1. Introduction
In the following, we provide information about the collection of personal data when using our mobile app (hereinafter only "App").
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
1.1. Contact details
The controller within the meaning of Art. 4 (7) EU General Data Protection Regulation (GDPR) is PANDA GmbH, Augsburger Straße 5, 86415 Mering, Deutschland, email: [email protected]. We are legally represented by Isabelle Hoyer , Stuart B. Cameron.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: [email protected].
1.2. Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
● Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
● Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a user purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
● Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
● Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.
1.3. Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.
In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4. Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
1.5. Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
● Right of access,
● Right to correction or deletion,
● Right to limit processing,
● Right to object to the processing,
● Right to data transferability,
● Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
1.6. Obligation to provide data
Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
1.7. No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.
1.8. Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
2. Data processing in the app
2.1. Downloading the app
Our app is ready for download at Apple's App Store und Google's Play Store (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the 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. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.
2.2. Hosting
Our app is hosted by Hivebrite. The provider thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
The provider hosts the app on servers in Vereinigte Staaten von Amerika.
2.3. Informative use of our app
When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
The data processed to this extent are:
● IP address
● Date and time of the request
● Time zone difference from Greenwich Mean Time (GMT)
● Content of the request (concrete interface)
● Access status/HTTP status code
● Amount of data transferred in each case
● Operating system and its interface
● Language and version of the operating system
2.4. Access to functions or data
The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.
The data processed or access functions used in this respect are
● bestehende Fotoaufnahmen und (gesamten) Speicher
2.5. Data processing for the provision of functions
In the app, we process data in order to provide the user with functions of the app. The legal basis for the processing is the usage agreement concluded with the user via the app.
The data processed to this extent are
● Nur die vom Nutzer selbst in die App eingegebenen Daten, Universal Unique Identifier des Endgeräts (UUID), Anderen Identifikator außer UUID und Fotos
2.6. Our application
Users can open a customer account on our app. We process the data requested in this context on the basis of our contract. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. b DSGVO.
Which personal data is processed in this context is determined by the respective input mask used for registration. Disclosure to one or more processors, such as cooperating partner companies, shall only take place with the express prior consent of the data subject.
Furthermore, with the registration, the IP address assigned to the data subject by the Internet Service Provider (ISP), the date and the time of registration are stored. The storage of this data takes place against the background that only in this way can the misuse of our services be prevented and, if necessary, this data makes it possible to investigate criminal offences committed. In this respect, the storage of this data is necessary to protect the controller. This data is not passed on to third parties unless there is a legal obligation to do so or if the passing on of the data serves the aim of criminal prosecution.
Registration for events
We offer the opportunity to apply for various events organised by us via forms on our app. The data entered in the course of this application can be seen from the input mask of the application form. They are collected and stored exclusively for the use of our offer.
The following data is involved:
● First name, last name, email address, telephone number, postcode, place of residence,
● current job title, current employment type, current company
● academic background, industry
● who else should definitely be at the event? Name 3 other people you would like to recommend (first name, last name, email address) > voluntary information
● how did you hear about Panda?
● upload CV (as a PDF please)
In this context, the IP address and the date and time of registration will also be stored. This serves as a safeguard for us in the event that a third party misuses your data and registers on our site without your knowledge.
The data will not be passed on to third parties. One exception to this is the forwarding of your CV to corporate partners of the event for which you have applied to participate. This forwarding will only take place at your express request and with your explicit consent. This will be obtained as follows as part of your application:
PANDA CV-Book* Before the event, we offer you the opportunity to appear with your CV in the ‘PANDA CV-Book’.The CV book will be forwarded to our partner companies. Companies that are interested in your profile can contact you and invite you to a personal meeting at the PANDA event. If you would like to attend, we will use the CV we have on hand for this purpose (unless you would like to provide us with a different version).
IMPORTANT: Your CV will be accessible to the partner companies for a period of four weeks – after that your contact information will be deleted. Participation in the CV book is of course voluntary and is intended to offer added value. Your profile will not be forwarded without your consent.
● Yes, I would like to appear in the CV book.
● No, I do not want to appear in the CV book.
2.7. Payment providers
We use payment processors to process payments, and these payment processors are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as these payment processors receive data and payment data entered by us in the ordering process, we thereby fulfil the contract concluded with our customers (Art. 6 para. 1 sentence 1 lit. b GDPR).
These payment service providers are:
● Stripe Payments Europe, Ltd., Ireland
3. Compliance with Child Safety laws & reporting
Our app complies with applicable child safety laws and regulations.
Our app ensures all content shared within the app is appropriate for a mixed audience, including children. User-generated content is moderated to prevent inappropriate material from being accessible.
Any CSAM (Child Safety Abuse Material) content will be automatically removed when flagged or reported through our moderation features or if we are directly contacted for this purpose.
We will systematically take action to report confirmed CSAM content to the National Center for Missing and Exploited Children.
CSAM consists of any visual depiction, including but not limited to photos, videos and computer-generated imagery, involving the use of a minor engaging in sexually explicit conduct.
Child safety point of contact
You can reach out to Isabelle Hoyer, [email protected] if CSAM content is detected.
Privacy and Data Protection
Our app is committed to protecting user data, especially for children under 13, in compliance with applicable regulations.
The privacy policy is displayed clearly and is accessible from the app settings and our website
All data is encrypted during transmission and stored securely.
Ads and Monetization
Our app does not include ads or monetized content.
Transparency and Disclosures
Data safety: Detailed information is provided as per Google Play’s Data safety form.
Content ratings: IARC 3+, L, E, 3, 3, USK 0
Validation and updates
Regular internal testing is conducted to ensure compliance with Google Play’s child safety standards, including functionality reviews and content audits.
Policies are reviewed quarterly or as required to align with updated child safety standards.
4. Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
5. Questions and comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.