The controller in the context of the General Data Protection Regulation, other national data protection laws of EU Member States and other data protection regulations is:
Securepoint GmbH
Bleckeder Landstraße 28
21337 Lüneburg
Germany (headquarters)
Telephone: 04131/2401-0
Email: datenschutz@securepoint.de
Website: www.securepoint.de
Managing Directors: René Hofmann, Maximilian Senff
The controller's data protection officer can be contacted at:
Securepoint GmbH
Data protection officer
Bleckeder Landstraße 28
21337 Lüneburg
Germany (headquarters)
Telephone: 04131/2401-0
Email: datenschutz@securepoint.de
Website: www.securepoint.de
This app is intended for use together with the Securepoint MDM Toolbox app. The app is a plugin that is required on devices to support the additional MDM functions of Securepoint.
The app allows the administrator of your organization to request the location of the device in case the device is lost or stolen. When a device is located by the administrator, it transmits its location (longitude and latitude or possible errors) to our company's servers. The app will notify the user when this happens. The device does not routinely record the location, only when the administrator specifically requests it. After the request, the location is saved for a maximum of one hour.
User Privacy: We will never use user data before getting consent under any circumstances.
When a device is located by the administrator, the device transmits its location (longitude, latitude or potential errors) to our company's servers for location determination. The following data is stored in the process:
Longitude
Latitude
Error messages
Art. 6 Para. 1 (f) GDPR is the legal basis for processing personal data.
With the help of the location data, the device can be localized in case of loss.
Art. 6 Para. 1 (b) GDPR serves as the legal basis for the processing of personal data, which is necessary for the performance of a contract.
Art. 6 Para. 1 (a) of the GDPR serves as the legal basis insofar as we obtain the concerned data subject's consent to process personal data.
Art. 6 Para. 1 (b) GDPR serves as the legal basis where data processing is necessary for the performance of a contract to which the data subject is party. This also applies in order to take steps at the request of the data subject prior to entering into a contract.
Art. 6 Para. 1 (c) GDPR serves as the legal basis where processing is necessary for compliance with a legal obligation to which our company is subject.
The stored data is deleted after the expiration of one hour.
The personal data of data subjects are deleted or blocked as soon as the purpose of data storage no longer applies. Data storage beyond this purpose is permissible if provided for in EU regulations, laws or other directives issued by the EU or national legislator to which the controller is subject. Data will also be deleted or blocked on expiry of a storage period specified by the named standards, unless continued data storage is necessary for the purpose of contract conclusion or contract performance.
When the location data is transferred, a server request is performed. This generates log data in the server.
When transmitting the location data, our system automatically collects data and information from the device of the caller. The following data is collected in this process:
(1) Information about the type of device and the version used
(2) The operating system of the user
(3) The user's Internet service provider
(4) The IP address of the user
(5) The date and time of access
This data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
Art. 6 Para 1 (f) GDPR is the legal basis for temporary data and log file storage.
The temporary storage of the IP address by the system is necessary to enable the transmission of data. For this purpose, the user's IP address must remain stored for the duration of the session.
The storage in log files takes place in order to ensure the functionality of the service. An evaluation of the data for marketing purposes does not take place in this context.
These purposes reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.
Data are deleted as soon as they are no longer required for the purpose for which they were collected.
In the context of storing data in log files, this is the case after a maximum of 35 days. Data may be stored beyond these time periods. In this event the users' IP addresses are erased or alienated so that an allocation of the requesting client is no longer possible.
The collection of data for the provision of the service 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.
The diagnostic function can be activated in the app via opt-in. Log files are then automatically created and saved in the app. This data can be viewed in the app. Furthermore, this data can be made available to third parties via a share dialog.
The following data is collected in the log:
(1) App version number
(2) Device manufacturer
(3) Device model
(4) Android version
(5) MDM enrollment type
(6) Miscellaneous errors and status messages
Art. 6 Para 1 (b) and (f) GDPR are the legal basis for the data storage.
The storage of diagnostic data is intended to help diagnose and fix any problems in the functioning of the app.
These purposes reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.
The data can be deleted in the app by the user. Furthermore, the data is deleted when the memory limit is exceeded or the app is deleted.
When the help page is opened, a server request is performed. This generates log data in the server.
Each time our website is called up, our system automatically collects data and information from the calling device. The following data is collected:
(1) Information about the browser type and version used
(2) The operating system of the user
(3) The user's Internet service provider
(4) The IP address of the user
(5) The date and time of access
This data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
Art. 6 Para 1 (b) and (f) GDPR is the legal basis for temporary data and log file storage.
The temporary storage of the IP address by the system is necessary to enable delivery of the website 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 website. In addition, we use the data to optimize the website 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 reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.
Data are deleted as soon as they are no longer required for the purpose for which they were collected. In the context of collecting data to make the website available to the user, this is the case when the session is terminated.
In the context of storing data in log files, this is the case after a maximum of 35 days. Data may be stored beyond these time periods. In this event the users' IP addresses are erased or alienated so that an allocation of the requesting client is no longer possible.
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
When we process your data, you are the data subject in the context of the GDPR and you have the following rights vis-à-vis the controller:
You can obtain confirmation from the controller as to whether personal data concerning you are processed by us.
In the event your personal data are processed by us, you can obtain the following information from the controller:
(1) The purposes for which your personal data are processed;
(2) The categories of personal data that are processed;
(3) The recipients or categories of recipients to whom your personal data have been or will be disclosed;
(4) The planned duration of storage of your personal data or, if concrete details cannot be provided in this regard, the criteria for determining the duration of storage;
(5) The existence of a right to correction or deletion of your personal data; the right to restriction of processing by the controller or the right to object to data processing;
(6) The right to complain to a supervisory authority;
(7) All available information concerning the origin of the data if the personal data were not collected from the data subject;
(8) The existence of automated individual decision-making, including profiling, pursuant to Art. 22 Paras. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the implications and intended effects of processing for the data subject.
You have the right to obtain information as to whether the personal data relating to you are transferred to a third country or an international organisation. In this context you have the right to be informed of appropriate guarantees pursuant to Art. 46 GDPR in relation to the transfer of personal data.
You have the right to obtain from the controller the rectification of inaccurate or incomplete personal data concerning you. The controller must make the corrections without undue delay.
You have the right to obtain from the controller restriction of processing where one of the following applies:
(1) the accuracy of the personal data is contested by you, for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(3) the controller of personal data no longer needs the data for the original processing purpose but you require them for the purpose of asserting, exercising or defending legal claims, or
(4) you have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override yours.
If you have restricted the use of your personal data, it shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence 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 of a Member State.
If you have obtained restriction of processing pursuant to the preceding conditions, you will be informed by the controller before the restriction of processing is lifted.
a) Deletion obligation
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(1) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(2) you withdraw consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing;
(3) you object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR;
(4) the personal data have been unlawfully processed;
(5) your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(6) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
b) Disclosing information to third parties
Where the controller has made the personal data public and is obliged pursuant to paragraph Article 17 Para. 1 GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
c) Exceptions
The right to erasure shall not apply to the extent that processing is necessary:
(1) for exercising the right of freedom of expression and information;
(2) for compliance with a legal obligation which requires processing by 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;
(3) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR, in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(5) for the establishment, exercise or defence of legal claims.
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with GDPR provisions to each recipient to whom your personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
The controller shall inform you about those recipients at your request.
You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(1) the processing is based on consent pursuant to point (a) of Article 6 (1) GDPR or point (a) of Article 9 (2) GDPR or on a contract pursuant to point (b) of Article 6 (1) GDPR; and
(2) the processing is carried out by automated means.
In exercising your right to data portability, you also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The right referred to shall not adversely affect the rights and freedoms of others.
The right to data portability shall not apply to the 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 have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6 (1) GDPR, including profiling based on those provisions.
The controller will then no longer process your personal data unless he demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or if processing serves the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that 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 such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If you wish to have your personal data corrected, blocked or deleted or if you wish to obtain information about your personal data held in storage or if you have questions concerning the collection, processing or use of your personal data or wish to withdraw your consent, please write to the following email address: datenschutz@securepoint.de.
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:
(1) is necessary for entering into, or performance of, a contract between you and a data controller;
(2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
(3) is based on your explicit consent.
Decisions referred to in the preceding shall not be based on special categories of personal data referred to in Article 9 (1) GDPR, unless point (a) or (g) of Article 9 (2) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.
In the cases referred to in points (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your 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 habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.