As of May 23, 2018
The protection of the personal data of users is of great importance to the CodeKonditor UG (haftungsbeschränkt), hereinafter
of personal information that results from your use of our software applications ("apps") and web sites (collectively
referred to as "the offer"). Unless otherwise stated, the following information refers to our offer in general.
In the collection, processing and storage of personal data, we comply with the statutory provisions of the Federal Data Protection
Act (BDSG) and the Telemedia Act (TMG) of the Federal Republic of Germany, as well as to the General Data Protection
Regulation (GDPR) of the European Union.
The collection, processing and storage of personal data always takes place under the principle of data avoidance, data transparency
and data security.
The responsible entity within the meaning of the General Data Protection Regulation and the data protection law applicable
in the Federal Republic of Germany is the
CodeKonditor UG (haftungsbeschränkt)
1. General information about the data processing
Policy, the term
‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether
or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction;
‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain
personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s
performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or
‘controller’ means 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 determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided
for by Union or Member State law;
‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf
of the controller;
‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed,
whether a third party or not. However, public authorities which may receive personal data in the framework of a particular
inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data
by those public authorities shall be in compliance with the applicable data protection rules according to the purposes
of the processing;
‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller,
processor and persons who, under the direct authority of the controller or processor, are authorised to process personal
‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s
wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of
personal data relating to him or her;
‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships
or associations regularly engaged in an economic activity;
‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article
51 of the GDPR;
‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the
European Parliament and of the Council;
‘international organisation’ means an organisation and its subordinate bodies governed by public international law, or any
other body which is set up by, or on the basis of, an agreement between two or more countries.
1.2 Scope of the collection, processing and storage of personal data
Personal data about you will only be collected, processed and stored by us, if this is permitted or required by law or if
you have expressly consented to the data collection.
2. What information is collected and how is it used?
2.1 Data collected when using our websites
Each time you access our web pages, our system automatically collects various data from the calling computer. These data
include, but are not limited to, the name of the retrieved web page, which file was retrieved, the date and time of the retrieval,
the amount of data transmitted, a message that the retrieval was successful, the type and version of the browser you are
using, your operating system, possibly the referrer URL (the previously visited page), your IP address, as well as your Internet
service provider and other similar information that serves to guard against dangers in the event of an attack on our systems.
This data is stored in the log data of our system. We use this log data only for statistical evaluations for the purpose
of operation, safety and optimization of our offer. An evaluation of the data for marketing purposes does not take place
in this context. A storage of this data together with other personal data of you also does not take place. The data will
be deleted as soon as it is no longer necessary for the purpose of its collection. This is the case after seven days at the
latest. Further storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment
of the calling client is no longer possible.
Our websites currently do not use analytics tools such as Google Analytics. If we use analytics tools in the future, we will,
2.2 Data collected when contacting us
When contacting us (for example via contact form or e-mail), your data transmitted to us will be stored for the purpose of
processing your request as well as in case of follow-up questions. There is no disclosure of this data to third parties.
Please note that e-mails sent unencrypted to us may possibly be read by third parties during transmission. We usually can
not verify your identity and we do not know who is behind an email address. A legally secure communication by simple
e-mail is therefore not guaranteed. We also use filters against unwanted advertising (so-called "SPAM filters"), which
in rare cases also automatically classify and delete normal e-mails as unwanted advertising. E-mails containing harmful
programs ("viruses") will be automatically deleted by us in any case.
If you would like to send us messages that you would like to protect, we recommend encrypting and signing them to prevent
unauthorized access or falsification in the transmission path or to send the message to us by conventional mail. The
PGP key identifier of our contact address firstname.lastname@example.org is 3A975A479A8D04AA.
2.3 Data collected when using our apps
All data collected, processed and stored using our apps always has the clear purpose of providing a specific feature within
our apps. During installation, our apps may request specific access permissions. Our apps never claim more privileges than
is strictly necessary to properly deliver their functionality. Here are some of the permissions our apps require and what
they are necessary for.
Some of our applications detect and use the exact location of the user, e.g. via GPS or similar technologies. This information
is necessary for the correct operation of the application, e.g. to show you your current position on a map. In some cases,
we also use this information to provide you with more relevant advertising. For this, your current location will be forwarded
to our advertising partners. If you do not want that, you can turn off location tracking in your device.
Some of our applications use the camera (s) in your mobile device (smartphone or tablet PC). This is necessary for the correct
functioning of the application, for example, to display a camera image of your environment in which an object is displayed
(so-called Augmented Reality). The images recorded by the camera are processed exclusively locally on your device and (if
at all) stored only locally on your device. Further use of the pictures taken by the camera does not take place.
Some of our applications can access the storage of your mobile device. This permission is necessary and will be used exclusively
to allow you to set your own picture as wallpaper in some of our "live wallpaper" apps. An additional use of the authorization
does not take place.
3. Transfer of data to third parties
To give you the best possible app experience, we use third-party services, such as Google, in some of our apps. Third-party
providers must agree to the restrictions on the access, storage and use of personal data. Where necessary, we will enter
into contractual agreements (for example through a data-processing agreement) and take appropriate technical measures
to prevent possible misuse of such data by third-party providers. However, we can not guarantee that all third party
providers comply with these restrictions and agreements. A transfer to third party providers takes place exclusively
via a TLS / SSL encrypted connection. The only third party is currently Google. Here you can find more information about
the privacy policies of Google:
4. Data erasure and storage duration
Personal data of users will be deleted or blocked as soon as the purpose of the storage is no longer existent. It may also
be stored if provided for by the European or national legislator in EU regulations, laws or other regulations to which we
are subject. Blocking or deletion of the data also takes place when a storage period prescribed by the standards mentioned
expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.
5. Security of data
CodeKonditor uses appropriate technical and organizational security measures to protect users' personal data stored on its
products against manipulation, loss and unauthorized access by third parties. In addition, we are constantly improving our
security measures in line with technical developments. Although we make every effort to protect our systems, there can be
no assurance that our systems will be 100% immune from misconduct, malfunction, improper interception or access, or other
types of misuse.
6. Your rights
Right of access by the data subject
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning
him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients
in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used
to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of
processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and,
at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the
right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal
data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to
have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’)
- The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her
without undue delay and the controller shall have the obligation to erase personal data without undue delay where
one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise
- the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or
point (a) of Article 9(2), and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds
for the processing, or the data subject objects to the processing pursuant to Article 21(2);
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which
the controller is subject;
- the personal data have been collected in relation to the offer of information society services referred to in
- Where the controller has made the personal data public and is obliged pursuant to paragraph 1 GDPR to erase the personal
data, the controller, taking account of available technology and the cost of implementation, shall take reasonable
steps, including technical measures, to inform controllers which are processing the personal data that the data subject
has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
- Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller
is subject or for the performance of a task carried out in the public interest or in the exercise of official
authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article
9(2) as well as Article 9(3); GDPR
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
in accordance with Article 89(1) in so far as the right referred to in paragraph 1 GDPR is likely to render
impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
Right to restriction of processing
- The data subject shall have the right to obtain from the controller restriction of processing where one of the following
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify
the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction
of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by
the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate
grounds of the controller override those of the data subject.
- Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only
be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for
the protection of the rights of another natural or legal person or for reasons of important public interest of the
Union or of a Member State.
- A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller
before the restriction of processing is lifted.
Right to data portability
- The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided
to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those
data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR
or on a contract pursuant to point (b) of Article 6(1) GDPR; and
- the processing is carried out by automated means.
- In exercising his or her right to data portability pursuant to paragraph 1 GDPR, the data subject shall have the right
to have the personal data transmitted directly from one controller to another, where technically feasible.
- The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17 GDPR. That
right shall not apply to processing necessary for the performance of a task carried out in the public interest or
in the exercise of official authority vested in the controller.
- The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Right to object
- The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time
to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including
profiling based on those provisions. 2The controller shall no longer process the personal data unless the controller
demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of
the data subject or for the establishment, exercise or defence of legal claims.
- Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any
time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent
that it is related to such direct marketing.
- Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed
for such purposes.
- At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and
2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately
from any other information.
- In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject
may exercise his or her right to object by automated means using technical specifications.
- Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to
Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to
object to processing of personal data concerning him or her, unless the processing is necessary for the performance
of a task carried out for reasons of public interest.
Automated individual decision-making, including profiling
- The data subject shall have the right not to be subject to a decision based solely on automated processing, including
profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
- Paragraph 1 shall not apply if the decision:
- is necessary for entering into, or performance of, a contract between the data subject and a data controller;
- is authorised by Union or Member State law to which the controller is subject and which also lays down suitable
measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
- is based on the data subject’s explicit consent.
- In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures
to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human
intervention on the part of the controller, to express his or her point of view and to contest the decision.
- Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article
9(2)1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights
and freedoms and legitimate interests are in place.
Right to withdraw consent
The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect
the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed
thereof. It shall be as easy to withdraw as to give consent.
7. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing of personal data, Article 6 (1) (a) of the GDPR serves
as the legal basis.
The processing of personal data necessary for the performance of a contract to which the data subject is a party is the legal
basis of Article 6 (1) (b) of the GDPR. This also applies to processing operations required to carry out pre-contractual
Insofar as it is necessary to process personal data in order to fulfill a legal obligation that our company is subject to,
Article 6 (1) (c) of the GDPR serves as the legal basis.
In the event that vital interests of the data subject or any other natural person require the processing of personal data,
Article 6 (1) (d) of the GDPR shall serve as the legal basis.
If the processing is necessary to safeguard the legitimate interests of our company or a third party and the interests, fundamental
rights and fundamental freedoms of the person concerned do not outweigh the former interest, then Article 6 (1) (f) of
the GDPR serves as the legal basis for the processing.
8. Contact us
If you have any questions regarding the processing of your personal information, or you wish to avail yourself of one or
more of the rights listed in Section 6, you can always contact us. We are also available to you in case of requests for
information or complaints:
CodeKonditor UG (haftungsbeschränkt)
there be any differences in meaning between the English and the German version due to the translation, the German version