We know that the handling of your personal data is important to you and because of that we take the greatest possible care to handle your personal data in accordance with the General Data Protection Act (“GDPR”).
When designing the APP, we also have made sure that as little as possible information that directly identifies you is collected. As however some countries including the European Union, have a broad definition of personal data this policy covers it. In this sense we would need to first of all explore the definition of personal data.
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Who are we?
The responsible entity is:
Legal bases for processing
The processing of your personal data may be based on the following legal grounds:
- consent where we obtain your consent (Art. 6 (1) a) GDPR).
- contract, insofar as the processing of personal data is necessary for the performance of a contract (Art. 6 (1) b) GDPR).
- legal obligation, insofar as we are subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations (Art. 6 (1) c) GDPR).
- legitimate interest, applies on the basis of our legitimate interests, e.g., when using service providers as part of the APP (Art. 6 (1) f) GDPR). Our interest is directed towards the use of a user-friendly, appealing, and secure presentation as well as optimization of the APP, which serves our business interests as well as meeting your expectations.
What are your rights?
You have the following rights with respect to us processing your personal data:
- Right of access
- Right to rectification
- Right to restriction of processing
- Right to erasure
- Right to information
- Right to data portability
- Right to object
- Right of withdrawal
- Right to complain to a supervisory authority
To assert these rights, please contact us at any time using the details provided. You also have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority.
Accuracy and updating your information
If you believe that the personal data, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer your requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of Personal Data, notably where such requests would not allow us to provide our service to you anymore.
Collection of Personal Data
Personal data may be collected in two ways, that is directly when you for example volunteer it to us or automatically for example when you install and use our APP. As indicated above we have made sure that as little as possible information that directly identifies you is collected.
- When you create an account
Personal data will continue to be collected and processed if you provide it to us for the performance of a contract or when opening an account. We also use a Token-based Authentication system which is a protocol that generates encrypted security tokens and enables users to verify their identity and then generates a unique encrypted authentication token. Which data is collected can be seen from the respective input forms.
Deletion of your account is possible at any time and can be done by sending a message to us. We store and use the data provided by you for the purpose of processing the contract. After complete processing of the contract or deletion of your customer account, your data will be blocked with regard to tax and commercial law retention periods and deleted after expiry of these periods, unless you have expressly consented to a further use of your data or a legally permitted further use of data has been reserved on our part.
- When you use our APP
We process personal and non-personal data of users for the purpose of using the app, connecting your bank cards, scan your receipts or share them with your accountant or tax professional as well as all the other functions of our APP and of course for the purpose of fulfilling the contract. You can manage and change all personal information you provide in the APP. If you use our APP, we store the data required for the fulfillment of the contract until you delete it or its final deletion of the access and/or after expiry of the statutory retention periods. As such the legal basis for processing the personal and non-personal data you provide to us (including sharing, transferring, uploading, or connecting to our APP) is based on your consent and it is processed on the basis of fulfilling the contract we have with you.
- When you contact us
If you contact us per e-mail, your transmitted personal data will be automatically stored for the purpose of processing the request or contacting you. We delete the data accruing in this context after the storage is no longer necessary for the processing of your request or restrict the processing if there are legal retention obligations. The legal basis for processing is our legitimate interest and/ or a contractual or precontractual measure.
Automatically collected data
- Downloading the APP
The APP can be downloaded from the "Google Playstore" a service offered by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, US, if you are resident outside the EU and Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland if you are a resident within the EU, or the Apple App service "App Store" a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.
- Installing the APP
As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.
As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, It cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.
- Starting the App
Every time you start the App, your data is synchronized, and your device communicates with our server through a signed token. The transmission takes place automatically and is a prerequisite for the secure functioning of the APP and is therefore mandatory.
- Device information
We or rather Google and Apple on our behalf collects information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.
How we use information?
The main reason we use your data is to deliver and improve our services as follows:
- to provide our APP to you,
- provide you with customer support and respond to your requests,
- to improve our APP and develop new features and services,
- retain data related to fraudulent activities to prevent against recurrences,
- to ensure legal compliance,
- Analyze your profile, activity on the service;
- assist law enforcement, and
- enforce or exercise our rights.
How long do we store your data?
We keep your personal data only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your data upon deletion of your account (following the safety retention window), unless:
- we must keep it to comply with applicable law,
- we must keep it to evidence our compliance with applicable law,
- there is an outstanding issue, claim or dispute requiring us to keep the relevant data until it is resolved, or
- the data must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.
Keep in mind that even though our APP is designed to carry out data deletion processes according to the above standards, we cannot promise that all data will be deleted within a specific time-frame due to technical constraints.
Duration of data storage
In general, your APP data is saved and stored on our secure servers in the USA, and we only store personal data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.
How do we protect your data?
We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal data. As with all online technology, we take steps to secure your data, however we do not promise, and you should not expect, that your personal data will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.
How we share your data?
We may disclose your personal data to third parties:
- for the purposes of providing services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, in connection with your use of the APP,
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or
- if we or substantially all of our shares or assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets.
Obligation to provide personal data
You are not obliged to provide us with personal data. However, depending on the individual case as described above, the provision of certain personal data may be necessary for the provision of the services. If you do not provide us with this personal data, we may not be able to provide the requested service.
Authorizations and Access
We may request permission to store your APP data including your camera from your mobile device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny the storage of game data on your device via Settings/Notifications/ in your device, however this means that your game data cannot be saved.
To ensure the full functionality of the App, we ask for your permission to access the Push notifications feature of your device. If you have enabled push notifications in the settings of your device, we can send you messages directly to your device and inform you about news, updates, and changes to our services. You can adjust or stop receiving push messages at any time via the device settings of your device.
Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
You can stop the collection of information by our APP by uninstalling it using the standard uninstall procedure for your device.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Because we’re always looking for new and innovative ways to improve our APP, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the following contact details: