1. Responsibilities

1.1. Responsible person (according to Article 4 No. 7 GDPR):

The protection of your personal data is important to WTG communication GmbH. For this reason, we will inform you below about the scope, purposes and benefits of the processing. 

The person responsible within the meaning of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and other data protection regulations is 
  
WTG communication GmbH 
Willy-Brandt-Weg 11 
48155 Münster 
Email: infowtg.com 
hereinafter referred to as “controller” or “we”. 

1.2. Processor (according to Article 28 GDPR):

We use contract processors for certain data processing activities. These partners act on our behalf and in accordance with our instructions. We have put in place agreements in accordance with Article 28 GDPR to ensure that your data is protected. 

1.3. Data protection officer (if applicable, in accordance with Article 37 GDPR):

The following was appointed as data protection officer: 

yourIT GmbH
Thomas Ströbele
Häselstraße 10
72336 Balingen
Fon +49 7433 30098-30
datenschutz@yourit.de

2. Definitions

2.1. Definitions from the GDPR

This declaration uses the terms of the GDPR. You can view the definitions (Art. 4 GDPR) at https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32016R0679&qid=1702979236994

2.2. Definition of data categories

The processed data categories specified in this data protection declaration include: master data (e.g. names), contact data (e.g. address, telephone numbers), personal data and connection data (e.g. IP addresses, profile picture, duration of registration, access times).

3. Information on data collection, processing and use of personal data 

We only process personal data to the extent permitted by law. Personal data will only be passed on in the cases described below. Your personal data is protected through appropriate technical and organizational measures. If there is no legal obligation to store or pass on data to third parties (in particular law enforcement authorities), storage and transfer depends on which functions of our services you use in the individual case. A general transfer to third parties does not take place (hosting service providers and providers of technical communication to the servers are excluded from this). The processing is therefore based on the following legal bases in accordance with Article 6, Paragraph 1 b) GDPR.

Data

Description

SIP account credentials

Required for push notifications and the WebRTC app to work. They are used to register the account on the server and forward all incoming calls and messages to the device via push notifications.

Address book data

Required for Contact Sync and Smart Contacts features to work. A copy of your address book is stored on the server and is used to display your address book in the WebRTC app and to inform you about your contacts who also use the service.

IP addresses

When using features that require server components, such as push notifications or contact synchronization and smart contacts, or any web services, the IP address and browser information may be logged by the servers. The logs are created automatically, rotated, and the information contained therein is processed only to troubleshoot specific issues or when required by law.

Usage Data

The servers collect information about whether the app has been actively used within the current month, for accounting/billing purposes. The data has a pseudonymized identifier that is reported by the app when it is used and the time since the last report is more than 14 days.

3.1. Data sharing for support purposes

The data you process will be passed on to the following recipients:

Category

Purpose

Support service provider

1st level support

WTG communi­cation GmbH

Technical provision of the portal and services

3.2. Purpose of processing

Storage and use of technical protocols to ensure and prove the functionality of our services. The legal basis in this respect is Article 6 Paragraph 1 Letter b GDPR (fulfillment of the contract), at the same time this is also our legitimate interest in accordance with Article 6 Paragraph 1 Letter f GDPR. Legal basis: Article 6 Paragraph 1 Letter f GDPR. 
Data categories: usage data, connection data, registration, personal master data, contact data

3.3. Processing the order for the app including transaction emails and support

Collection and collection of your user ID and email address for license measurement and support purposes as well as to ensure the security of our information technology systems. Legal basis: Article 6 Paragraph 1 Letters b, f GDPR 
Data categories: master data, contact data, usage data, connection data, contract data, payment data  

3.4. Download the app

You have the option of downloading our WTG Cloud PURE app from both the Google Play Store (Android) and the Apple App Store (iOS). In this context, we would like to inform you in detail about how we handle your data. 
  
In order to provide you with the app and enable it to be downloaded to your mobile device, the necessary information is transferred to the relevant app store. These include in particular:

  • E-mail address 
  • Time of download 
  • individual device code 
  • IP address 

We would like to point out that we have no influence on this data collection. The respective operator of the app store is responsible for this.

 3.5. Login area

When you log in via the login area of the app with your email address and password, we process the relevant data to verify and authenticate your identity as a user. In addition, the date and time of registration are saved. Data processing is carried out in accordance with Article 6 paragraph 1 letter b GDPR to fulfill the purpose of the contract.

3.6. Using the app

During the course of using the app, the following processes are affected in detail: 

  • Telephony 
  • Personal settings for call forwarding 
  • Call history 
  • Function keys 
  • User status 
  • PBX phone book 
  • Device settings 
  • In-app rating (Android): Rating of the app (optional) 
  • Language: Language settings are saved directly in the app 

As part of these processes, the following data is processed:

  • Name first Name 
  • Extension number 
  • Inbound extension 
  • E-mail address 
  • Phone number 
  • Call duration 
  • Phone ID 
  • IP address 
  • Presence status – Line status (in conversation or not) 
  • Presence status – User status (available, busy, offline), optionally adjustable 
  • FaceID or Touch ID (optional) (iOS): If login with Face or Touch ID is activated, the facial data or fingerprint is stored on your mobile device and is never transmitted to our servers. 

The data is processed within the framework of the existing contractual relationship in accordance with Article 6 paragraph 1 letter b GDPR. The processing of the data that you can optionally provide is based on your consent in accordance with Article 6 Paragraph 1 Letter a GDPR.

3.7. Data storage during uninstallation 

In case you decide to stop using the service and uninstall the associated apps, all personal data stored will be removed from our servers within 7 days, except for the data that we need to keep for compliance reasons with a legal obligation, which requires processing under Union or Member State law in accordance with Article 17 paragraph 3 GDPR.

4. Permissions

In order for you to be able to fully use all the functions of the app on your device, it is necessary that the app can access various functions and data on your device. To do this, you must grant certain authorizations, which corresponds to your consent in accordance with Article 6 paragraph 1 letter a GDPR. 
  
You can revoke the permissions in the settings of your device or directly in the app settings under “App permissions”. Please note that revoking permissions may result in you no longer being able to use certain features of the app. 
  
The scope of the individual permissions is described below:

Authorization

Description

Contacts

To use your address book contacts, the app requires access to your contacts and address book.

Microphone

In order to enable phone calls over an internet connection or the mobile telephone network, the app must have access to the microphone. This permission is essential for the app to function properly. If you don't grant this permission, the app won't run.

Mobile data/WiFi

The app requires access to mobile data or Wi-Fi for the following purposes: making and managing Cloud PBX calls, managing app settings, accessing the corporate address book, managing presence status and call history.

Notifications

You have the option of activating the “Notifications” function in order to receive so-called push notifications from the app on your device. These are priority notifications that concern, for example, unanswered calls. These notifications are processed based on your consent in accordance with Article 6 Paragraph 1 Letter a GDPR. You can revoke your consent at any time in the app settings under “Notifications”.

5. Automated decisions in individual cases including profiling

Automated decisions including profiling in accordance with Art. 22 Para. 1, 4 GDPR do not take place.

6. Rights of data subjects

As a data subject, you have the following rights: 

  • Right to information in accordance with Art. 15 GDPR, 
  • Right to correction in accordance with Art. 16 GDPR, 
  • Right to deletion in accordance with Art. 17 GDPR, 
  • Right to restriction of data processing in accordance with Art. 18 GDPR 
  • Right to data portability in accordance with Art. 20 GDPR 
  • Right to object, especially when processing in accordance with Article 6, Paragraph 1 a) and f) GDPR. 

If you would like to exercise one of these rights, we ask you to contact us informally in writing using the data protection contact address provided. 
The restrictions in Sections 34 and 35 BDSG apply to the right to information and the right to deletion. 
You have the right to complain to a data protection supervisory authority (Article 77 GDPR in conjunction with Section 19 BDSG). 
The data protection supervisory authority responsible for us  is: 
The State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia, Kavalleriestr. 2-4, 40213 Düsseldorf. 
You are also free to complain to another data protection supervisory authority. You can find a list of the supervisory authorities at: https://www.bfdi.bund.de/ (under Infothek/Addresses and Links).

6.1. Right to object and revocation of consent

You have the right to revoke any consent you have given at any time without giving reasons with future effect by post or email. This does not affect the lawfulness of processing based on consent until its revocation. Upon your revocation, we will delete the personal data processed based on your consent if there is no other legal basis for their processing. Objection and revocation can be made informally to the person responsible using the contact details mentioned. 

7. Obligation to provide

Unless otherwise explained in the information on the legal basis, you are not obliged to provide personal data. To the extent that the legal basis for the processing is Art. 6 Para. 1 b) GDPR, the personal data is necessary to fulfill or conclude the contract. In order to use the services and functions of the app, access rights may be required. These are explained in more detail in the “Permissions” section.

8. Data processing in connection with the use of the app

In order to use the app, the processing of personal data is necessary. When using the app, we are responsible for the following processing within the meaning of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and other data protection regulations.

8.1. Location

The data processed in the app is processed exclusively on our servers in Germany , unless another storage location, such as the device or the app, is specified.

8.2. Storage period 

Your personal data will be deleted as soon as it is no longer required for the purposes mentioned above, taking into account the retention periods under tax and commercial law. Your data will only be stored further if you have agreed to the continued use of your data or if we reserve the right to use your data beyond this, which is permitted by law and is explained in this data protection declaration.

9. Place of jurisdiction and legal binding force

For all legal matters in connection with this data protection declaration is Germany. The German version of this privacy policy takes precedence and is legally binding, even if translated into other languages.

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