LJUSDAL — Functional Digital Objects

1. Introduction

In the following, we provide information about the collection of personal data when using

our website
our social media profiles
our app: On You

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Benjamin Griebeler (LJUSDAL), Tornowstraße 53, 60486 Frankfurt am Main, Germany — Email: info@ljusdal.app

1.2. Scope, purposes, legal bases

Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR). In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework. In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer is usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us regarding their personal data:

Right of access,
Right to correction or deletion,
Right to limit processing,
Right to object to the processing,
Right to data transferability,
Right to revoke a given consent at any time,

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship. Mandatory data are marked as such.

1.7. No automated decision‑making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Competitions

Occasionally, we offer competitions via our website or in other ways. We process the data requested in these competitions in order to determine and notify the winners. Afterwards, we delete the data. It may also be that we only offer competitions for existing customers. In this case, we only process the name to determine the winners and the contact data to notify the winners. It is our legitimate interest to offer competitions to attract customers or to interact with our existing customers. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

1.10. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Data processing in our app

2.1 Downloading the app

Our app is ready for download at Apple's App Store und Google's Play Store (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular username, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.

2.2. Hosting

Our app is hosted by the provider. User data and game data are stored on our Google servers in a Mongo database. The app accesses this backend via an API. The provider processes the personal data transmitted via the app, e.g., content, usage, meta/communication data, or contact data. It is our legitimate interest to provide an app, so the legal basis for data processing is Art. 6 (1) (f) GDPR.

2.3. Informative use of our app

When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR. The data processed to this extent are:

IP address
Date and time of the request
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (concrete interface)
Access status/HTTP status code
Amount of data transferred in each case
Operating system and its interface
Language and version of the operating system

2.4. Access to functions or data

The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation. The data processed or access functions used in this respect are Push notifications.

2.5. Data processing for the provision of functions

In the app, we process data in order to provide the user with functions of the app. Users can create tasks, so called bets, to keep track of their goals and habits. In this context, the following personal data is processed:

Name
Email address
Date of birth
Stats
details of the created bets

The legal basis for the processing is the usage agreement concluded with the user via the app (Art. 6 para. 1 s. 1 lit. b GDPR).

2.6. User account

Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR. We delete the data when users delete their user account.

2.7. Single sign-on

Users can log in to our app using one or more single sign-on methods. In doing so, they use the login data already created for a provider. The prerequisite is that the user is already registered with the respective provider. When a user logs in using a single sign-on procedure, we receive information from the provider that the user is logged in to the provider and the provider receives information that the user is using the single sign-on procedure in our app. Depending on the user's settings in his account on the provider's site, additional information may be provided to us by the provider. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing users with a simple log-in option. At the same time, the interests of the users are safeguarded, as use is only voluntary.

Providers of the offered method(s) are:

Apple Inc., Infinite Loop, Cupertino, CA 95014, USA (Privacy policy: https://www.apple.com/legal/privacy/de-ww/).
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (Privacy policy: https://policies.google.com/privacy).

2.8. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

Apple Inc., USA (for Apple Pay)
Google Ireland Limited, Ireland (for Google Pay)

2.9. Third-party tools

2.9.1. Google Analytics for Firebase

We use Google Analytics for Firebase for analytics and to develop applications. The provider is Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), contact data (e.g. e-mail addresses, telephone numbers), and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://firebase.google.com/terms/data-processing-terms/#1.-data-center-and-network-security.

2.9.2. Firebase Crashlytics

We use Firebase Crashlytics to track errors in applications or on websites and to manage repairs. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

2.9.3. Firebase App Check

We use Firebase App Check to track errors in applications or on websites and to manage repairs. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland . The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in adequately monitoring the functionality of our applications.

2.9.4. Google Analytics

We use Google Analytics for analytics. The provider is Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is the contract concluded with the user (Art. 6 s. 1 para. 1 lit. b GDPR).

The legal basis for the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.

2.9.5. RevenueCat

We use RevenueCat for product analytics. The provider is RevenueCat, Inc., 631-633 Taraval St #101, San Francisco, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

Further information is available in the provider's privacy policy at https://www.revenuecat.com/privacy/.

2.9.6. TikTok Pixel

We use TikTok Pixel for analytics and for advertisement. The provider is TikTok, Inc., 10100 Venice Blvd Suite 401 Culver City, CA 90232, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

2.9.7. Meta Pixel

We use Meta Pixel for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

3. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address. Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

4. Date processing on our website

4.1. Informational use

When you visit our website for informational purposes only (i.e. without actively transmitting data via a contact form or similar), certain data are automatically transmitted to our server by your browser in order to ensure technical functionality, stability, and security. These include:

IP address
Date and time of the request
Browser type and version
Operating system
Referrer URL
Host name of the accessing device

This data is processed on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest in secure and stable website operation).

5. Data processing on our social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data. If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

Instagram — Meta Platforms Ireland Ltd. — https://help.instagram.com/519522125107875
TikTok — TikTok Technology Limited — https://www.tiktok.com/de/privacy-policy
YouTube — Google Ireland Limited — https://policies.google.com/privacy?hl=de
X (Twitter) — Twitter Inc. — https://twitter.com/de/privacy — Ads: https://twitter.com/personalization

6. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

7. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

Privacy Policy