Privacy Policy for the LRT PowerUp App

Privacy Policy for the LRT PowerUp App

Preamble

This service (hereinafter "App") is provided by LRT Automotive GmbH, Impexstraße 7, 69190 Walldorf, anfrage@lrt-automotive.de (later "we" or "us") as the responsible party within the meaning of the applicable data protection law.

Within the scope of the app, we enable you to retrieve and display the following information:

With the help of our App, you can control charging stations for electric vehicles and display the associated charging statistics.

When you use the app, we process personal data about you. Personal data means any information relating to an identified or identifiable natural person. Because protecting your privacy when using the app is important to us, we would like to inform you with the following information about which personal data we process when you use the app and how we handle this data. In addition, we will inform you about the legal basis for the processing of your data. Asides this, we will inform you on the basic rights to the processing of your personal data, and as far as the processing is necessary to protect our legitimate interests, also about our legitimate interests.

You can access this privacy policy at any time under the menu item "Privacy policy” in the app.

1. information about the processing of your data

Certain information is already processed automatically as soon as you use the app. We have listed exactly which personal data is processed for you below:

1.1     Information collected during the download.

When you download the app, certain required information is transmitted to the app store you have selected (e.g. Google Play or Apple App Store); in particular, the username, the email address, the customer number of your account, the time of the download, payment information and the individual device identification number may be processed. The processing of this data is carried out exclusively by the respective app store and is beyond our control.

1.2     Information that is collected automatically

As part of your use of the App, we automatically collect certain data that is required for the use of the App.

This includes:

Internal device ID, version of your operating system, time of access.

This data is automatically transmitted to us, but is not stored,

(1) to provide you with the Service and related features;

(2) to improve the functions and performance features of the App; and

(3) prevent and eliminate misuse and malfunctions.

This data processing is justified by the fact that.

(1) the processing is necessary for the performance of the contract between you as a data subject and us pursuant to Art. 6(1) lit. b DSGVO for the use of the App; or

(2) we have a legitimate interest in ensuring the functionality and error-free operation of the app and in being able to offer a service that is in line with the market and interests, that your rights and interests in the protection of your personal data within the meaning of Art. 6(1) lit. f DSGVO prevail here.

1.3     1.3 Creation of a user account (registration) and login

When you create a user account or log in, we use your access data (e-mail address and password) to grant you access to your user account and to manage it ("mandatory data"). Mandatory data within the scope of registration are marked with an asterisk and are required for the conclusion of the user contract. If you do not provide this data, you will not be able to create a user account.

In addition, you can provide the following voluntary information as part of the registration process: First Name, Last Name.

We use the mandatory information to authenticate you when you log in and to follow up on requests to reset your password. We process and use the information you provide as part of the registration or login process,

(1) to verify your authorization to manage the user account;

(2) to enforce the App's Terms of Use and any rights and obligations related thereto; and

(3) contact you to send you technical or legal notices, updates, security alerts, or other messages, such as those related to the administration of the User Account.

We use voluntary information to display according to the settings you have made it within the App and to make it available to other users of the App at your request.

This data processing is justified by the fact that.

(1) the processing is necessary for the performance of the contract between you as a data subject and us pursuant to Art. 6(1) lit. b DSGVO for the use of the App; or

(2) we have a legitimate interest in ensuring the functionality and error-free operation of the app, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6(1) lit. f DSGVO.

1.4     Using the app

Within the scope of the app, you can enter, manage and edit various information, tasks and activities. This information includes data about the service description of the app as presented in the preamble.

The app also requires the following authorizations:

- Internet access: this is required to store your entries on our servers and to communicate with the backend.

- Device location: Your location is transmitted to us periodically after your confirmation and we only use your most recently communicated location at any given time and delete the previous location messages. When location collection is active, your smartphone will indicate data processing via a compass icon in the top bar.

The processing and use of usage data is done to provide the service. This data processing is justified by the fact that the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6(1) lit. b DSGVO for the use of the app.

1.5     Use of technical aids, in particular cookies

In addition, technical aids are used for various functions during your use of our mobile app, in particular cookies, which may be stored on your end device. Cookies are text files or information in a database that are stored in the device memory of your mobile device and assigned to the mobile app you are using. Cookies allow certain information to flow to the entity that sets the cookie. Cookies cannot execute programs or transfer viruses to your mobile device but are primarily used to make the Internet offer faster and more user-friendly. This app uses the following types of cookies, whose functionality and legal basis we will explain below.

• Transient cookies: Such cookies, especially session cookies, are automatically deleted when the mobile app is closed or by logging out. They store a so-called session ID. In this way, various requests from your browser can be assigned to the joint session and your computer can be recognized when you return to our app.

 

• Persistent cookies: such are deleted automatically after a predefined duration, which is set differently depending on the cookie. You can view the cookies set and the durations at any time in your browser settings and delete the cookies manually.

Mandatory functions that are technically necessary for the function of the mobile app:

The technical structure of the mobile app requires us to use techniques, in particular cookies. Without these techniques, our app cannot be used (completely correctly) or the support functions could not be enabled. These are basically transient cookies that are deleted after the end of the usage process, at the latest after 30 days. You cannot unselect these cookies if you wish to use our app. The legal basis for this processing is Art. 6 (1) sentence 1 lit. f DSGVO.

Optional cookies when you give your consent: We set various cookies only after your consent, which you can select via the Consent Manager during your first visit to our mobile app. The functions are only activated in the event of your consent and may serve in particular to enable us to analyze and improve the use of our mobile app, to make it easier for you to use it via different browsers or end devices, to recognize you when you visit, or to serve advertising (possibly also to orient advertising to interests, to measure the effectiveness of ads, or to show you interest-based advertising).

The legal basis for this processing is Art. 6 (1) sentence 1 lit. a DSGVO. The revocation of your consent is possible at any time without affecting the permissibility of the processing until the revocation].

2. Disclosure and transfer of data

In addition to the cases explicitly mentioned in this privacy policy, your personal data will only be passed on without your express prior consent if it is legally permissible or required.

2.1 If it is necessary for the clarification of an illegal or abusive use of the app or for legal prosecution, personal data will be forwarded to law enforcement agencies or other authorities and, if necessary, to injured third parties or legal advisors. However, this only happens if there are indications of unlawful or abusive behavior. A transfer may also take place if this serves the enforcement of terms of use or other legal claims. We are also legally obligated to provide information to certain public authorities upon request. These are law enforcement agencies, authorities that prosecute administrative offenses subject to fines, and the tax authorities.

Any disclosure of personal data is justified by the fact that.

(1) the processing is necessary for compliance with a legal obligation to which we are subject pursuant to Art. 6(1)(f) DSGVO in conjunction with national legal requirements to disclose data to law enforcement authorities, or

(2) we have a legitimate interest in disclosing the data to the forementioned third parties if there are indications of abusive behavior or to enforce our terms of use, other conditions or legal claims and your rights and interests in the protection of your personal data within the meaning of Art. 6(1) lit. f DSGVO do not override this.

2.2 We rely on the following third-party companies and external service providers to provide our service:

1. (a) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland - use of the cloud service "Google Cloud Platform" as well as "Google Firebase Authentication".
2. b) MongoDB, Inc., 3 Shelbourne Buildung, Crampton Avenue Ballsbridge, Dublin 4, Ireland - use of the database service "Atlas".

Any disclosure of personal data is justified by the fact that.

(1) we have a legitimate interest in disclosing the data for administrative purposes within our group of companies and your rights and interests in the protection of your personal data within the meaning of Art. 6(1) lit. f DSGVO do not override and

(2) we have carefully selected our third-party companies and external service providers as processors within the scope of Art. 28(1) DSGVO, regularly reviewed them and contractually obligated them to process all personal data exclusively in accordance with our instructions.

2.3 In the course of the further development of our business, the structure of our company may change by changing the legal form, establishing, buying or selling subsidiaries, parts of companies or components. In such transactions, customer information may be transferred along with the part of the company being transferred. In any transfer of personal information to third parties to the extent described above, we will ensure that it is done in accordance with this Privacy Policy and applicable data protection law.

Any transfer of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances as necessary and that your rights and interests in the protection of your personal data within the meaning of Art. 6(1) lit. f DSGVO are not overridden.

3. data transfers to third countries

We also process data in countries outside the European Economic Area ("EEA"). This concerns in detail:

3.1 Use of Google Firebase Authentication.

3.1.1 Our App uses Google Firebase Authentication, a login and authentication service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Firebase").

3.1.2 Google acts as a processor and we have concluded a corresponding contract with Google. For the transfer and processing of personal data, in particular username, profile picture and email address as well as mobile phone number when registering by means of an SMS identification, on Google's servers, Google has, according to its own information, imposed a standard on itself that corresponds to the former EU-US Privacy Shield and has promised to comply with applicable data protection laws in the international transfer of data. We have also agreed to so-called standard contractual clauses with Google, the purpose of which is to ensure compliance with an appropriate level of data protection in the third country.

3.1.3 The legal basis for the collection and further processing of the information is your consent (Art. 6(1) sentence 1 lit. a DSGVO). The revocation of your consent is possible at any time without affecting the permissibility of the processing until the revocation. The easiest way to install the revocation is via Google's browser add-on, which can be accessed via the following link: https://tools.google.com/dlpage/gaoptout?hl=de/.

For more information on Google's privacy policy, see https://google.de/intl/de/policies/privacy/ as well as below https://firebase.google.com/support/privacy.

3.2 Use of Google Cloud Platform

3.2.1 Our App uses Google Cloud Platform, a cloud service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google Cloud Platform").

3.2.2 Google acts as a processor and we have concluded a corresponding contract with Google. For the transfer and processing of personal data, in particular username, profile picture and email address as well as mobile phone number when registering by means of an SMS identification, on Google's servers, Google has, according to its own information, imposed a standard on itself that corresponds to the former EU-US Privacy Shield and has promised to comply with applicable data protection laws in the international transfer of data. We have also agreed to so-called standard contractual clauses with Google, the purpose of which is to ensure compliance with an appropriate level of data protection in the third country.

3.2.3 The legal basis for the collection and further processing of the information is your consent (Art. 6 (1) sentence 1 lit. a DSGVO). The revocation of your consent is possible at any time without affecting the permissibility of the processing until the revocation. The easiest way to install the revocation is via Google's browser add-on, which can be accessed via the following link: https://tools.google.com/dlpage/gaoptout?hl=de/.

For more information on Google's privacy policy, please visit https://google.de/intl/de/policies/privacy/ and https://cloud.google.com/terms/cloud-privacy-notice?hl=de.

3.3 Use of MongoDB

3.3.1 Our App uses Atlas, a database service provided by MongoDB, Inc, 3 Shelbourne Buildung, Crampton Avenue Ballsbridge, Dublin 4, Ireland ("MongoDB").

3.3.2 MongoDB acts as a processor and we have entered a corresponding contract with MongoDB. We have agreed to so-called standard contractual clauses with MongoDB, the purpose of which is to ensure compliance with an adequate level of data protection in the third country.

3.3.3 The legal basis for the use of MongoDB is Art. 6 (1) sentence 1 lit. f DSGVO.

For more information on MongoDB's privacy policy, please visit https://www.mongodb.com/legal/privacy-policy and https://www.mongodb.com/de-de/atlas.

In order to ensure the protection of the personal rights of users also within the scope of these data transfers, we make use of the standard contractual clauses of the EU Commission pursuant to Art. 46 (2) lit. c DSGVO when structuring the contractual relationships with service providers in third countries. You can also request these documents from us using the contact options below

4. Changes of purpose

Processing of your personal data for purposes other than those described above will only take place if permitted by law or if you have consented to the changed purpose of the data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you of these other purposes prior to further processing and provide you with all other relevant information.

5. Period of data storage

We will delete or anonymize your personal data as soon as it is no longer necessary for the purposes for which we collected or used it in accordance with the preceding paragraphs. Unless otherwise specified, we store your personal data for the duration of the usage or contractual relationship via the app plus a period of 7 days, during which we keep backup copies after deletion, unless this data is needed longer for criminal prosecution or to secure, assert or enforce legal claims.

Specific statements in this privacy policy or legal requirements for the retention and deletion of personal data, in particular those that we must retain for tax law reasons, remain unaffected.

6. Your rights as a subject

6.1     Right to information

You have the right to receive information from us at any time, upon request, about the personal data we process that concerns you within the scope of Art. 15 DSGVO. For this purpose, you can submit a request by mail or e-mail to the address given below.

6.2     Right to rectify inaccurate data.

You have the right to request that we correct the personal data concerning you without delay if it should be incorrect. To do so, please contact us at the contact addresses provided below.

6.3     Right to deletion

You have the right, under the conditions described in Art. 17 DSGVO, to demand that we delete the personal data concerning you. These conditions provide in particular for a right to erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of an obligation to erase under Union law or the law of the Member State to which we are subject. For the period of data storage, please also see Section 5 of this Privacy Policy. To exercise your right to erasure, please contact us at the contact addresses below.

6.4     Right to restriction of processing

You have the right to demand that we restrict processing in accordance with Article 18 DSGVO. This right exists in particular if the accuracy of the personal data is disputed between the user and us, for the period of time required to verify the accuracy, as well as in the event that the user requests restricted processing instead of erasure in the case of an existing right to erasure; furthermore, in the event that the data is no longer necessary for the purposes pursued by us, but the user requires it for the assertion, exercise or defense of legal claims, as well as if the successful exercise of an objection is still disputed between us and the user. To exercise your right to restrict processing, please contact us at the contact addresses below.

6.5     Right to data portability

You have the right to receive from us the personal data concerning you that you have provided to us in a structured, commonly used, machine-readable format in accordance with Article 20 DSGVO. To exercise your right to data portability, please contact us at the contact addresses below.

7. Right of objection

You have the right to object at any time, on grounds relating to your situation, to the processing of personal data concerning you, which is carried out, inter alia, on the basis of Article 6(1)(e) or (f) DSGVO, in accordance with Article 21 DSGVO. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or if the processing serves the assertion, exercise or defense of legal claims.

8. Right of complaint

You also have the right to contact a supervisory authority in case of complaints.

9. Contact

If you have any questions or comments about the methods by which we handle your personal data, or if you wish to exercise your rights as a data subject listed out in sections 6 and 7, please contact LRT Automotive GmbH using the following contact details:

LRT Automotive GmbH,

Impexstraße 7,

69190 Walldorf, Germany

Phone: +49 (0) 6227 - 63692

E-Mail: support@lrt.de.

10. Changes to this privacy policy

We always keep this privacy policy up to date. The current version of the privacy policy is always available under "Privacy Policy" within the app.

 

 

 

 

Status: April 2022