Linearity Privacy Policy
Last Update: February 2024
1. Introduction
In the following, we provide information about the collection of personal data when using our mobile app (hereinafter only "App").
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
1.1. Contact details
The controller within the meaning of Art. 4 (7) EU General Data Protection Regulation (GDPR) is Linearity GmbH, Schönhauser Allee 9, 10119 Berlin, Germany, email: privacy@linearity.io. We are legally represented by Vladimir Danila, Moritz Poewe.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.
1.2. Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
● Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
● Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a user purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
● Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
● Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.
1.3. Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.
In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4. Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
1.5. Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
● Right of access,
● Right to correction or deletion,
● Right to limit processing,
● Right to object to the processing,
● Right to data transferability,
● Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
1.6. Obligation to provide data
Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
1.7. No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.
1.8. Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
2. Data processing in the app
2.1. Downloading the app
Our app is ready for download at Apple's App Store (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.
2.2. Hosting
Our app is hosted by AWS. The provider thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
2.3. Informative use of our app
When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
The data processed to this extent are:
● IP address
● Date and time of the request
● Time zone difference from Greenwich Mean Time (GMT)
● Content of the request (concrete interface)
● Access status/HTTP status code
● Amount of data transferred in each case
● Operating system and its interface
● Language and version of the operating system
2.4. Access to functions or data
The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.
The functions or data processed to this extent are
● (entire) memory and existing photos
2.5. Data processing for the provision of functions
In the app, we process data in order to provide the user with functions of the app. The legal basis for the processing is the usage agreement concluded with the user via the app.
The data processed to this extent are
● Identifier other than UUID
2.6. User account
Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR. We delete the data when users delete their user account.
2.7. Single sign-on
Users can log in to our app using one or more single sign-on methods. In doing so, they use the login data already created for a provider. The prerequisite is that the user is already registered with the respective provider. When a user logs in using a single sign-on procedure, we receive information from the provider that the user is logged in to the provider and the provider receives information that the user is using the single sign-on procedure in our app. Depending on the user's settings in his account on the provider's site, additional information may be provided to us by the provider. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing users with a simple log-in option. At the same time, the interests of the users are safeguarded, as use is only voluntary.
Providers of the offered method(s) are:
● Apple Inc., Infinite Loop, Cupertino, CA 95014, USA (Privacy policy: https://www.apple.com/legal/privacy/de-ww/).
● Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (Privacy policy: https://policies.google.com/privacy).
2.8. Payment processors
For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).
● Stripe Payments Europe, Ltd., Ireland
2.9. Third-party tools
2.9.1. Adjust
We use Adjust for analytics. The provider is Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.adjust.com/terms/privacy-policy/.
2.9.2. Amazon AWS
We use Amazon AWS for hosting. The provider is Amazon Web Services EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxemburg. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in maintaining a modern and cost-effective hosting environment.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://aws.amazon.com/privacy/.
2.9.3. Amplitude
We use Amplitude for product analytics. The provider is Amplitude, Inc., 631 Howard St. Floor 5. San Francisco, CA 94105, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://amplitude.com/privacy.
2.9.4. Braze
We use Braze to communicate with customers and for customer relationship management. The provider is Braze, Inc., 330 W 34th St 18th floor, New York, NY 10001, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in addressing our customers as easily as possible and thus improving the exchange with them.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.braze.com/company/legal/privacy.
2.9.5 Bugsnag
We use Bugsnag for tracking bugs and errors in the app. The provider is SmartBear Limited, Mayoralty House, Flood Street, Galway, Ireland. The provider processes user information (user ID), meta/communication data (e.g. device information, IP addresses) and bug information (e.g. error code) in the EU.
The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in tracking bugs and errors in our application in order to correct them.
The data is deleted when the purpose of its collection has ceased to apply and there is no retention obligation to the contrary. Further information is available in the provider's privacy policy at https://docs.bugsnag.com/platforms/ios/automatically-captured-data/.
2.9.6. Postmark
We use the services of ActiveCampaign, LLC, 1 N Dearborn St., 5th Floor, Chicago, Illinois 60602, USA, to perform transactional emails via the app. The provider processes meta/communication data (e.g. device information, IP addresses), contact data (e.g. email addresses, phone numbers) and master data (e.g. names, addresses).
The legal basis of the processing is Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in sending e-mails.
The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93 para. 2 GDPR (Article 46 para. 2 lit. c GDPR), which we have agreed with the provider.
The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://postmarkapp.com/privacy-policy.
2.9.7. metabase
We use metabase for product analytics. The provider is Metabase Inc., 660 4th Street #557, San Francisco, CA 94107, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
Further information is available in the provider's privacy policy at https://www.metabase.com/privacy/.
2.9.8. RevenueCat
We use RevenueCat for product analytics. The provider is RevenueCat, Inc., 631-633 Taraval St #101, San Francisco, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
Further information is available in the provider's privacy policy at https://www.revenuecat.com/privacy/.
3. Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
4. Questions and comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.