Privacy

I. Name and address of the person responsible

The person responsible within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:

Mr Anatol Mayen

Glafeystraße 21

04299 Leipzig

Germany

Tel.: +49 176 66886194

E-Mail: contact@betterkeywords.app

Website: https://betterkeywords.app

II. General information on data processing

1. Scope of processing personal data

We only collect data that we need to provide you with our services and improve our product. No content created by you is recorded and we have no access to the data stored in your iCloud.

2. Legal basis for the processing of personal data

Insofar as we obtain the data subject's consent for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data, which is necessary for the performance of a contract to which the data subject is a party, Art. 6 Para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 Para. 1 lit. f GDPR serves as the legal basis for processing.

3. Deletion of data and duration of storage

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage can also take place if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the person responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

III. Provision of the app

1. Description and scope of data processing

When using the app, data and information about the use of the app are automatically collected. This data is anonymous and you can end the collection of the data at any time via the menu item "Help" -> "Privacy Policy". The information transmitted depends on the use of our services and can be processed by the following services:

Apple

CloudKit database service and iCloud Drive data storage service operated by Apple, Inc.

Personal data: digital proof of purchase, use of advertising and demo products, pseudonymized user identification

Data processing takes place in Europe / USA

Microsoft App Center

Crash analysis software provided by Microsoft Corporation.

Personal data: crash reports

Data processing takes place in the USA

All service providers involved adhere to the requirements of the GDPR. Further information can be requested from the relevant services or from us.

Legal basis for data processing

The legal basis for the temporary storage of the data is Art. 6 Para. 1 lit. f GDPR.

Purpose of data processing

We collect data only to identify problems in the app and to quantify the frequency with which individual functions are used.

Duration of storage

We store your data for as long as German law provides or as it is necessary for the execution or initiation of a contract or as long as there is a legal claim on our part. Thereafter the data will be deleted or completely anonymized.

Opposition and removal options

You can stop the collection and storage of the data at any time via the menu item "Help" -> "Privacy Policy".

You can request deletion of all previously stored data, unless we are legally obliged to store it and it is not necessary for the performance of a contract.

IV. Rights of the data subject

If personal data from you is processed, you are the person concerned in the sense of GDPR and you have the following rights vis-à-vis the person responsible:

Right of providing information

You can ask the person responsible to confirm whether we process personal data relating to you.

If such processing is available, you can request the following information from the person responsible:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data that are processed;

(3) the recipients or the categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the planned duration of the storage of your personal data or, if specific information is not possible, criteria for determining the storage duration;

(5) the existence of a right to correction or deletion of your personal data, a right to restriction of processing by the person responsible or a right to object to this processing;

(6) the right to lodge a complaint with a supervisory authority;

(7) all available information about the origin of the data if the personal data is not collected from the data subject;

(8) the existence of automated decision-making, including profiling, in accordance with Art. 22 Para. 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you will be transferred to a third country or to an international organization. In this context, you can request the appropriate guarantees in accordance with Art. 46 GDPR to be informed in connection with the transmission.

Right to rectification

You have a right to correction and / or completion vis-à-vis the person responsible if the processed personal data concerning you is incorrect or incomplete. The person responsible must make the correction immediately.

Right to restriction of processing

You can request that the processing of your personal data be restricted under the following conditions:

(1) if you contest the accuracy of your personal data for a period of time that enables the person responsible to check the accuracy of the personal data;

(2) the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;

(3) the person responsible no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or

(4) if you have objected to processing in accordance with Art. 21 Para. 1 GDPR and it is not yet certain whether the legitimate reasons of the person responsible outweigh your reasons.

If the processing of your personal data has been restricted, this data - apart from its storage - may only be obtained with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest the Union or a Member State.

If the restriction of processing according to the above You will be informed by the person responsible before the restriction is lifted.

Right of removal

a) Obligation to delete

You can request the data controller to delete your personal data immediately, and the data controller is obliged to delete this data immediately if one of the following reasons applies:

(1) The personal data relating to you are for the purposes for which they were collected or otherwise processed are no longer necessary.

(2) You revoke your consent on which the processing was based in accordance with Art. 6 para. 1 lit. a or Art. 9 Para. 2 lit. a GDPR was based, and there is no other legal basis for the processing.

(3) According to Art. 21 para. 1 GDPR and there is no overriding legitimate reason for the processing, or you file an objection pursuant to Art. Art. 21 para. 2 GDPR to object to processing.

(4) The personal data concerning you have been unlawfully processed.

(5) The deletion of your personal data is required to fulfill a legal obligation under Union law or the law of the member states to which the controller is subject.

(6) The personal data concerning you were collected in relation to information society services offered in accordance with Art. 8 Para. 1 GDPR.

b) Information to third parties

If the person responsible has made your personal data public and is acc. Article 17 (1) GDPR obliges them to delete them, taking into account the available technology and the implementation costs, appropriate measures, including technical ones, to inform those responsible for data processing who process the personal data that you as the data subject Person has requested that they delete all links to this personal data or copies or replications of this personal data.

c) Exceptions

The right to deletion does not exist if the processing is necessary

(1) to exercise the right to freedom of expression and information;

(2) to fulfill a legal obligation that requires processing in accordance with the law of the Union or the Member States to which the controller is subject, or to perform a task that is in the public interest or in the exercise of official authority vested in the controller;

(3) for reasons of public interest in the area of ​​public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 Para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes acc. Art. 89 Para. 1 GDPR, insofar as the right mentioned under section a) is likely to render impossible or seriously impair the achievement of the objectives of this processing, or

(5) to assert, exercise or defend legal claims.

Right to be informed

If you have asserted the right to correction, deletion or restriction of processing against the person responsible, he is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You have the right vis-à-vis the person responsible to be informed about these recipients.

Right to data portability

You have the right to receive the personal data that you have provided to the person responsible in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that

(1) the processing is based on consent in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR or on a contract acc. Art. 6 para. 1 lit. b GDPR is based and

(2) the processing is carried out using automated processes.

In exercising this right, you also have the right to have your personal data transmitted directly from one controller to another, insofar as this is technically feasible. The freedoms and rights of other people must not be affected by this.

The right to data portability does not apply to the processing of personal data that is necessary for the performance of a task that is in the public interest or in the exercise of official authority that has been transferred to the person responsible.

Right to object

You have the right, for reasons that arise from your particular situation, at any time against the processing of your personal data, which is based on Art. 6 Para. 1 lit. e or f DSGVO takes place to object; this also applies to profiling based on these provisions.

The controller will no longer process your personal data unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is connected to such direct advertising.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58 / EC, you have the option of exercising your right to object in connection with the use of information society services using automated procedures that use technical specifications.

Right to withdraw the data protection declaration of consent

You have the right to withdraw your declaration of consent under data protection law at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing - including profiling - which has legal effect on you or similarly significantly affects you. This does not apply when making the decision

(1) is necessary for the conclusion or performance of a contract between you and the person responsible,

(2) is permissible on the basis of legal provisions of the Union or the member states to which the controller is subject and these legal provisions contain appropriate measures to safeguard your rights and freedoms as well as your legitimate interests or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data according to Art. 9 Para. 1 GDPR, unless Art. 9 Para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

With regard to the cases mentioned in (1) and (3), the person responsible takes appropriate measures to safeguard your rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the person responsible, to express your own position and heard the appeal of the decision.

Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, your place of work or the place of the alleged violation, if you believe that the processing of your personal data is against the GDPR violates

The supervisory authority to which the complaint was submitted will inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy in accordance with Art. 78 GDPR.