Privacy Policy of the App WASH Butler (date of creation: 13th of Dec 2019)

Personal data (usually referred to just as "data" below) will only be processed by us to the extent necessary and for the purpose of providing a functional and user-friendly App, including its contents, and the services offered there.

Per Art. 4 No. 1 of Regulation (EU) 2016/679, i.e. the General Data Protection Regulation (hereinafter referred to as the "GDPR"), "processing" refers to any operation or set of operations such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction performed on personal data, whether by automated means or not.

The following privacy policy is intended to inform you in particular about the type, scope, purpose, duration, and legal basis for the processing of such data either under our own control or in conjunction with others. We also inform you below about the third-party components we use to optimize our App and improve the user experience which may result in said third parties also processing data they collect and control.

Our privacy policy is structured as follows:

I. Information about us as controllers of your data
II. The rights of users and data subjects
III. Information about the data processing

I. Information about us as controllers of your data

The party responsible for this website (the "controller") for purposes of data protection law is:

Pfeilstetter Gemeinschaftswaschanlagen GmbH
Hainbuchenstraße 18 b
80935 München
Germany

Chief executing officers:
Mrs. Ursula Pfeilstetter
Mrs. Sabine Brunner

Court: Amtsgericht München
Registry: Handelsregister: HRB 172034

Phone: +49 (0) 89/351 25 65
Fax:+49 (0) 89/351 77 18
Email: Info@pfeilstetter-gwa.de

Due to the constitution of this company, not data officer has to be named but you can ask the CEOs above your questions regarding the privacy policy. 

II. The rights of users and data subjects

With regard to the data processing to be described in more detail below, users and data subjects have the right

• • to confirmation of whether data concerning them is being processed, information about the data being processed, further information about the nature of the data processing, and copies of the data (cf. also Art. 15 GDPR);
• • to correct or complete incorrect or incomplete data (cf. also Art. 16 GDPR);
• • to the immediate deletion of data concerning them (cf. also Art. 17 DSGVO), or, alternatively, if further processing is necessary as stipulated in Art. 17 Para. 3 GDPR, to restrict said processing per Art. 18 GDPR;
• • to receive copies of the data concerning them and/or provided by them and to have the same transmitted to other providers/controllers (cf. also Art. 20 GDPR);
• • to file complaints with the supervisory authority if they believe that data concerning them is being processed by the controller in breach of data protection provisions (see also Art. 77 GDPR).

In addition, the controller is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.

Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the controller's future processing of their data pursuant to Art. 6 Para. 1 lit. f) GDPR. In particular, an objection to data processing for the purpose of direct advertising is permissible.

III. Information about the data processing

Your data processed when using our App will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations or unless otherwise stipulated below.

Server data

We don’t collect server data, not even logfiles. We only process the data which we explain in the following. But Google and Apple may collect and process further data of you (see below).

Order processing / payment / app services

The data you submit when using the App WASH Butler will have to be processed in order to fulfill your wished actions within the App. Please note that the fullfillment of our tasks through the app cannot be processed without providing this data, because there’s an electronic payment solution within the app in order to enable you to buy virtual coins by which you can pay the services of our washing and drying machines. 

The legal basis for this processing is Art. 6 Para. 1 lit. b) GDPR.

Regarding the deletion of your data we have to take care of the retention periods required by tax and commercial law. Moreover we delete userdata which is necessary to run the app’s services, only after your explicit order to do so. Otherwise a usage of the app won’t be possible after an extended period of time while the app wasn’t used by you. Please note: In case of deleting your user account, you will also erase your remaining balance of virtual coins! This balance can’t be paid out or transferred. Therefore please use the remaining balance before deleting your account! 

In order to process your order, we will share your data with the payment service Mollie B.V., Keizersgracht 313, 1016 EE Amsterdam („Mollie“) whenever sharing is necessary for payment reasons. Depending on the chosen way of paying through „Mollie“, the services collects the necessary data directly from you. More information about „Mollie’s“ data privacy can be found on https://www.mollie.com/de/privacy

The legal basis for the transfer of this data is Art. 6 Para. 1 lit. b) GDPR.

The data requested at the app’s registration process is also being used in order to run some services within the app („app services“). For example your email address is being used for the account’s activation as well as for the reset of a forgotten password but also for getting in touch with you in case of an error report which you have sent to us through the app. 

Forwarding data to Apple and Google / Analytics

The native apps are being sent to Google’s PlayStore and Apple’s AppStore in order to provide the app WASH Butler to their users for download. By doing so Google and Apple will collect data of your behaviour as the user of our app. The privacy policies of Google and Apple can be found with help of the following links. 

Google: https://policies.google.com/privacy#intro
Apple: https://www.apple.com/legal/privacy/en-ww/

Customer account / registration / withdrawal (deletion)

If you create a customer account with us via our app (and that’s the only way to use our app’s services), we will use the data you entered during registration (e.g. your name, your address, or your email address) exclusively for services leading up to your potential in app usage or for some other contractual relationship with us, to fulfill such orders or contracts, and to provide customer care (e.g. to respond to you when you should have sent an error report to us via the app). We also store your IP address and the date and time of your registration. This data will not be transferred to third parties.

During the registration process, your consent will be obtained for this processing of your data, with reference made to this privacy policy. The data collected by us will be used exclusively to provide your customer account. 

If you give your consent to this processing, Art. 6 Para. 1 lit. a) GDPR is the legal basis for this processing.

If the opening of the customer account is also intended to lead to the initiation of a contractual relationship with us or to fulfill an existing contract with us, the legal basis for this processing is also Art. 6 Para. 1 lit. b) GDPR.

You may revoke („withdraw“) your prior consent to the processing of your personal data at any time under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent. This can be done easily by going to „settings“ within the app and then by choosing the list entry „Delete account“.

The data previously collected will then be deleted as soon as processing is no longer necessary. However, we must observe any retention periods required under tax and commercial law.

Contact

If you contact us via the app’s section „Report error“, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your inquiry; otherwise we will not be able to answer it in full or at all.

The legal basis for this data processing is Art. 6 Para. 1 lit. b) GDPR.

Your contact data will be saved even after we have fully answered your inquiry, because maybe we will have to come back to you about the solution to an error reported by you and which was considered as solved.

Necessary access privileges of WASH Butler & exchanged data (BL, GPS & QR)

Within the app WASH Butler you can – like mentioned above – purchase virtual coins with the help of the payment service „Mollie“ in order to pay our washing and drying machines. Therefore you have to connect your smartphone with a central cashier device. This is only possible via an encrypted bluetooth connection which you have to enable for this purpose. For Android devices it also will be necessary to turn on GPS in order to provide a stable bluetooth connection. At least you will have to give the app the allowance of enabling bluetooth for you. We won’t process exact location based data by using your GPS. Afterwards you will have to scan a QR Code with your smartphone in order to automatically connect your smartphone to the correct central cashier device (because there can be several in one basement). Therefore you need to give WASH Butler also the permission to use your smartphone’s camera for this single use case. After a successful connection via bluetooth, your user data will be exchanged between the central cashier device and your smartphone in order to ensure the payment by using your virtual coins and also in order to prevent misuse.

This privacy policy is a customized version of the Model Data Protection Statement from Anwaltskanzlei Weiß & Partner