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App Privacy Policy

This data protection declaration explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of providing our services via mobile application (hereinafter collectively referred to as “online offering”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible person

 Our company MyKetobrain (company of Dinnova AG), Bahnhofplatz 1, 8001, Zurich, contact@myketobrain.ch is responsible for data processing (Art. 5 lit. j DSG, Art. 13 para. 1 lit. a GDPR).

Our data protection officer in accordance with Art. 37 GDPR is Astrid Louinci, Bahnhofplatz 1, 8001, Zurich, astrid.lounici@hotmail.com . If you have any data protection concerns, please address them by post or email to the address mentioned above.

Types of data processed

– Contact details (e.g., email, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Meta/communication data (e.g., device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter we refer to the affected persons collectively as “users”).

Purpose of processing

– Provision of the online offer, its functions and content.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach measurement/marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

“Processing” means any operation or series of operations relating to personal data, carried out with or without the aid of automated procedures. The term is broad and encompasses virtually every way data is handled.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not be assigned to an identified or identifiable natural person.

“Profiling” means any type of automated processing of personal data, which consists in using that personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or movements of that natural person.

The “controller” is the natural or legal person, public authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, institution or other body that processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Article 13 GDPR, we will inform you of the legal basis for our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the data protection declaration: 

The legal basis for obtaining consent is Article 6 Paragraph 1 Letter a and Article 7 GDPR;

The legal basis for processing to fulfill our services and implement contractual measures as well as answer inquiries is Article 6 Paragraph 1 Letter b GDPR;

The legal basis for processing to fulfill our legal obligations is Article 6 (1) (c) GDPR;

In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 Letter d GDPR serves as the legal basis.

The legal basis for the processing necessary to carry out a task that is in the public interest or in the exercise of official authority vested in the person responsible is Article 6 (1) (e) GDPR. 

The legal basis for processing to protect our legitimate interests is Article 6 (1) (f) GDPR. 

The processing of data for purposes other than those for which they were collected is determined in accordance with the provisions of Art. 6 Para. 4 GDPR. 

The processing of special categories of data (according to Art. 9 Para. 1 GDPR) is determined in accordance with the provisions of Art. 9 Para. 2 GDPR.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, securing availability and its separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and data are at risk. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Collaboration with processors, joint controllers and third parties

If, as part of our processing, we disclose data to other people and companies (processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this only takes place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfillment of the contract), users have consented, a legal obligation requires this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). 

If we disclose, transmit or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, moreover, on a basis that complies with legal requirements. 

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of using third-party services or disclosing or transferring data to other people or companies If this happens, this will only occur if it is to fulfill our (pre-)contractual obligations, based on your consent, based on a legal obligation or based on our legitimate interests. Subject to express consent or contractually required transfer, we only process or leave the data in third countries with a recognized level of data protection, which include US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses the EU Commission, the existence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, EU Commission information page).

Rights of data subjects

You have the right to request confirmation as to whether the data in question is being processed and to receive information about this data as well as further information and a copy of the data in accordance with legal requirements.

You have accordingly. In accordance with legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.

In accordance with the legal requirements, you have the right to demand that the relevant data be deleted immediately, or alternatively, in accordance with the legal requirements, to request a restriction on the processing of the data.

You have the right to request that the data concerning you that you have provided to us be received in accordance with the legal requirements and to request that it be transmitted to other responsible persons. 

In accordance with legal requirements, you also have the right to lodge a complaint with the responsible supervisory authority.

Right of withdrawal

You have the right to revoke your consent with effect for the future.

Right to object

You can object to the future processing of your data at any time in accordance with legal requirements. The objection can in particular be made against processing for direct advertising purposes.

Deletion of data

The data we process will be deleted or its processing restricted in accordance with legal requirements. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any legal retention obligations. 

Unless the data is deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Contact

When contacting us (e.g. via contact form, email, telephone or via social media), the user’s details are used to process the contact request and process it in accordance with Article 6 Paragraph 1 Letter b. (as part of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) GDPR processed. The user information can be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization get saved.

We delete the requests if they are no longer necessary. We review the necessity every two years; The statutory archiving obligations also apply.

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