Last updated: 09/09/2019
Personal data (hereinafter referred to as the „data“) will only be processed by us to the extent necessary and for the purpose of providing a functional app on iOS and Android and user-friendly presence, including its contents and the services offered there.
Pursuant to Art. 4 clause 1 of Regulation (EU) 2016/679, that is to say the General Data Protection Regulation (hereinafter referred to simply as „GDPR“), „processing“ shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
- Information about us as controller
II. Rights of users and data subjects
III. Information about the data processing
- Information about us as controller
The responsible provider of this internet presence according to the data protection regulations is:
SNORE FREE GmbH
1040 Vienna / Austria
+43 676 5236465
Data Protection Officer at snore free is: Sigismund Gänger
He can be reached at the above e-mail address.
- Rights of users and data subjects
With regard to the data processing described in more detail below, users and data subjects have the right
- to confirmation of whether data concerning them are being processed, information about the data being processed, further information about the nature of the data processing as well as copies of the data (see also Art. 15 GDPR);
- to rectification or integration of inaccurate or incomplete personal data (see also Art. 16 GDPR);
- to immediate erasure of data concerning the person (see also Art. 17 GDPR), or, alternatively, if further processing in accordance with Art. 17, para. 3 GDPR is required, to restriction of processing in accordance with Art. 18 GDPR;
- to receive the data concerning them and/or provided by them and to have the same transmitted to other providers/controllers (see also Art. 20 GDPR);
- of complaint to the supervisory authority if they believe that data concerning them are being processed by the provider in breach of data protection provisions (see also Art. 77 GDPR).
In addition, the provider is obliged to inform all recipients, to whom the provider has disclosed data, of any rectification or erasure of data or the restriction of processing pursuant to Art. 16, 17 para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.
Likewise, under Art. 21 GDPR users and data subjects have the right to object to the future processing of data concerning them, provided that the data provided by the provider in accordance with Art. 6 para. 1 lit. f) GDPR is processed. In particular, an objection to data processing for the purpose of direct advertising is permissible.
III. Information about the data processing
Your data processed when using our app on iOS and Android and our internet presence will be erased or blocked as soon as the purpose for its storage ceases to apply, provided the erasure does not conflict with any statutory retention obligations and no other specifications with regard to individual processing methods are stipulated below.
We process personal data that the customer provides us even through the use of our services, but also data provided by third parties:
For technical reasons data are transmitted by your internet browser to us or to our webspace provider, especially to ensure a secure and stable internet presence. These so-called server log files record the type and version of your browser, the operating system, the website from which you have changed to our internet presence (referrer URL), the website(s) of our internet presence you visited, the date and time of your access as well as the IP address of the internet connection from which you visited our internet presence.
The data thus collected will be temporarily stored, but not in association with any other of your data.
This storage is based on the legal basis of Art. 6 para. 1 lit f) GDPR. Our legitimate interest lies in the improvement, stability, functionality and security of our internet presence.
The data will be deleted within no more than seven days, unless continued storage is required for evidentiary purposes. In which case, all or part of the data will be excluded from erasure until the investigation of the relevant incident is finally resolved.
The data you submit when using our service offering will be processed by us for the purpose of implementing the contract and to the extent required. Please note that orders cannot be completed and processed without providing your data.
The legal basis for processing is Art. 6 para. 1 lit b) GDPR.
After your order has been completed, your personal data will be deleted, but only after the retention periods required by tax and commercial law.
Within the framework of implementing the contract, we disclose your data to third parties (such as financial service providers for the processing of payment transactions), provided that the disclosure is required for the provision of service or payment purposes.
The legal basis for the disclosure is Art. 6 para. 1 lit b) GDPR.
Customer account/registration function
If you create a customer account on our internet presence or via our apps on iOS and Android, we will collect and store the data entered by you during registration (e.g. your name, address or e-mail address, telephone number, device number, telephony provider) exclusively for pre-contractual services, for the fulfillment of the contract or for the purpose of customer service. We also store your IP address and the date and time of your registration. Furthermore, we ask questions about your possible causes of snoring and store the data to improve our offer. We do not store this data anonymous, but this data is attributable to the respective user, also to allow, for example, a synchronization between multiple devices. The data concerning the causes of snoring, if at all, is only disclosed anonymously.
Provided you have consented to this processing, Art. 6 para. 1 lit. a) GDPR is the legal basis for processing.
If the opening of the customer account additionally serves pre-contractual measures or the fulfillment of the contract, the legal basis for this processing is also Art. 6 para. 1 lit. b) GDPR.
You may revoke the consent to open and maintain your customer account at any time with effect for the future according to Art. 7 para. 3 GDPR. All you have to do is inform us of your revocation.
The collected data will be erased as soon as processing is no longer necessary. In doing so, warranties, limitation periods or retention periods are taken into consideration, if necessary.
Contact request / contact options
If you contact us via e-mail or the contact form, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your request; otherwise we will not be able to answer it in full or at all.
The legal basis for this processing is Art. 6 para. 1 lit b) GDPR.
Your data will be erased once we have fully answered your request and provided that the erasure does not conflict with any statutory retention obligations.
In our internet presence as well as the use of the SnoreFree App, we use Google Analytics or Fire Base Performance Monitoring. This is a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, hereinafter only referred to as „Google“.
With the certification according to the EU-US Privacy Shield www.privacyshield.gov
Google guarantees that it will follow data protection regulations of the EU when processing data in the United States.
The Google Analytics service is used to analyze how our website is used. The legal basis is Art. 6 para. 1 lit f) GDPR. Our legitimate interest lies in the analysis, optimization and economic operation of our internet presence.
Our apps use IDs for mobile devices, such as the Google Advertising ID („GAID“) and the ID for Advertising for iOS („IDFA“) as well as technologies similar to cookies for the use of Google Analytics for mobile phones.
User and user-related information, such as IP address, place, time or frequency of your visits to our internet presence will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function. With this function Google truncates the IP address already within the EU or the EEA.
The data so collected is in turn used by Google to provide us with an evaluation about the visits of our internet presence as well as the usage activities. This data can also be used to provide other services related to the use of our internet presence and of the Internet in general.
A complete list of automatic traces recorded by Fire Base Performance Monitoring can be found at here.
Google states that it will not connect your IP address to other data. In addition, Google has other data protection information available for you at https://www.google.com/, including, for example, options that you can exercise to prevent the data use.