Privacy

Privacy Information BRAINMEE Application

The protection of your privacy and data when using our application is a top priority for us. As a result, this data protection information explains in detail which personal data of yours is processed when you use our internet offer and how we (= responsible party) protect this data.

Responsible for data processing:

digitAAL Life GmbH
Schubertstraße 6a
8010 Graz
AUSTRIA

Phone: +43 316 931 285
E-Mail: privacy@DIGITAAL.life

Data Protection Officer:
Data Protection Officer of digitAAL Life GmbH
Schubertstraße 6a
8010 Graz
AUSTRIA

Phone: +43 316 931 285
E-Mail: privacy@DIGITAAL.life

 

A)   Use of our application

The BRAINMEE app (=application) is a training for holistic cognitive performance activation. The methodology is built on five pillars (memory, movement, perception, everyday activities and playful-creative). Each training unit focuses on a specific topic (for example, water) and includes a series of exercises that stimulate the various senses. Warm-up exercises include movement and perception exercises, which are followed by knowledge questions, math problems, cloze words and texts, puzzles, picture pairs, troubleshooting pictures, audio puzzles, songs, and other activities.

The table below provides an overview of the categories of personal data processed by you via the Application and, in each case, related thereto:

  • the purposes for which personal data will be processed, as well as the legal basis for such processing;
  • The recipients or categories of recipients of personal data, if applicable;
  • the storage period, or the criteria for determining this period if this is not possible.

Data classification

  • Your login credentials (e.g. your name, your user name and your password)
  • Your account information (e.g. your name, username, address, date of birth or e-mail address)
  • The outcomes of the trainings you have attended
  • The requesting device’s IP address
  • Access date and time
  • The name and URL of the file that was accessed
  • Data volume and content transferred
  • Indicate whether or not the retrieval was successful (HTTP status code)
  • Browser and operating system identification data

Purpose
The processing (or receiving and storing your data) is done so that we can train your cognitive performance with the application and you can perform the holistic training (according to the 5 pillars memory, movement, perception, everyday activities and playful-creative).

After the personal reference is no longer required, your data will be completely and irreversibly anonymized. As a result, no conclusions can be drawn about a natural person based on this data. The anonymous data is used for statistical purposes as well as to improve the offer and technology.

Legal basis
The processing is based on your consent, as defined in Art. 6 para. 1 lit. a DS-GVO. This means that before accessing the application, you, as the data subject, gave your consent to the processing of the personal data in question for the aforementioned purposes.

You have the right to revoke your consent at any time. The data controller or his representative, or the data protection officer, may revoke the consent at any time in writing, by e-mail, or verbally (see contact details under “Data controller”).

The withdrawal of consent has no effect on the lawfulness of the processing carried out on the basis of the consent prior to the withdrawal.

The processing of your personal data is required for the application to function.

Data retention
The data is typically saved for at least the duration of your application use, as this is required for the evaluation and presentation of your training progress. After you uninstall the app, your data will be stored for a maximum of seven years for our billing data retention obligation and then either deleted or anonymized as described above at the end of this period.

Log files and cookies
To use our application, log files and cookies must be temporarily stored and processed, which is why you are prompted for your consent when you launch it (= declaration of consent).

You cannot use our application without these cookies because only technically necessary cookies are processed.

The consent you provided for the use of the additional log files and cookies serves as the legal basis for their use (Art 6 para 1 lit a DSGVO). However, if the consent is not granted, we would like to point out that you will be unable to use the functions of our application.

The legal basis for processing log files and cookies for the conclusion or fulfillment of a contract is Art 6 (1) lit b DSGVO.

The collected data is processed for the purposes of enabling (better) application use (connection establishment), system security, technical administration of the network infrastructure, and anonymized, statistical evaluation of use and optimization of our offer.

The collected data will be kept for 90 days.

We would like to emphasize in this context that the IP address is only evaluated in the event of an attack on our network infrastructure.

You can also specify whether or not cookies of any kind may be set in your browser settings. You can refuse to accept cookies by changing the settings on your browser; however, you may not be able to use the full functionality of this website if you do so.

You have the right to revoke your consent at any time. The revocation may be revoked at any time in writing, by e-mail, or verbally to the person in charge or his representative, or to the data protection officer (see contact details under “Person responsible for data processing”).

The withdrawal of consent has no effect on the lawfulness of the processing carried out on the basis of the consent prior to the withdrawal.

Recipients / Recipient Types
Data collected while using our application will be transmitted to third parties not named in this data protection declaration without your consent only if we are required to do so by law or by court order, or if the transmission is required for legal or criminal prosecution in the event of an attack on our Internet infrastructure. Data will not be shared with third parties for non-commercial or commercial purposes.

Your information will be shared with the following people/organizations:

  • The employees of the responsible company
  • Processors necessary for the processing (the processors currently used are mentioned below.):
    Hetzner Online GmbH
    Industriestr. 25:
    91710 Gunzenhausen
    Germany
    as the operator of the data center in which the servers of the responsible party are located.

Data portability / profiling
There is the right to data portability. Automated decision-making (profiling) with the data does not take place.

 

B)   Data subject rights

We would also like to inform you of the following rights that you, as the data subject, have in relation to your personal data under the GDPR:

  • According to Art. 15 DSGVO, you have the right to obtain information from the controller about the personal data concerning you, as well as additional information about the data processing and copies of the data.
  • According to Art. 16 DSGVO, the right to rectification and/or completion of inaccurate and/or incomplete data
  • Right to be forgotten under Article 17 DSGVO
  • Processing restriction right under Art. 18 DSGVO
  • According to Art. 20 DSGVO, the right to data portability
  • Right to object to processing under Art. 21 DSGVO

You may also file a complaint with the data protection authority (Article 77 DSGVO, 24 Data Protection Act). In this regard, we also refer to the data protection authority’s homepage, which can be found at https://www.dsb.gv.at/.

 

C)   Data protection by design

We use technical and organizational security measures to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons. Our security measures are continuously improved in line with technological developments.

 

D)   Validity and timeliness of the privacy information

This privacy statement is effective immediately and replaces all previous privacy statements. We reserve the right to change this privacy information if we deem it appropriate or necessary.

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