Status: July 2024
The controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is: Seneration GmbH The data protection officer of the controller is: DataCo GmbH On this page, we inform you about the privacy policy applicable in the onesome app for Android and iOS (“App” or (“Web App”). The App is an offering of Seneration GmbH, Maximilianstrasse 43, 80538 Munich, Germany (“Seneration GmbH”, “we” or “us”) and is also available to users as a web application. onesome is an application of education, business & lifestyle and allows customers to use functionalities of personal development & individual coaching. onesome is an app that revolutionizes classic coaching and staff development through innovative technology. It draws on proven coaching methods and enables a purely digital development process through game-based training. In particular, onesome enabled users to take advantage of self-organized personal coaching and further development. This is done via the following functionalities: The provision of corresponding functionalities corresponds to the purposes of the processing. In addition, personal data is processed to ensure the continuous improvement and security of the system as well as error-free functioning of the app. As a matter of principle, we only process personal data of our users to the extent that this is necessary for the provision of a functional app as well as our content and services. The processing of personal data of our users is regularly carried out only after consent of the user, if there is a legitimate interest of the processing or a processing of personal data is necessary for the implementation of a contractual relationship. By using our app, the following personal data may be processed: In addition, through the use of our app, personal data of special categories may also be processed on a voluntary basis. This data includes information on personal coaching and development (e.g. feelings, thoughts, moods and problems). The processing of this data takes place exclusively with your express consent prior to the use of the relevant functionality within the app. The legal basis for the processing of personal data in the context of the creation of a user account and use of personal data for the use of described functionalities is the consent of the user pursuant to. Art. 6 par. 1 S. 1 lit. a GDPR in connection with Art. 9 para. 2 lit. a GDPR. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 S. 1 lit. b GDPR as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. The processing of technical data serves to protect a legitimate interest of our company to provide a functional application for users and is therefore based on Art. 6 para. 1 S. 1 lit. f GDPR as the legal basis for the processing. The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage ceases to apply. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted at the latest when a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract. When using the app, various processors may be recipients of personal data if they take over a partial service of the processing process. Categories of recipients of personal data are in particular: If recipients of personal data are located outside the EU or the EEA, Seneration GmbH actively creates suitable guarantees for legally compliant data transfer to third countries, e.g. by concluding standard data protection clauses in accordance with Art. 46 para. 2 lit. c GDPR. Seneration GmbH can process aggregated data from the user base of onesome for the further development of the application and internal company services. In this case, Seneration GmbH acts as the data controller and processes the related information on user behavior exclusively in anonymized form. You can object to the processing of your personal data at any time by sending an informal email to office@onesome.de. All other rights for you as a data subject, you can also address to this email address. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-Ã -vis the controller: You may request confirmation from the controller as to whether personal data concerning you are being processed by him. If there is such processing, you can request information from the controller about the following: You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to. Article 46 of the GDPR in connection with the transfer. You have a right to rectification and/or completion vis-Ã -vis the data controller, insofar as the personal data processed concerning you are inaccurate or incomplete. The responsible party shall make the correction without undue delay. Under the following conditions, you may request the restriction of the processing of personal data concerning you: Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only 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 Union or a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted. a) Obligation to delete You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies: b) Information to third parties If the controller has made the personal data concerning you public and is responsible pursuant to. Art. 17 para. 1 GDPR to erase them, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as data subject, have requested erasure of all links to or copies or replications of such personal data. c) Exceptions The right to erasure does not exist insofar as the processing is necessary to If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients by the data controller. You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 S. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications. You have the right to withdraw your consent for data protection at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or b DSGVO applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests. With regard to the cases referred to in 1. and 3. above, the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision. 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, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR. Each time our app is called up, our system automatically collects data and information from the computer system of the calling computer. The following data is collected: This data is stored in the log files of our system. This data is not stored together with other personal data of the user. The App is hosted using computing capacity provided by Microsoft Corporation , 1 Microsoft Way, Redmond, WA 98052, USA. The service provider may obtain access to the above-mentioned data. For data protection-compliant use and legally compliant data transfer to third countries, appropriate order processing agreements and suitable guarantees, e.g., by concluding standard data protection clauses pursuant to Art. 46 Par. 2 lit. c GDPR concluded. The server location of the data processing is geographically in Germany. The temporary storage of the IP address by the system is necessary to enable delivery of the web app to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session. The storage in log files is done to ensure the functionality of the app. In addition, we use the data to optimize the app and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 S. 1 lit. f GDPR. The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 S. 1 lit. f GDPR. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the app, this is the case when the respective session has ended. In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible. The collection of data for the provision of the app and the storage of the data in log files is mandatory for the operation of the app. Consequently, there is no possibility of objection on the part of the user. Our web app uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is accessed again. We use cookies to make our app more user-friendly. Some elements of our app require that the calling browser can be identified even after a page change. The following data is stored and transmitted in the cookies: We also use cookies on our app that enable an analysis of the user’s surfing behavior. These are only set with the consent of statistical cookies. In this way, the following data can be transmitted: The user data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data is not stored together with other personal data of the users. The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our web app cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change. We need cookies for the following applications: The user data collected through technically necessary cookies are not used to create user profiles. Analytics cookies are used for the purpose of improving the quality of our app and its content. Through the analysis cookies, we learn how the app is used and can thus constantly optimize our offer. Technically necessary cookies Name: Web app onesome cookies Name: Stripe Statistical cookies Name: Web app onesome Cookie The legal basis for the processing of personal data using technically unnecessary cookies is Art. 6 para. 1 S. 1 lit. a GDPR. The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 S. 1 lit. f GDPR. Cookies are stored on the user’s computer and transmitted by the user to our site. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transfer of cookies. Cookies that have already been saved can be deleted at any time. This can also be automated. If cookies are deactivated for our app, it may no longer be possible to use all of the app’s functions to their full extent. If you use a Safari browser version 12.1 or higher, cookies are automatically deleted after seven days. This also applies to opt-out cookies, which are set to prevent tracking measures. On our app, it is possible to contact us via the email address provided. In this case, the user’s personal data transmitted with the email will be stored. The data will be used exclusively for the processing of the conversation. In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data. The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f GDPR. If the email contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified. The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by email at datenschutz@onesome.de, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. All personal data stored in the course of contacting us will be deleted in this case. On our app, we offer users the opportunity to register by providing personal data. The data is entered in an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process: As part of the registration process, the user’s consent to the processing of this data is obtained. The identification of the user is necessary to ensure the use of the application within the framework of the contract of use of the application concluded between Seneration GmbH and you within the framework of your registration and creation of a user account. The legal basis for the processing of personal data in the context of the creation of a user account and use of personal data for the use of described functionalities is the consent of the user pursuant to. Art. 6 par. 1 S. 1 lit. a GDPR in connection with Art. 9 para. 2 lit. a GDPR. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. As a user, you have the option to cancel the registration at any time. You can have the data stored about you changed at any time. If the user contacts us by email at datenschutz@onesome.de, he can object to the storage of his personal data at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. We utilize features of the technology provided by OneSignal, located at 201 San Antonio Circle Suite #140, Mountain View, CA, USA. OneSignal enables us to send registration emails and follow-up emails for the use of onesome. During this process, OneSignal stores cookies on your device. OneSignal processes the following personal data, in particular: The data is processed and stored in both Europe and the United States. The utilization of OneSignal is intended for sending registration emails, follow-up emails, and push notifications related to the use of onesome (reminder emails, product marketing emails, etc.). After registering with onesome, you can customize settings within the web app to receive follow-up emails. The processing of users’ personal data is primarily based on the user’s consent according to Article Art. 6 para. 1 lit. a GDPR. Your personal information will be retained for the duration necessary to fulfill the purposes outlined in this privacy policy or as mandated by law, such as for tax and accounting purposes. You have the right to withdraw your consent for data protection at any time. The revocation of consent does not affect the legality of the processing carried out based on the consent before the revocation. Microsoft Azure CDN On our website, we use functions of the content delivery network Microsoft Azure CDN of Microsoft Corporation, One Microsoft Way, Redmond, WA 8052-6399, USA (hereinafter referred to as: Microsoft Azure CDN). A content delivery network (CDN) is a network of regionally distributed servers connected via the Internet that is used to deliver content – especially large media files such as videos. Microsoft Azure CDN provides web optimization and security services that we use to improve our website load times and protect it from misuse. When you visit our website, a connection is established to the servers of Microsoft Azure CDN in order to retrieve content, for example. As a result, personal data can be stored and analyzed in server log files, especially the user’s activity (in particular, which pages have been visited) and device and browser information (in particular, the IP address and the operating system). For more information about the collection and storage of data by Microsoft Azure CDN, click here: https://www.microsoft.com/de-de/TrustCenter/Privacy/default.aspx Part of the order processing contract with Microsoft are so-called EU standard data protection clauses (Art. 46 para. 2 p. 1 lit. c GDPR). These are to be classified as an appropriate guarantee for the protection of the transfer and processing of personal data outside the EU. A copy of the standard data protection clauses can be requested by sending us an informal e-mail. Leverage Microsoft Azure CDN capabilities to deliver and accelerate online applications and content. The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected. Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law. For information on opt-out and removal options against Microsoft Azure CDN, see: https://www.microsoft.com/de-de/TrustCenter/Privacy/default.aspx We collect telemetry data on our app. We implement this with the following tools: The data will be processed for the following purposes: The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The app operator has a legitimate interest in the technically error-free presentation and optimization of its app. Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law. You can object to the processing of your personal data at any time by sending an informal email to datenschutz@onesome.de. All other rights for you as a data subject, you can also address to this email address. To provide specific functionalities, device permissions for your end device are requested during the use of the app. Without it, we cannot provide certain services. Device permissions always require your explicit consent. The following permissions are requested to implement the functions in the app: The authorization assignment is necessary to use certain functionalities of our app. The app does not gain access to device functionalities before the user has explicitly granted authorization. You can change the permissions at any time on your end device. In addition, meta-information can be collected to monitor our application and identify errors. The processing of data is necessary for the full use of all features of the app. The meta information is collected on the basis of Art. 6 para. 1 lit. f GDPR. The app operator has a legitimate interest in the technically error-free presentation and optimization of its app. The authorization assignment and processing of internal data of the device is done by your explicit release and thus by your consent according to Art. 6 para. 1 lit. a GDPR. Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law. You can object to the processing or revoke your consent at any time by sending an informal e-mail to datenschutz@onesome.de. You can prevent the use of device functions yourself at any time by making the appropriate settings on your terminal device. By using our plugins, some of your personal data will be sent to the USA or other third countries outside the EU. To ensure appropriate safeguards for the protection of the transfer and processing of personal data outside the EU, the transfer of data to and processing of data by our plugin operators is based on appropriate safeguards pursuant to Art. 46 et seq. DSGVO, in particular by concluding so-called standard data protection clauses pursuant to Art. 46 para. 2 lit. c GDPR. A copy of the standard data protection clauses can be requested by sending us an informal email. We use plugins for various purposes. The plugins used are listed below: Use of Matomo We use the open source tracking tool Matomo (https://matomo.org/) to analyze the surfing behavior of our users. Matomo sets a cookie on your computer. Personal data may be stored and analyzed, in particular the activity of the user (especially which pages have been visited and which elements have been clicked on), device and browser information (especially the IP address and the operating system), data about the displayed advertisements (especially which advertisements have been displayed and whether the user has clicked on them) and also data from advertising partners (especially pseudonymized user IDs). Translated with www.DeepL.com/Translator (free version) We do not use this data to identify the user and the data is not merged with other personal data of the user. The data is anonymized and processed on a server rented from InnoCraft Ltd. in Frankfurt am Main and also stored in Ireland as a backup. They will not be transmitted to third parties. InnoCraft does not pursue its own purposes with the storage and processing of the data. For more information on the processing of data by Matomo, click here: The processing of users’ personal data enables us to analyze the surfing behavior of our users. By evaluating the data obtained, we are able to compile information about the use of the individual components of our online presence. This helps us to constantly improve our online presence and its user-friendliness. The processing of users’ personal data is primarily based on the user’s consent according to Article Art. 6 para. 1 lit. a GDPR. Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law, such as for tax and accounting purposes. You have the right to withdraw your consent for data protection at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. You can prevent the collection and processing of your personal data by Matomo by preventing the storage of third-party cookies on your computer, using the “Do Not Track” function of a supporting browser, deactivating the execution of script code in your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. With the following link you can deactivate the processing of your personal data by Matomo: https://matomo.org/privacy-policy/ For more information on objection and removal options vis-Ã -vis Matomo, please see: https://matomo.org/privacy-policy/ This privacy policy was created with the support of DataGuard. Privacy Data Art. 13, 14 DSGVO
1. Name and address of the responsible person
Maximilianstrasse 43
80538 München
Germany
08935768940
datenschutz@onesome.de
www.onesome.de2. Contact details of the data protection officer
Dachauer Straße 65
80335 München
Germany
+49 89 7400 45840
www.dataguard.de3. General information on data processing
3.1 Scope of the processing of personal data
3.2 Legal basis for the processing of personal data
3.3 Data deletion and storage period
3.4 Recipients of personal data
3.5 Data processing by Seneration GmbH for the further development of the Services
3.6 Possibility of objection and removal
4. Rights of the data subject
4.1 Right to information
4.2 Right to rectification
4.3 Right to restriction of processing
4.4 Right to deletion
4.5 Right to information
4.6 Right to data portability
4.7 Right of objection
4.8 Right to revoke the declaration of consent under data protection law
4.9 Automated decision in individual cases including profiling
4.10 Right to complain to a supervisory authority
5. Provision of the app and creation of the log files
5.1 Description and scope of data processing
5.2 Purpose of the data processing
5.3 Legal basis for data processing
5.4 Duration of storage
5.5 Possibility of objection and removal
6. Use of cookies
6.1 Description and scope of data processing
6.2 Purpose of data processing
6.3 onesome Cookies
Provider: Owner of this website
Purpose: Technically necessary information on the use of the website
Cookie name: webapp.onesome.de
Cookie duration: 365 days
Provider: Stripe Payments Europe
Purpose: For the purchase processing of onesome via the app. Information on cookies from websites that are linked to onesome can be found on the respective websites.
Cookie name: .s.stripe and m.stripe.network
Provider: Owner of this website
Purpose: For session ID tracking via Matomo Information on cookies from websites that are linked to onesome can be found on the respective websites.
Cookie name: webapp.onesome.de
Cookie duration: 365 days6.4 Legal basis for data processing
6.5 Duration of storage, objection and removal options
7. Email contact
7.1 Description and scope of data processing
7.2 Purpose of the data processing
7.3 Legal basis for data processing
7.4 Duration of storage
7.5 Possibility of revocation, objection and removal
8. Registration
8.1 Description and scope of data processing
8.2 Purpose of the data processing
8.3 Legal basis for data processing
8.4 Duration of storage
8.5 Possibility of revocation, objection and removal
9. OneSignal
9.1 Description and scope of data processing
When using the app, we ask for your permission to send future messages (Push Notifications) to alert you to news and information.
– First and last name
– Email address
– IP address, system configuration
– Visited websites with the SDK, information about visits
– Details about the end-user’s browser, such as browser language type and operating system version (e.g., Android, iOS), network provider, language setting, time zone
– Cookie ID
– Push Notification message
OneSignal is certified under the Data Privacy Framework. For more information about OneSignal and data protection at OneSignal, please visit https://onesignal.com/privacy_policy9.2 Purpose of the data processing
9.3 Legal basis for data processing
9.4 Duration of storage
In the event of revoking your consent to receive emails, the relevant personal data will also be deleted.9.5 Possibility of revocation, objection and removal
For Apple devices: If you own an Apple device, you can disable most app-based tracking for interest-based advertising by turning “Limit Ad Tracking” to ON. You can do this by navigating to Settings > Privacy> Advertising and turning “Limit Ad Tracking” to ON.
For Android devices: If you own an Android device, you can disable most app-based tracking for interest-based advertising by opening the Google Settings app on your device, selecting Ads, and then choosing the option to disable interest-based ads.
For more information on objection and removal options regarding OneSignal, please visit: https://onesignal.com/privacy_policy
In most cases, you can disable the receipt of push notifications by going to “Notifications” in the “Settings” of your device and then adjusting these settings for some or all apps on your device. Settings for receiving onesome emails can be modified directly in your onesome settings in your profile.10. Content Delivery Networks
10.1 Description and scope of data processing
10.2 Purpose of the data processing
10.3 Legal basis for data processing
10.4 Duration of storage
10.5 Possibility of objection and removal
11. Telemetry data
11.1 Description and scope of data processing
11.2 Purpose of data processing
11.3 Legal basis for data processing
11.4 Duration of storage
11.5 9.5 Possibility of revocation, objection and removal
12. Device authorisations
12.1 Description and scope of data processing
12.2 Information on the app authorisations
12.3 Purpose of data processing
12.4 Legal basis for data processing
12.5 Duration of storage
12.6 9.5 Possibility of revocation, objection and removal
13. Plugins used
13.1 Scope of the processing of personal data
The software is set so that the IP addresses are not stored completely, but 2 bytes of the IP address are masked for anonymization (Ex: 192.168.xxx.xxx). In this way, it is no longer possible to assign the shortened IP address to the calling computer.
https://matomo.org/privacy-policy/13.2 Purpose of data processing
13.3 Legal basis for the processing of personal data
13.4 Duration of storage
13.5 Possibility of revocation, objection and removal