Privacy policy for the following apps:
Smart Urinal and Smart Control

Responsible for data processing:
KWC Aquarotter GmbH, Parkstrasse 1-5, D-14974 Ludwigsfelde

PREAMBEL
This service (hereinafter “App”) is provided by KWC Aquarotter GmbH, Parkstrasse 1-5, D-14974 Ludwigsfelde (hereinafter “we” or “us”) as the controller within the meaning of the applicable data protection law.

As part of the app, we enable you to set up, operate and parameterize sensors and modules that KWC Aquarotter GmbH has developed and sells. When you use the app, we process personal data about you. Personal data means any information relating to an identified or identifiable natural person. Because the protection of your privacy when using the app is important to us, we would like to inform you with the following information about which personal data we process when you use the app and how we handle this data. In addition, we will inform you about the legal basis for processing your data and, if processing is necessary to protect our legitimate interests, also about our legitimate interests.

You can access this privacy policy at any time under the menu item “Privacy policy” within the app.

1. . INFORMATION ABOUT THE PROCESSING OF YOUR DATA
Certain information is already processed automatically as soon as you use the app. We have listed exactly which personal data is processed for you below:

1.1    Informations collected during downloading
When you download the app, certain required information is transmitted to the app store you have selected (e.g. Google Play or Apple App Store), in particular the user name, email address, customer number of your account, time of download, payment information and the individual device identification number may be processed. This data is processed exclusively by the respective app store and is beyond our control.

1.2    Information collected automatically
As part of your use of the app, we automatically collect certain data that is required for the use of the app. This includes: [internal device ID, version of your operating system, statistical and diagnostic data, such as model, article number, date of manufacture, device settings, profile settings, counter readings, hygiene rinse history, error codes, error history].
This data is not automatically transmitted to us. Unless you send it to us, e.g. as part of a customer service order. Within the app, you have the option of voluntarily transmitting your personal data, e.g. by using the “Share” function, with which you can send us the statistical data by e-mail. We use this data, including personal data, to investigate errors on your behalf. The legal basis for this is Art. 6 para. 1, lit. B.

1.3    Use of the app
You can enter, manage and edit various information, tasks and activities in the app. This information includes, in particular, technical data required to parameterize and control the connected KWC devices.
The app also requires the following authorizations:
- Internet access: not required for operational use of the app.
- Bluetooth (BLE): This is required to establish a wireless connection to modules
   to be able to establish a wireless connection.
- Location service: This is only required for Android operating systems, as otherwise the
   BLE function is not available.

KWC only processes and uses usage data if you transmit it to us, see 1.2.

2. DISCLOSURE AND TRANSFER OF DATA
Your technical and personal data will not be passed on to third parties.

3. DATA TRANSFER TO THIRD COUNTRIES
We also process data in countries outside the European Economic Area (“EEA”).
This applies in detail to: Switzerland, UK

Both countries have adequacy decisions from the EU Commission in accordance with Art. 45 GDPR. Both countries therefore have an adequate level of data protection.

4. CHANGES OF PURPOSE
Your personal data will only be processed for purposes other than those described if this is permitted by law or if you have consented to the changed purpose of the data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you of these other purposes prior to further processing and provide you with all other relevant information in this regard.

5. PERIOD OF DATA STORAGE
We delete or anonymize your personal data as soon as it is no longer required for the purposes for which we collected or used it in accordance with the above paragraphs. As a rule, we store your personal data for the duration of the usage or contractual relationship via the app plus a period of [7] days, during which we keep backup copies after deletion, unless this data is required for longer for criminal prosecution or to secure, assert or enforce legal claims.

Specific information in this privacy policy or legal requirements for the retention and deletion of personal data, in particular those that we must retain for tax law reasons, remain unaffected.

6. YOUR RIGHTS AS AN AFFECTED PERSON

6.1    Right to information
You have the right to request information from us at any time about the personal data processed by us concerning you within the scope of Art. 15 GDPR. To do so, you can send a request by post or email to the address below.

6.2    Right to correct incorrect data
You have the right to demand that we correct your personal data immediately if it is incorrect. To do so, please use the contact addresses below.

6.3    Right to deletion
You have the right to obtain from us the erasure of personal data concerning you under the conditions described in Art. 17 GDPR. In particular, these conditions provide for a right to erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of an obligation to erase under Union law or the law of the Member State to which we are subject. For the period of data storage, see also section 5 of this privacy policy. To assert your right to erasure, please use the contact addresses below.

6.4    Right to restriction of processing
You have the right to demand that we restrict processing in accordance with Art. 18 GDPR. This right exists in particular if the accuracy of the personal data is disputed between the user and us, for the period of time required to verify the accuracy, as well as in the event that the user requests restricted processing instead of deletion in the case of an existing right to deletion; furthermore, in the event that the data is no longer required for the purposes pursued by us, but the user needs it to assert, exercise or defend legal claims, as well as if the successful exercise of an objection between us and the user is still disputed. To exercise your right to restriction of processing, please contact us at the addresses below.

6.5    Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with Art. 20 GDPR. To assert your right to data portability, please use the contact addresses below.

7. RIGHT OF OBJECTION
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based, inter alia, on point (e) or (f) of Article 6(1) GDPR pursuant to Article 21 GDPR. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the establishment, exercise or defense of legal claims.

8. RIGHT TO COMPLAIN
You also have the right to lodge a complaint with the competent supervisory authority. The competent supervisory authority is:
The State Commissioner for Data Protection, Stahnsdorfer Damm 77; 14532 Kleinmachnow, Poststelle@LDA.Brandenburg.de.

9. CONTACT
If you have any questions or comments about our handling of your personal data or if you would like to exercise the rights as a data subject mentioned in sections 6 and 7, please contact KWC-DPC-INT.DE@kwc.com.
Our data protection officer can be reached at the following contact details: KWC-DPC-INT.DE@kwc.com.

10. CHANGES TO THIS PRIVACY POLICY
We always keep this privacy policy up to date. We therefore reserve the right to amend it from time to time and to update it to reflect changes in the collection, processing or use of your data. The current version of the privacy policy is always available under “Privacy policy” within the app.

Stand: 31.07.2023