50 Apps UG (hereinafter, "the Company" or "we") takes the protection of your personal data seriously. At this point, we would like to inform you about how your personal data is processed when visiting our website, www.soberway.app.
In the sense of Art. 4 (7) of the General Data Protection Regulation (GDPR) of the EU, the entity responsible for the processing of your personal data in connection with the use of our website is:
50 Apps UG
Alt-Tegel 6
13507 Berlin
Email: amr@soberway.app
When visiting our website, some of your private data could be processed by us.
When you visit our website, a so-called log data record (in the form of server log files) is stored on our web server, temporarily and anonymously. This consists of:
– the page from which you were redirected (so-called referrer URL)
– the name and URL of the page that is called up
– the date and time of the call-up
– the description of the type, language and version of the web browser used
– the IP address of the computer used to call up the website, shortened in such a way that it is no longer possible to make any reference to any specific person
– the volume of the transmitted data
– the operating system used
– notification as to whether or not the call-up was successful (access status/http status code)
– the GMT time-zone difference
This data is processed in order to facilitate the technical operation of our website and for the purposes of statistical analysis, the identification and tracing of unauthorized access to the web server and other criminal offenses.
The legal basis for the processing of data is Art. 6 (1) p. 1 (f) GDPR. Our legitimate interest for the need to temporarily store the technical access data is to enable us to provide you with a technically functional and user-friendly website, and to be able to guarantee the security of our systems.
The storage of information on your end device and the extraction of this information takes place independently of the technology used (cookies, object storage, pixels, web beacons, etc.) on the basis of your consent, pursuant to § 25 (1) of the German Telecommunications Services Data Protection Act (TTDSG), which you automatically declare by means of an opt-in. You can revoke the consent you have declared in this way at any time, via the cookie settings. If the storage is absolutely necessary to enable the functioning of the website, the legal basis for the storage of data is § 25 (2) (2) TTDSG.
The recipients of the data are our hosting service providers.
Log file information is saved for a maximum of 30 days from the end of your visit, and thereafter, it is deleted.
The processing of the data is required for the operation of our website. If you do not want us to process your data, you can avoid this by not visiting our website.
The provision of personal data is neither legally nor contractually required, but it is necessary for the functioning of our website.
We use cookies on our website. Cookies are small text files that are allocated to the browser you are using and stored on your hard drive by means of a distinctive character string. Certain information flows through these files to the entity that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer; therefore they cannot do any damage. Their primary purpose is to make the overall internet offer faster and more effective, in other words, more user-friendly for you.
Cookies can contain data that enables the recognition of the device used. In some cases, however, cookies only contain information on certain settings that cannot be attributed to a specific person. However, cookies are not able to identify a user directly.
A differentiation is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. Cookies are further differentiated in terms of their function:
– Technical Cookies: These are essential in order to navigate the website, utilize basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, and neither do they store any information on the web pages you have visited;
– Performance Cookies: These collect information about the way you use our website, which pages you visit and whether any errors occur during the use of the website, for example; they do not collect any information that could identify you – all of the information that is collected is anonymous and it is only used to improve our website and to find out what interests our users;
– Advertising Cookies, Targeting Cookies: These are used to offer our users needs-based advertising or fitting offers from third parties on the website, and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
– Sharing Cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.
The use of cookies enables us to ensure the proper functioning of our website. It also allows us to optimize the website experience for our users. This is for data processing purposes.
Any use of cookies that is not absolutely necessary from a technical point of view constitutes data processing that is only permitted with your consent, pursuant to Art. 6 (1) p. 1 (a) GDPR. This applies particularly to the use of advertising, targeting or sharing cookies. Furthermore, we will only disclose your personal data that is processed by cookies to third parties if you have given your consent for us to do so, in accordance with Art. 6 (1) p. 1 (a) GDPR. In the following section, we will list the legal bases relating to the respective service.
The storage of cookies on your end device and the reading out thereof, is done on the basis of your consent, pursuant to § 25 (1) TTDSG, which you declare through an opt-in. You can revoke your consent at any time via the cookie settings. If the storage of any data is absolutely necessary, in order to make the website available, the legal basis for the storage of this data is § 25 (2) (2) TTDSG.
We only store your data for as long as it is required in order to fulfill the aforementioned purposes. Thereafter, the cookies are deleted.
Insofar as your consent pursuant to Art. 6 (1) p. 1 (a) GDPR is the legal basis for the processing of the data, you can revoke your consent at any time. You can do so by deleting the cookies in your browser.
The provision of personal data is neither legally nor contractually required, but it is necessary for the functioning of our website, and if you withhold such data, the functionality of our website may not be guaranteed, and some of the individual services might not be available to you.
If you contact us by email, via a contact form or over the phone, the data you provide us with, such as your email address, your name where applicable and your telephone number, as well as details of your request, will be stored by us, to enable us to answer your questions.
The processing of your data is for the purpose of dealing with your inquiry.
If the purpose of establishing contact is the conclusion of a contract for the use of the services offered by the platform, or if it concerns an existing contract with you, then the legal basis for the processing is Art. 6 (1) (1) (b) GDPR.
In other cases, the legal basis for the processing of personal data concerning you is Art. 6 (1) p. 1 (f) GDPR. The legitimate interest is derived from the need to process your data in order to be able to answer your inquiry.
As an integral part of processing your inquiry, your data will be transferred to our IT service providers and to the relevant employees who will process your inquiry.
We only store your data for the period of time required for this purpose, i.e. until we have answered your inquiry in full, or, if the inquiry is assigned to a contract, according to the time limits for the term of the contract.
You are not under any legal obligation to provide us with your personal data. However, if you do not wish to provide us with your data, it will not be possible for us to contact you.
As a matter of principle, we do not transmit any personal data to third parties. In exceptional cases, data will be passed on to government agencies/authorities if this is necessary for the fulfillment of a legal obligation. The legal basis for the transfer is then Art. 6 (1) p. 1 (c) GDPR.
We delete or block your personal data as soon as the reason or legal basis for storing it no longer applies. In principle, your data is only stored on our servers in Germany.
However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or any other legal proceedings, or if the storage of data is stipulated by statutory provisions to which we, as the responsible entity, are subject (e.g. Section 257 of the German Commercial Code (HGB), Section 147 of the German Tax Code (AO)). When the required storage period stipulated by legal regulations expires, the personal data will be blocked or deleted, unless we are required to continue storing it and a legal basis for doing so exists.
We make use of suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss and destruction, and against unauthorized access by third parties (e.g. TLS encryption for our app), taking into account the latest technology, the implementation costs, and the nature, scope, context, and purpose of the processing, as well as the existing risks of a data breach (including its probability and impact) for the data subject. We improve our security measures on an ongoing basis, in line with technological developments.
We do not transmit any data to non-European Economic Community (EEC) countries (third-party countries).
We do not use any personal data collected from you for automated decision-making (including profiling).
We do not make the provision of offers on our platform dependent on whether or not you provide us with personal data in advance. For you as a customer, there is also basically no legal or contractual obligation to provide us with your personal data; however, it is possible that we will be unable to provide certain offers, or only to provide some offers to a limited extent, if you do not provide the required data. In such cases, you will be informed accordingly, in this Privacy Policy.
Under certain circumstances, we may be subject to a specific legal or statutory obligation to provide lawfully processed personal data to third parties, particularly public authorities (Art. 6 (1) P. 1 (c) GDPR).
You may assert your rights as a data subject regarding the processing of your personal data at any time by contacting us via the contact details provided at the beginning of this document. As a data subject, you have the right to:
– request information about your personal data processed by us, pursuant to Art. 15 GDPR. Specifically, you can request information about the reasons for processing the data, the category of the processed data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it was not collected by us, as well as the existence of automated decision-making, including profiling, and, if applicable, conclusive information about the details thereof;
– demand the correction of inaccurate data or the completion of your data which is being stored by us without undue delay in accordance with Art. 16 GDPR;
– request the deletion of your data which is being stored by us, pursuant to Art. 17 GDPR, unless the processing thereof is necessary for exercising the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defense of legal claims;
– request the restriction of the processing of your data pursuant to Art. 18 GDPR, insofar as you dispute the accuracy of the data, or insofar as the processing thereof is unlawful;
– receive the data you have provided us with in a structured, commonly used and machine-readable format or to request its transfer to another responsible entity ("data portability"), pursuant to Art. 20 GDPR;
– object to the processing, pursuant to Art. 21 GDPR, provided that the processing is carried out on the basis of Art. 6 (1) p. 1 (e or f) GDPR. This applies particularly if the processing is not necessary for the fulfillment of a contract with you. Unless your objection relates to direct marketing, when you exercise such an objection, we request that you explain the reasons why you do not want us to process your data the way we have. In the event of your justified objection, we will examine the merits of the case and either discontinue or adapt the data processing or demonstrate our overriding reasons, which are worthy of protection, on the basis of which we will continue processing your data;
– revoke the consent previously given by you, (also before the GDPR came into force, i.e. before 25.5.2018) i.e. your voluntary consent clearly expressed in an informed manner by means of a declaration or any other unambiguous affirmative action, that you consent to the processing of the personal data in question for one or more specific purposes, at any time, pursuant to Art. 7 (3) of the GDPR, insofar as you have given such consent. As a result, we will no longer be permitted to continue processing any of your data that was based on this consent, in the future, and
– complain to a data protection supervisory authority about the processing of your personal data by our company, pursuant to Article 77 of the GDPR.
Due to changes in legal or regulatory requirements and possible further developments in terms of technical standards and our offer, adjustments to this Privacy Policy may become necessary. Therefore, this Privacy Policy will be reviewed regularly to determine whether any changes or amendments are required. The Privacy Policy can therefore be changed at any time, with effect for the future.
This Privacy Policy is effective as of August 2022.