Version from 20.12.2020
Responsible party for processing according to DSGVO.
The controller within the meaning of the General Data Protection Regulation and other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature (Schengen Data Protection Act, SDSG) is:
c/o Impact Hub
Together hereinafter referred to as “NALA.care”.
Email: [email protected]
Phone Privacy: +41797652407
Data Protection Officer: Jeremy Henrichs, NALA.care GmbH
The NALA.care App (hereinafter referred to as the “App”) publishes. NALA.care App does not have access to or insight into your personal data. NALA.care is the sole publisher of the App and is solely responsible for the development, content, data management and customer support.
2 What is personal data?
The term personal data is defined in the German Federal Data Protection Act (BDSG), the Schengen Data Protection Act (SDSG) and in the European Data Protection Regulation EU-DSGVO. Accordingly, this is individual information about personal or factual circumstances of a specific or identifiable natural person. This includes, for example, your civil name, your address, your telephone number or your date of birth. Likewise, special personal data is collected when using the app, such as: blood pressure values, BMI data. For this, NALA.care takes increased measures so that an appropriate level of protection is guaranteed in accordance with Art 32 DSGVO.
3 Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 (1) a) DSGVO and Art. 9 (2) a) DSGVO serve as the legal basis for the processing of personal data.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures or are required for support requests.
Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) c) DSGVO serves as the legal basis.
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) f) DSGVO serves as the legal basis for the processing.
4 What data is collected for a specific purpose?
NALA.care collects, stores and processes data that you provide to NALA.care or that you transfer through the use and registration of the app. We process the following personal data for the purpose of communication & settlement on the basis of Art. 6 (1) lit. b) DSGVO:
Pseudonym / Nickname;
NALA.care App customer number;
Consent to receive notifications;
Text input in chat, answers to questions in chat and quiz questions.
We process the following personal data for the purpose of analyzing user behavior, optimizing the app and troubleshooting on the basis of Art. 6 (1) f) DSGVO:
Meta/communication data, e.g. duration and frequency of visits, device information, operating system, IP addresses, server log files.
App usage data (including information viewed data);
Communications with us via phone, email, text messages (SMS, push notification, etc.).
Individualized and personal or anonymous and group detection, classification and analysis of current and potential user needs and user interests;
Individualized and person-related or anonymous and group-related classification and analysis of user potential;
We process the following specific personal data for the purpose of providing functionalities of the app on the basis of Art. 9 (2) lit. a) DSGVO:
Relevant medical measurement values for the supported indications, e.g.
5 Sharing with third parties
We may also disclose your personal and health information if we believe it is necessary to do so in order to comply with applicable laws and regulations, in the event of legal proceedings, at the request of the competent courts and authorities, or as a result of other legal obligations, in order to protect and defend our rights or property.
5.1 Disclosure for scientific purposes and to NALA.care App.
We pseudonymize or anonymize your personal data in accordance with appropriate technical and organizational measures pursuant to Article 32 (1) a) DSGVO so that no conclusions can be drawn about your person. The disclosure for scientific purposes relates primarily to the following data (not exhaustive):
This anonymized data is shared in aggregated form with research institutes, universities and clinics. Our legal basis for this is formed from Article 6(1)(f) DSGVO, as NALA.care has a legitimate interest in the improvement & anonymized evaluation of the data-based results.
The anonymized data may also be passed on to the NALA.care app.
5.2 Hosting via GTT Communications, Inc.
All data is hosted in Switzerland by a specialized server hosting company. The hosting services we use are for the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating the NALA.care system. The processor for hosting services is: GTT Communications, Inc, Josefstrasse 225, CH-8005 Zurich. GTT is certified in accordance with ISO27001: 2013, SOC1, SOC2 and PCI DSS.
5.3 Google Crashlytics via Firebase.
To be able to improve the stability and reliability of our apps, we rely on crash reports. For this purpose, we use ” Crashlytics”, a developer platform operated by Google Ireland Ltd, Google Building Gordon House, Barrow Street, Dublin 4, Ireland, to find bugs in the app. NALA.care relies on Google’s European servers and thus no data is transmitted to a third country.
Crashlytics receives user data such as mobile ad IDs, installation UUID (universally unique ID), Android IDs and IP addresses for error analysis.
The data processing is based on our legitimate interests (Art.6 para.1 lit. f DSGVO) in the technically error-free and optimized provision of our services.
Duration of data storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In addition, the data will be deleted if you revoke your consent or request the deletion of personal data.
Further data protection information via link
For further information on data protection, please refer to the data protection information of Crashlytics at https://firebase.google.com/support/privacy and https://docs.fabric.io/apple/fabric/data-privacy.html#data-collection-policies.
5.5 Push notifications via Google Cloud Messaging (Firebase) and Apple.
If you want to receive push notifications even when you are not in our app, you must allow us to do so. We ask for this the first time you install (Android) or use (iOS) the app.
All notifications or access can be subsequently turned on or off in the settings menu.
We use the services Firebase Cloud Messaging of the company Google (Google Ireland Ltd., Google Building Gordon House, Barrow Street, Dublin 4, Ireland) and Apple Push Notifications (Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014) for push notifications.
In the process, Firebase and Apple generate a calculated key (pseudonymized Device Token ID), which is composed of the app’s identifier and its device identifier. This key is stored on our push platform by with the settings you have chosen in order to provide you with the content according to your wishes. The Firebase or Apple servers cannot draw any conclusions about the requests of users or determine any other data related to a person. Firebase and Apple serve exclusively as transmitters.
The data processing is based on our legitimate interests (Art.6 para.1 lit. f DSGVO) in an optimized provision of our services. In addition, you give your consent to Apple and Google locally on your terminal device according to Art. 6 para. 1 lit. a) DSGVO.
Duration of data storage
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In addition, the data will be deleted if you revoke your consent or request the deletion of personal data.
Further data protection information via link
Further information on Google Firebase and data protection can be found here: https://www.google.com/policies/privacy/
Further information on Apple and data protection can be found here: https://www.apple.com/privacy/
NALA.care App makes the App available to your customers for use. Whether a user is authorized to use the app with extended functionality is determined by entering a contract number and date of birth via a service provided by NALA.care App. This verifies the data and sends the result of the verification back to NALA.care. NALA.care does not process or store this data beyond this query. NALA.care App has neither access to nor insight into your data entered when using the otherwise.
6 Rights of the data subject
If personal data of yours is processed, you are a data subject within the meaning of the DSGVO and you are entitled to the following rights vis-à-vis the controller:
6.1 Right to information
You may request confirmation from the controller as to whether personal data concerning you are being processed by us. If such processing is taking place, you may request information from the controller about the following:
the purposes for which the personal data are processed
the categories of personal data which are processed;
the recipients or categories of recipients to whom your personal data have been or will be disclosed;
the planned duration of the storage of your personal data or, if concrete information on this is not possible, criteria for determining the storage period;
the existence of a right to rectification or erasure of your personal data, a right to restriction of processing by the controller or a right to object to such processing;
The existence of a right of appeal to a supervisory authority;
any available information about the origin of the data, if the personal data is not collected from the data subject;
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the 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 about whether your personal data 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 Art. 46 DSGVO in connection with the transfer.
6.2 Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
6.3 Right to restriction of processing
You may request the restriction of the processing of your personal data under the following conditions:
if you dispute the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims; or
if you have objected to the processing pursuant to Article 21 (1) DSGVO and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.
If the processing of your personal data has been restricted, this data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an 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.
6.4 Right to erasure
You may request the controller to erase your personal data without delay, and the controller is obliged to erase this data without delay, if one of the following reasons applies:
The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
b) You revoke your consent on which the processing was based pursuant to Art. 6 (1) a) or Art. 9 (2) a) DSGVO and there is no other legal basis for the processing.
You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or the You object to the processing pursuant to Art. 21 (2) DSGVO.
The personal data concerning you has been processed unlawfully.
The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.
If the controller has made your personal data public and is obliged to erase it pursuant to Article 17 (1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
The right to erasure does not exist to the extent that the processing is necessary
For the exercise of the right to freedom of expression and information;
for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the area of public health pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) DSGVO;
for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) DSGVO, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or for the establishment, exercise or defense of legal claims.
6.5 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform 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 vis-à-vis the controller to be informed about these recipients.
6.6 Right to data portability
You have the right to receive your personal data that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
the processing is based on consent pursuant to Art. 6 (1) a) DSGVO or Art. 9 (2) a) DSGVO or on a contract pursuant to Art. 6 (1) b) DSGVO and
the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to have your personal data 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.
6.7 Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.
The controller will no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to processing of your personal data for 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, your personal data 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.
6.8 Right to revoke the declaration of consent under data protection law.
You have the right to revoke your declaration of consent under data protection law 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.
6.9 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 produces legal effects vis-à-vis her or similarly significantly affects her. This does not apply if the decision:
is necessary for the conclusion or performance of a contract between you and the controller,
is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
is carried out with your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases mentioned in a. and c., the Controller shall take reasonable measures to safeguard the 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 Controller, to express your point of view and to contest the decision.
6.10 Right to complain to 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, workplace or the place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR. The supervisory authority to which the complaint has been submitted will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.
7 User surveys for product optimization
Our claim is that users feel the maximum satisfaction when using our digital solutions. As developers, we rely on receiving direct feedback from our users. For this purpose, we usually include information about suggestions for improvement, bugs or malfunctions and additional functions. As a rule, primarily information about the product is collected, however, this information is brought in connection with your user data, so that a processing of personal data must take place.
Our legal basis for contacting you to participate in a feedback conversation or feedback form is formed by Art. 6 (1) lit. f) DSGVO. The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In addition, the data will be deleted if you request the deletion of personal data (information from the surveys).
8 Integration of other third-party services and content.
Our app and related communications (for example, emails) may contain links to third-party websites. However, we have no influence on information and offers on third-party websites. Similarly, we cannot influence how third-party providers handle data collected on their own websites. We are therefore not responsible for the compliance with data protection and other legal provisions by third-party providers with links in the app or related communications. If you have any questions about this, please contact these third-party providers directly.
9 Duration of storage of personal data
Personal data is stored for the duration of the respective statutory retention period. After expiry of the period, the data is routinely deleted, unless there is a necessity for initiating or fulfilling a contract.
We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to technological progress. In addition, data protection is continuously guaranteed at our company, through constant auditing and optimization of the data protection organization.
The subscription has a price of 20CHF / month and will auto-renew unless you turn off auto-renew in your iTunes Account Settings. Payment will be charged to your iTunes Account upon confirmation of purchase. Once purchased, refunds will not be provided for any unused portion of the term. Note: We’re adding a subscription management feature soon.