Privacy policy

We greatly appreciate your interest in our company. Data protection is of particularly high importance to the management of 28Apps Software GmbH. The use of the Applications and Internet pages of 28Apps Software GmbH is possible without providing any personal data. However, if a data subject wishes to use special services provided by our company via our website, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to 28Apps Software GmbH. Through this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Additionally, this privacy policy informs data subjects of the rights to which they are entitled.

As the controller, 28Apps Software GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, such as by telephone.

The privacy policy of 28Apps Software GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be both easy to read and understand for the public, as well as for our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this privacy policy, we use the following terms, among others:

Personal data means any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction

Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union, and other provisions related to data protection is:

28Apps Software GmbH
Martinistraße 43
28195 Bremen
Germany
Tel.: +49 421 301 59 900
Email: kontakt@28apps.de
Website: www.28apps.de

The data protection officer of the controller is:

Andreas Bethke
B³ Datenschutz GmbH
Papenbergallee 34
25548 Kellinghusen
Germany
Tel.: +49 421 301 59 900
Email: ext-dsb@b3-datenschutz.de

Any data subject may, at any time, contact our data protection officer directly with all questions and suggestions regarding data protection.

The website of 28Apps Software GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

The controller shall process and store personal data of the data subject only for the period necessary to achieve the purpose of storage or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in cases of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his or her name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Article 6(1)(d) GDPR. Ultimately, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal grounds, if the processing is necessary for the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

The criterion used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obligated to provide us with personal data when our company signs a contract with him or her. The non-provision of personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.