Privacy Policy
Last Updated: November 2020
This Privacy Policy shall apply to the RealNote.one mobile App (the “App”) and the websites www.realnote.de and www.realnote.one (these websites together also the “Website”) (App and Website together the “Services”).
1. GENERAL
Regarding the Services RealNote GmbH, Kreuzbergstraße 27, 53125 Bonn Deutschland (“RealNote”, “we”, “us” or “our”) is the controller within the meaning of the General Data Protection Regulation (“GDPR”).
This privacy policy shall inform you on how we collect, process and use (“Use”) your Personal Data in connection with the Services.
2. DATA WE COLLECT, PROCESS AND USE
a. In general, you can use the Services without providing any personal information such as e.g. your name, email address, postal address, telephone number, financial information (all such information concerning the personal or material circumstances of an identified or identifiable individual data subject together “Personal Data”). Therefore, unless otherwise provided for in this privacy policy if you do not provide us directly with Personal Data in another way or actively consent to the use by us of certain Personal Data, we do not use your Personal Data.
b. Regarding the Website: if you visit the Website your browser automatically transfers certain data so that it can access the Website, in particular:
- the IP address
- the date and time of the request
- the browser type
- the operating system
- the language and version of the browser software
Such data is processed, in particular, as without such data the Website cannot be accessed.
c. In connection with the use of the App a random user number (hash value) is generated for you based on your mobile device that allows us to allocate your activities (posts, replies, likes, etc.) to an account. The use of such number is required for the registration of your account (as without such value we cannot connect your activities within the App to your account and therefore a use of the App would not be possible). We cannot relate this number or the account to your name or other personal information of you.
d. In addition, regarding the App certain data transmitted by your mobile device is collected, namely your IP address, the periods of time in which you use the App, the date of the registration of your account, the operating system of your device (Android or iOS) and the type of device you use (e.g. iPhone, Samsung Galaxy). Such data is collected, in particular, in order to be able to distinguish actual App users from bots, prevent abusive behavior and block abusive content that is reported by other users.
e. If you actively provide us in the App with additional basic demographic data such as profession, gender and age we might use such data to personalize the experience for you with regard to the App, as well as providing information tailored towards your profession, gender or age. Regarding your age, we might process such data also in order to verify whether you are old enough to use the App.
f. In addition, the full functionalities of the App are only accessible to you if you grant access to your mobile device’s geo location and your mobile device’s camera. To this end, when you use the App for the first time you will be asked by your device whether location data may be used and whether your camera may be used. If you do not allow this or if you allow this, but later deactivate this functionality in the settings of your mobile device, please note that the App or at least certain features and functionalities of the App might not work or might not be accessible to you.
g. If you provide to us information on the Website via a request form contained on the Website or on another way then we will process your data in order to answer your respective (information) requests.
h. We might disclose your Personal Data where such disclosure is required by law (for example, upon request of a court or of law enforcement authorities).
i. The legal basis for the processing of personal data described above in
- section 2.b (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests to Use such data arises from the fact that without such data the Website cannot be accessed).
- section 2.c (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures).
- section 2.d (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests are that we need a way to distinguish users from bots, prevent abusive behaviour and block abusive content when users report it).
- section 2.e is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests are that we use and analyze the respective data to improve the App, such as by gaining a better understanding of your interests and to help personalize your user experience, as well as providing you features exclusive to your specific demographic; regarding age verification we have an interest to verify whether you are old enough to use the App).
- section 2.f is Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures) and Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interest is that we can only provide the App services with all its functionalities, if respective geo location data is processed). For the avoidance of doubt: we will not process your geo location data if you choose to not allow your device to share such data with regard to the App (cf. also above under 2.f).
- section 2.g is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests are that we need to process the respective data in order to being able to answer your (information) requests.
3. USE OF ANALYZING, ADVERTISING AND OTHER TOOLS
a. We use the following tools to better understand user preferences through user actions:
aa. We use the platform Firebase to control and ensure stability in our App as well as to better understand user engagement within the App. Firebase is certified under the Privacy Shield Framework certification as well as the SOC certification. The Firebase services process the users installation UUID and an IP address as well as certain events (e.g. page views and button clicks) to provide analytic information.
bb. The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyze how you use the Website. The information generated by the cookie about your use of the Website will normally be transmitted to and stored by Google on servers in the United States. In case IP-anonymization is activated on the Website, your IP address will be truncated within the area of member states of the European Union or within other contracting states to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of the Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services for the Website operator relating to Website activity and internet usage. The IP-anonymization is active on the Website. The IP address that your browser transfers within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use all functions of the Website. You can also opt-out from the storage by Google of the data that is created by the cookie and is related to the use of the Website (including your IP address) and the processing of such data by Google by downloading and installing the Google Analytics opt-out Browser add-on available under https://tools.google.com/dlpage/gaoptout?hl=en. As an alternative to the browser add-on or within browsers on mobile devices, you can click this link in order to opt-out from being tracked by Google Analytics within this Website in the future (this opt-out option applies only for the browser in which you set it and with regard to the Website). In this case an opt-out cookie is put on your device. In case you delete your cookies, you will have to use the aforementioned link again. For further information on Google Analytics please refer to: http://www.google.com/analytics/terms/gb.html, https://support.google.com/analytics/answer/6004245?hl=en, http://www.google.de/intl/en-GB/policies/privacy/. To our best knowledge Google complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU member countries. Google Inc. (and its wholly-owned US subsidiaries) has certified that it adheres to the relevant Privacy Shield Principles, including for Google Analytics. The European Commission qualifies the US to provide an adequate legal protection for personal data transferred from the EU to self-certified organisations in the US that are certified under the Privacy Shield programme. Further information can be found at: https://www.privacyshield.gov/EU-US-Framework.
cc. If you decide to deactivate (some of) the tools described in this section 3.b (to the extent this is possible), please note that certain features and functionalities of the Services might not work or might not be accessible to you.
dd. We use the tool Kochava with regard to the App. Kochava is a real-time database, which we are using for real-time data exchange and data storage. Kochava also allows for analyzing anonymized behavioural data, in particular, the analyzing of active users and activity events (e.g. page views). Certain (anonymized) user data might be sent to Kochava Metrics. For further information regarding Kochava please refer to https://www.kochava.com/support-privacy/. To our best knowledge Kochava complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU member countries. Kochava has certified that it adheres to the relevant Privacy Shield Principles. The European Commission qualifies the US to provide adequate legal protection for personal data transferred from the EU to self-certified organisations in the US that are certified under the Privacy Shield program.
ee. We use Facebook Analytics with regard to the App. Facebook Analytics is a real-time database, which we are using for real-time data exchange and data storage. Facebook Analytics also allows for analyzing anonymized behavioural data, in particular, the analyzing of active users and activity events (e.g. page views) and the mobile advertisement-ID. For further information regarding Facebook SDK please refer to https://www.facebook.com/business/m/one-sheeters/gdpr-developer-faqs . To our best knowledge Facebook Analytics complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU member countries. Facebook Analytics has certified that it adheres to the relevant Privacy Shield Principles. The European Commission qualifies the US to provide adequate legal protection for personal data transferred from the EU to self-certified organisations in the US that are certified under the Privacy Shield program.
b. The legal basis for the processing of the data described in the sections 3a (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests to Use such data is that we use and analyze the respective data (i) to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services, (ii) to help personalize your user experience, (iii) to recognize user patterns in order to protect the App against bots, abusive members and abusive content, and (iv) to provide you with certain features of the Services (without us using such data some of the functionalities of the Services might not work or might not be accessible (this applies, in particular, to the tools mentioned above in sections 3.a aa,bb; with regard to item (iv) such processing of data is also based on Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures)).
4. DURATION OF STORAGE OF PERSONAL DATA
Unless no shorter storage period is indicated in this privacy policy, we, in general, store Personal Data as long (i) as required for the provision of the Services to you, and/or (ii) as it is necessary with regard to the contractual relationship with you, thereafter only if and to the extent that we are obliged to do so by mandatory statutory retention obligations. If we no longer require the respective Personal Data for the purposes described above, such Personal Data will only be stored during the respective legal retention period and not processed for other purposes.
5. YOUR RIGHTS
You have the right to request information from us at any time about your Personal Data stored by us. If the legal requirements are met, you also have rights vis-à-vis us to request from us access to and rectification or erasure or restriction of processing concerning your Personal Data or to object to the processing of your Personal Data as well as the right to receive from us your Personal Data provided to us in a structured, established and machine-readable format (you can transfer this data to other parties or have it transferred; data portability).
If you have given your consent to the use of personal data, you can revoke such consent at any time (for the future).
If you believe that the processing of your Personal Data by us is in breach of the applicable data protection laws, you can issue a complaint with the competent supervisory authority for data protection.
6. CONTACT; DATA PROTECTION OFFICER
You can contact us, for example, via the address indicated above in section 1 and/or by using the contact info contained in the App or on the Website.
For all questions regarding data protection at RealNote (including the assertion of your rights further describe above under section 5.), you can also contact RealNote’s Data Protection Officer directly. The contact details of the data protection officer are:
- Data Protection Officer, RealNote GmbH, Kreuzbergstraße 27, 53127 Bonn, Germany
7. KEEPING YOUR PERSONAL DATA SECURE
We place great importance on the security of all Personal Data associated with the use of our Services. We have security measures in place to attempt to protect against the loss, misuse and alteration of Personal Data under our control. Our security and privacy policies are periodically reviewed and enhanced as we consider it appropriate and only authorised personnel have access to Personal Data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
We have taken additional extensive security precautions relating to our Services and its use. However you should bear in mind that in spite of such security measures, submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our Services whilst it is in transit over the internet.