Privacy Policy Bounti App
Everything you need to know about how we protect your data.
Version 1.1 – Oct 6, 2024
In the following, we provide information about the collection of personal data when using our mobile app (hereinafter only"App").
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
Contact details
The controller within the meaning of Art. 4 para. 7 EUGeneral Data Protection Regulation (GDPR) is Honeycraft GmbH, Hundsteinweg 66, 12107 Berlin, Germany, email: deniz@bounti.co. We are legally representedby Deniz Bayraktaroglu, Ziar Khosrawi.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.
Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
· Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
· Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a user purchases a product from us, or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
· Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfil a legal obligation by processing personal data, as may be the case, for example,in tax law.
· Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g.for cookies that are necessary for the technical operation of our website.
Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist(e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
Right of access,
Right to correction or deletion,
Right to limit processing,
Right to object to the processing,
Right to data transferability,
Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available athttps: //www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
Obligation to provide data
Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.
Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
Downloading the app
Our app is ready for download at Apple's App Store and Google's Play Store (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.
Users can also download this mobile app directly to their mobile device via our website. When downloading, further user data is processed via the website, which we inform about in the privacy policy of our website.
Hosting
Our app is hosted by
· Scaleway. The provider is SCALEWAY S.A.S, 8 rue de la Ville l‘Evêque, 75008 Paris, France.
· Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA
· Microsoft Ireland Operations Limited. One Microsoft Place, South County Business Park, Leopardstown, Dublin
The providers thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
Informative use of our website
When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR. The data processed to this extent are:
· IP address
· Date and time of the request
· Time zone difference from Greenwich Mean Time (GMT)
· Content of the request (concrete interface)
· Access status/HTTP status code
· Amount of data transferred in each case
· Operating system and its interface
· Language and version of the operating system
Access to functions or data
The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation. The functions or data processed to this extent are
· Camera
· Microphone
· Location
Data processing for the provision of functions
We process personal data in the app to offer training courses to users. The legal basis is the performance of an employment contract with their employers under Art. 6 para. 1 lit. b) GDPR and §26 BDSG.
The data processed for this purpose are:
· IP-Address
· Name
· E-Mail-Adress
· Telephone number
Users with manager rights are able to see information about the user’s progress in the training courses. The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it.
User account
Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6para. 1 s. 1 lit. b GDPR. We delete the data when users delete their user account.
Payment processors
For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6para. 1 s. 1 lit. b GDPR). These payment processors are:
· Mastercard Europe SA, Belgium
· Visa Europe Services Inc., Great Britain
Third-party tools: Mixpanel
We use Mixpanel for analytics. The provider is Mixpanel, Inc., One Front Street, Floor 28, San Francisco, CA 94111, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers),meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://mixpanel.com/legal/privacy-policy/.
Third-party tools: Twilio
We use Twilio for sending e-mails. The provider is Twilio, Inc, 375 Beale Street, Suite 300, San Francisco, CA 94105, USA. The provider processes communication data (telephone number, name, messages) in the USA.
Insofar as the e-mails sent are transaction-related, the processing is necessary for the performance of a contract with the data subject, so that the legal basis is Art. 6 (1) (b) GDPR. For optional emails,the legal basis is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, via the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
Insofar as processing is carried out as part of our activities as a processor, this is done on the basis of Art. 28 GDPR and the legal basis for the processing is determined by the controller.
The legal basis for transfers to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses that we have agreed with the provider as part of the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR).
The data is deleted when the purpose of its collection has ceased to exist and there is no obligation to retain it. For more information, see the provider's privacy policy at https://www.twilio.com/legal/privacy.
Third-party tools: Sentry
We use Sentry to monitor our applications and to track errors in our application. The provider is Functional Software, Inc., 132Hawthorne Street San Francisco, CA 94107, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1lit. f GDPR. We have a legitimate interest in adequately monitoring the functionality of our applications.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://sentry.io/privacy/.
Third-party tools: Firebase Crashlytics
We use Firebase Crashlytics to track errors in applications or on websites and to manage repairs. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1lit. f GDPR. We have a legitimate interest in adequately monitoring the functionality of our applications.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy.
Third-party tools: Firebase Performance Monitoring
We use Firebase Performance Monitoring to measure the performance of marketing campaigns. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy.
Third-party tools: Google Analytics for Firebase
We use Google Analytics for Firebase to measure the performance of marketing campaigns. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy.
Third-party tools: Intercom
We use Intercom to communicate with users. The provider is R&D Unlimited Company 2nd Floor, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times), contact data (e.g. e-mail addresses, telephone numbers), and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1lit. f GDPR. We have a legitimate interest in optimizing the interaction with our website visitors.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://www.intercom.com/legal/privacy.
Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
Questions and comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.
