Personal data (hereinafter referred to as “Data”) will be processed by us only to the extent necessary and for the purpose of providing a functional and user-friendly Internet presence, including its contents and the services offered there (in particular AppArranger and HelpArranger).

According to Article 4(1) of Regulation (EU) 2016/679, i.e. the Basic Data Protection Regulation (hereinafter referred to only as “DPA”), “processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

With the following data protection declaration we inform you in particular about the type, scope, purpose, duration and legal basis of the processing of personal data, insofar as we decide either alone or together with others about the purposes and means of processing. In addition, we inform you in the following about the third-party components we use for optimisation purposes and to increase the quality of use, insofar as third parties process data on their own responsibility.

Our privacy policy is structured as follows:

1. Information about us as responsible persons / data protection officer
   II. Rights of users and data subjects
   III. Information on data processing
2. Information about us as responsible persons

Responsible provider of this service in the data protection sense is:

AppArranger AG
Lerchenfeldstrasse 3
9014 St. Gallen
Switzerland

Phone: +41 44 515 95 00

E-Mail: [email protected]

1. Rights of users and data subjects

With regard to the data processing described in more detail below, users and data subjects have the right

– to obtain confirmation as to whether or not data relating to him/her are being processed, information on the data processed, further information on the data processing and copies of the data (see also Art. 15 GDPR)

– the correction or completion of incorrect or incomplete data (see also Art. 16 GDPR);

– to the immediate deletion of data relating to them (cf. also Art. 17 GDPR), or, alternatively, if further processing is necessary pursuant to Art. 17 para. 3 GDPR, to the restriction of processing in accordance with Art. 18 GDPR;

– to the receipt of data concerning them and provided by them and to the transfer of such data to other providers/responsible parties (cf. also Art. 20 GDPR);

– to lodge a complaint with the supervisory authority if they are of the opinion that data concerning them is being processed by the provider in breach of data protection provisions (cf. also Art. 77 GDPR).

In addition, the provider is obliged to inform all recipients to whom data has been disclosed by the provider about any correction or deletion of data or the restriction of processing that is carried out on the basis of Articles 16, 17 (1), 18 GDPR. However, this obligation does not apply if such notification is impossible or involves disproportionate effort. Notwithstanding this, the user has a right to information about these recipients.

Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the future processing of data concerning them, provided that the data are processed by the provider in accordance with Art. 6, paragraph 1, letter f) GDPR. In particular, an objection to data processing for the purpose of direct marketing is permitted.

III. Information on data processing

Your data processed when using our website will be deleted or blocked as soon as the purpose of the storage no longer applies, the deletion of the data does not conflict with any legal storage obligations and no other information on individual processing methods is provided below.

Server data

For technical reasons, in particular to ensure a secure and stable Internet presence, data is transmitted to us or to our web space provider by your Internet browser. These so-called server log files are used to record, among other things, the type and version of your Internet browser, the operating system, the website from which you have switched to our Internet presence (referrer URL), the website(s) of our Internet presence that you visit, the date and time of the respective access and the IP address of the Internet connection from which our Internet presence is used.

This data is temporarily stored, but not together with other data about you.

This storage takes place on the legal basis of Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in the improvement, stability, functionality and security of our Internet presence.

The data will be deleted after one year at the latest, unless further storage is required for evidential purposes. Otherwise, the data are completely or partially excluded from deletion until the final clarification of an incident.

Contract implementation

The data transmitted by you for the use of our service offer are processed by us for the purpose of contract implementation and are required in this respect. Conclusion and processing of the contract are not possible without providing your data.

The legal basis for the processing is Art. 6 para. 1 lit. b) GDPR.

We delete the data when the contract has been completely processed, but must observe the retention periods under tax and commercial law.

Within the scope of contract processing, we pass on your data to the company or person commissioned with the service, insofar as the passing on of data is necessary for the fulfilment of the service or for payment purposes.

The legal basis for the transfer of data is then Art. 6 para. 1 lit. b) GDPR.

Customer account / registration function

If you create a customer account with us via our website, we will collect and store the data you enter during registration (e.g. your name, your address or your e-mail address) exclusively for pre-contractual services, for the fulfilment of the contract or for the purpose of customer care (e.g. to provide you with an overview of your previous orders with us or to offer you the so-called notepad function). At the same time we will save the IP address and the date of your registration together with the time. Of course, this data will not be passed on to third parties.

Within the scope of the further registration process, your consent to this processing will be obtained and reference will be made to this data protection declaration. The data collected by us in the process will be used exclusively for the provision of the customer account and for the provision of our services.

Insofar as you consent to this processing, Art. 6 para. 1 lit. a) GDPR is the legal basis for the processing.

Insofar as the opening of the customer account additionally serves pre-contractual measures or the fulfilment of the contract, the legal basis for this processing is also Art. 6 para. 1 lit. b) GDPR.

You may revoke the consent given to us to open and maintain the customer account at any time with effect for the future in accordance with Art. 7 para. 3 GDPR. To do so, you must only inform us of your revocation.

The data collected in this respect will be deleted as soon as the processing is no longer necessary. However, we have to observe tax and commercial law retention periods.

Newsletter

If you register for our free newsletter, the data requested by you for this purpose, i.e. your e-mail address and – optionally – your name and address, will be transmitted to us. At the same time we save the IP address of the internet connection from which you access our website as well as the date and time of your registration. During the further registration process, we will obtain your consent to send you the newsletter, describe the content specifically and refer you to this data protection declaration. We use the data collected in the process exclusively for sending the newsletter – they are therefore in particular not passed on to third parties.

The legal basis for this is Art. 6 para. 1 lit. a) GDPR.

You can revoke your consent to receive the newsletter at any time with effect for the future in accordance with Art. 7 para. 3 GDPR. To do so, you only need to inform us of your revocation or click on the unsubscribe link contained in every newsletter.

Contact enquiries and possibilities

If you contact us via contact form or e-mail, the data you provide will be used to process your request. The provision of the data is necessary for processing and answering your enquiry – without the provision of this data, we cannot answer your enquiry or can only answer it to a limited extent.

The legal basis for this processing is Art. 6 para. 1 lit. b) GDPR.

Your data will be deleted if your enquiry has been finally answered and the deletion is not opposed by any legal storage obligations, as for example in the case of a possible subsequent contract processing.

Google Analytics

We use Google Analytics in our Internet presence. This is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter referred to as “Google”.

Through the certification according to the EU-US Privacy Shield https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

guarantees Google that the data protection requirements of the EU will also be observed when processing data in the USA.

The Google Analytics service is used to analyse the usage behaviour of our website. The legal basis is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimisation and economic operation of our website.

Usage and user-related information, such as IP address, place, time or frequency of the visit to our website, is transferred to a Google server in the USA and stored there. However, we use Google Analytics with the so-called anonymisation function. With this function Google shortens the IP address already within the EU or EEA.

The data collected in this way is in turn used by Google to provide us with an evaluation of the visit to our website and the usage activities there. This data can also be used to provide other services related to the use of our website and the use of the Internet.

Google states that it will not link your IP address to other data. Google also keeps a record of your IP address under

https://www.google.com/intl/de/policies/privacy/partners

will provide you with further information on data protection law, for example on the possibilities of preventing the use of data.

In addition, Google offers under

https://tools.google.com/dlpage/gaoptout?hl=de

a so-called. deactivation add-on along with further information about it. This add-on can be installed with all common internet browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs the JavaScript (ga.js) of Google Analytics that information about your visit to our website should not be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analysis services. Whether and which other web analysis services are used by us, you will of course also find out in this data protection declaration.

Subcontracted processors

We contract with the following trusted sub-processors who provide parts of the service related to the processing of personal information on behalf of AppArranger:

Microsoft (Azure)- Location: Switzerland – Service: Data Processing and Hosting

Twillio (SendGrind)- Location: San Francisco USA – Service: Cloud communication platform

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