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Privacy Policy

Information on the processing of your data pursuant to Art. 13 of the European General Data Protection Regulation (GDPR).

The protection of your personal data is an important concern for us.

This Privacy Policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter “data”) in connection with the provision of our services. Regarding the terminology used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Changes and Updates to the Privacy Policy

Privacy Policy Version 1.1, December 2024.

App Manufacturer

The app manufacturer is not the controller within the meaning of the GDPR.

Your personal data is processed on instructions from the following company, in accordance with the applicable legal requirements, in particular the GDPR:

Perbility GmbH
Starkenfeldstraße 21
96050 Bamberg
Phone: +49 951 408 331-00
https://www.perbility.de

Controller

The controller within the meaning of the GDPR is the respective client of Perbility or, indirectly, their distribution partners.

Employees or other persons associated with the client who have a corresponding user account have access to the app (software). Further data protection-related aspects may be regulated between the parties through a data processing agreement.

Contact for Data Protection Complaints

The data protection officer of the controller is available for complaints.

Please refer to an internal directory of the controller for the contact details of their data protection officer.

Personal Data and Purposes of Processing

The subject of data protection is personal data (Art. 4 No. 1 GDPR). This includes all information relating to an identified or identifiable natural person (“data subject”). This includes, for example, information on personal or factual circumstances, such as name, address, email address, or telephone number.

When using the app, the following required data is processed:

  • Device storage: Access to files and folders on the device to store or retrieve data. Files not managed by the app itself (e.g., cache or login storage) are only accessed through user interaction (e.g., uploading a PDF) or saved (e.g., downloading a PDF).
  • Internet: Access to the internet to send and receive data, e.g.
  • Employee data: email address, user ID, name, etc. (see below)
  • Accessed function, e.g. time tracking; overview and editing of assigned web-based training; access to time balances, vacation and absence data.

The app does not access:

  • Contacts: No access to the user’s contact list, e.g. to send invitations or import contacts.
  • Calendar: No ability to access calendar entries or create new appointments.
  • Notifications: No access to the notification system to send push notifications.
  • Bluetooth: No ability to connect to other Bluetooth devices.
  • Sensors: No access to various sensors such as accelerometer, gyroscope, or proximity sensor.

Processing of Employee Data

The processing of personal data takes place in the employment context, i.e. in particular for the purpose of fulfilling the contractual relationship, including compliance with obligations established by individual (employment contract) or collective legal provisions (works agreements, collective bargaining agreements), and for the purpose of exercising individual or collective rights and benefits associated with employment.

Examples:

  • Recording attendance and absence times (e.g. training, vacation, incapacity for work)
  • Conducting and documenting legally or operationally required legal, technical, or economic audits (e.g. auditors, internal audit, reliability checks pursuant to the German Money Laundering Act, internal control system);
  • Ensuring proper data processing in accordance with IT security and data protection requirements (e.g. log files);
  • Analysis and correction of technical errors;
  • Ensuring system security and availability;
  • Personnel development (in particular training and further education, targeted staffing, objective setting and achievement);
  • Process data (e.g. status, deadlines).

The legal basis for the processing of the above-mentioned personal data is Art. 6 para. 1 lit. b) GDPR, Art. 6 para. 1 lit. c) GDPR, and Art. 6 para. 1 lit. f) GDPR.

We process and store your personal data for the above-mentioned purposes generally for the duration of your employment relationship, unless there are legally required shorter periods.

Use of Cookies

Cookies are small files sent from our web server to your end device (e.g. PC, tablet, smartphone) and usually stored on your local storage. They cannot cause any damage on your end device. Most browsers are set to automatically accept cookies.

In the context of app use, only such information (“cookies”) is stored on your end device as is strictly necessary for the technical operation of the website in order for us to provide the service you have requested. For this we do not require the explicit consent of users (§ 25 para. 2 no. 2 TDDDG).