Data Protection Policy
The protection of your privacy is of great importance to us. sobu AG therefore carries out its activities in compliance with the applicable statutory regulations for data protection. In this document, we will explain what information.
- Types of Data collected
- Mode and place of processing the Data
- The purposes of processing
- Facebook permissions asked by sobu Ltd
- Detailed information on the processing of Personal Data
- Further information about Personal Data
- The rights of Users
- Additional information about Data collection and processing
- Owner and Data Controller
1. Types of Data collected
Among the types of Personal Data that sobu AG collects, by itself or through third parties, there are: first name, last name, email address, various types of Data, Cookies, Usage Data, country, password, gender, date of birth, address, username, ZIP/Postal code, language and phone number.
Users are responsible for any third-party Personal Data obtained, published or shared through sobu AG and confirm that they have the third party’s consent to provide the Data to the Owner.
2. Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of sobu AG (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislation the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any per-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
3. The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Access to third-party accounts, Data transfer outside the EU, Heat mapping and session recording, Hosting and backed infrastructure, Managing contacts and sending messages, Registration and authentication, SPAM protection and Analytics.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
4. Facebook permissions asked by sobu AG
sobu AG may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows sobu AG to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
The permissions asked are the following:
Basic information – By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Birthday – Provides access to the birthday.
Contact email – Access the User’s contact email address.
List of Friends
Photos – Provides access to the photos the User has uploaded, and photos the User has been tagged in.
Publish to the Wall – Enables the app to post content, comments, and likes to a User’s stream and to the streams of the User’s friends.
5. Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Access to third-party accounts
This type of service allows sobu AG to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically but require explicit authorization by the User.
- Facebook account access (sobu AG) This service allows sobu AG to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Birthday, Contact email, Current City, List of Friends, Photos and Publish to the Wall.
- Twitter account access (Twitter, Inc.) This service allows sobu AG to connect with the User’s account on the Twitter social network, provided by Twitter, Inc.
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
- Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of sobu Ltd, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States
Contacting the User
- Contact form (sobu AG) By filling in the contact form with their Data, the User authorizes sobu AG to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.
- Mailing list or newsletter (sobu AG) By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning sobu AG. Your email address might also be added to this list as a result of signing up to sobu AG or after making a purchase.
Personal Data collected: email address, first name and last name.
Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
- Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (sobu AG)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data collected: various types of Data.
Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior. Some of these services may record sessions and make them available for later visual playback.
- Crazy Egg (Crazyegg) Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
Personal Data collected: Cookies and Usage Data.
Hosting and backed infrastructure
This type of service has the purpose of hosting Data and files that enable sobu AG to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of sobu AG. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
- DigitalOcean (DigitalOcean Inc.) DigitalOcean is a hosting service provided by DigitalOcean Inc.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
- MailChimp (The Rocket Science Group, LLC.) MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: country, email address, first name and last name.
Registration and authentication
By registering or authenticating, Users allow sobu AG to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, sobu AG will be able to access some Data, stored by these third-party services, for registration or identification purposes.
- Facebook Authentication (Facebook, Inc.) Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
- Direct registration (sobu AG) The User registers by filling out the registration form and providing the Personal Data directly to sobu AG.
Personal Data collected: address, country, date of birth, email address, first name, gender, language, last name, password, phone number, username and ZIP/Postal code.
This type of service analyses the traffic of sobu AG, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
- Google reCAPTCHA (Google Inc.) Google reCAPTCHA is a SPAM protection service provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
6. Further information about Personal Data
Unique device identification
sobu AG may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.
User identification via a universally unique identifier (UUID)
sobu AG may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
7. The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on per-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
8. Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of sobu Ltd or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, sobu Ltd and any third-party services may collect files that record interaction with sobu Ltd (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
sobu Ltd does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
9. Owner and Data Controller
Owner contact email: email@example.com
Definitions and legal references
Personal Data (or Data) – Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiable of a natural person.
Usage Data – Information collected automatically through sobu AG (or third-party services employed in sobu AG), which can include: the IP addresses or domain names of the computers utilized by the Users who use sobu AG, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User – The individual using sobu AG who, unless otherwise specified, coincides with the Data Subject.
Data Subject – The natural person to whom the Personal Data refers.
Data Controller (or Owner) – 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, including the security measures concerning the operation and use of sobu AG. The Data Controller, unless otherwise specified, is the Owner of sobu AG.
sobu AG (or this Application) – The means by which the Personal Data of the User is collected and processed.
Service – The service provided by sobu AG as described in the relative terms (if available) and on this site/application.
European Union (or EU) – Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies – Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislation, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).