A few words in advance:
YogaEasy GmbH, hereinafter referred to as "YogaEasy", takes the protection of your data very seriously. YogaEasy has set itself the goal of treating your data with the strictest confidentiality.
YogaEasy will not pass on your data to third parties unless this is necessary for the provision of the services you have requested, there is a legal obligation to do so or you have expressly requested that your data be passed on. Your data will be protected by YogaEasy against unauthorized access by third parties with the help of efficient technical means of protection.
The following data protection provisions inform you about the processing of personal data when you use our YogaEasy app.
Table of contents:
1. Name and contact details of the controller
2. Collection and storage of personal data and the nature and purpose of their use
3. Analysis, personalization and marketing tools
4. Use of Google Remarketing Services
5. Use of Facebook remarketing tools / Facebook Insights
8. Data erasure and storage duration
13. Status and amendment of these data protection provisions
1. Name and contact details of the responsible person
Controller
YogaEasy GmbH
Hoheluftchaussee 95a
20253 Hamburg
Phone: +49 40 41 49 83 22
Mail: support@yogaeasy.de
Data protection officer at YogaEasy
Hoheluftchaussee 95a
20253 Hamburg
Phone.: +49 176 32288975
Mail: datenschutz@yogaeasy.de
2. Collection and storage of personal data and the nature and purpose of their use
When you use our app, information (cookies) is stored on your end device. Some are absolutely necessary for the use of the app. Certain cookies are not necessary, but help us to optimize the use of the app and improve our services. Consent includes all non-essential cookies selected by you, the corresponding storage of information on your device and its processing. The legal basis for consent with regard to the storage and processing of information is Section 25 (1) TTDSG and with regard to the processing of personal data Art. 6 (1) lit. a GDPR.
a) When downloading the app
When you download the mobile app, the required information is transmitted to the App Store, in particular your user name, email address and customer number of your 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. The contract is concluded with the respective provider of the app store and in accordance with their terms and conditions of use and data protection provisions. We only process this data to the extent that it is absolutely necessary for the process of downloading our app to your mobile device.
b) Creating a data profile when you register for our services by providing your email address
When registering for our services via an app (this includes newsletter registration, registration for a free trial membership as well as registration with the conclusion of a paid membership), a data profile is automatically created for communication and personalization of the user experience.
The service providers used in this context are our customer engagement tool Leanplum Inc. and the analytics software Mixpanel.
Leanplum
The services of "Leanplum", operated by Leanplum Inc. (European headquarters: TOO Herengracht 280, 1016 BX Amsterdam, Netherlands) are used to personalize communication. As a result, your email address and other data collected when you use our website (see below) will also be processed and stored on Leanplum servers in the USA.
You can find Leanplum's privacy policy here:
Leanplum helps us to build long-term and sustainable customer relationships, in particular through the use of personalized content and targeted customer contact via our app and website, through the use of emails, in-app messages and push notifications. On our behalf, the service analyzes the use of our app offering by our users. In this way, we try to understand how our users interact with the YogaEasy app. Leanplum also enables us to analyze and improve our digital advertising campaigns. For this purpose, the following data, among other things, is transmitted to Leanplum from the device you are using.
The legal basis for data processing is the fulfillment of our contract with you pursuant to Art. 6 para. 1 lit. b and our legitimate interest pursuant to Art. 6 para. 1 lit. f.The legal basis according to the Telecommunications Telemedia Data Protection Act with regard to the storage and processing of information is § 25 para. 2 no. 2 TTDSG: The storage is absolutely necessary so that the provider of a telemedia service can provide a telemedia service requested by the user.
We use the Leanplum service to tailor and optimize the service you have booked to your needs.
Mixpanel
We use the Mixpanel analysis service from Mixpanel Inc, 405 Howard St, Floor 2 San Francisco, CA 94105 ("Mixpanel") in our apps. Mixpanel uses so-called identifiers to provide us with statistical data about your use of the app. The data collected is transmitted to Mixpanel and stored there. Mixpanel shortens your IP address for this purpose if you are located within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Mixpanel server and shortened there.
Mixpanel processes the collected data statistically on our behalf so that we can use it to continuously improve our apps and make individual functions clearer and simpler. The logged data includes your user activity and the content of the pages accessed in the YogaEasy app.
The legal basis for data processing is the fulfillment of our contract with you pursuant to Art. 6 para. 1 lit. b and our legitimate interest pursuant to Art. 6 para. 1 lit. f.The legal basis according to the Telecommunications Telemedia Data Protection Act with regard to the storage and processing of information is § 25 para. 2 no. 2 TTDSG: The storage is absolutely necessary so that the provider of a telemedia service can provide a telemedia service requested by the user.
We use the Mixpanel service to tailor and optimize the service you have booked to your needs.
c) When accessing our app on the Internet
The use of our app regularly requires the establishment of an internet connection in order to load content (in particular videos) on our server. When an internet connection is established, your device automatically sends technical information to our server. This information is temporarily stored in a so-called log file. The following information is recorded without any action on your part and stored until it is automatically deleted after 14 days:
- IP address
- Access time
- Operating system used by the visitor
- Content of the request (specific page)
- Access status / http status code
- Amount of data transferred in each case
- Number of screens accessed
We process the aforementioned data for the following purposes:
- Ensuring a smooth connection to the website,
- To ensure a comfortable use of our website,
- Evaluation of system security and stability.
The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above. We do not use the data collected for the purpose of drawing conclusions about your person. This data is also not merged with other data. However, we reserve the right to check the log files retrospectively if we become aware of specific indications of unlawful use.
d) When you register in our app
Your registration is required to use our offer. This requires you to enter a valid email address and a password of your choice. You can then use this data to log in online via our website www.yogaeasy.com and use the YogaEasy website. The legal basis for the processing of your personal data is Art. 6 para. 1 sentence 1 lit. b GDPR.
If you have only registered for a free trial subscription, the email address you used will continue to be stored for a certain period of time after this trial subscription has expired. This storage takes place on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR, for the purpose of preventing abusive multiple registrations for our free trial subscription.
e) Registration and login via Facebook
You can also register using your Facebook profile. Such registration would also be processed accordingly by Facebook (Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). If personal data is nevertheless transferred to Facebook servers in the USA, we would like to point out that Facebook has submitted to the EU-US Data Privacy Framework and thus offers a guarantee of compliance with European data protection law.
In such a case, we store the information that you have registered with us via the Facebook login until you cancel your membership with us, disconnect from your Facebook profile or delete your Facebook account. We do not receive your access data to Facebook.
When you register via Facebook, we may also receive and process the following data about you: Your email address, your so-called "public information" on Facebook and information that you make publicly accessible or share for the respective application. Information is "public" if it is visible to everyone (i.e. also outside of Facebook). This applies to: your name, your profile and cover picture, your gender, your networks, your user name (Facebook URL) and your user ID (Facebook ID). You can see which information on your Facebook profile is public and which data you have released for which applications in your Facebook profile settings.
We process the data that you make available to us via Facebook in this way on the legal basis of your express consent (Art. 6 para. 1 sentence 1 lit. a GDPR) to set up your user account with us so that you can log in automatically and use our online yoga studio in an uncomplicated manner.
We would like to point out that due to the above-mentioned link between your Facebook membership and our online offer, Facebook may have an extended possibility to collect and process data about your use of our online yoga studio. For more detailed information on the processing and use of your data by Facebook, please refer to Facebook's privacy policy.
f) Registration and login via Apple ("Sign in with Apple")
You can also register for our offer using your Apple ID. In such a case, data processing would be carried out by Apple Distribution International Limited (Hollyhill Industrial Estate, Hollyhill, Cork, Republic of Ireland). Insofar as an international transfer of personal data should also take place, we would like to point out that Apple uses so-called model contract terms for this and thereby offers a guarantee of compliance with European data protection standards (see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en)
In the event of such registration, we store the information that you have registered with us via "Sign in with Apple", as well as a so-called identifier, which is generated by Apple and transmitted to us. This enables us to automatically identify you as an authorized user of our offer as long as you are logged in to Apple with your end device, without us gaining knowledge of your Apple ID itself or other information linked to it. However, we will ask you for an email address that we can use to provide you with relevant information about our offer. By default, the email address stored for your Apple ID is used for this purpose. However, you can select in the settings during registration that this email address should be hidden from third-party providers. In this case, Apple will generate a one-time address which will be forwarded to us.
This information is stored until you cancel your membership with us, disconnect from your Apple account (you can do this at any time in the settings of your Apple account) or delete this account completely. The email address you have stored will only be deleted when you terminate your membership with us.
The sole purpose of using the "Sign in with Apple" procedure is to provide you with another way of signing in to our app that is as simple as possible for you. The legal basis for the data processing carried out in this context is your previously granted consent (Art. 6 para. 1 sentence 1 lit. a GDPR). You can revoke this consent at any time with effect for the future. The easiest way to do this is to remove our app from the list of services linked to your Apple ID within your Apple account. You can also contact us with your request at any time by email at datenschutz@yogaeasy.de.
Of course, Apple also receives personal data from you regarding your use of the "Sign in with Apple" procedure. To our knowledge, however, Apple's data processing is limited to the data technically required to enable the functionality of this login procedure (in particular the recording of the fact of your registration for the use of "Sign in with Apple" for our app) and, in particular, there is no tracking of your logins or even the use of our app. You can find more detailed information on how Apple handles your personal data when you use the "Sign in with Apple" procedure in Apple's privacy policy and here.
g) When taking out a YogaEasy subscription via the app (in-app purchase)
If you as a user of the app purchase a YogaEasy subscription by means of an in-app purchase, we receive the following information via the respective AppStore:
- Time of purchase
- Product (type of yoga pass)
- User ID
We need this in order to check your authorization to access our fee-based offer via our app and to be able to make it available to you.
In addition, registration as a user is also required to use our YogaEasy subscriptions (see above). The registration data will be stored by us until you have terminated your subscription. The legal basis for the processing of your personal data is Art. 6 para. 1 sentence 1 lit. b GDPR, as we need it to fulfill the subscription we have concluded with you.
h) Voluntary provision of further personal data
As a subscriber, you also have the opportunity to provide additional information about yourself, which can help us in particular to personalize our offer for you. This information includes, in particular, your age, gender, previous yoga experience and, if applicable, preferred yoga styles, as well as your motivation for participating in our offer.
Based on your information, we can customize our offer, i.e. in particular the videos shown to you on your start page, to make them more interesting for you. For example, we will then suggest videos that best suit your chosen yoga style and the physical condition you have indicated, or we will not show you any videos that are clearly uninteresting or unsuitable for you. Your data may also be used by us for the purposes of statistical analysis and to improve our offer for our customers; your data will only be processed anonymously.
The legal basis for the processing of your voluntarily provided data is your consent in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as your voluntary information concerns data relating to your health.
You can revoke your consent at any time with effect for the future by informing us of this by sending an email to datenschutz@yogaeasy.de. In addition, if you log in via our website, you can delete or change your (voluntary) personal details within your profile area (at www.yogaeasy.com/mein-konto). Further processing for the above-mentioned purposes is then excluded.
i) Data processing within the scope of the user account
As a registered subscriber, you automatically have your own user account in which you can manage your personal details. The data in your user account cannot be viewed by third parties.
The personal data stored in your user account includes all information that you have disclosed to us when purchasing your subscription (see sections 2 c), d) and e) above). You have the option of correcting all of this information (such as your email address, your address or the yoga styles you are interested in) or, in the case of voluntarily provided information, to simply delete it.
However, your full user account (including the change function) is currently only available online at www.yogaeasy.com/mein-konto. In the app, under the menu item "My profile", you will only find details of your email address and your yoga pass.
As long as your membership was not concluded as an in-app purchase, you will also find your previous invoices in your user account under "My account" for tax purposes.
The legal basis for the storage of the data in your user account is, insofar as the data is required for the execution of the contract with you, Art. 6 para. 1 lit. b GDPR; insofar as it is not required for this (this applies to your voluntarily provided information), the processing is based on your consent, Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time with effect for the future by informing us of this by sending an email to datenschutz@yogaeasy.de. However, you can also simply delete your (voluntary) personal data within your user account. Further processing is then excluded.
j) Marketing to existing customers
We may also process the data you provide when you sign up for membership with us in order to inform you about other YogaEasy offers. The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in customer loyalty and the promotion of our business activities by providing product information based on your previous orders. You can object to the sending of such information emails at any time without incurring any costs other than the transmission costs according to the basic rates. To do so, simply send an email to support@yogaeasy.de or click on the unsubscribe link at the end of each of our information emails.
k) For inquiries to our support
You are welcome to contact our support team with your concerns regarding the use of our services, in particular by sending an email to support@yogaeasy.de. We process the information you provide solely for the purpose of processing your request and store it for possible follow-up questions (maximum 2 years). The legal basis for this is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in increasing our customer satisfaction.
If you contact us by email, your data will be transmitted in encrypted form using the Secure Socket Layer (SSL), a security standard supported by most Internet browsers and mail servers.
We use the support widget from Zendesk, a customer service platform from Zendesk Inc, 989 Market Street #300, San Francisco, CA 94102, to process customer inquiries. For this purpose, necessary data such as surname, first name, postal address, telephone number, e-mail address are collected via our website in order to be able to answer your questions.
Further information on data processing by Zendesk can be found in Zendesk's privacy policy at http://www.zendesk.com/ company/privacy.
If you contact us by e-mail or via a form, we will only use the personal data you provide to process the specific inquiry. The data provided will be treated confidentially. The data provided and the message history with our Service Desk will be stored for follow-up questions and subsequent contact. The legal basis for this is an order processing contract with Zendesk in accordance with Art. 28 GDPR and the EU standard contractual clauses concluded with Zendesk.
l) When registering for our newsletter
If you register for our free newsletter, we will use your email address to send it to you. We will then provide you with regular updates on new yoga videos, programs, articles and special offers from YogaEasy.
We use the so-called double opt-in procedure to subscribe to our newsletter. This means that after you have registered, we will send you an email to the email address you have provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 1 month, your information will be blocked and automatically deleted. The provision of further data in addition to your e-mail address is voluntary and will be used to address you personally.
After your confirmation, we store your e-mail address for the purpose of sending you the newsletter. In addition, we store the IP addresses you use and the times of registration and confirmation in order to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data. The legal basis is your express consent (Art. 6 para. 1 sentence 1 lit. a GDPR).
You can revoke your consent at any time with effect for the future or object to receiving further newsletters, for example via a link at the end of each newsletter. Alternatively, you can also send your unsubscribe request at any time to support@yogaeasy.de by email.
m) When you use our newsletter - Notes on the use of Leanplum
Statistical survey and evaluation of user behavior
When you open our newsletter or interact with it, your behavior is evaluated as follows: The emails sent via Leanplum contain so-called web beacons or tracking pixels. These are one-pixel image files that are stored on the Leanplum server and are retrieved from there when you open our newsletter. As part of this retrieval, the data mentioned in section 2 lit. a (technical information, such as information about the browser and your system, as well as your IP address and time of retrieval) is first collected and used for the technical improvement of the service (the delivery of our newsletter).
The information obtained as part of the statistical survey (e.g. whether or when a newsletter was opened and which links contained therein were clicked) can be assigned to the individual recipients of the newsletter for technical reasons. However, neither we nor Leanplum pursue the goal of observing individual newsletter recipients. Rather, the evaluations help us to recognize the reading habits of our users in general and to adapt our content to them or to send different content according to the interests of different user groups.
We would like to point out that Leanplum states that it may also use the above-mentioned data for the purpose of improving its own services and for its own commercial purposes. However, Leanplum will not use the data to write to you personally and will not pass your data on to third parties.
Data processing when accessing the Leanplum website
In some cases, you may be redirected to the Leanplum website when you subscribe to our newsletter, for example if you click on the link (contained in every newsletter) to access the newsletter online, or if you subsequently wish to correct your email address. Leanplum's privacy policy is also only available on their website.
In this context, we would like to point out that cookies are used on Leanplum's websites, which lead to the processing of personal data by Leanplum, its partners and service providers (such as Google Analytics). We have no influence on this data processing. If necessary, please refer to Leanplum's privacy policy (see above).
Legal basis and revocation options
The legal basis for data processing when using Leanplum is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR.
You can revoke your consent to the aforementioned data processing at any time with effect for the future by objecting to the receipt of our newsletter, for example by clicking on the corresponding link at the end of each newsletter. Alternatively, you can also unsubscribe from the newsletter at any time by sending an email to support@yogaeasy.de or unsubscribe from the newsletter directly in your customer account.
We would like to point out that tracking by the web beacon is also not possible if you have deactivated the display of images in your email program. In this case, the newsletter will not be displayed in full and you may not be able to use all the functions. However, allowing the images to be displayed manually would again lead to the tracking described above.
n) When using the videos
Your use of the videos (playback on the native players of your end device) is technically recorded and evaluated by us in our so-called backend. In addition to the log data caused by accessing the respective video in accordance with section 2 b), we collect the following data: Your user ID, the respective video ID and up to which point you have viewed the respective video. This makes it possible, for example, for us to restart a video that you have not watched in full from the point up to which you had already watched it the next time you access it. It also allows us to recommend other YogaEasy videos that you might be particularly interested in (for example, because you seem to particularly like a certain yoga teacher or yoga style). The above data processing is necessary to make our online yoga offering as easy and helpful for you as you may expect it to be. The legal basis for this data processing is therefore Art. 6 para. 1 lit. b GDPR.
o) In your evaluation of videos
You can rate our videos by either assigning a certain number of "stars" to a specific video after watching it, or by marking a video as a "favorite". Your rating according to "stars" is included in the overall rating of the respective video according to "stars" on our website. If you also post a comment on a video, your star rating will also be visible within the comment (see also the following section "When using the comment function"). Your rating will be used to improve the personal recommendations made to you for further videos and, if applicable, to include the video in the "Rated well by me" or "Favorites" sections of your personal profile.
In our app, you can also rate videos as "too easy", "just right" or "too difficult" for you after watching them. We also use these ratings primarily to improve the personal recommendations we make to you for further videos. In addition, these ratings are also used to improve the description of our videos (e.g. with regard to the level of difficulty or suitability for certain user groups).
The legal basis for the above data processing is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the continuous improvement of our offer, in particular in increasing the accuracy of personal recommendations for our users.
p) When using the comment function
It is also possible to comment on our videos within our app. However, this function is reserved exclusively for our registered members. When a comment is submitted, the comment is accordingly attributed to the respective member and the user name is displayed together with the time the comment was submitted. In addition, any rating given by the member is also displayed by "stars" within the comment field.
Furthermore, when a comment is submitted, the IP address of the commenter is stored for a period of seven days so that, if necessary, the author of an inappropriate or illegal comment (for which we as the operator of the website can be held responsible) can be identified
The legal basis for the aforementioned data processing is Art. 6 para. 1 lit. f GDPR. Our legitimate interests lie in the continuous improvement of our offer, in particular in making it easy to find videos that are suitable for the respective user, as well as in preventing and, if necessary, prosecuting illegal comments.
The comments remain stored permanently - or until the member concerned objects at any time. To object, please contact datenschutz@yogaeasy.de.
q) In our competition
If you decide to take part in competitions organized by us, we will generally ask you to provide us with your name and e-mail address so that we can inform you if you win and to ensure that each participant only takes part in the competition once. For some competitions, further information may be required in individual cases (e.g. age etc.). Data provided for a competition will only ever be used to run the competition and will only be stored for as long as is necessary to run the competition. The legal basis for the processing of your personal data in the context of competition entries is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR. Further details can be found in the respective information directly in the competition.
3. Analysis, personalization and marketing tools
General information
With the tracking measures described below, we want to ensure a needs-based design and communication with the users as well as the continuous optimization of our offer. The specific data processing purposes and data categories can be found in the information on the respective tracking tools.
Legal basis
Unless otherwise stated, all of the following tracking measures are carried out on the basis of your previously granted consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.
You can revoke your consent to the data processing by the tools listed below at any time with effect for the future (without prejudice to the following information on advertising identifiers) by deactivating the respective tracking measures in the app under the menu item "Settings/Data protection". Under the same menu item, you can also decide at any time to allow the corresponding data processing again.
Information on the use of advertising identifiers
For advertising purposes, some of the tools listed below (in the case of Apple devices) use the so-called "Advertising Identifier" (IDFA). This is a unique, but non-personalized and non-permanent identification number for a specific end device, which is provided by iOS. The data collected via the IDFA is not linked to other device-related information. We use the IDFA to provide you with personalized advertising and to evaluate your usage.
If you activate the "No ad tracking" option in the iOS settings under "Privacy" - "Advertising", we can only take the following measures: Measuring your interaction with banners by counting the number of times a banner is displayed without being clicked on ("frequency capping"), click rate, determining unique usage ("unique user") as well as security measures, fraud prevention and troubleshooting. You can delete the IDFA at any time in the device settings ("Reset Ad ID"), in which case a new IDFA will be created that will not be merged with the data collected previously. We would like to point out that you may not be able to use all the functions of our app if you restrict the use of the IDFA.
When using Android end devices, the advertising ID is used in a similar way, which can be reset under "Settings/Account/Google/Adverts".
a) Firebase, Crashlytics
We use the tools Firebase and Crashlytics in our app. Firebase and Crashlytics are subsidiaries of Google LLC (1600 Amphitheater Parkway, Mountainview, California 94043, USA) and are based in San Francisco (CA), USA.
Crashlytics provides us with reports on malfunctions of our app, in particular crashes, via a real-time data exchange. The data is only transmitted to us in anonymized form so that we cannot establish any reference to a natural person. Crashlytics is used solely for the purpose of technical improvement and further development of our app.
You can find Crashlytics' privacy policy at:
https://firebase.google.com/terms/crashlytics-app-distribution-data-processing-terms
We also use Firebase to enable us to analyze your use of our app. Firebase uses the advertising ID of your device for this purpose. We thus receive statistical evaluations via Firebase, for example on the number of purchases made via the app and the number of times the app is accessed. This helps us to design our app to meet your needs and to continuously optimize it, for example in terms of stability and security. We would like to point out that the user data is transmitted to Firebase in anonymized form.
You can find Firebase's privacy policy at https://www.firebase.com/terms/privacy-policy.html and Google's privacy policy at https://www.google.de/intl/de/policies/privacy/.
Google has submitted to the EU-US Data Privacy Framework, https://dataprivacyframework.gov.
The processing of your personal data in the context of the use of Firebase and Crashlytics is based on our so-called legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR). This lies in enabling the provision of a service for our users that is as stable as possible and not susceptible to disruptions and thus ultimately in promoting our business interests.
b) Adjust
We use the analytics service Adjust (from the provider adjust GmbH, Saarbrücker Str. 38a, 10405 Berlin) to analyze the use of our app. Adjust analyzes the functionality and actual use of the app using anonymized IP and Mac addresses of the users of our app, as well as the advertising IDs of Apple ("IDFA") and Google ("Android Advertiser ID"). It is not possible to draw conclusions about individual persons. Based on the data collected, Adjust only creates statistical evaluations and graphics for us regarding the number of visits, number of pages accessed per user, etc. We use these analyses exclusively to determine the effectiveness of advertising campaigns. The legal basis for this processing of personal data is Art. 6 para. 1 sentence 1 lit. f GDPR; our legitimate interest lies in improving our advertising campaigns. The Adjust service has been tested and certified in accordance with the ePrivacyseal (European Seal for your Privacy). You can find Adjust's privacy policy at: https://www.adjust.com/privacy-policy/.
Adjust initially uses the above-mentioned data to enable a specific activity (e.g. loading or installing the app) to be assigned to a previously placed advertising campaign (which is usually achieved in the web area via cookies from the respective third-party providers such as Facebook, Google, etc.). Adjust acts as a so-called attribution partner (intermediary) with regard to the remarketing and conversion functions of Google and Facebook: It is only through the involvement of Adjust that we are able to (statistically) measure the success of such marketing campaigns at all. Further information on the respective remarketing services, etc., including the options for (de)activating them, can be found in sections 4 and 5.
You also have the option of preventing any tracking by Adjust on the following websites: https://www.adjust.com/forget-device/ or www.adjust.com/opt-out.
4. Use of Google Remarketing Services
a) Google Adwords Conversion
We use Google Adwords (from the provider Google LLC, 1600 Amphitheater Parkway, Mountainview, California 94043, USA ("Google")) to draw attention to our offers with the help of advertising material (so-called Google Adwords) on external websites or apps. We can determine how successful the individual advertising measures are in relation to the advertising campaign data. In this way, we pursue the interest of showing you advertising that is relevant to you and optimizing our advertising costs.
For this purpose, it is necessary for Google to be able to link a specific activity, such as the installation of our app by you, with the previously displayed AdWords ad, via which you accessed the respective AppStore. This is done using the pseudonymized data collected by Adjust (see section 3 c) above), the comparison of which with the data from Google AdWords makes it possible to identify your device, but not you personally.
We ourselves do not collect and process any personal data as part of these advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users on the basis of this information.
b) Google Remarketing
In addition to Adwords Conversion, we use the Google Remarketing application. This application can be used to show you advertisements from our company after and based on your use of our app when you continue to use the internet (or use other apps that allow advertising). Your end device is identified by Google accessing the pseudonymized data collected by Adjust (see section 3 c) above) and is used solely to display the advertisement commissioned by us. Further processing of this pseudonymized data by Google, in particular a combination of the data collected in the context of remarketing with your personal data, which may be stored by Google, does not take place according to Google's own statements.
According to Google, pseudonymization is also used for remarketing.
c) Legal basis for the processing of your data
The legal basis for the processing of your personal data through the use of the remarketing services described above is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR. You can revoke your consent to this data processing at any time with effect for the future by deactivating the respective tracking measures in the app under the menu item "Settings/Privacy/Marketing Tracking". Under the same menu item, you can also decide at any time to allow the corresponding data processing again.
Further information on data protection at Google can be found at: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org/.
Google has submitted to the EU-US Data Privacy Framework, https://dataprivacyframework.gov.
5. Use of Facebook remarketing tools / Facebook Insights
a) Facebook remarketing tools (Facebook conversion and mobile custom audiences)
We place ads on the social network Facebook (operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook")) in order to draw attention to our offers. We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns (so-called "conversion"). In this way, we pursue the interest of showing you advertising that is relevant to you and optimizing our advertising costs.
For this purpose, it is necessary for Facebook to be able to link a certain activity, such as the installation of our app by you, with the previously played ad through which you accessed the respective app store. This is done using the pseudonymized data collected by Adjust (see section 3 c) above), the comparison of which with the Facebook data enables your device, but not you personally, to be identified.
With the help of the aforementioned pseudonymized data collected by Adjust, we can also ensure that only those users on Facebook who have previously used our app are shown one of our ads; in addition, we are able to target advertising to those Facebook user groups to which Facebook assigns certain characteristics (based on the data collected by Facebook about these users) that match the characteristics that we have previously reported to Facebook as relevant for the display of our ads (so-called "(Mobile) Custom Audiences").
We ourselves do not collect and process any personal data as part of these advertising measures. We only receive statistical evaluations from Facebook. Based on these evaluations, we can recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users on the basis of this information.
If you are a member of Facebook and have allowed Facebook to do so via the privacy settings of your account, Facebook will also link the information about your use of our app to your member account and may use it for the targeted placement of Facebook ads. For us, however, the data collected remains anonymous, i.e. we cannot draw any conclusions about the identity of the user.
Information on data processing by Facebook can be found in the Facebook data policy at www.facebook.com/about/privacy .
As a member of Facebook, you can use the following link to object to the data collection described above for the purposes of targeted advertising or to make settings for the types of advertisements you accept within Facebook: www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are adopted for all computers or mobile devices.
The legal basis for the processing of your personal data through the use of the remarketing services described above is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR. You can revoke your consent to this data processing at any time with effect for the future by deactivating the respective tracking measures in the app under the menu item "Settings/Privacy/Marketing Tracking". Under the same menu item, you can also decide at any time to allow the corresponding data processing again.
b) Insights
You can also find us with our own fan page on Facebook (https://www.facebook.com/yogaeasy). For this fan page, Facebook provides us with so-called "insights" about its users. This is aggregated data, i.e. statistical evaluations of the use of our fan page. In this way, we can obtain information about the retrieval of individual contents of our fan page or the interaction with them. The underlying data processing is also carried out using personal data. However, it is not possible for us to draw conclusions about specific persons (and their behavior on our fan page) from the data transmitted to us by Facebook. The processing of your personal data is based on our legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR) in providing a website that is attractive to users and thus ultimately promotes our business interests.
We are jointly responsible with Facebook for data processing within the scope of our fan page within the meaning of data protection law. We have entered into an agreement with Facebook that describes this responsibility in more detail (at https://www.facebook.com/legal/terms/page_controller_addendum). You can therefore contact both us and Facebook directly to process inquiries regarding your rights as a data subject, although asserting them against Facebook is much more effective due to its technical capabilities. Further information on the processing of personal data in the context of the provision of "Insights" and on exercising your rights as a data subject can be found at https://www.facebook.com/legal/terms/information_about_page_insights_data.
6. Connection to third-party fitness services - additional information on the use of the Yoga Easy app
a) Connection to Apple HealthKit
At the request of the respective user, data relating to the use of our app can be transferred to Apple Health. To do this, the user must first grant the relevant approval via the operating system of their end device. After each viewing of a video, the user is also asked by the app whether the relevant data should be shared with Apple Health. Our app only allows the unilateral transmission of data to Apple Health; the YogaEasy app does not access the user's Apple Health data.
The following data is transmitted from our app to the Apple HealthKit if the user has given their consent:
- Training duration
- Video title
- Teacher name
- Date and time of the start and end of video usage
- Date and time when the workout was added to the Apple Health Kit
- "Yoga" as a type of training
Data sent to the Apple HealthKit is stored in encrypted form on the user's device. The legal basis for the data processing described above is the voluntarily given consent of the user (Art. 6 para. 1 sentence 1 lit. a GDPR). The user can revoke their consent to data processing at any time with effect for the future via the settings in Apple Health. The corresponding data will then no longer be accessible via Apple Health. Please also note Apple's privacy policy, currently available at: https://www.apple.com/legal/privacy/de-ww/
b) Connection to Google Fit
At the request of the respective user, data relating to the use of our app can be transferred to Google Fit. To do this, the user must first grant the relevant approval via the operating system of their end device. After each viewing of a video, the user is also asked by the app whether the relevant data should be shared with Google Fit. Our app only allows the unilateral transmission of data to Google Fit; the YogaEasy app does not access the user's Google Fit data.
The following data is transmitted by our app to Google Fit if the user has given consent:
- Training duration
- Video title
- Teacher name
- Date and time of the start and end of video usage
- Date and time when the workout was added to Google Fit
- "Yoga" as a type of training
The legal basis for the data processing described above is the voluntarily given consent of the user (Art. 6 para. 1 sentence 1 lit. a GDPR). The user can revoke their consent to data processing at any time via the settings in Google Fit with effect for the future. The corresponding data will then no longer be accessible via Google Fit. Please also note Google's privacy policy, currently available at https://policies.google.com/privacy. Specific information on data protection when using Google Fit can currently also be found at https://support.google.com/fit/answer/6098255?co=GENIE.Platform%3DAndroid&hl=de
7. Recipient of your data
We only transfer your data to third parties if this is permitted by law, if you have given your consent or if the transfer is necessary to fulfill our business purposes.
For example, we transfer personal data to third parties as part of the performance of the contract concluded with you (providers who enable us to provide our online services) or to support marketing measures (e.g. newsletter mailing service providers). Furthermore, we may transfer personal data to public bodies and institutions (tax offices, authorities, customs offices) if there is a legal or regulatory obligation to do so, or to legal advisors and debt collection agencies for the purpose of enforcing contractual claims.
Details about recipients or categories of recipients of your data can also be found within this privacy policy as part of our explanations of the individual processing situations.
8. Data erasure and storage duration
We will delete your personal data as soon as the purpose of storage no longer applies or you revoke your previously granted consent to storage and the deletion does not conflict with any statutory retention obligations. If your data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes, e.g. if it must be retained for commercial or tax law reasons.
9. Rights of data subjects
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
- in accordance with Art. 16 GDPR, to immediately request the correction of incorrect or incomplete personal data stored by us;
- in accordance with Art. 17 GDPR, to demand the deletion of your personal data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest
- or is necessary for the establishment, exercise or defense of legal claims;
- in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR;
- in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller
- in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing that was based on this consent in the future;
- to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
10. Right of objection
In accordance with Art. 21 para. 1 GDPR, 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 based on Art. 6 para. 1 lit. f GDPR; this also applies to profiling based on this provision. When exercising this objection, you must provide us with your personal reasons why we should not process your personal data. We will examine your objection and either discontinue or adapt the data processing or show you compelling reasons on our part worthy of protection on the basis of which we may continue the processing.
If personal data concerning you is processed for direct marketing purposes on the basis of Art. 6 para. 1 lit. f GDPR, you have the right to object to the processing of personal data concerning you for the purpose of such advertising at any time without giving reasons in accordance with Art. 21 para. 2 GDPR; this also applies to profiling insofar as it is associated with such direct advertising. If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes.
To exercise your right to object, simply send an email to datenschutz@yogaeasy.de.
There may be specific technical options for exercising your right of revocation or objection for individual types of data processing. We may have already informed you of this in the explanation of the respective data processing measures.
11. Right to withdraw consent
You have the right to revoke a declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
12. Data security
We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.
To prevent unauthorized access by third parties, all data that you enter during the registration process on our website is transmitted in encrypted form via an SSL server.
13. Status and amendment of these data protection provisions
These data protection provisions are currently valid.
The further development of our app and changes to legal or regulatory requirements may necessitate changes to this privacy policy. You can find the current data protection provisions at any time in our app and within the product description in the respective app stores.
14. Data protection consent
Due to data protection regulations, some functionalities and analyses that we have generally provided in our app and described in more detail in this privacy policy require your consent.
By accepting the privacy policy for the YogaEasy app, you declare your consent to the types of data processing listed below:
I. Analysis tracking
You agree that we may collect and statistically evaluate data about the use of our app using pseudonymized user profiles that do not identify you as an individual user for the purpose of continuously improving our app, including the simpler design of individual functions. Insofar as this is done with the involvement of third-party companies and they have undertaken to comply with European data protection standards, data processing may also take place outside the European Union.
II. Marketing tracking
You consent to us using pseudonymized so-called "identifiers" or user profiles, which do not allow you to be identified as an individual user, to collect and evaluate data about the use of our app with the involvement of third-party companies such as Google and Facebook for the purpose of a more targeted display of advertising campaigns. In the event that such data processing takes place outside the European Union, these third-party companies have undertaken to comply with European data protection standards.
III. Communication & personalization tracking
You agree that we may collect and evaluate data about the use of our app using pseudonymized user profiles that do not allow you to be identified as an individual user for the purpose of a better, personalized customer approach and to enable suitable video recommendations to you. Insofar as this is done with the involvement of third-party companies and they have undertaken to comply with European data protection standards, data processing may also take place outside the European Union.
You can revoke your consent to any of the aforementioned data processing at any time with effect for the future by deactivating the respective tracking measures in the app under the menu item "Settings/Data protection". However, this may mean that some functions of our app are no longer available as usual. You can also decide to allow the relevant data processing again at any time under the same item ("Settings/Data protection") in our app.
Status: Sept 2024