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We take the protection of your personal data very seriously and treat it confidentially and in accordance with legal data protection regulations as well as this privacy policy. This privacy policy applies to our mobile iPhone and Android app (hereinafter referred to as “APP”). It explains the type, purpose, and scope of data collection when using the APP.Please note that data transmission over the internet can have security vulnerabilities. Complete protection of data from third-party access is not possible.
The entity responsible for data processing within this APP is:
elephantz UG (haftungsbeschränkt)
Burgstraße 28
60316 Frankfurt am Main
Commercial Register: HRB 128580
Register Court: Handelsregister B des Amtsgerichts Frankfurt am Main
Represented by Managing Director:
Igor Radovic
Phone: +49 69 790 081 69
Email: hello@elephantz.io
The “responsible entity” is the entity that collects, processes, or uses personal data (e.g., names, email addresses, etc.).
Unless otherwise specified within this privacy policy, personal data collected by this APP will be stored until you request its deletion, withdraw your consent for storage, or the purpose for data storage ceases. If there is a legal obligation to retain the data or another legally recognized reason for storage (e.g., legitimate interest), the respective personal data will not be deleted until the relevant reason for retention ceases.
The processing of personal data is only permitted if there is a valid legal basis for such processing. If we process your data, this is typically based on your consent in accordance with Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, for the fulfillment of a contract in accordance with Art. 6 para. 1 lit. b GDPR (e.g., when using in-app purchases or other paid APP functions), or due to legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR, which are always weighed against your interests (e.g., in the context of marketing activities). The applicable legal bases are specified separately within this privacy policy if necessary.
For security reasons and to protect the transmission of confidential content—such as inquiries you send to us as the APP operator or communication between APP users—this APP uses encryption. This encryption ensures that the data you transmit cannot be read by unauthorized third parties.
We reserve the right to change this privacy policy at any time in compliance with legal requirements.
The GDPR grants certain rights to individuals whose personal data is processed by us. We would like to inform you about these rights below:
Many data processing operations are only possible with your consent. We will explicitly obtain this consent from you before processing any data.You can withdraw your consent at any time by sending us an informal email. The legality of data processing carried out before the withdrawal remains unaffected.
RIGHT TO OBJECT TO DATA COLLECTION IN SPECIAL CASES AND TO DIRECT MARKETING (ART. 21 GDPR)
IF DATA PROCESSING IS BASED ON ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE REASONS FOR THE PROCESSING THAT OUTWEIGH YOUR INTERESTS, RIGHTS, AND FREEDOMS OR THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND LEGAL CLAIMS.IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING IN CONNECTION WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES.
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority. This right exists without prejudice to any other administrative or judicial remedies.
You have the right to obtain free information at any time about your stored personal data, its origin, recipients, and the purpose of data processing, as well as the right to correct or delete this data. For this purpose, and for any further questions regarding personal data, you can contact us at any time using the address provided in the Legal Notice.
You have the right to request the restriction of the processing of your personal data. To do so, you can contact us at any time using the address provided in the Legal Notice. The right to restriction of processing applies in the following cases:
If you have restricted the processing of your personal data, these data—apart from being stored—may only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.
You have the right to receive the data that we process automatically based on your consent or in fulfillment of a contract in a commonly used, machine-readable format, or to have it transferred to a third party. If you request the direct transfer of the data to another controller, this will only be done if it is technically feasible.
To provide our services through the APP, we require the following permissions, which allow us to access certain functions of your device.
Access to these device functions is necessary to ensure the functionality of the APP. The legal basis for this data processing is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, your consent pursuant to Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, and—if a contract has been concluded—the fulfillment of our contractual obligations pursuant to Art. 6 para. 1 lit. b GDPR.
The retention period for the data collected in this way is regulated as follows:
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When you use our APP, we collect the following personal data from you:
The processing of this personal data is necessary to ensure the functionality of the APP. The legal basis for this data processing is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, your consent pursuant to Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, and—if a contract has been concluded—the fulfillment of our contractual obligations pursuant to Art. 6 para. 1 lit. b GDPR.
The retention period for the data collected in this way is regulated as follows:
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If you contact us (e.g., via a contact form within the APP, by email, phone, or fax), your inquiry, including all personal data resulting from it (e.g., name, inquiry), will be stored and processed for the purpose of handling your request.The processing of this data is based on Art. 6 para. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or necessary for pre-contractual measures. In all other cases, processing is based on your consent (Art. 6 para. 1 lit. a GDPR) and/or our legitimate interests (Art. 6 para. 1 lit. f GDPR), as we have a legitimate interest in effectively processing inquiries addressed to us.The data you provide to us in contact inquiries will remain with us until you request deletion, withdraw your consent for storage, or the purpose for data storage ceases (e.g., after your request has been fully processed). Mandatory legal provisions—especially legal retention periods—remain unaffected.We do not share your data without your consent.
If you would like to receive the newsletter offered in our APP, we require your email address and information that allows us to verify that you are the owner of the provided email address and consent to receiving the newsletter. No additional data will be collected, or only on a voluntary basis. This data is used exclusively for sending the requested information and will not be shared with third parties. The newsletter is sent based on your consent (Art. 6 para. 1 lit. a GDPR).
You can withdraw your consent at any time. The data you provide for the purpose of receiving the newsletter will be stored until you unsubscribe and deleted afterward. For the distribution of newsletters, we use third-party service providers, which are described below.
This APP uses Brevo for sending newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.
Brevo is a service that enables the organization and analysis of newsletter distribution. The data you provide for the purpose of receiving the newsletter is stored on the servers of Sendinblue GmbH in Germany.
Data Analysis by Brevo
With the help of Brevo, we can analyze our newsletter campaigns. For example, we can see whether a newsletter email was opened and which links were clicked. This allows us to determine which links are particularly popular.
Additionally, we can track whether certain predefined actions were taken after opening or clicking the newsletter (conversion rate). For example, we can see if you made a purchase after clicking on a newsletter link.
Brevo also enables us to segment newsletter recipients into different categories (clustering). For instance, recipients can be categorized by age, gender, or location. This allows us to tailor newsletters more effectively to specific target groups.
If you do not want your data to be analyzed by Brevo, you must unsubscribe from the newsletter. A corresponding link is included in every newsletter email.
For detailed information on Brevo’s functions, please visit the following link: Brevo Newsletter Software.
Legal Basis
The processing of your data is based on your consent (Art. 6 para. 1 lit. a GDPR). You can withdraw this consent at any time. The legality of data processing carried out before the withdrawal remains unaffected.
Retention Period
The data you provide for the purpose of receiving the newsletter will be stored by us and the newsletter service provider until you unsubscribe from the newsletter. After unsubscribing, your data will be removed from the newsletter distribution list.
Data stored for other purposes will remain unaffected. After you unsubscribe from the newsletter, your email address may be stored in a blacklist by us or the newsletter service provider to prevent future mailings, if necessary. The data in the blacklist is used only for this purpose and is not combined with other data. This serves both your interest and our interest in complying with legal requirements for sending newsletters (legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR).
Storage in the blacklist is not time-limited. You can object to the storage if your interests outweigh our legitimate interest.
For more information, please refer to Brevo’s privacy policies:
Brevo Datenschutz-Uebersicht
Brevo Privacy Policy
Data Processing Agreement
We have concluded a Data Processing Agreement (DPA) for the use of the aforementioned service. This is a legally required contract that ensures the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
When you access our APP, your behavior may be statistically analyzed using certain analytics tools for advertising, market research, or improving our services. When using such tools, we ensure compliance with legal data protection regulations. If we engage external service providers (data processors), we ensure through appropriate contracts that data processing complies with German and European data protection standards.
We use Google Analytics Firebase (hereinafter referred to as Google Firebase) to analyze user behavior. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.Google Firebase includes various features that allow us to analyze your in-app behavior. This enables us to track screen views, button interactions, in-app purchases, or the effectiveness of advertising campaigns. Additionally, we can determine which features within our APP are used frequently or rarely.
To achieve this, Google Firebase stores data such as the number and duration of sessions, operating systems, device models, regions, and other relevant data.
For a detailed overview of the data collected by Google Firebase, please visit:
Google Analytics for Firebase Data Collection
The use of Google Firebase may involve the transfer of your personal data to the USA.The retention period for the data collected in this way is regulated as follows:
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The use of Google Firebase is intended to optimize this APP and improve our services. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If consent has been obtained, the use of Google Firebase is based on Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG.Consent can be withdrawn at any time.
For more information about Google Firebase, please visit:
https://firebase.google.com/
https://www.firebase.com/terms/privacy-policy.html
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