This Data Protection Policy describes the processing of personal data when using the www.cleverdialer.de websites, including the Clever Dialer mobile iOS applications. It also explains the choices you have regarding your personal information (“Your Rights”) and how you can contact us.
I. Who is the Responsible Party and how can I contact the Data Protection Officer?
The responsible person within the meaning of the GDPR is
validio GmbH & Co. KG
Pretzfelder Straße 13
90425 Nuremberg, Germany
Commercial Register Nuremberg HRA 12160
Managing Director: Dipl.-Kfm. Michael Oschmann
For questions about the processing of your personal data by us or about data protection in general, please contact our Data Protection Officer Dr. Stefan Drewes at the address given under the section Company Information or at the following e-mail address: email@example.com
II. Your rights as a data subject
Each data subject has the following rights:
- Right of access of the data subject (Article 15 GDPR)
- Right to rectification of incorrect data (Art. 16 GDPR)
- Right to erasure, right to be “forgotten” (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to data portability (Article 20 GDPR).
You may object to the processing of personal data for advertising purposes at any time without providing justification, including analysis of customer data for advertising purposes.
In addition, a data subject also has a general right to object (see Art. 21(1) GDPR). In this case, the opposition against data processing should be justified. If data processing is based on consent, your consent can be revoked at any time with effect for the future.
The easiest way for data subjects to exercise theirs right is to contact firstname.lastname@example.org or the address stated in under the section Company Information. In addition, you have the right to file a complaint with your local data protection supervisory authority.
III. Processing of personal data by validio GmbH & Co. KG
In the following, we would like to give you an overview of how we ensure the protection of your personal data when accessing our website and what types of personal data we process for what purposes and to what extent.
1. Processing of personal data
Clever Dialer warns of incoming spam phone calls. The required directory of spam numbers is located on the device and is updated automatically at regular intervals. No data that is connected to a call is transferred to a server.
2. Processing data when using the app – your inquiries
If you send us an inquiry via e-mail or via the contact form, we will collect the information you have provided for processing and answering your inquiry. We store this information for verification purposes over a period of up to two years. The legal basis for this data processing is Article 6(1)(1)(f) GDPR.
3. Information on ensuring data security
We take technical and operational security precautions on our pages to protect the personal data stored by us against access by third parties, loss or misuse, as well as to ensure secure data transfer.
We would like to point out that due to the structure of the Internet, unwanted data access by third parties may occur. It is therefore your responsibility to protect your data against misuse by using encryption or other methods of protection. Without appropriate protective measures, unencrypted data in particular can be read by third parties, even if such data are transferred by e-mail.
Tracking by Google Firebase
This app uses Google Firebase, an app analytics service provided by Google Inc. (“Google”). Google Firebase is able to provide an analysis of the use of the app through a software development kit (SDK). The generated information about your use of this app is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymisation in this app, your IP address will be truncated by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and truncated there. Google will use this information on our behalf to evaluate your use of the app, compile reports on the app’s activities, and provide us with other services related to the use of the app and Internet usage. The IP address provided by your app on Google Firebase will not be merged with other Google data.
You can easily prevent tracking by Google Firebase by disabling tracking in the app’s settings. Go to the gear icon in the top right corner. On this page you will find the item “Tracking”. Disable this point.
We use Google Firebase to analyse and regularly improve the use of our app. By using these statistics we can improve our offer and make it more interesting for you as a user. For exceptional cases in which personal data are transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The analysis of the data collected by Google Analytics takes place over a period of 26 months on the basis of Art. 6 Para. 1 Sent. 1 lit. f of the GDPR.
For more information, see https://www.google.de/intl/de/policies/privacy/ (general information about Google Analytics and privacy).
Usage analysis with Appsflyer
We use Appsflyer to analyse usage within our app Clever Dialer. Appsflyer is a tool for analysing and assigning app installations to campaigns. We collect the Apple Advertiser ID (IDFA) as well as an anonymous hash value generated from various data that are transmitted when using an app or the device within the framework of Appsflyer – if approved by the user.
You can easily prevent such an analysis by AppsFlyer by disabling tracking in the app’s settings. Go to the gear icon in the top right corner. On this page you will find the item “Tracking”. Disable this point.
We use this data in our legitimate interest to analyse and optimise the use of our offer. (Article 6(1)(f) of the General Data Protection Regulation).
If you use our app, the above data will be transmitted to Appsflyer LTD, 100 1st Street, San Francisco, 94105, which operates Appsflyer on our behalf.
Current as of: July 4, 2019