Notes on data protection when using the ELECTRIFYtoday app

Notes on data protection when using this app

We, PHOENIX CONTACT GmbH & Co. KG, as the provider of the online service (game) "ELECTRIFYtoday", are responsible for processing the personal data of users of the online service. The exact details about us, including contact details, can be found in the site notice of the app or the website. The term "app" is used here both for the use of the online service in a browser and for the use of the respective app from the Apple or Google Play App Store and as a desktop app.

We take the protection of your privacy and your private data very seriously. We collect, store and use your personal data only in accordance with the content of this data protection information and the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR) and the national data protection regulations.

With this data protection information we would like to inform you to what extent and for what purpose personal data is processed in connection with the use of the app.

Personal data

Personal data is information about an identified or identifiable natural person. This includes all information about your identity, such as your name, email or postal address. However, information that cannot be linked to your identity (such as statistical data, e.g. the number of users of the app) is not considered personally identifiable information.

To use the app, it is necessary to disclose your identity during registration, as you enter into a contractual user relationship with us to use the app and registration also enables cross-device use. If data is not absolutely necessary for the fulfillment of the contract, further data is requested on a voluntary basis. We point out in each case which data is mandatory and which data can be added on a voluntary basis.

Automated decision-making based on your personal data does not take place in connection with the use of the app.

Processing of personal information

Your data is stored by us on specially protected servers within the European Union. These are protected by technical and organizational measures against loss, destruction, access, modification or dissemination of your data by unauthorized persons. Access to your data is only possible for a few authorized persons. These persons are responsible for the technical, commercial or editorial support of the servers. Despite regular checks, however, complete protection against all risks is not possible.

Your personal data is transmitted in encrypted form via the Internet. We use TLS encryption (Transport Layer Security) for data transmission.

Disclosure of personal data to third parties

We only use your personal information to provide the services you have requested. If external service providers are used by us in the course of providing the service, their access to the data is also exclusively for the purpose of providing the service. We take technical and organizational measures to ensure compliance with the data protection regulations and oblige our external service providers to do the same.

Furthermore, we do not share the data to third parties without your express consent, in particular not for advertising purposes. Your personal data will only be shared if you have consented to the data being shared or if we are entitled or obliged to do so on the basis of statutory provisions and/ or official or court orders. In particular, this may involve the provision of information for the purposes of criminal prosecution, averting danger or enforcing intellectual property rights.

Insofar as we transfer your personal data ourselves or through service providers to countries outside the European Union, we comply with the special requirements of Art. 44 et seq. GDPR and also oblige our service providers to comply with these regulations. We will therefore only transfer your data to countries outside the European Union subject to the level of protection warranted by the GDPR. This level of protection is warranted in particular by an adequacy decision of the European Commission or by suitable guarantees in accordance with Art. 46 GDPR.

Legal basis for data processing

Insofar as we obtain consent for the processing of your personal data, Art. 6 para. 1 lit. a) GDPR serves as the legal basis for data processing.

Insofar as we process your personal data because this is necessary for the performance of a contract or in the context of a quasi-contractual relationship with you, Art. 6 para. 1 lit. b) GDPR serves as the legal basis for data processing.

Insofar as we process your personal data to fulfill a legal obligation, Art. 6 para. 1 lit. c) GDPR serves as the legal basis for data processing.

Art. 6 para 1 lit. f) GDPR also serves as the legal basis for data processing if the processing of your personal data is necessary to safeguard a legitimate interest of our company or a third party and your interests, fundamental rights and freedoms do not require the protection of the personal data.

As part of this data protection information, we always indicate the legal basis on which we base the processing of your personal data.

Data erasure and storage duration

We always delete or block your personal data when the purpose of storage no longer applies. However, data may be stored beyond this if this is provided for by legal requirements to which we are subject to, for example with regard to statutory retention and documentation obligations. In such a case, we delete or block your personal data after the end of the corresponding obligations.

Information about your end device

We record and log the IP address of your end device each time you access the app. In addition, the status and the amount of data transferred are recorded as part of this request. We also collect product and version information about the app, the operating system and the mobile end device. The IP address of your end device is only stored for the time you use the app and is then deleted or anonymized by shortening.

We use this data for the operation of the app, in particular to detect and eliminate errors and constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f) GDPR.

Registration

The use of the app requires a registration, in the course of which a separate account is created for you for the following. The central identifier is your email address, which must be confirmed by you. You can choose your own username and password. Further information is requested on a voluntary basis during registration. Registration creates a contractual user relationship; the legal basis for data processing is therefore the initiation of a contract pursuant to Art. 6
para. 1 lit. b) GDPR.

User activities in the app

You can select an avatar to use the app and personalize it according to your wishes. Your respective activities, including content used and other activities relating to user behavior (such as usage time), are stored in your account. The data is required, among other things, to display the correct content when the app is called up again to fulfill the contract in accordance with Art. 6 para. 1 lit. b) GDPR.
In addition, we evaluate the user behavior of all users on an aggregated
level (i.e. by summarizing results and without personal reference in the results) for the further development and optimization of the app. For this purpose, we rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR as the legal basis, insofar as the evaluation is carried out by processing personal data.

Interaction of the users

The app also offers the possibility of interaction between different users and enables the exchange of information between users, for example via friends lists, user groups or ranking lists (high scores). In this respect, the username you have chosen will be displayed to other users and the personalized avatar will also be visible. We do not disclose any further details about you to other users.

Advertising in the app

The app may contain advertising for our partners. In the event of corresponding advertising cooperations, we share certain findings, such as the reach of such advertising measures with our partners. However, our partners will not receive your personal data without your express consent.

Deactivation and deletion of data

If you no longer wish to use the app, you can delete it. Deleting the app does not automatically delete the account once it has been created. However, you have the option of deleting (deactivating) your account yourself. In the event of such deactivation, your data will be deleted or anonymized immediately.

Crash reports (when using the Android/iOS app)

In the unlikely event that a serious problem occurs during the use of the app that temporarily prevents further use (crash), we have an interest in determining the cause of the crash and - if the cause lies within its area of responsibility - taking precautions to prevent similar crashes in the future.
For this purpose, the app is set so that in the event of such a crash, certain information is transmitted to us as part of a crash report. The crash report includes information on the function called up and details of the error message. In addition, data about the device used is transmitted so that this data can be taken into account in the analysis. For example, the hardware used, the version of the operating system and the memory utilization are important.
Based on the above information, it is possible to identify a device in the event of frequent crashes, but not its user. Nevertheless, the user has the option of deactivating the transmission of crash reports in the software settings. The transmission of crash reports is activated by default. The software of one of our service providers, on whose systems the crash reports are received, is used to transmit the crash reports. This service provider is obliged by us to comply with data protection regulations and is regularly checked in this regard.

We have an interest in determining the causes of crashes in order to take appropriate precautions to prevent future crashes. This also constitutes our legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR.

Use of cookies

Cookies are used for our app. Cookies are small text files that are stored on your end device and that store certain settings and data for exchange with the app via your end device. A cookie usually contains the name of the domain from which the cookie file was sent, as well as information about the age of the cookie and an alphanumeric identifier. Cookies enable us to recognize your end device and make any pre-settings and preferences immediately available. Cookies help us to improve our offers and to provide you with a better and more personalized service. Cookies that are not technically necessary are only set with your consent in accordance with Art. 6 para. 1 lit. a) GDPR.

The legal basis for the use of technically necessary cookies is our legitimate interest in the proper provision of our app within the meaning of Art. 6 para. 1 lit. f) GDPR and - insofar as contracts are concluded or fulfilled via our app - the fulfillment of the contract within the meaning of Art. 6 para. 1 lit. b) GDPR.

Your rights and contact

We attach great importance to explaining the processing of your personal data as transparently as possible and to informing you of the rights to which you are entitled. If you would like more information or wish to exercise your rights, you can contact us at any time so that we can take care of your request.

Data subject rights

You have extensive rights regarding the processing of your personal data. First of all, you have a comprehensive right to information and, if necessary, you can request the correction and/ or deletion or blocking of your personal data. You can also request a restriction of processing and have the right to object. You also have the right to data portability with regard to the personal data you have provided to us.

If you would like to assert one of your rights and/ or receive more information about this, please contact: electrifytoday@tech-education.com. Alternatively, you can also contact our data protection officer.

Withdrawal of consent and objection

Once you have given your consent, you can freely withdraw it at any time with effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To do so, please also contact: electrifytoday@tech-education.com and our data protection officer.
If the processing of your personal data is not based on consent, but on another legal basis, you can object to this data processing. Your objection will lead to a review and, if necessary, termination of the data processing. You will be informed of the result of the review and - if the data processing is nevertheless to be continued - you will receive more detailed information from us as to why the data processing is permissible.

Data protection officer and contact

We have appointed a data protection officer who supports us in data protection issues and whom you can also contact directly. If you have any questions regarding our handling of personal data or require further information on data protection issues, please contact our data protection officer and his team via datenschutz@phoenixcontact.com:

Complaints

If you believe that we are not processing your personal data in accordance with this data protection information or the applicable data protection regulations, you can lodge a complaint with our data protection officer. The data protection officer will then investigate the matter and inform you of the outcome of the investigation. You also have the right to lodge a complaint with a supervisory authority.

Links to websites

Our app may contain links to websites. These links are usually marked as such. We have no influence on the extent to which the applicable data protection regulations are complied with on the linked websites. We therefore recommend that you also inform yourself about the respective data protection information on other websites.

Changes to this data protection information

The status of this data protection information is indicated by the date (below). We reserve the right to amend this data protection information at any time with effect for the future. Changes will be made in particular in the event of technical adjustments to the app or changes to data protection regulations. The data protection information can be accessed directly via the app or via the app store.

Status: May 2024