1. Subject matter of this data protection declaration
Thank you for your interest in our apps Drynk, QuizPoker & Guess What; the “Service”.
The protection of your personal data is important to us at Siwalu Software GmbH (“Siwalu”, “us”, “we”). Therefore, we would like to offer you comprehensive transparency regarding the processing of your data. Because only if the processing is comprehensible for you as the person concerned are you sufficiently informed about the extent, the purposes and the use of the processing. In the following, we will also show you which accompanying protective measures we have taken from a technical and organizational point of view.
Please note that you can use links in our app to access other apps or websites that are not operated by us but by third parties. Such links are either clearly identified by us or can be identified by a change in the address line of your browser or by a change to another app pre-installed by you in this case. We are not responsible for compliance with data protection regulations and safe handling of your personal data on these apps or websites operated by third parties.
2. Responsible office
Siwalu Software GmbH with its address is the responsible body within the meaning of the Basic Data Protection Ordinance (DSGVO) and the Federal Data Protection Act (BDSG): An der Schluse 122a, 48329 Havixbeck, Germany. Please address any questions or comments regarding this data protection declaration or data protection in general to the following e-mail address: email@example.com.
3. General information on data processing
We process personal data within the legally permissible limits. This means that data processing operations must be based on a legal basis. These are standardized in Art. 6 para. 1 DSGVO. Most data processing operations are based on a legitimate interest on our part (Art. 6 para. 1 lit. f DSGVO), on processing operations necessary for the execution of the contract (Art. 6 para. 1 lit. b DSGVO) or on your consent (Art. 6 para. 1 lit. a DSGVO). In these cases, you will be informed separately of the consent procedure and will receive additional information. Personal data will only be passed on in the cases described below.
Personal data must also be processed for clear purposes (Art. 5 para. 1 lit. b DSGVO). As soon as the purpose of the processing no longer applies, your personal data will be deleted or protected by technical and organizational measures (e.g. pseudonymization). The same applies to the expiry of a prescribed storage period, subject to the cases in which further storage is necessary for the conclusion or performance of a contract. In addition, there may be a legal obligation to store the data for a longer period of time or to pass it on to third parties (in particular to law enforcement authorities). In other cases, the storage period and type of data collected as well as the type of data processing depend on which functions of the app you use in the individual case. We will also be happy to provide you with information on this in individual cases, in accordance with Art. 15 DSGVO.
4. Collection and processing of your data
If you use our app, the following data will be saved and processed by us. The data processing is carried out to ensure the functionality and security of our information technology systems and services and the further development and optimization of our services, including for marketing purposes. Such purposes constitute legitimate interests in the sense of Art. 6 Para. 1 lit. f DSGVO. The processing is therefore carried out with legal grounds.
4.1 Log data
We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.
4.2 Forced disclosure
We disclose your personal information to law enforcement authorities, investigating authorities or in legal proceedings if we are required to do so by law or authority or if it is absolutely necessary for the performance of the services or for the protection of our or your rights.
4.3 Sale or Merger
We may disclose your personal information in the event of a merger, acquisition or sale of all or any of our assets. We will notify you of this via a notice on our website and inform you of your rights.
5. Cookies, tracking providers, analysis services
5.1 Use of Google Ads Conversion Tracking
We use the services of Google Ads, an online advertising program of Google Ireland Limited, Gordon House, 4 Barrow Street, D04 E5W5 Dublin, Ireland (“Google”), to advertise our services on external websites by means of advertising media (so-called Google Ads). Siwalu Software GmbH thus pursues a legitimate interest pursuant to Art. 6 Para. 1 lit. f DSGVO in displaying targeted advertising to you, adapting advertising offers and analyzing user behavior.
6. Right of revocation and objection
If the processing of your personal data is based on your consent (Art. 6 para. 1 lit. a DSGVO), you can revoke this at any time in accordance with Art. 7 para. 3 DSGVO. The processing is lawful until your revocation – the revocation therefore only affects the processing after receipt of your revocation. You can declare your revocation informally by post or e-mail. The processing of your personal data will then no longer take place, subject to approval by another legal basis. If this is not the case, your data must be deleted immediately after revocation in accordance with Art. 17 para. 2 DSGVO.
Art. 21 DSGVO gives you the right to object: This means that you have the right to object to the processing of personal data concerning you at any time for reasons arising from your particular situation. The processing of this data must therefore have been carried out in accordance with Art. 6 Para. 1 lit. e or f. A special reason for processing need not exist if you object to the processing of data used for direct marketing. This also applies to profiling as far as it is related to direct marketing.
To do this, please send an informal e-mail to: firstname.lastname@example.org.
7. Data security
We use technical and organizational security measures in order to protect personal data that are collected or that may be collected, in particular against accidental or intentional manipulation, loss, destruction or against attacks by unauthorized persons. Our security measures are continuously improved in line with technological developments.
8. Rights of data subjects
The legal data protection regulations grant you the following rights as a person concerned:
The right of access pursuant to Art. 15 DSGVO, the right of rectification of your data pursuant to Art. 16 DSGVO, the right of deletion and oblivion pursuant to Art. 17 DSGVO, the right of limitation of the processing of your data pursuant to Art. 18 DSGVO and the right of data transfer pursuant to Art. 20 DSGVO. The right of deletion and the right to information are subject to the restrictions of §§ 34, 35 BDSG.
To exercise these rights, please send an informal e-mail to: email@example.com. In addition, there is a right of appeal to a data protection supervisory authority (Art. 77 DSGVO in conjunction with § 19 BDSG).
9. Automated decisions in individual cases including profiling
Automated decisions in individual cases, including profiling, are not made.