Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
2. Hosting
We are hosting the content of our website at the following provider:
External Hosting
This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.
The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
We are using the following host(s):
Serverprofis GmbH
Otto-Lilienthal-Ring 34-36
85622 Feldkirchen
Germany
Zweck: Web-Hosting (Backend/Frontend)
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
Thomas Riedl
Heubergstr. 54
83026 Rosenheim
Phone: +49 302 239951 431
E-mail:
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.
Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.
4. Recording of data on this website
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
Counting downloads and short links
We count how often the Android APK is downloaded via caliora.org/download/tagwerk.apk and how often our short links under caliora.org/go/… are used. We store nothing but anonymous daily totals per file or link, for example “24 Oct: 12 downloads”. For this we store neither your IP address nor your browser, operating system or referrer, not even encrypted or hashed, and we set no cookies. So that link previews and automated requests are not counted, your browser’s identifier (user agent) is checked briefly during the request and then discarded. The totals contain no personal data.
5. Newsletter
Newsletter data
If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address, and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.
Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
6. Buying a tagwerk Pro licence
Payment processing through Stripe
When you buy a tagwerk Pro licence, the payment is handled by Stripe. The provider is Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland. The checkout itself is operated by Stripe; your payment details – card numbers in particular – are entered there and never reach us at any point.
The data transmitted to or collected by Stripe is what the payment requires: your e-mail address, the name you give for the licence, amount and currency, the payment method, and the technical details needed for fraud prevention and for working out the tax (for example the IP address and the country derived from it). We do not ask for a postal address. The legal basis is Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(c) GDPR where we are subject to tax record-keeping obligations.
A transfer to Stripe, Inc. in the United States is possible. It relies on the European Commission’s standard contractual clauses. Details of Stripe’s processing are at https://stripe.com/privacy.
The licence itself
After a successful purchase we generate your licence and store alongside it: the name you gave, your e-mail address, the payment provider’s order number, the licence itself and the time it was issued. The purpose is to perform the contract and to be able to send you the licence again later should you lose it (Art. 6(1)(b) GDPR). The name is also inside the licence file and is displayed by the app.
We keep this data for as long as commercial and tax law require. The licence stays stored so that recovery remains possible indefinitely – a one-off purchase does not expire.
The “send my licence again” form
On the licence page you can have your licence sent to you again. To do so you enter your e-mail address; we send only to the address stored with us, and the response does not reveal whether a licence exists for any given address. What you type is not stored beyond the request. To stop the form being used to trigger mails in bulk, we only keep a hash of your e-mail and IP address with the times of the requests in the server's temporary storage, formed with a secret key that changes daily and deleted an hour after the last request (Art. 6(1)(f) GDPR).
What the app sends
tagwerk itself processes your notes only on your own device and in the folder you choose for them. The licence is checked offline; there is no sign-in, no account, and no report back to us about whether or how you use the app. If you use the built-in sync, the app talks to the server you entered, and to no other.
The one exception is the Android build you download directly from caliora.org (“tagwerk_”, package org.caliora.tagwerk.direct). It does not apply to the builds from the Google Play Store or the Microsoft Store.
Update check of the Android APK from caliora.org
This build is not updated through an app store. So that it can tell you about a new version, it fetches the file https://api.caliora.org/tagwerk/download/android/version.json once after it starts, and again when you choose “Check now” in the settings. The request contains nothing from your notes, no device identifier and no licence data. As with any request for a web page, the server processes your IP address, the time of the request and the app’s identifier with its version number (e.g. tagwerk-android-direct/1.8.10), and records them in the server log files described in section 4. The server logs the download of the APK itself like any other request.
The legal basis is our legitimate interest in making new versions with fixes available to you although the app is not updated through a store (Art. 6(1)(f) GDPR).
7. Waitlist for tagwerk
Purpose and data
On caliora.org/tagwerk you can join a waitlist for platforms tagwerk is not available on yet (iOS, macOS, Linux, Android without Google services). We then write to you once, when tagwerk is out for the platform you chose. Separately and optionally, you can also sign up for news about tagwerk.
For this we store: your e-mail address, the platforms you chose and whether you want news, the language of the page, the version of the consent text, and the times of sign-up and confirmation. No name, and no IP address in the database.
Legal basis and double opt-in
The legal basis is your consent (Art. 6(1)(a) GDPR). After you submit the form you receive an e-mail with a confirmation link. Only after you confirm is your address on the list. This makes sure nobody can sign up somebody else's address.
Storage period
Sign-ups that are not confirmed are deleted after seven days. The entry for a platform is deleted once we have sent you the message that it is out. Consent to news remains valid until you withdraw it.
Withdrawal
Every e-mail contains a link that deletes your address completely. Alternatively, an informal message to the address given in the imprint is enough. Withdrawal does not affect the lawfulness of processing before it.
Protection against abuse
The form contains a field that is invisible to people and measures in your browser how long the page was open before you sent it; this value is checked and not stored. To limit repeated sign-ups we keep a hash of your IP address and of your e-mail address, together with the times of the requests, in the server's temporary storage. The hash is formed with a secret key that changes daily, so no address can be worked back out of it, and the file is deleted an hour after the last request. The legal basis is our legitimate interest in a form that cannot be abused for spam (Art. 6(1)(f) GDPR). We use no captcha and no third-party services.
Sending
The e-mails are sent through our host's servers (see section 2). We do not pass your address on. The e-mails are plain text, with no tracking pixels and no tracked links.