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Data Protection Notice »ich pflege« App

LifeBonus Gesundheitsmanagement GmbH provides you with the »ich pflege« app, which you can download and use on your mobile device. In the following, we inform you about the processing of personal data when using our mobile app.

 

Personal data is all data that can be related to you personally. This includes, for example, information about your user behaviour. Personal data also includes the assigned IP address or the device identification.

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Person responsible

The data controller is:

 

LifeBonus Gesundheitsmanagement GmbH,

Flughafenstr. 1-3,

Airport Plaza (Building C, Level 3),

22335 Hamburg

 

Phone: +49 40 5075 3733

 

Email: datenschutz@lifebonus.health

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Downloading the app from the App Store

The app must be downloaded from the service provider Google Play Store or the App Store (Apple). As a precaution, we would like to point out that when downloading the app from the App or Play Store, data may be transferred to the operators of the stores. This can be found in the terms of use of the respective operators. We have no influence on this data collection and are not responsible for it.

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Storage period

Unless otherwise stated in the following information, we only store data processed via the Carers' App for as long as is necessary to achieve the processing purpose pursued or to fulfil our contractual or legal obligations. We will then delete the processed data. We are obliged to carry out this deletion pursuant to Art. 17 (1) a) DSGVO. It is therefore based on the legal basis of Art. 6 para. 1 lit. c) DSGVO.

 

Statutory retention obligations may arise in particular from commercial or tax regulations. From the end of the calendar year in which the data was collected, we will retain such personal data contained in our accounting data for ten years and retain personal data contained in commercial letters and contracts for six years. The legal basis for the storage in this case is Art. 6 para. 1 lit. c) in conjunction with the legal obligation to retain data.

 

In addition, we will store data in connection with consents requiring proof as well as with complaints and claims for the duration of the statutory limitation periods. The legal basis for the storage in this case is Art. 6 para. 1 letter f) DSGVO. The storage of this data serves our legitimate interest in asserting, exercising or defending claims under civil law.

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Categories of data recipients

We use processors as part of the processing of your data. The processing operations carried out by such processors include, for example, the hosting of the app or maintenance and support of the IT systems used.

 

The processing of the data takes place on the German servers of our technical service provider Amazon Web Services Inc. which acts as a processor for us. A processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the data controller. Processors do not use the data for their own purposes, but carry out the data processing exclusively for the controller and are contractually obliged to ensure appropriate technical and organisational measures for data protection.

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Technical service provider

The data is processed on the German servers of our technical service provider Amazon Web Services, Inc. which has been commissioned by us for this purpose. The service provider only processes the data according to explicit instructions and is contractually obliged to guarantee sufficient technical and organisational measures for data protection.

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Data processing when using the app

When you use our mobile app, we process the following data, among others, which are technically necessary for us to offer you the functions of our mobile app and to ensure stability and security:

  • Anonymized IP address

  • Operating system

  • Country/State

  • Language

  • Time zone

  • Connection speed

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Registration and account

Our app offers you the possibility to create a free personal account. Registration is necessary for this. You can use the account to save your personal settings. As a registered user, you will also receive regular information about news in the app that are relevant to you.

 

For registration, it is necessary that you provide your e-mail address and a first name and set a password for your account. Providing this information is mandatory in order to complete the registration.

 

Alternatively, you can also use the Google SignIn or Apple SignIn functions to create an account. In this case, the respective provider will provide us with the email address and first name that you have stored in your account with the respective provider.

 

The processing of the provided data in the context of the registration and use of the account is based on the legal basis of Art. 6 para. 1 letter b) DSGVO.

 

We also use the data provided to personalise our offer and to address you personally. In particular, we will use your email address to send you further news and offers about our app.

 

The processing is based on the legal basis of Art. 6 (1) (f) DSGVO. It serves our legitimate interest to get in touch with the users of our app.

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Processing of data in the content management system

When you use functions of our app, data about this use is stored in the app's content management system. LifeBonus employees have access to the data stored on the German servers. This data can be viewed via the content management system. Data processing takes place exclusively in this way. Whether and to what extent data is processed when a function is used can be found below in the respective note on the function. This processing serves the purpose of obtaining information about the activities of the users of our app, which is necessary for the use of the app. The legal basis for the processing is Art. 6 para. 1 letter b) DSGVO.

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Mobile marketing tool

When you use functions of our app, data about your usage behavior is stored in the mobile marketing tool. This data is used to generate and send personalized content and messages. We only use this data ourselves and only pass it on to a service provider that provides the marketing tool and acts as a processor for us.
We use functions of the web analysis service Amazon Pinpoint for this purpose.
 

The provider
Amazon Web Services EMEA SARL
38 Avenue John F. Kennedy
L-1855, Luxembourg
 

The legal basis for processing is Art. 6 (1) (b) GDPR. The data is only stored and processed on European servers.

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Analytics Tool

In order to enable statistical processing of the data collected when using the app (such as the number of all people active in the app), the data is processed using analytics software. No data is read from the device memory of the end device used for the analysis. The processing takes place exclusively on LifeBonus Gesundheitsmanagement GmbH's own servers and thus within the EU. There is no data transfer to a third country.

 

The analytics software creates a user ID the first time it is used. The measured user behaviour, such as navigation events in the app, is linked to this. Only data on user behaviour within the app is processed.

 

The processing of personal data in the context of the use of these functions is based on the legal basis of Art. 6 (1) (f) DSGVO. This processing serves our legitimate interest in obtaining information about the use of our app and to make adjustments to our app or our offer on this basis.  You can object to this processing at any time by notifying LifeBonus Gesundheitsmanagement GmbH of your objection using the contact details provided above.

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Subscription

To use all the functions of the app, you must take out a paid subscription. The subscription is managed via the Google Play platform or the App Store. We do not receive any personal data from Apple regarding the purchase. We receive the following data from Google Play:

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  • First name

  • Last name

  • Email

  • Country (country code)

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We use this data to manage the subscription and, if necessary, to communicate with you. The storage and processing of this data is based on the legal basis of Art. 6 (1) (f) DSGVO. The processing serves our legitimate interest in obtaining information about the users of our app and being able to contact them.

 

If you have taken out a subscription, the following functions are available to you. Without a subscription, you have limited access.

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Care

This section covers everything you need to know for home care. The information is conveyed via videos. Data about your usage behaviour is collected here.

 

The processing of personal data in the context of the use of these functions is based on the legal basis of Art. 6(1)(b) DSGVO.

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For me

This section includes information and exercises to help you stay healthy yourself. The information is provided via videos. Data about your usage behaviour is collected here.

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Favourites  

Favourite content is only stored locally on the smartphone.

These are analysed with the analysis tool.

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Google Firebase

We use the Google Firebase development platform of the provider Google Cloud EMEA Limited (Google) based in Ireland/EU for our apps.

 

Google Firebase is a platform for developing apps for mobile devices and websites. Google Firebase provides functions such as analyses, databases, messaging and crash reports as well as the technical infrastructure for operating the app via a software development kit (SDK).

 

Depending on the respective function, online identifiers such as the IP address used and the Firebase installation IDs are processed for this purpose. In addition, some functions use further information about the end device used. Furthermore, individual functions process additional personal data. Further information on the Google Firebase functions, the data processed in each case and the respective storage period can be found at https://firebase.google.com/support/privacy. The data is transmitted to Google and processed on our behalf.

 

The processing of personal data within the scope of Google Firebase is carried out to protect our legitimate interest in managing and controlling our app on the basis of a developer platform. The legal basis for the processing of personal data in this case is Art. 6 (1) (f) DSGVO.

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Google Analytics for Firebase

We use the Google Analytics for Firebase service of the provider Google Ireland Limited (Google Ireland) in our app.

 

The Google Analytics for Firebase service is a function of the Google Firebase development platform. Google Analytics is an analysis service that enables us to collect and analyse data about the behaviour of the users of our app in order to compile reports about the activities within our app. This involves the processing of personal data in the form of online identifiers, IP addresses, device identifiers and information about interaction with our app. You can find further information on data collection in Google Analytics at https://support.google.com/firebase/answer/6318039. The data is transmitted to Google Ireland and processed on our behalf.

 

Some of this data is information stored in the device you are using. In addition, Google Analytics may also store further information on the end device you are using. Such storage of information by Google Analytics or access to information already stored in your terminal device will only take place with your consent. The legal basis for data processing in connection with the Google Analytics service is therefore Art. 6 (1) a) DSGVO. You can revoke your consent at any time with effect for the future in the settings of our app.

 

Google Analytics stores certain data linked to an advertising identifier for 60 days and retains aggregated reporting without automatic expiry. Retention of user-level data, including conversions, is set at up to 14 months. For all other event data, retention is set at 2 months.

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Processing when exercising your rights according to Art. 12 to 22 DSGVO

Pursuant to Articles 15 to 22 of the GDPR, you have the right to information and access, deletion, restriction of processing and objection to your personal data. If you exercise these rights, we process the transmitted personal data for the purpose of implementing these rights and to be able to provide proof thereof.

 

We then process the stored data exclusively for the purpose of providing information and preparing it, as well as for data protection control purposes.

 

These processing operations are based on the legal basis of Art. 6 para. 1 lit. c) DSGVO in conjunction with. Articles 15 to 22 DSGVO and Section 34 (2) BDSG.

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Your rights

As a data subject, you can assert your data subject rights against us. In doing so, you have the following rights:

  • In accordance with Art. 15 DSGVO and Section 34 BDSG, you have the right to request information as to whether and, if so, to what extent we are processing personal data relating to you or not.

  • The right, in accordance with Art. 16 DSGVO, to demand that we correct your data if it is incorrect.

  • The right to demand that we delete your personal data in accordance with Art. 17 DSGVO and § 35 BDSG. You can delete your account yourself at any time or instruct LifeBonus Gesundheitsmanagement GmbH to delete individual or all data. If the account is deleted independently, all personal data on our servers will be deleted immediately.

  • The right to have the processing of your personal data restricted in accordance with Art. 18 DSGVO. For this purpose, you can deactivate or not use the functions of the app.

  • The right, in accordance with Article 20 of the GDPR, to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and to transfer this data to another controller.

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Right to object

In accordance with Art. 21 GDPR, you have the right to object to any processing based on the legal basis of Art. 6 Para. 1 Letter e) or f) GDPR. To do this, contact the data protection officer at LifeBonus Gesundheitsmanagement GmbH. You can reach this at: datenschutzbeauftragter@lifebonus.health

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Complaint to a supervisory authority

If you believe that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR.

 

To complain, contact:

 

Hamburg Commissioner for Data Protection and Freedom of Information

Ludwig-Erhard-Str. 22, 7th floor

20459 Hamburg

 

Phone: (040) 428 54 - 4040

 

Email: mailbox@datenschutz.hamburg.de

 

 

Status: April 2023

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