sensor is triggered.
This data is automatically transmitted to us and stored by us (1) to provide you with the service and the associated functions; (2) to improve the functions and performance features of the app and (3) to prevent and eliminate misuse and malfunctions. An assignment to a specific user is not possible for us.
The app also requires the following permissions:
- Internet access: This is required to save your entries on our servers.
- Location access: This is required in order to be able to offer the corresponding location-related functions.
This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) (b) DSGVO for the use of the app, or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the app (Art. 6 (1) (f) DSGVO).
If another user uses the Crash Sensor System, you must inform him or her about this data processing and the transfer to us in accordance with Art. 13 DSGVO.
2 Passing on and transfer of data
In addition to the cases explicitly mentioned in this data protection declaration, the data to be processed will only be passed on to third parties without your express prior consent if this is permitted or required by law.
2.1 The data provided by you during registration will be passed on within our group of companies for internal administrative purposes, including joint customer support, to the extent necessary.
Any disclosure of personal data is justified by the fact that we have a legitimate interest in disclosing the data for administrative purposes within our group of companies and that your rights and interests in the protection of the data to be processed within the meaning of Art. 6 Para. 1 lit. f) DSGVO do not prevail.
2.2 We rely on the following third-party companies and external service providers to provide our service:
GPS Tuner Systems Kft, Vérmezö ÚT 4, 1012 Budapest. Hungary
Any transfer of personal data is justified by the fact that we have carefully selected our third-party companies and external service providers as processors within the framework of Article 28 (1) of the GDPR, regularly checked them and contractually obliged them to process all personal data exclusively in accordance with our agreements.
3. data transfers to third countries
A transfer to countries outside the European Economic Area does not take place.
4. period of data storage
We delete or anonymize The Data to be Processed as soon as it is no longer necessary for the purposes for which we collected or used it in accordance with the above paragraphs. As a rule, we store The Data to be Processed for the duration of the usage or contractual relationship via the App plus a period of 30 days, during which we keep backup copies after deletion, unless this data is needed for longer for criminal prosecution or to secure, assert or enforce legal claims.
Specific statements in this privacy policy or legal requirements for the retention and deletion of personal data, in particular those that we must retain for tax reasons, remain unaffected.
5. your rights as a data subject
5.1 Right to information
You have the right to receive information from us at any time upon request about the personal data processed by us that concerns you within the scope of Art. 15 DSGVO. For this purpose, you can submit a request by mail or e-mail to the address given above.
5.2 Right to rectify incorrect data
You have the right to request that we correct the personal data concerning you without delay if it should be incorrect. To do so, please contact us at the contact address given above.
5.3 Right to deletion
You have the right to request that we delete the personal data concerning you under the conditions described in Article 17 of the GDPR. These conditions provide in particular for a right to erasure if the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of a duty to erase under Union law or the law of the Member State to which we are subject. For the period of data storage, please also refer to section 5 of this data protection declaration. To assert your right to deletion, please contact us at the above contact address.
5.4 Right to restriction of processing
You have the right to demand that we restrict processing in accordance with Article 18 DSGVO. This right exists in particular if the accuracy of the personal data is disputed between the user and us, for the duration that the verification of the accuracy requires, as well as in the event that the user requests restricted processing instead of erasure in the case of an existing right to erasure; furthermore, in the event that the data is no longer necessary for the purposes pursued by us, but the user requires it for the assertion, exercise or defense of legal claims, as well as if the successful exercise of an objection is still disputed between us and the user. To exercise your right to restrict processing, please contact us at the above contact address.
5.5 Right to data portability
You have the right to receive from us the personal data concerning you that you have provided to us in a structured, commonly used, machine-readable format in accordance with Article 20 DSGVO. To exercise your right to data portability, please contact us at the above con-tact address.
6. right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out, inter alia, on the basis of Art. 6(1)(e) or (f) DSGVO, in accordance with Art. 21 DSGVO. We will stop the processing of the data to be processed unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or if the processing serves the assertion, exercise or defense of legal claims.
7. right of complaint
You also have the right to contact the competent supervisory authority in the event of complaints.
8. changes to this data protection declaration
We always keep this privacy policy up to date. Therefore, we reserve the right to change it from time to time and to update changes in the collection, processing or use of your data.
Status: 19.04.2022