Data Protection Information for Memoriser App

Your personal data will be processed by PROAKTIV Management GmbH, Welfenstrasse 22, 81541 Munich (“PROAKTIV”).

We have appointed Dr. Annette Demmel, SPB DPO Services GmbH, Unter den Linden 21, 10117 Berlin, annette.demmel@spb-dpo-services.com, as our external Data Protection Officer.

Your personal data will be processed for the use of the Memoriser App (“App”). The legal basis for the processing is Art. 6 par. 1 b) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Your personal data will be accessible for employees of PROAKTIV who are responsible for the administration of the App. In addition, we employ external IT employees for the maintenance of our IT systems, who may be able to access your personal data during their work.

PROAKTIV will not transfer your personal data that is required for the use of App to any third country outside the EU.

Download:

If you download our App from the App Store the required categories of personal data will be transferred to the App Store to enable the download. This is in particular true for:

• Your name and user name,
• Your email address,
• the ID that is associated with your App Store account
• time of download,
• Your device ID.

The legal basis for processing is Article 6 par. 1 b) GDPR. The processing of your data by the operator of the App Store is carried out outside of the control of PROAKTIV and we are not responsible for this processing. PROAKTIV processes such personal data only insofar as this is required for the download to your mobile device. Your personal data in connection with the download will be stored for the time of your use of the App. Registration When you sign up for the App, we will edit your name, email address, and the time, date, and time zone of your signup to create and maintain an account. We do not store any password-relevant information. The legal basis for such processing is Article 6 par. 1 b) GDPR. If you delete your account, we will delete your registration data within one month after deleting the account. Use of the App When you use the App, we process the following personal information:

• IP address,
• email address,
• date and time of request,
• Time zone,
• encrypted password,
• content of the request (specific page),
• access status / HTTP status code,
• amount of each transferred data,
• browser,
• operating system and its interface,
• Language and version of the browser software as well
• the country of origin of the visitor.

The legal basis for processing is Article 6 par. 1 b) in conjunction with Article 6 par. 1 f) GDPR. The legal interest for processing is to ensure the functionality and a user-friendly visit of our App. In addition to the above categories of personal data, PROAKTIV also requires your device ID and IMEI. Your personal data in connection with the use of the App are processed only for the purpose of using the App and is stored for the time of your use of the App.

Cookies:

In addition to the processing of personal data described above, PROAKTIV will place cookies on your mobile device when you use the App. Cookies are small text files that are stored on your device's memory and tuned to our App. Cookies provide PROAKTIV certain information and should enable the functionality of the App. Our App uses the following cookies:

Session cookies that are deleted when you close or log out of our mobile App. Session cookies store a session ID that can be used to tailor various requests to the App.

Persistent cookies, which are deleted after a defined period of time that may vary depending on the cookie and which is apparent from the cookie. You may change your device preference or app settings to delete third-party cookies or cookies, and to refuse cookies. Please note that you may not be able to use all features of our App if you delete cookies or refuse cookies.

Legal basis for the processing is your consent according to Art. 6 par. 1 a) GDPR. You may revoke your consent at any time by changing your device settings with effect for the future.

For Apple device users:

Advertising Identifier: For advertising purposes we use a so-called "Advertising Identifier" ("IDFA"). This is a unique, but not personalized and non-permanent identification number of a particular Apple device. Data processed by IDFA will not be matched against other device data. PROAKTIV uses IDFA for personalized advertising and analysis of your user behavior. If you opted for "Restrict Ad Tracking" under> Settings> Privacy> Advertising, we can only measure the following: We count the number of banners you did not click on ("Frequency Capping"), and click rates and determine the "unique user". You can reset IDFA at any time. In this case, a new IDFA will be created. This new IDFA will not be matched against previously processed data. Please note that you may not be able to use all the features of the App if you restrict IDFA. Legal basis for the processing is your consent according to Art. 6 par. 1 a) GDPR. You may revoke your consent at any time by changing your device settings with effect for the future.

Through the scan function, only the data of the memorisers that were previously handed out during training are recorded.

You may contact us either in writing or by e-mail (info@proaktiv-online.de) to exercise the following rights:

• Access your data to check and review it;
• Obtain a copy of your personal data;
• Demand that we correct or delete your personal data, or restrict the processing of your personal data; this also includes the right to have incomplete or incorrect personal data completed, including by means of providing a supplementary statement;
• Object to the processing of your personal data;
• Receive your personal data in a structured, commonly used and machine-readable format and, subject to any rights of use of third parties, have it transmitted to another controller, provided that you have consented to the processing or the processing is based on a contract with you.
• You also have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal data.

Your personal data will not be used for automated-decision making.