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Privacy Policy for the Flip App

– Information in accordance with the General Data Protection Regulation("GDPR") –

1.             Introduction

In the following, we provide information about the collection of personal data when using our mobile app (hereinafter only "App"). Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1           Contact details

The controller within the meaning of Art. 4 (7) EU General Data Protection Regulation (GDPR) is:

 

Flip GmbH

Rotebühlstraße 50

contact@getflip.com

 

Contact Data Privacy:

datenschutz@flipapp.de

 

1.2          Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.

1.3          Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4         Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

 

1.5          Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.     

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6          Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7          No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8          Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2.            Data processing in the app

2.1          Downloading the app

Our app is ready for download at the following stores:

  • Apple's App Store

(hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.

2.2         Hosting

Our app is hosted by ​

  • Microsoft Ireland Operations Limited, One Microsoft Court, South County Business Park, Leopardstown, Dublin 18, D18DH6k

 

The provider thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data in the EU. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

2.3         Informative use of our website

When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

The data processed to this extent are:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete interface)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Operating system and its interface
  • Language and version of the operating system

 

2.4        Access to functions or data

The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.

The functions or data processed to this extent are

  • Storage, camera, microphone and gallery
  • Push-notification​.

2.5         Data processing for the provision of functions

In the app, we process data in order to provide the user with functions of the app. The legal basis for the processing is the usage agreement concluded with the user via the app.

The data processed to this extent are

  • Universal Unique Identifier of the device (UUID), other identifications than UUID

2.6        User account

Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR. We delete the data when users delete their user account.

2.7         Single sign-on

Users can log in to our app using one or more single sign-on methods. In doing so, they use the login data already created for a provider. The prerequisite is that the user is already registered with the respective provider. When a user logs in using a single sign-on procedure, we receive information from the provider that the user is logged in to the provider and the provider receives information that the user is using the single sign-on procedure in our app. Depending on the user's settings in his account on the provider's site, additional information may be provided to us by the provider. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing users with a simple log-in option. At the same time, the interests of the users are safeguarded, as use is only voluntary.

Providers of the offered method(s) are:

 

2.8        Third-party tools

2.8.1      ​Firebase Cloud Messaging​

We use Firebase Cloud Messaging to communicate with users. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://firebase.google.com/support/privacy.

 

1.1.1         Google Cloud Paltform (optional)

 

We use Google for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

  

1.1.2       Hibase UG (optional)

 

We use hibase UG for analytics. The provider is hibase UG, Wildenbruchstr. 88, 12045 Berlin, Germany. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://hibase.co/privacy-policy. 

 

1.1.3       Mixpanel​ (optional)

We use Mixpanel for analytics. The provider is Mixpanel, Inc., One Front Street, Floor 28, San Francisco, CA 94111, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://mixpanel.com/legal/privacy-policy/.

       

1.1.4       DeepL (optional)

We use DeepL for translations. The provider is DeepL SE, Maarweg 165, 50825 Cologne, Germany. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in automatically translating information on our website.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.deepl.com/privacy.

 

1.1.5       Mailjet (optional)

We use Mailjet to send password reset emails. The provider is Mailjet GmbH, Friedrichstraße 68, 10117 Berlin. The provider processes meta/communication data (e.g. IP addresses) and email addresses in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in providing users with a way to reset their password so that they can access the app.

The data is deleted when the purpose of its collection no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.mailjet.com/legal/privacy-policy/.

 

1.1.6       Zendesk (optional)

We use Zendesk for customer relationship management and administration of customer support requests. The provider is Zendesk, Inc., 1019 Market St., San Francisco, CA 94103, USA. The provider processes content data (e.g. entries in online forms), contact data (e.g. email addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.zendesk.de/company/agreements-and-terms/privacy-policy/.

 

1.1.7        Jitsi (optional)

We use Jitsi for video conferencing. The provider is Helsinki Systems GmbH, Industriestr. 24, 70565, Stuttgart, Germany. The provider processes meta/communication data (e.g. IP addresses) and email addresses in the EU.

The processing takes place exclusively outside of our app. If a user wants to start a video conference, they can create an external Jitsi link in the app and go to their website. We do not share any of your personal data with Jitsi ourselves.

Further information can be found in the provider's privacy policy at https://jitsi.org/meet-jit-si-privacy/.

2.            Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

3.            Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.