DÉCLARATION DE PROTECTION DES DONNÉES

1) Information on the collection of personal data and contact details of the data controller

1.1 We are pleased that you are using our application (hereinafter referred to as “app”). In the following, we will inform you about how we handle your personal data when you use our app. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing in relation to this app, within the meaning of the General Data Protection Regulation (GDPR), is Revenite UG (haftungsbeschränkt), Welscher Heide 19, 51429 Bergisch Gladbach, Deutschland, E-Mail: info@comeback-tracker.de. The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

1.3 Le responsable du traitement a désigné un délégué à la protection des données, DÉCLARATION DE PROTECTION DES DONNÉES.

1) Informations sur la collecte de données à caractère personnel et coordonnées du responsable du traitement des données

1.1 Nous sommes heureux que vous utilisiez notre application (ci-après « l’application »). Nous vous informons ci-après de la manière dont nous traitons vos données à caractère personnel lorsque vous utilisez notre application. Les données à caractère personnel sont toutes les données qui permettent de vous identifier personnellement.

1.2 Le responsable du traitement des données relatives à cette App au sens du Règlement général sur la protection des données (RGPD) est Revenite UG (haftungsbeschränkt), Welscher Heide 19, 51429 Bergisch Gladbach, Allemagne, e-mail : info@comeback-tracker.de. Le responsable du traitement est la personne physique ou morale qui, seule ou conjointement avec d’autres, détermine les finalités et les moyens du traitement des données à caractère personnel.

1.3 The controller has appointed a data protection officer who can be contacted as follows: Email: Datenschutz@comeback-tracker.de

1.4 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller), this app uses SSL or TLS encryption. You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser line.

2) Log files when using our mobile app

If you download our mobile app via an app store, the required information is transmitted to the app store, in particular your user name, your e-mail address and the customer number of your account, the time of the download, payment information and the individual device ID. We have no influence on this data collection and are not responsible for it. We only process the data to the extent necessary to download the mobile app to your mobile device.

When you use our mobile app, we collect the personal data described below to enable you to use the function conveniently. If you wish to use our mobile app, we collect the following data, which is technically necessary to provide you with the functions of our mobile app and to ensure stability and security:

• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request
• Access status/HTTP status code
• Amount of data sent in bytes
• Source/reference from which you accessed the page
• Browser used
• Language and version of the browser software
• Operating system used and its interface
• IP address used (if applicable: in anonymized form)

Processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our app. The data is not passed on or used in any other way. However, we reserve the right to check the aforementioned log files retrospectively if there are concrete indications of illegal use.

We also require your unique device number (IMEI = International Mobile Equipment Identity), unique network subscriber number (IMSI = International Mobile Subscriber Identity), mobile phone number (MSISDN), any MAC address for WLAN use and the name of your mobile device.

3) Cookies

In order to make our app attractive and to enable the use of certain functions, we use so-called cookies. These are small text files that are stored on your end device. Some of the cookies we use are deleted again after you close the app (so-called session cookies). Other cookies remain on your device and enable us to recognize you (persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data as well as IP address values to an individual extent. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.

In some cases, cookies are used to simplify the operation of the app by saving settings. If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR for the execution of the contract, in accordance with Art. 6 para. 1 lit. a GDPR in the case of consent given or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the app and a customer-friendly and effective design of the app use.

You can configure the settings of your mobile operating system and the app according to your wishes and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out that in this case you may no longer be able to use all the functions of our mobile app.

4) Collection of location data

Our offer includes so-called location-based services, with which we offer you special offers that are tailored to your respective location. You can only use this function after you have agreed via a pop-up that we can collect your location data using GPS and your IP address in anonymized form for the purpose of providing the service. You can allow or revoke this function at any time in the settings of the app or your mobile operating system. Your location will only be transmitted to us if you use functions when using the app that we can only offer you if we know your location.

5) Contact us

Personal data is collected when you contact us (e.g. via contact form or email). Which data is collected when using a contact form can be seen from the respective contact form in the app. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted after final processing of your request. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6) Data processing when opening a customer account

In accordance with Art. 6 para. 1 lit. b GDPR, personal data will continue to be collected and processed if you provide it to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to the above-mentioned address of the controller. We store and use the data provided by you to process the contract. After complete processing of the contract or deletion of your customer account, your data will be blocked with regard to retention periods under tax and commercial law and deleted after expiry of these periods, unless you have expressly consented to further use of your data or we have reserved the right to further use of your data as permitted by law, about which we will inform you accordingly below.

7) Data processing for contract processing

7.1 Utilisation de prestataires de services spéciaux pour le traitement et l’exécution des contrats

– Billbee GmbH

We use the following provider for order processing: Bilbee GmbH, Arolser Straße 10, 34477 Twistetal, Germany

Name, address and any other personal data will be passed on to the provider exclusively for the purpose of processing the online order in accordance with Art. 6 para. 1 lit. b GDPR. Your data will only be passed on if this is actually necessary for processing the order.

7.2 – Amazon Pay

If you select the payment method “Amazon Pay”, payment will be processed via the payment service provider Amazon Payments Europe s.c.a., 38 Avenue J.F. Kennedy, L-1855 Luxembourg (hereinafter: “Amazon Payments”), to whom we will forward your information provided during the ordering process together with the information about your order in accordance with Art. 6 para. 1 lit. b GDPR. Your data will only be passed on for the purpose of payment processing with the payment service provider Amazon Payments and only to the extent that it is necessary for this purpose. If cookies, i.e. small text files that are stored on the end device, are set when using Amazon Pay, this is done exclusively on the basis of your express consent in accordance with Art. 6 para. 1 lit. a GDPR. This consent can be revoked at any time via the “cookie consent tool” implemented on the website. You can find more information about Amazon Payments’ privacy policy at the following Internet address: https://pay.amazon.com/de/help/201751600

– Apple Pay

If you opt for the “Apple Pay” payment method from Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, payment will be processed via the “Apple Pay” function of your device operated with iOS, watchOS or macOS by charging a payment card stored with “Apple Pay”. Apple Pay uses security functions that are integrated into the hardware and software of your device to protect your transactions. To authorize a payment, you must therefore enter a code that you have previously defined and verify it using the “Face ID” or “Touch ID” function on your device.

For the purpose of payment processing, the information you provide during the ordering process, together with information about your order, will be forwarded to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay to process the payment. The encryption ensures that only the website through which the purchase was made can access the payment data. After the payment has been made, Apple sends your device account number and a transaction-specific, dynamic security code to the source website to confirm the success of the payment.

If personal data is processed during the described transmissions, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR. Apple stores anonymized transaction data, including the approximate purchase amount, the approximate date and time and whether the transaction was successfully completed. This anonymization completely excludes any personal reference. Apple uses the anonymized data to improve “Apple Pay” and other Apple products and services.

If you use Apple Pay on your iPhone or Apple Watch to complete a purchase that you have made via Safari on your Mac, the Mac and the authorization device communicate via an encrypted channel on the Apple servers. Apple does not process or store any of this information in a format that can be used to identify you. You can disable the ability to use Apple Pay on your Mac in your iPhone settings. Go to “Wallet & Apple Pay” and deactivate “Allow payments on Mac”.

You can find further information on data protection with Apple Pay at the following Internet address: https://support.apple.com/de-de/HT203027

– Google Pay

If you choose the “Google Pay” payment method from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), payment will be processed via the “Google Pay” application on your mobile device running at least Android 4.4 (“KitKat”) and equipped with an NFC function by charging a payment card stored with Google Pay or a payment system verified there (e.g. PayPal). To approve a payment via Google Pay of more than €25, your mobile device must first be unlocked using the verification measure set up in each case (e.g. facial recognition, password, fingerprint or pattern).

For the purpose of payment processing, the information you provide during the ordering process, together with information about your order, will be passed on to Google. Google then transmits your payment information stored in Google Pay to the source website in the form of a unique transaction number, which is used to verify that a payment has been made. This transaction number does not contain any information about the real payment data of your means of payment stored with Google Pay, but is created and transmitted as a uniquely valid numerical token. For all transactions via Google Pay, Google only acts as an intermediary for processing the payment process. The transaction is carried out exclusively in the relationship between the user and the source website by debiting the means of payment stored with Google Pay.

If personal data is processed during the described transfers, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR. Google reserves the right to collect, store and evaluate certain transaction-specific information for each transaction made via Google Pay. This includes the date, time and amount of the transaction, merchant location and description, a description of the goods or services purchased provided by the merchant, photos that you have attached to the transaction, the name and email address of the seller and buyer or the sender and recipient, the payment method used, your description of the reason for the transaction and, if applicable, the offer associated with the transaction.

According to Google, this processing takes place exclusively on the basis of Art. 6 para. 1 lit. f GDPR on the basis of the legitimate interest in proper accounting, the verification of transaction data and the optimization and functional maintenance of the Google Pay service. Google also reserves the right to merge the processed transaction data with other information collected and stored by Google when using other Google services.

The Google Pay terms of use can be found here: https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=googlepaytos&ldl=de

Further information on data protection at Google Pay can be found at the following Internet address: https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=de

– Paypal

One or more online payment methods of the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

If you select a payment method of the provider for which you make advance payment, the payment data you provide during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 para. 1 lit. b GDPR. In this case, your data will only be passed on for the purpose of payment processing with the provider and only to the extent that it is necessary for this purpose.

If you select a payment method for which we make advance payments, you will also be asked to provide certain personal data (first and last name, street, house number, zip code, city, date of birth, e-mail address, telephone number, data on an alternative means of payment, if applicable) during the order process.

In order to safeguard our legitimate interest in determining your solvency in such cases, we will forward this data to the provider for the purpose of a credit check in accordance with Art. 6 para. 1 lit. f GDPR. On the basis of the personal data provided by you and other data (such as shopping cart, invoice amount, order history, payment experience), the provider checks whether the payment option you have selected can be granted with regard to payment and/or default risks.

The credit report may contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary to process payments in accordance with the contract.

– Stripe

If you choose a payment method from the payment service provider Stripe, the payment will be processed via the payment service provider Stripe Payments Europe Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we will pass on the information you provided during the ordering process together with the information about your order (name, address, account number, bank code, credit card number if applicable, invoice amount, currency and transaction number) in accordance with Art. 6 para. 1 lit. b GDPR. Your data will only be passed on for the purpose of payment processing with the payment service provider Stripe Payments Europe Ltd. and only to the extent that it is necessary for this purpose. You can find more information about Stripe’s data protection at https://stripe.com/de/privacy#translation.

8) Registration in the app

You can register in our app by providing personal data. Which personal data is processed for registration is determined by the input mask used for registration. We use the so-called double opt-in procedure for registration, i.e. your registration is not complete until you have confirmed your registration by clicking on the link contained in a confirmation e-mail sent to you for this purpose. If you do not confirm your registration within 24 hours, your registration will be automatically deleted from our database. Providing the above data is mandatory. You can provide all other information voluntarily by using our portal.

If you use our app, we will store your data required to fulfill the contract, including any information on payment methods, until you finally delete your access. We also store the data you provide voluntarily for the duration of your use of the portal, unless you delete it beforehand. You can manage and change all information in the protected customer area. The legal basis is Art. 6 para. 1 lit. f GDPR. In addition, we store all content published by you (e.g. public posts, pinboard entries, guestbook entries, etc.) in order to operate the app. We have a legitimate interest in providing the app with complete user-generated content. The legal basis for this is Art. 6 para. 1 lit. f GDPR.

9) Use of your data for direct marketing

Subscribe to our e-mail newsletter

If you register for our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The provision of further data is voluntary and is used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter if you have expressly confirmed to us that you consent to receiving the newsletter. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on a corresponding link.

By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 para. 1 lit. a GDPR. When you register for the newsletter, we store your IP address entered by the Internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter will be used exclusively for the purpose of advertising via the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the controller named at the beginning. Once you have unsubscribed, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

10) Server location and hosting

You can register to receive our push notifications. You will receive regular information about the services we offer via our push notifications.

To register, you must confirm or allow the receipt of notifications in the settings of your operating system. This process is documented and saved. This includes saving the time of registration and your device identification. The collection of this data is necessary so that we can display the push notifications on the one hand and, on the other, so that we can trace the processes in the event of misuse and therefore serves our legal protection. This data is processed on the basis of Art. 6 para. 1 lit. a GDPR.

You can revoke your consent to the storage and use of your personal data to receive our push notifications and the statistical survey described above at any time with effect for the future. To revoke your consent, you can unsubscribe from the setting provided for receiving push notifications in your app settings in your operating system. Your data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. Your data will therefore be stored for as long as the subscription to our push notifications is active.

11) Outils et autres

Our app is hosted on servers of Strato AG, a renowned hosting provider based in Germany. Data processing takes place exclusively on servers located within the Federal Republic of Germany. This ensures that all data protection requirements in accordance with the General Data Protection Regulation (GDPR) are met and that your data is protected by high security standards.

12) Tools and miscellaneous

Google Web Fonts

This app uses so-called web fonts from the following provider for the uniform display of fonts: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

When using this app, the required web fonts are loaded in order to display texts and fonts correctly and establish a direct connection to the provider’s servers. Certain browser information, including your IP address, is transmitted to the provider.

Data may also be transmitted to Google LLC, USA

The processing of personal data in the course of establishing a connection with the provider of the fonts is only carried out if you have given us your express consent to do so in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the “cookie consent tool” provided in the app. If your browser does not support web fonts, a standard font will be used by your computer.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

13) Rights of the data subject

13.1 The applicable data protection law grants you comprehensive data subject rights (rights of access and intervention) vis-à-vis the controller with regard to the processing of your personal data, about which we inform you below:

– Right to information in accordance with Art. 15 GDPR: In particular, you have the right to information about your personal data processed by us, the purposes of processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it was not collected by us from you, the existence of automated decision-making including profiling and, if applicable, meaningful information on the logic involved and the scope and intended effects of such processing on you, as well as your right to be informed of the guarantees pursuant to Art. 46 GDPR if your data is transferred to third countries;

– Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain without undue delay the rectification of inaccurate data concerning you and/or the completion of incomplete data stored by us;

– Right to erasure in accordance with Art. 17 GDPR: You have the right to request the erasure of your personal data if the requirements of Art. 17 para. 1 GDPR are met. However, this right does not exist in particular if the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims;

– Right to restriction of processing in accordance with Art. 18 GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is verified, if you refuse to delete your data due to inadmissible data processing and instead request the restriction of the processing of your data, if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have lodged an objection for reasons of your particular situation, as long as it is not yet clear whether our legitimate reasons prevail;

– Right to information in accordance with Art. 19 GDPR: If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.

– Right to data portability in accordance with Art. 20 GDPR: You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller, insofar as this is technically feasible;

– Right to withdraw consent given in accordance with Art. 7 para. 3 GDPR: You have the right to withdraw your consent to the processing of data at any time with effect for the future. In the event of revocation, we will delete the data concerned immediately, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

– Right to lodge a complaint pursuant to Art. 77 GDPR: If you believe that the processing of personal data concerning you infringes the GDPR, you have the right – without prejudice to any other administrative or judicial remedy – to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

13.2 Cancellation policy

If we process your personal data as part of a balancing of interests on the basis of our overriding legitimate interest, you have the right to object to this processing at any time with effect for the future on grounds relating to your particular situation.

If you exercise your right to object, we will stop processing the data concerned. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing which override your interests, fundamental rights and freedoms, or if the processing serves the establishment, exercise or defense of legal claims.

If we process your personal data for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing. You can exercise your objection as described above.

If you exercise your right to object, we will stop processing the data concerned for direct marketing purposes.

14) Duration of storage of personal data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and – if relevant – additionally by the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of express consent in accordance with Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.

If there are statutory retention periods for data that is processed within the scope of legal or similar obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after the retention periods have expired, provided that it is no longer required for contract fulfillment or contract initiation and/or we no longer have a legitimate interest in further storage.

When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 para. 2 GDPR.

Unless otherwise stated in the other information in this statement on specific processing situations, stored personal data will be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.