Privacy Policy

Last updated: April 07, 2020

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions
Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

    Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Thinktronic GmbH, Tulpenweg 7, 83714 Miesbach.

    For the purpose of the GDPR, the Company is the Data Controller.

  • Application means the software program provided by the Company downloaded by You on any electronic device, named Locbase

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Website refers to Thinktronic, accessible from thinktronic.com

  • Service refers to the Application or the Website or both.

  • Country refers to: Bayern, Germany

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

  • Personal Data is any information that relates to an identified or identifiable individual.

    For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Collecting and Using Your Personal Data
Types of Data Collected
Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Usage Data
Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with your prior permission:

  • Information regarding your location

  • Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Provisions on the use of cookies

We use cookies to ensure the provision, protection and improvement of our services. Below we describe the cookies we use and explain why we use cookies and how we use the information we collect. We also explain how cookies enable the proper functioning of our Website and why you may not be able to use the full functionality of the Website if you disable the use of cookies. If you do not consent to the use of cookies, you may change your cookie setting at any time by following the instructions below.

What are cookies?

Cookies are text files that contain small amounts of information and are stored on your computer or mobile device when you visit a website. During subsequent website visits, cookies are sent back to the original website or another website that recognizes the cookie. Cookies are primarily used to ensure the proper or efficient functioning of a website and to provide information to the website operator. Cookies perform several functions. For example, they allow you to better navigate between different pages, store your preferences and generally improve your user experience. There are two main types of cookies:

  • our own cookies, which we store directly on your computer or mobile device;
  • third-party cookies that are stored for us and can be used by us for various purposes related to functionality, performance/analysis, contact/newsletter subscription, and payment processing.

Cookies may be stored on your computer or mobile device for different periods of time. Some cookies are session cookies; they only remain temporarily for the duration of a session and end when you close your browser. Other cookies are persistent cookies that remain on your computer or mobile device for a fixed period of time and are not deleted when you close your browser. Persistent cookies may be used by our Website to recognize your computer or mobile device when you reopen your browser and surf the Internet.

Why do we use cookies?

We use cookies for several purposes, including:

  • to facilitate, simplify and improve your access to and operation of our Website;
  • track data flows and usage behavior related to our Website;
  • understand how many users regularly use our Website and which operating systems (e.g. Windows or Mac OS) and Internet browsers (e.g. Internet Explorer, Chrome or Safari) they use;
  • monitor and continuously improve the performance of our Website;- personalize and improve your online experience.

What types of cookies do we use?

‍The types of cookies we or our partners use in connection with our Website can be divided into three categories: "cookies required for basic purposes", "functionality cookies" and "performance and analysis cookies". Below we have collected additional information for each category, including information about the purpose of the cookies we or a third party store.

Type of cookie What it does How to block it
Cookies required for basic purposes These cookies are necessary to provide you with our services and the services available through the Website and to enable you to use various website features. Without these cookies, services that you have requested could not be provided. Please read the instructions below under "How to delete or manage cookies".
Functionality cookies Functionality cookies save the settings you have made on the Website and allow us to tailor the Website for you. This means that when you stay on or return to the Website, we can offer you our services in exactly the way you want. We use the MailChimp service to contact you and send you our newsletter. To provide this service, MailChimp uses cookies over which Malao has no control. Further information on MailChimp can be found in section 1.3. Please read the instructions below under "How to delete or manage cookies".
Performance and analysis cookies We use these cookies to analyze how our Website is accessed, how it is used or what services the Website provides, to provide you with a better user experience and to maintain, operate and continually improve the Website. Performance and analysis cookies allow us, for example:
- better understand the visitors to our Website to improve the presentation of our content;
- determine the number of unique users of our Website;
- improve our Website by tracking errors that occur; and
- to conduct research and diagnostics to improve our offerings.

We use Google Analytics and MailChimp to understand how users use our Website. For more information, see sections 1.3 and 1.4.
Please read the instructions below under "How to delete or manage cookies".

How to delete or manage cookies

You have the right to accept or decline the storage of cookies on your device. You can exercise this right at any time by changing the settings in your browser according to your wishes.

However, if you disable cookies, you may no longer be able to use the website properly.

Most browsers provide instructions on how to customize cookie settings. The cookie settings are usually located under the menu item "settings" of your browser. If you wish to limit the use of third-party cookies, you can do so using one of the following links:

Please note that many companies are listed on these pages that do not set cookies via our Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, for payment processing, to contact You.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data
Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

  • Google Analytics

    When you access our Websites, the Google Analytics service is loaded for statistical evaluation of the use of our Websites. This service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). By using the "anonymizeIp()" extension, we ensure that Google Analytics only transfers a shortened version of your IP address to Google.

    By accessing the Websites and loading the service, Google obtains knowledge that our Websites were accessed via your IP address. Google Analytics uses cookies which are stored on your terminal device unless you have prohibited the use of cookies in your browser and allow for an analysis of your use of our Websites. The information generated by the cookies about your use of the Websites will be transferred to and stored by Google on servers in the United States.

    The use of Google Analytics is based on our legitimate interests (Article 6 para. 1 sentence 1 lit. f) GDPR), which consist in appropriately designing and optimizing our Websites. In addition, we have concluded an agreement for data processing with Google in accordance with the requirements of the German data protection authorities for the use of Google Analytics. Data transfers to the US are carried out under the EU-U.S. Privacy Shield.

    We collect your IP address to enable its shortening and then transmission to Google. You are not obliged to provide this personal data, a use of our Websites is possible without the provision. You can prevent the provision of this personal data by setting your browser software accordingly by installing the browser add-on available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

    More information about Google Analytics can be found at http://www.google.com/intl/de_ALL/analytics. Google's privacy policy can be found at https://www.google.com/policies/privacy/.

  • Firebase (Google Analytics for Firebase & Firebase Crashlytics)

    Firebase is an analytics service provided by Google Inc.

    You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

    We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245

    For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy. An example of data collected by the services offered by Firebase can be found on the following Firebase webpage: https://firebase.google.com/support/privacy#examples_of_end-user_personal_data_processed_by_firebase.

    To disable tracking through Google Analytics for Firebase & Firebase Crashlytics, you can visit our mobile apps settings and use the provided options.

Advertising

We may use Service providers to show advertisements to You to help support and maintain Our Service.

  • Google AdSense & DoubleClick Cookie

    Google, as a third party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

    You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

  • AdMob by Google

    AdMob by Google is provided by Google Inc.

    You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

    For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

GDPR Privacy
Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us at:

Thinktronic GmbH
Tulpenweg 7
83714 Miesbach
Deutschland

E-Mail: mail (ät) thinktronic (dot) com

Thinktronic
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