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Leifheit Aktiengesellschaft

 

Soehnle Connect app data protection information

Current status: June 2017

 

I. Summary information

Leifheit Aktiengesellschaft, Leifheitstraße, 56377 Nassau (Lahn) (“Leifheit” or “we”) are delighted that you have expressed an interest in the Soehnle Connect products and the Soehnle Connect app.

We take the security of your personal data very seriously and, as the party with legal responsibility for data protection, are keen for you to feel safe when using the Soehnle Connect app and Soehnle Connect products, including when it comes to the protection of your personal data. It goes without saying that we ensure compliance with German and European data protection requirements.

The Soehnle Connect app has been developed to make it easier for you to lead a healthy, body-conscious life and to support you in maintaining and improving your health.

 

We must point out that your data will be used on the basis

You may withdraw this consent at any time.

Personal data is information relating to your identity. This includes, for example, details such as your name, address, telephone number, e-mail address and date of birth.

Specific types of personal data, which are therefore in need of special protection, are, inter alia, data relating to your health. The Soehnle Connect products measure your body weight and, depending on the range of functions, you can calculate additional health/body‑related information, such as weight, water content, fat content, muscle content, calorie consumption and the date and time of the measurement.

The range of data collected and used will depend on the measurement functions of the product you purchase. These measurement functions can be found on the product information for each Soehnle Connect product.

All the default settings installed by us have been selected so that, in principle, the only personal data used is data that has to be processed for the specific purpose of the processing.

You can switch any push notifications on or off using the settings on your smartphone. Please consult your smartphone’s operating instructions in this regard. You will not receive any advertising from Leifheit within the Soehnle Connect app.

In no event will we forward your data to your health insurance provider and/or other insurers with whom you hold policies without your explicit separate consent. Nor will your data be passed on for research purposes and/or marketing purposes. Furthermore, we will not sell your data to third parties, nor do we allow third parties to advertise within our Soehnle Connect product range.

 

II. Minimum age requirement

Our Soehnle Connect product range is only available to people over the age of 16. Any collection or use of personal data from subjects under 16 years of age takes place expressly against our will and without our knowledge. This also represents an infringement of our General Terms and Conditions.

 

III. How can our product range be used?

Whether or not personal data is collected and used, and which data is involved, depends, in particular, on whether you choose to use our products with or without a user account. This is entirely up to you:

We offer all our users the opportunity to set up a user account on our Soehnle Connect platform. You can, however, also use our Soehnle Connect app without registering by way of a user account; this may result in a limited range of applications, details of which will be given below.

In any case, the following data are collected and used during installation of the app, and the following access permissions are required:

We will not set up any motion profiles.

Please find below information regarding the data that will be processed when using the Soehnle Connect app.

 

1. Use of the Soehnle Connect app without a user account

If you would like to use the Soehnle Connect app without a user account, your information will not be sent to our servers or to servers belonging to third-party companies commissioned by us.

In order to use the app, you will, however, be obliged to provide certain mandatory information when setting up the app. Essentially, the following information will be recorded and processed:

You also have the option of uploading a photo, but there is no obligation to do so.

In addition, it is also possible, depending on the extent to which you use the app and the corresponding hardware supplied by you, to collect and process the following health‑related information:

Should you decide to delete the app, your data will be deleted from your mobile telephone/smartphone in full, depending on your operating system. If you were then to reinstall the Soehnle Connect app, under certain circumstances the data would no longer be able to be used.

However, some operating systems are set up in such a way that user data is still stored on the local device. We have no power over these settings, and you will therefore have to contact the manufacturer of your operating system to find out how to manually delete this data.

 

Use of the Soehnle Connect app with a registered user account

If you decide to create a user account on our Soehnle Connect platform, the following additional provisions and instructions shall apply.

 

a) Collection and processing of personal data

Once you have created a user account on our Soehnle Connect platform and synchronized your data, your personal data will no longer be saved exclusively on your (mobile telephone) device, but will also be stored on a server via the Internet. Your data will, of course, be sent and also stored in an encrypted manner.

Setting up a user account means that we have access to your personal data and can use this data for your benefit within our Soehnle Connect product range.

The following information will be collected and processed:

You also have the option of uploading a photo.

It is also possible, depending on the extent to which you use the app and the corresponding hardware supplied by you, to collect and process the following health‑related information:

Mandatory information: In order to be able to use the Soehnle Connect platform, you will need to provide the data designated as mandatory information in the electronic registration form when completing your registration. This includes your own choice of user name, a password chosen by you, and your e-mail address. You are not required to give your full name here either. We would advise you to choose a secure, complex password.

We are often unable to identify you on the basis of this information.

To allow us to analyse your data properly, you will need to input your date of birth, height and current weight, as well as your gender, when setting up a user account.

The data collected will be stored on our behalf on the servers of our contractual partner, Microsoft Corporation One Microsoft Way Redmond, WA 98052-6399 USA. We have selected this company very carefully. The data will only be stored in the territory of the Federal Republic of Germany, meaning that European and German data protection laws shall apply and your rights will also be protected within the contractual relationship with our contractual partner.

Your Soehnle Connect data will be sent to the server(s) in an encrypted manner by your Soehnle Connect product each time synchronization takes place via the app. This data is stored so that you can enjoy the full benefits of our Soehnle Connect product range. The data is also connected, i.e. linked, to your user account.

When assigning a Soehnle Connect product to your user account, you will also need to input specific technical information (such as, for example, the identification number of your Soehnle Connect product or hardware supplied with the Soehnle Connect product). We will treat this information in the same way as personal data.

When the transmission function is activated, the data measured or calculated by the Soehnle Connect product in question is sent to the associated user account on the Soehnle Connect platform via the Soehnle Connect app. Details of the transmission function and the activation and deactivation thereof can also be found in the help section under https://www.soehnle.de/en/service/faq/ on the Soehnle Connect platform.

An individual Soehnle Connect product can also be linked to multiple user accounts (e.g. of family members or housemates). If the Soehnle Connect product is operated properly, it is not usually technically possible for personal data to be sent to the other users of this Soehnle Connect product. In cases of incorrect operation, however, it cannot be ruled out that specifically measured values may be assigned to the wrong user. Details of these possible uses can also be found in the help section under https://www.soehnle.de/en/service/faq/ or in the product information provided with the Soehnle Connect product.

 

b) Why is personal data processed on the Soehnle Connect platform?

We use

information provided during registration solely to provide and manage the respective user account, to control access to the user account, to send the necessary information to the Soehnle Connect platform or to use this information (such as, for example, replacement passwords).

the Soehnle Connect data sent by a Soehnle Connect product solely to allow you to display and analyse them in your user account.

No data is currently used for interest‑based advertising via our Soehnle Connect product range. We reserve the right, however, to carry out data processing of this kind in order to improve our range. If we were to introduce such a function, we would, however, inform you of this in good time and obtain a new consent form.

 

c) Duration of data collection and processing

We will only store your data for as long as you have a user account with Soehnle

Connect, or until there are grounds to delete it. Stored personal data will be

deleted immediately as soon as you withdraw your consent for your data to be used,

or once the information is no longer required for the purpose for which it was used

(for example upon termination of our contractual relationship) or once the data can

no longer be stored on other legal grounds.

 

d) Collecting and forwarding to government bodies

Personal data will only be collected and forwarded to government bodies who are authorized to receive such information in the context of the relevant laws and where we are obliged to do so as a result of a judicial decision. Our employees and the service companies commissioned by us are obliged by us to maintain confidentiality and to comply with the provisions of the data protection laws in force.

 

e) Piwik web analysis

The Soehnle Connect platform uses Piwik, a web analysis service for the statistical analysis of visitor access. Piwik uses so-called “Cookies”, text files saved on your computer that allow us to analyse your use of the app. The information produced by the Cookies regarding your use of the Soehnle Connect platform is saved on the servers of our contractual partner, Microsoft Corporation One Microsoft Way Redmond, WA 98052-6399 USA in Germany. The IP address is anonymized immediately after being processed and before being saved.

You can disable Cookies by adjusting the settings on your browser software accordingly. Disabling Cookies can, however, result in limited functionality of the Soehnle Connect platform.

f)Use of apps and tools from third-party providers

Our default settings do not allow third-party provider apps to access your data. You can, however, allow us to link your Soehnle Connect profile to a third-party provider app by adjusting your settings accordingly. In particular, we allow your data to be synchronized with Google Fit and the Apple Health app. Where we forward data to a third party at your request, these data shall be subject to this third party’s data protection guidelines. You can withdraw your consent for the release of data to third parties at any time via your Soehnle Connect profile or in the Settings menu on your mobile phone.

The Soehnle Connect platform also allows you to share information on your Soehnle Connect product to other platforms, using so-called widgets or plug-ins for social networks, such as Facebook and LinkedIn. Information is only entered manually, meaning that these third-party providers do not have access to the data on the Soehnle Connect platform. However, the possibility that the product offered by these third-party providers will collect and process personal data cannot be ruled out. We have no power over the interaction with these programmes; this is governed by the data protection guidelines of the company that provides them.

 

IV. Security

We employ technical and organizational security measures in order to protect your data that is stored with us from being manipulated, lost, destroyed or accessed by unauthorized individuals. Our security measures are subject to continuous improvement in line with technological advances.

All the information is sent and saved in an encrypted manner in accordance with the state of the art and the European and German data protection regulations (in cases where the Soehnle Connect app is being used with a registered user account). When a Soehnle Connect product is being assigned to your user account or the app, a PIN must be entered for authentication purposes in the so-called “pairing procedure” with the device, which takes place in an encrypted manner. Details of this procedure can also be found in the help section under https://www.soehnle.de/en/service/faq/ or in the product information provided with the Soehnle Connect product.

In your own interests, we would also advise you to ensure that your mobile phone has adequate security, by way of a password or other suitable method.

 

V. Amendments to our data protection provisions

We reserve the right to amend our security and data protection measures where this proves necessary as a result of technical developments. In these cases, we will – where necessary – also modify our data protection information accordingly and will actively inform you of this without delay. It is therefore important that you are familiar with the latest version of our data protection declaration. The date of the most recent revision of this data protection declaration can be found at the top of the page.

Where this is required by law, we will obtain your consent for the new data use and the amended data protection information. We will inform you of this by e-mail or within the Soehnle Connect app.

In principle, amendments shall enter into force when the revised data protection declaration is published on the corresponding websites.

Please be aware of the fact that the establishment of new product ranges often results in updates to our Soehnle Connect app. Where your consent is required for use of the data, your consent will be sought the first time you restart once the update has taken place.

If you have installed the automatic background updates on your mobile phone, this can result in the latest version of the app being downloaded automatically and may also mean that you will no longer be able to use the Soehnle Connect app in future if you do not consent to the amended data protection declaration. We would therefore recommend that you turn off background updates so that you can check this first. The latest version of our data protection declaration can also always be found in your App Store.

 

VI. Links

If you use external links that are offered within the context of our Soehnle Connect products, our data protection declaration does not extend to the ranges offered there. Where we offer links, we try to ensure that these also comply with our data protection and security standards. However, we have no influence on other providers’ compliance with the data protection and security regulations. It is therefore important that you find out from the other providers about their data protection regulations.

 

VII. Right to information

You can request information about the personal data we have saved about you, the origin and recipient thereof and the purpose of the data processing at any time free of charge. In particular, you can also e-mail LEIFHEIT AG’s data protection officer at Datenschutz@leifheit.com.

 

VIII.    Withdrawal, correction, blocking and deletion

You can also withdraw your consent to the collection and storage of your personal data by us at any time. You are also entitled to correct, block/restrict the processing of or to delete your information that has been collected and processed. In accordance with the conditions of Art. 20 of the General Data Protection Regulation, you also have the right to data portability, i.e. to receive the personal data relating to you that you have provided to us in a structured, current and machine‑readable format and to have this information sent by us to another responsible official without hindrance.

Where you would like to assert your claims under data protection laws, please use our contact information from the disclaimer or send an e-mail to LEIFHEIT AG’s data protection officer at Datenschutz@leifheit.com.

 

IX.Questions, suggestions, complaints

You can access the data protection declaration within the app at any time from the main menu under “Datenschutzerklärung [data protection declaration]’.

If you have any further questions, suggestions or complaints regarding our guidelines on data protection and on the processing of your personal data, you can contact LEIFHEIT AG’s data protection officer directly at Datenschutz@leifheit.com.

Irrespective of any other administrative or judicial legal remedy, you also have the right to appeal to a (data protection) supervisory body, in particular in the Member State in which you are resident, are employed or in which alleged infringement took place if you believe that the processing of your personal data constitutes an infringement of German or European data protection laws.

Responsible person in respect of data protection law:

Gerhard Liebscher

Leifheit AG

Leifheitstraße 1

56377 Nassau

Telephone: +49 (0) 2604 – 977 0

Fax: +49 (0) 2604 – 977 402

E-mail: info@leifheit.com

Court of registration: Montabaur District Court

Registration number: HRB 2857

 

Members of the Board of Directors

Thomas Radke (CEO)

Ansgar Lengeling (COO)

Ivo Huhmann (CFO)