Privacy Policy for WHOSCLOSE APP
I. General
Introduction
We take the protection of your personal data very seriously. We treat data confidentially and in accordance with the legal data protection regulations and this privacy policy. This privacy policy applies to our mobile iOS and Android apps (hereinafter "APP" and/or "PRODUCT"), as you can use all platforms simultaneously with your WhosClose account. This document explains the type, purpose and scope of data collection in connection with the use of our products. The following notes provide a simple overview of what happens to your personal data when you use our PRODUCT. Personal data are all data with which you can be personally identified. For detailed information on data protection, please refer to our privacy policy listed below this text. We would like to point out that data transmission over the Internet may have security gaps. It is not possible to completely protect data from access by third parties.
Responsible party
The responsible party for data processing in the context of this APP is: WhosApp GmbH, Zugspitzstraße, 15, 82049, Pullach/Germany "Responsible party" is the party that collects, processes or uses personal data.
Data protection contact
You can reach out to us at: Email: dp@whosclose.app WhosApp GmbH - Zugspitzstraße, 15, 82049, Pullach/Germany
General information on data retention for personal data
Subject to deviating or more specific information within this privacy policy, the personal data collected by this PRODUCT will be stored until you request us to delete it, revoke your consent for storage or the purpose for which the data was stored ceases to apply. If there is a legal obligation to store the data or any other legally recognized reason for storing the data (e.g. legitimate interest), the personal data concerned will not be deleted until the respective reason for storage no longer applies.
Legal basis for the storage of personal data
The processing of personal data is only permitted if there is an effective legal basis for the processing of such data. If we process your data, this is regularly done on the basis of your consent in accordance with Article 6 (1) (a) General Data Protection Regulation (GDPR) (e.g. when you voluntarily provide your data in the registration form or in the contact form), for the purpose of fulfilling the contract in accordance with Article 6 (1) (b) GDPR (e.g. when using In-APP purchases or the use of other chargeable functions of the PRODUCT) or on the basis of legitimate interests according to Article 6 (1) (f) GDPR, which are always weighed against your interests (e.g. in the context of advertising measures). The relevant legal basis will be specified in a separate place in this privacy policy.
Encryption
This PRODUCT uses SSL or TLS encryption for reasons of security and to protect the transmission of confidential content, such as the requests you send to us as the operator, or communication between users. This encryption prevents the data you transmit from being read by unauthorized third parties.
Changes to this privacy policy
We reserve the right to change these data protection regulations at any time in compliance with legal requirements.
II. Your rights
General
The GDPR grants data subjects whose personal data are processed by us certain rights about which we would like to inform you at this point:
Revocation of your consent to data processing
Many data processing operations are only possible with your consent. We will expressly obtain this from you before we start processing the data. You can revoke this consent at any time. For this purpose, an informal notification by email to us is sufficient. The legality of the data processing operations carried out up to the point of revocation remains unaffected by the revocation.
Right to object to data collection in special cases and in case of direct advertising (Article 21 GDPR)
If the data processing is carried out on the basis of Article 6 (1) (E) or (F) GDPR, you have the right at any time to object, for reasons arising from your particular situation, to the processing of personal data concerning you, which also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process the personal data concerned unless we can prove that there are valid reasons for processing worthy of protection which outweigh your interests, rights and freedoms or which serve the processing of the assertion, exercise or defence of legal claims. If your personal data are processed for the purpose of direct marketing, you have the right to object, at any time, to the processing of your personal data for the purpose of such marketing, including profiling, insofar as it is connected with such direct marketing. If you object, your personal data will no longer be used for the purpose of direct marketing. Right of appeal to a supervisory authority In the event of violations of the GDPR, those affected have a right of appeal to a supervisory authority. This right of appeal is without prejudice to other administrative or judicial remedies. Information, deletion and correction You have the right to receive information free of charge at any time about your stored personal data, its origin and recipients and the purpose of data processing, as well as the right to correct or delete this data. You can contact us at any time by email for this purpose and for further questions on the subject of personal data.
Right to restricting of processing
You have the right to request that the processing of your personal data be restricted. For this purpose, you can contact us at any time by email. The right to limit processing exists in the following cases:
- If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the review, you have the right to demand the restriction of the processing of your personal data.
- If the processing of your personal data was/is unlawful, you can demand the restriction of data processing instead of deletion.]
- If we no longer need your personal data, but you need it for the exercise, defence or assertion of legal claims, you have the right to demand the restriction of the processing of your personal data instead of deletion.
- If you have lodged an objection in accordance with Article 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to demand the restriction of the processing of your personal data.
Right to data portability
You have the right to have data, which we process automatically on the basis of your consent or in fulfillment of a contract, handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible party, this will only be done to the extent technically feasible.
III. Access rights of the APP
In order to provide our services via the APP, we require the access rights listed below, which enable us to access certain functions of your device.
- Wi-Fi connections
- Receiving data from the Internet
- Network access
- GPS information
- Mobile Contact List
- Push Notifications
Access to the device functions is required to ensure the functionality of the APP. The legal basis for this data processing is our legitimate interest within the meaning of Article 6 (1) (f) GDPR, your consent within the meaning of Article 6 (1) (a) GDPR and/or - if a contract has been concluded - the fulfillment of our contractual obligations (Article 6 (1) (b) GDPR).
The data collected in this way will generally not be stored for longer than is necessary for the use of the corresponding functions, but at most until 24 hours after the uninstallation of the App.
Usage of Collected Contact List
WhosClose may collect and use contact list information provided by you solely for the purpose of enhancing the functionality of our services. This information may include names, phone numbers, email addresses, and other contact details stored on your device. How We Use Contact List Information
- Enhanced User Experience: We may use contact list information to provide features that enhance your experience within the app, such as facilitating communication between users or offering personalized services.
- Social Features: Certain features within the app may allow you to interact with contacts from your address book. This can include inviting friends, sharing content, or connecting with other users of the app.
- Improving Services: Analyzing aggregated contact list data may help us improve and optimize our services, ensuring better functionality and relevance to our users.
IV. Collection of personal data in the context of the use of the App
General
When you use our App, we collect the following personal data from you, depending on availability:
- Usage data
- Metadata
- IP address
- Device identification
- Email address
- Phone Number
- Location
- Time zone
- Language
- ID of social networks / external service providers when registering externally (if activated, see below for the individual service providers such as Google Account and Apple login)
- Profile picture (if activated)
- Age group
- Chat conversations
- Mobile IDs (IDFA, IDFV, Android ID etc.)
WEB: Cookies
Our Internet pages use so-called "cookies". Cookies are small text files and do not cause any damage on your end device. They are either temporarily stored on your device for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or until they are automatically deleted by your web browser. In some cases, cookies from third-party companies may also be stored on your terminal device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for the processing of payment services). Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies are used to evaluate user behavior or display advertising. Cookies that are required to carry out the electronic communication process (necessary cookies) or to provide certain functions that you have requested (functional cookies, e.g. for the shopping basket function) or to optimize the website (e.g. cookies for measuring the web audience) are stored on the basis of Article 6 (1) (f) GDPR, unless another legal basis is given. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimized provision of his services. If consent to the storage of cookies has been requested, the storage of the cookies in question will be carried out exclusively on the basis of this consent (Article 6 (1) (a) GDPR); the consent can be revoked at any time. You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for specific cases or in general and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited. Insofar as cookies are used by third-party companies or for analysis purposes, we will inform you separately about this within the scope of this privacy policy and, if necessary, request your consent.
Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser or the PRODUCT automatically sends to us. These are:
- Operating system used
- Hostname of the accessing computer
- Time of the server request
- IP address
- WEB: Browser type and version
- WEB: Referer URL
The collection of these data is based on Article 6 (1) (f) GDPR. The operator has a legitimate interest in the technically error-free display and optimization of his application - for this purpose the server log files must be recorded.
Registration in the PRODUCT
You can register in the PRODUCT to use additional features. We will use the data entered for this purpose only for the purpose of using the respective offer or service for which you have registered. The mandatory data requested during registration must be provided in full. Otherwise, we will refuse the registration. In the event of important changes, for example in the scope of the offer or technically necessary changes, we will use the email address provided during registration to inform you in this way. The data entered during registration is processed for the purpose of implementing the user relationship established by the registration and, if applicable, for the initiation of further contracts (Article 6 (1) (b) GDPR). The data entered during registration is stored by us for as long as you are registered in this PRODUCT and is then deleted. Legal retention periods remain unaffected.
Registration with Google Account
Instead of a direct registration you can register with your Google Account. The provider of this service is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. However, according to Google, the data collected is also transferred to the USA and other third countries. If you choose to register with your Google Account and click on the button, you will be automatically redirected to the Google platform. There you can log in with your usage data. This will link your Google Account with this PRODUCT or our services. This link gives us access to your data stored at Google. This is above all:
- Email address
This data is used to set up, provision and personalize your account. The registration with your Google Account and the associated data processing procedures are based on your consent (Article 6 (1) (a) GDPR). You can revoke this consent at any time with effect for the future. You can find further information in the Google Terms of Use and the Google Privacy Policy. These can be found under: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=de.
Registration with Apple
We offer you the possibility to register and log in via your Apple account using "Apple Login". When you register for the first time using the Apple ID, the app will ask you for your email address so that an account can be set up for you. We will store your email address with us and will contact you at this address with instructions if necessary. While using the "Register with Apple ID" feature, Apple will not track you or create a profile of you. Apple collects only the information necessary to ensure that you can login and manage your account. As long as you remain logged on to your device, you will automatically remain logged on to our app. For more information about Apple login, please see: https://support.apple.com/HT210318
Request within the App, by email or by phone
If you contact us (e.g. via contact form within the PRODUCT, by email, telephone or fax), your inquiry including all personal data resulting from it (e.g. name, inquiry) will be stored and processed by us for the purpose of processing your request. This data is processed on the basis of Article 6 (1) (b) GDPR, provided that your inquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases the processing is based on your consent (Article 6 (1) (a) GDPR) and/or on our legitimate interests (Article 6 (1) (f) GDPR), as we have a legitimate interest in the effective processing of the inquiries addressed to us. The data sent to us by you via contact request will remain with us until you request us to delete it, revoke your consent for storage or the purpose for which the data was stored no longer applies (e.g. after your request has been processed). Mandatory legal provisions - in particular legal retention periods - remain unaffected. We will not pass on your data without your consent.
Newsletter data
If you would like to receive the newsletter offered in our PRODUCT, we need an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. Further data will not be collected. We use these data exclusively for sending the requested information and do not pass them on to third parties. The dispatch of the newsletter is based on your consent (Article 6 (1) (a) GDPR). You can revoke this consent at any time. For the maintenance and analysis of our newsletters we use the following data through our service providers:
- Opening of emails
- Clicks on emails
- Newsletter subscriptions
Google Ads / Google Admob
APP: If you use the free membership and activate the ad-supported version, if available, in the APP, you will see ads that are currently provided by Google Ads (Google Admob). Thereby advertising IDs are collected by Google Ads (Mobile advertiser ID, iOS IDFA, Android Advertising ID). You can find more information here: https://policies.google.com/technologies/ads?lang=de-DE&hl=de WEB: Google Ads enables us to display ads in the Google search engine or on third party websites if the user enters certain search terms in Google (keyword targeting). Furthermore, targeted advertisements can be played out on the basis of user data available at Google (e.g. location data and interests) (target group targeting). We as the operator can evaluate this data quantitatively, for example by analyzing which search terms led to the playout of our ads and how many ads led to corresponding clicks. The use of Google Ads is based on Article 6 (1) (f) GDPR. The operator has a legitimate interest in marketing his service products as effectively as possible.
Google Conversion-Tracking
This PRODUCT uses Google Conversion Tracking. The service is provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. Google Conversion Tracking allows Google and us to see if the user has performed certain actions. For example, we can evaluate which buttons in our PRODUCT were clicked how often and which products were viewed or purchased particularly frequently. This information is used to create conversion statistics. We learn the total number of users who clicked on our ads and what actions they performed. We do not receive any information that can be used to personally identify the user. Google itself uses cookies or comparable recognition technologies for identification purposes. The use of Google Conversion Tracking is based on Article 6 (1) (f) GDPR. The operator has a legitimate interest in the analysis of user behavior in order to optimize both its web offering and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Article 6 (1) (a) GDPR; the consent can be revoked at any time. More information on Google Conversion Tracking can be found in the Google Privacy Policy: https://policies.google.com/privacy?hl=de.
Hosting and Content Delivery Networks (CDN)
The web services belonging to this PRODUCT are hosted by an external service provider (Hoster). The personal data collected in this PRODUCT is stored on the hoster's servers. The use of the hoster is for the purpose of fulfilling the contract with our potential and existing customers (Article 6 (1) (b) GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Article 6 (1) (f) GDPR). Our hoster will only process your data to the extent necessary to fulfill its performance obligations and will follow our instructions with regard to this data. In order to ensure that the processing complies with data protection regulations, we have concluded a data processing agreement with our hoster.
Google Firebase
This service is provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The use of Google Firebase may require the transfer of your personal data to the USA. Firebase is part of the Google Cloud Platform (Google Ireland Limited, Gordon House, Barrow Street, Sieblin 4, Ireland) and offers various services for web and app developers (https://firebase.google.com/terms/ ). Some Firebase services process personal data. In most cases, the personal data used is limited to so-called instance IDs, which are time-stamped. The instance IDs created by Firebase are only used once and therefore allow the assignment to certain events or processes. According to Google, the data collected in this process is not personal data. In other cases, Google Firebase stores, among other things, the number and duration of sessions, operating systems, device models, region and a number of other data. A detailed overview of the data collected by Google Firebase can be found at: https://support.google.com/firebase/answer/6318039 For Analytics for Firebase Google uses not only the above mentioned instance ID, but also the advertising ID of the end device. You can change the usage of the Ad ID in the device settings of your mobile device. Android: Settings > Google > Ads > Reset Ad ID iOS: Settings > Privacy > Advertising > No Ad Tracking We use Google Firebase above all:
- to select configuration data necessary for operation and to transfer this data to end user devices
- to analyze user behavior and solve problems in the user experience, for example by evaluating crash reports
- to open newly installed apps on a specific page or in a specific context
- to send push notifications or so-called in-app messages (notifications that are only displayed in the respective PRODUCT). You can disable and enable push notifications at any time through your device settings.
The paragraph at the top ("General information on data retention for personal data") applies to the storage period of data collected in this way. Personal data at Google Firebase is not stored longer than necessary for the purpose of the service (usually up to 14 months). Further information can be found under: https://support.google.com/analytics/answer/7667196?hl=de-DE This represents a legitimate interest in the sense of Article 6 (1) (f) GDPR. Further information about Google Firebase can be found at: https://firebase.google.com/ https://www.firebase.com/terms/privacy-policy.html
V. Data Analysis
General
If you access our PRODUCT, your behavior can be statistically evaluated with the help of certain analysis tools and analyzed for advertising and market research purposes or to improve our offers. When using such tools, we ensure that the legal data protection regulations are observed. When using external service providers (contract processors), we ensure through appropriate contracts with the service providers that the data processing complies with German and European data protection standards.
Google Analytics
This PRODUCT uses Google Analytics. The service is provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables the operator to analyze the behavior of users. In doing so, the operator receives various usage data, such as page impressions, length of stay, operating systems used and the origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or his terminal device. Google Analytics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google on the use of this PRODUCT is usually transferred to a Google server in the USA and stored there. The use of this analysis tool is based on Article 6 (1) (f) GDPR. The operator has a legitimate interest in the analysis of user behavior in order to optimize both the offered PRODUCT and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Article 6 (1) (a) GDPR; the consent can be revoked at any time. Data stored by Google at user and event level, which are linked to cookies, user IDs (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID), are usually anonymized or deleted after 14 months. Details can be found under the following link: https://support.google.com/analytics/answer/7667196?hl=de We have concluded a contract with Google for order processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
IP anonymization for Google Analytics and Google Firebase
We have activated the IP anonymization function in this application. As a result, your IP address will be truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before it is transmitted to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this PRODUCT, Google will use this information to evaluate your use of the PRODUCT, to compile reports on the activities and to provide further services to the operator in connection with the use of the PRODUCT and the use of the Internet. The IP address transmitted by your device within the framework of Google Analytics is not combined with other data from Google. You can find more information about this at: https://support.google.com/analytics/answer/2763052 WEB: Browser Plugin for Google Analytics You can prevent Google from collecting and processing your data by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de . For more information on how Google Analytics handles user data, please refer to the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=de . WEB: Google Optimize We use the Google Optimize tool to understand which of the different versions of our PRODUCT are more helpful to users and which are not. Optimize uses Google Analytics cookies to target content variants to a user and a content experiment cookie to determine a user's participation in an experiment. Information on data protection in this context can be found here: http://policies.google.com/?hl=en and /support.google.com/optimize/answer/6292487?hl=en. https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#optimize_-_cookie_usage
VI. Plugins and Tools
WEB: Google Fonts This PRODUCT uses so-called fonts, which are provided by Google, for the uniform representation of fonts. The Google fonts are installed locally. There is no connection to Google servers. Further information about Google Fonts can be found at https://developers.google.com/fonts/faq and in the Google privacy policy: https://policies.google.com/privacy?hl=de.
Date: 27/11/2023