Last Updated: July 2018
Regarding the Services the Rebels Technologies GmbH, Tannenstrasse 7, 9000 St. Gallen (“Rebels”, “we”, “us” or “our”) is the controller within the meaning of the General Data Protection Regulation (“GDPR”).
2. DATA WE COLLECT, PROCESS AND USE
a. In general, you can use the Services by creating an account with your first name, university email address and a profile photo. Your first name and profile photo, as well as the name from your university that we deduct from your email, are visible by other users in proximity. This basic information helps build trust in the community and makes it more likely that meaningful interactions happen among users over the app.
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 anonymous user ID string is generated for you that allows us to allocate your Rebels activities (status, hangouts, messages, etc.) to your account. The use of such an ID 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). Furthermore, we also store data on the language in which you use the App in order to to provide to you the App and respective content in your preferred language.
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 behaviour and block abusive content that is reported by other users.
e. In addition, the full functionalities of the App are only accessible to you if you grant access to your mobile device’s geo location. 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. 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.
f. 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.
g. 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).
h. We might disclose certain (anonymous) user data (such as information about hangouts and information about activity) to universities in order for them to further analyse use patterns of our users and help us classify content created by our users. The respective data disclosed to such universities cannot be traced back by such universities to a specific user.
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.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.e).
- section 2.f 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.
- section 2.g is Art. 6 (1) sentence 1 lit. c GDPR (legal obligation).
- section 2.h (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the universities have a legitimate interest to analyze respective data from a scientific point of view and this analysis is not trivial for us to reproduce as we use the results of such analysis to further our understanding of our user base and its preferences).
3. USE OF ANALYZING, ADVERTISING AND OTHER TOOLS
We also use the following tools to better understand user preferences through user actions:
a. We use a self-developed tool with regard to the App that evaluates and stores user activity (in particular what features are used, what features are not used) and derive conclusions from that data to give us a better picture of how the App is used by our users. We use that data to improve the usability of the App for the users and to develop new features.
b. We also use the Facebook Software Development Kit (“Facebook SDK”) of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”) with regard to the App. The Facebook SDK allows for analyzing anonymized behavioral data, in particular the counting of active users and activity events (e.g. create a status, join a hangout, send messages). For further information regarding the Facebook SDK please refer to https://developers.facebook.com/docs/ios?locale=en_GB and https://developers.facebook.com/docs/android?locale=en_GB. This does not give us any access to data from Facebook or a user’s Facebook account by any means. Certain (pseudonymized) data of you might be submitted to Facebook servers in the USA. To our best knowledge Facebook 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 has certified that it adheres to the relevant Privacy Shield Principles. 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.
i. If you decide to deactivate (some of) the tools described in this section 3 (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.
The legal basis for the processing of the data described in the sections 3 (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; 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. TECHNICAL IMPLEMENTATION OF THE SERVICES BY SUBCONTRACTORS
We partly use service providers who process Personal Data on behalf of us to operate the technical platform for the Services. These service providers process the data exclusively according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).
5. DURATION OF STORAGE OF PERSONAL DATA
6. 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.
7. CONTACT; DATA PROTECTION OFFICER
You can contact us, for example, via the address indicated above in section 1., via
firstname.lastname@example.org and/or by using the contact info contained in the App or on the Website.
For all questions regarding data protection at Rebels (including the assertion of your rights further describe above under section 6.), you can also contact Rebels’s Data Protection Officer directly. The contact details of the data protection officer are:
- Data Protection Officer, Rebels Technologies GmbH, Tannenstrasse 7, 9000 St. Gallen
8. 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.