# Data privacy statement for Wooltasia apps

Thank you very much for your interest in our company and our apps. Data protection has a particularly high priority for the management of Wooltasia. It is possible to use Wooltasia's apps without providing any personal data. However, if a person concerned wishes to make use of special services of our company via our app, it can be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the EU's General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to Wooltasia. Through this data privacy statement, Wooltasia aims to inform the public about the nature, extent and purpose of the personal data we collect, use and process. In addition, this data privacy statement will inform individuals about their rights.

As the data controller, Wooltasia has implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this app. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed.

Term definitions Wooltasia's data privacy statement is based on the terms used by the European legislator and regulator in the adoption of the General Data Protection Regulation (GDPR). Our data privacy statement should be easy to read and understand for the public as well as for our customers and business partners. In order to guarantee this, we would like to explain the terms used in advance.

We use the following terms in this data privacy statement, among others:

a) Personal data Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). A natural person shall be considered identifiable if he can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
b) Data subject Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
c) Processing Processing means any operation or set of operations which is carried out with or without the aid of automated processes and which relates to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, restriction, erasure or destruction.
d) Restriction of processing Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) Profiling Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.
f) Pseudonymisation Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or data controller The controller or data controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the controller or controllers may be designated in accordance with Union law or with the law of the Member States on the basis of specific criteria.
h) Processor on order Processor on order is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient Recipient is a natural or legal person, public authority, agency or other body to whom personal data is disclosed, whether or not it is a third party. However, authorities which may receive personal data in the course of a specific investigation task under Union law or the law of the Member States shall not be considered as recipients.
j) Third party Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or processor.
k) Consent Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.

Name and address of the controller The person responsible in the spirit of the GDPR, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature:

Wooltasia GmbH

Taubenbergstr. 8a
83714 Miesbach
Germany

Email: info@wooltasia.com
Website: wooltasia.app

Collection of general data and information The Wooltasia App collects a series of general data and information each time the app is called up by an individual or an automated system. This general data and information is stored in the log files of the server. Recording can involve the (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the app from which an accessing system accesses our app (so-called referrer), (4) the sub-sites which are accessed via an accessing system on our app, (5) the date and time of an access to the App, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

By using this general data and information, Wooltasia does not draw any conclusions about the person concerned. This information is needed to (1) correctly deliver the content of our app, (2) optimize the content and advertising of our app, (3) ensure the long-term functionality of our information technology systems and the technology of our app, and (4) provide law enforcement authorities with the information they need to prosecute a cyber attack. This anonymously collected data and information is therefore evaluated by Wooltasia both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimum level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by the person concerned.

Routine deletion and blocking of personal data The controller shall process and store the personal data of the data subject only for the period of time necessary to achieve the storage purpose or where provided for by the European regulator and legislator or another legislator in laws or regulations to which the controller is subject.

If the storage purpose no longer applies or if a storage period prescribed by the European regulator and legislator or another competent legislator expires, the personal data shall be blocked or deleted routinely and in accordance with the statutory provisions.

Rights of the data subject

a) Right of confirmation Every data subject shall have the right, granted by the European regulator and legislator, to obtain from the controller confirmation as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.
b) Right of information Any person concerned by the processing of personal data has the right, granted by the European regulator and legislator, to obtain at any time, free of charge, from the controller, information on the personal data relating to him which has been stored and a copy of that information. Furthermore, the European regulator and legislator has granted the data subject access to the following information:

the processing purposes the categories of personal data processed the recipients or categories of recipients to whom the personal data has 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 that is not possible, the criteria for determining that 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 carried out 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 is not collected from the data subject: All available information on the origin of the data the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) GDPR and, at least in these cases, meaningful information on the logic involved, the scope and the intended effects of such processing on the data subject The data subject also has the right to know whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right of information, he or she may at any time contact an employee of the controller.

c) Right of rectification Any person concerned by the processing of personal data has the right, granted by the European regulator and legislator, to request the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject shall have the right, having regard to the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary statement.

If a data subject wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.

d) Right to deletion (right to be forgotten) Any person subject to the processing of personal data shall have the right, granted by the European regulator and legislator, to require the controller to erase without delay personal data concerning him which is subject to one of the following conditions and to the extent that the 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 Article 6(1)(a) GDPR or Article 9(2)(a) GDPR and there is no other legal basis for the processing. The data subject objects to the processing under Article 21(1) GDPR and there are no overriding legitimate reasons for the processing or the data subject objects to the processing under Article 21(2) GDPR. Personal data has been processed unlawfully. The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject. The personal data was collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR. If one of the above reasons applies and a data subject wishes to have personal data stored by Wooltasia deleted, he or she may at any time contact an employee of the data controller. The Wooltasia employee will ensure that the request for deletion is complied with immediately.

If the personal data have been made public by Wooltasia and if our company is obliged to delete the personal data as the person responsible pursuant to Art. 17 para. 1 GDPR, Wooltasia shall take appropriate measures, also of a technical nature, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data that the data subject has requested these other persons responsible for data processing to delete all links to this personal data or copies or replications of this personal data, insofar as this processing is not necessary. The employee of Wooltasia will take the necessary steps in individual cases.

e) Right to restrict processing Any person subject to the processing of personal data has the right, granted by the European regulator and legislator, to request the controller to limit the 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 allows the data controller to verify the accuracy of the personal data. The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data. The controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the assertion, exercise or defence of legal claims. The data subject has lodged an objection against the processing pursuant to Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the data subject. If one of the above conditions is met and a data subject wishes to request the limitation of personal data stored by Wooltasia, he/she may at any time contact an employee of the data controller. The Wooltasia employee will arrange for the processing to be restricted.

f) Right to data portability Any person subject to the processing of personal data has the right, granted by the European regulator and legislator, to obtain personal data concerning him or her which has been provided by the data subject to a controller in a structured, common and machine-readable format. He or she also has the right to communicate this data to another controller without being hindered by the controller to whom the personal data has been provided, provided that the processing is based on the consent pursuant to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR or on a contract pursuant to Art. 6 para. 1 letter b GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller.

Furthermore, when exercising his right to data transferability pursuant to Art. 20 (1) GDPR, the data subject shall have the right to obtain that the personal data be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.

In order to assert the right to data portability, the person concerned may contact a Wooltasia employee at any time.

g) Right to appeal Any person subject to the processing of personal data has the right, granted by the European regulator and legislator, to object at any time, for reasons related to his/her particular situation, to the processing of personal data concerning him/her on the basis of Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

Wooltasia will no longer process personal data in the event of an objection, unless we can prove compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.

If Wooltasia processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling in so far as it is connected with such direct advertising. If the data subject objects to processing by Wooltasia for direct marketing purposes, Wooltasia will no longer process the personal data for such purposes.

In addition, the data subject has the right to object to the processing of personal data concerning him by Wooltasia for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) GDPR on grounds relating to his particular situation, unless such processing is necessary for the performance of a task in the public interest.

To exercise the right to appeal, the person concerned may contact any Wooltasia employee or other employee directly. The data subject shall also be free to exercise his right of objection in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

h) Automated decisions in individual cases including profiling Any person subject to the processing of personal data has the right granted by the European regulator and legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon him or her or significantly affects him or her in a similar manner, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the data controller, or (2) is authorised by Union or national law or by the Member States to which the data controller is subject and which provides for adequate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, or (3) is taken with the express consent of the data subject.

Where (1) the decision is necessary for the conclusion or performance of a contract between the data subject and the data controller or (2) it is taken with the express consent of the data subject, Wooltasia shall take appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, including at least the right to have the data controller intervene, to present his or her point of view and to contest the decision.

If the data subject wishes to exercise rights relating to automated decisions, he or she may at any time do so by contacting an employee of the controller.

i) Right to revoke data privacy consent Any person subject to the processing of personal data has the right, granted by the European regulator and legislator, to revoke consent to the processing of personal data at any time.

If the data subject wishes to exercise his or her right to withdraw consent, he or she may do so at any time by contacting an employee of the controller.

Legal basis of the processing Art. 6 I lit. a GDPR serves our company as a legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the fulfilment of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same shall apply to such processing operations which are necessary for the implementation of pre-contractual measures, for example in cases of inquiries regarding our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our site were injured and his name, age, health insurance information or other vital information would have to be disclosed to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not predominate. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, he took the view that a legitimate interest could be assumed if the data subject is a customer of the data controller (recital 47 sentence 2 GDPR).
Qualified interests in the processing being pursued by the controller or a third party Is the processing of personal data based on Article 6 I lit. f GDPR, then our legitimate interest consists in conducting our business for the benefit of all of our employees and our shareholders.
Duration for which the personal data will be stored The criterion for the duration of the storage of personal data is the respective legal retention period. After this period has expired, the corresponding data will be routinely deleted if they are no longer required for the fulfilment or initiation of the contract.
Legal or contractual provisions governing the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the data We will inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a person concerned makes personal data available to us which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data would mean that the contract could not be concluded with the data subject. The data subject must contact one of our employees before providing personal data. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data and the consequences of not providing the personal data.
Existence of an automated decision making process As a responsible company, we refrain from automatic decision-making or profiling.
Crashlytics / Fabric.io We use the analysis tool Crashlytics from Fabric for the quality assurance of our apps. You can find Fabric's GDPR-compliant privacy statement here: Fabric data privacy statement (opens new window)
Because we operate a Facebook page and a Facebook group, we link you to Facebook's data privacy statement, so you have the opportunity to read information regarding the possible storage of personal data by Facebook:
Facebook data privacy statement (opens new window)

This data protection declaration was created by the data protection declaration generator of the DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external data protection officer for Munich, in cooperation with the lawyer for data protection law Christian Solmecke.
Point 11. was completed by Christian Ringshofer, the developer of the Wooltasia apps.