Data Protection Declaration

Information about the processing of personal data and health data by the syncredible app

The Data Controller is obliged under Article 13 of the General Data Protection Regulation (GDPR) to inform the data subject when collecting personal data in order to ensure fair and transparent processing.

Preamble
This App (hereinafter "syncredible App") is provided by syncredible GmbH, Münchener Str. 26, 85247 Schwabhausen, registered with the Registry Court of the Munich District Court under HRB 266740, Managing Director Dr. (UNC) Josef Baumgartner (hereinafter "we" or "us" or "Data Controller"), as the person responsible within the meaning of data protection law.

As part of using the syncredible App, we allow you to share your contact information, profile pictures, ringtones and notes with other users of the syncredible App in order to store them in their smartphone phonebook. In turn, other people can share their contact details, profile pictures, ringtones and notes with you via the syncredible App.

When you use the syncredible App, we process personal data (hereinafter "data") about you. By personal data, we mean any information relating to an identifiable or identified natural person. The protection of your privacy is also important to us when using the syncredible App. Therefore, we would like to inform you by means of the following information about which personal data we process when you use the syncredible App and how we handle this data. In addition, we inform you about the legal basis for the processing of your data and about our legitimate interests, insofar as the processing of your data is necessary for this purpose. The providing of your data is voluntary. However, you cannot use the syncredible App without providing your express consent to the processing of your data.

1. Data Controller and Data Protection Officer
The Data Controller is syncredible GmbH.

The address of our Data Protection Officer is:

Walter Lukmann
Packerstrasse 183
A-8561 Söding, Austria
service@dsgvoschutzteam.com
+43 660 60 888 01


2. Information on the processing of your data
By using the syncredible App, we only know the user's mobile phone number. Beyond that, only the information that the user provides us with is processed. This can be the following information:

Data:

  • Profile photos
  • Names (first names, middle names, nicknames, surnames, name prefix, name suffix)
  • Telephone numbers
  • E-mail addresses
  • Company name and position
  • Job descriptions within a group
  • Addresses
  • Social media accounts
  • Websites
  • Birthdays
  • Contact Notes


2.1 Information collected during download
When you download the syncredible App, certain required information is transmitted to the App store that you selected. The processing of this data is carried out exclusively by the respective App Store and is outside our control.

2.2 Automatically collected information
When using the syncredible App, we automatically collect certain data required for the use of the syncredible App. This includes the smartphone model, the operating system version and access times.

Although this data is not stored, it is automatically transmitted to us in order to (i) provide you with the functions associated with the syncredible App, (ii) improve the functions and performance features of the syncredible App and (iii) prevent and eliminate misuse and malfunctions. This data processing is justified by the fact that (i) the processing is necessary for the performance of the contract between you as a data subject and us pursuant to Art. 6 (1) lit b) GDPR for the use of the syncredible App, or (ii) we have a legitimate interest in ensuring the functionality and error-free operation of the syncredible App and to be able to offer a service that is in line with the needs and interests of the market and this interest outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) lit f) GDPR.

2.3 Information collected for registration and login purposes
When you create a user account (hereinafter "registration") or log in, we use your access data (mobile number) to grant you access to your user account. You cannot create a user account without providing this data. In this context, the syncredible App automatically generates a passphrase which is required from you in the event of a change of your mobile device or your mobile number.

You can view this passphrase in the App after entering your device password (or using your other security measures, such as fingerprint or FaceID).

The user account is also used to restore the account in the event of a change of device and to ensure that, in the event of a reassignment of the mobile number, any potential new user to this number does not gain access to your user account.

The home screen and messaging feature of the App will display the syncredible App's Terms of Use and any associated rights and obligations, as well as any technical or legal notices, updates, security alerts or other messages related to the syncredible App.

2.4 Information collected to enable you to use the syncredible App
With the syncredible App you can enter, manage and edit various information. This includes, in particular, your contact details, profile pictures, ringtones and notes, which you can share with other users of the syncredible App for them to save in their smartphone phonebook. In turn, other people can share their contact data, profile pictures and notes with you via the syncredible App for saving in your own phonebook.

The syncredible App requires the following access permissions for this purpose:

  • Internet: for the encrypted storage of your data on our server
  • Phonebook: to store your contacts (names, phone numbers, addresses, email addresses, notes) in the App and for encrypted storage on our server.
  • On devices with iOS 13.0 or higher operating system: Access to notes from contacts
  • Camera: to take photos that you can save in the App and that are stored encrypted on our server.
  • Media: to store your photos and ringtones in the App and to store them encrypted on our server.


The processing and use of usage data is for the purpose of providing the services of the syncredible App. This data processing is justified by the fact that the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) lit b) for the use of the syncredible App.

3. Disclosure and transfer of your data
In addition to the cases expressly mentioned in this data protection declaration, your data will only be passed on without your express prior consent if this is permitted or required by law. This may be the case, for example, if the processing is necessary to protect the vital interests of you or another natural person.

3.1 If it is necessary to clarify an unlawful or abusive use of the syncredible App or for law enforcement purposes, personal data will be forwarded to law enforcement agencies or other authorities and, if necessary, to injured third parties or legal advisors. However, this will only occur if there is evidence of unlawful or abusive conduct. Forwarding personal data may also take place if this is for the purpose of enforcing terms of use or other legal claims. In addition, we may be required by law to provide information upon request of certain public authorities (such as law enforcement agencies, tax authorities or bodies that prosecute administrative offences subject to fines).

Any disclosure of the data is justified by the fact that (i) the processing is necessary for compliance with a legal obligation to which we are subject pursuant to Art. 6 para. 1 lit f) GDPR in conjunction with national legal requirements to disclose data to law enforcement authorities, or (ii) we have a legitimate interest in disclosing the data to the aforementioned third parties if there are indications of abusive behaviour or to enforce our terms of use, other terms of use or legal claims where such legitimate interest overrides your rights and interests in the protection of your data within the meaning of Art. 6 (1) lit f) GDPR.

3.2 For the provision of our service, we rely on the Firebase development platform of the third-party company Google LLC.

4. Changes of purpose
Your data will only be processed for purposes other than those described if this is permitted by law or if you have consented to the changed purpose of the data processing. In the event of a change of purpose of the data processing, we will inform you in advance about the change of purpose and provide you with all further relevant information.

5. Data retention period
We delete or anonymise your data as soon as it is no longer required for the purposes for which we have collected or used it in accordance with the above paragraphs. This does not apply to data that is required for a longer period of time for the purposes of criminal prosecution or to secure, assert or enforce claims or to comply with legal requirements. Criteria or legal grounds for the duration of the processing are in particular the statute of limitations according to §§ 195 ff. German Civil Code (BGB), and also the contractually agreed basis for the use of the syncredible App.

6. Your rights as a data subject
As a data subject of a data processing operation, you have various rights.

• You have the right to receive information (including a copy free of charge) about your personal data that has been collected, processed or, if applicable, transmitted to third parties within the scope defined herein.

• In addition, you have the right to have the personal data collected about you communicated to a specified party and the right to have the personal data we process rectified or erased or to have the processing of that data restricted. If you exercise your right to data transfer, erasure or restriction of processing, we may not be able to perform the contractually agreed services.

• You have a right of appeal to any data protection authority in Europe. The competent data protection supervisory authority of the Data Controller is the:

Bavarian State Office for Data Protection Supervision
PO Box 606
91511 Ansbach
Germany


7. Right of withdrawal
You have the right to object to the processing of your data for the future. You can object to the processing of data by sending an email to privacy@syncredible.app or by contacting our data protection officer, whose address can be found in section 1 of this document.

If you exercise your right of withdrawal, we will no longer be able to provide the contractually agreed services, so that your withdrawal will result not only in the deletion of your data but also in the deletion of your account with the syncredible App.


8. Contact
If you have any questions or comments about our handling of your personal data or to exercise your rights as a data subject, please contact:

Dr. (UNC) Josef Baumgartner
Münchener Str. 26
D-85247 Schwabhausen, Germany
privacy@syncredible.app
+49 8138 6677429

or our data protection officer:

Walter Lukmann
Packerstrasse 183
A-8561 Söding, Austria
service@dsgvoschutzteam.com
+43 660 60 888 01


9. Changes to this privacy policy
We always keep this privacy policy up to date. Therefore, we reserve the right to change it from time to time and to adapt it in case of changes in the collection, processing or use of your data.

The currently valid version of this data protection declaration can be called up at any time under the menu option https://syncredible.app/en/privacy-policy/.