Your Privacy and Our Policy

We do value your privacy. This policy is to keep us safe and you informed about what we do with your data. Please kick back and read on.

  1. General
    1. It is of utmost importance for Pocketcoach GmbH, Kandlgasse 19-21, 1070 Vienna, [email protected] ("Pocketcoach", "we", "us") to protect your personal data. We therefore comply with the applicable data protection provisions, in particular the General Data Protection Regulation ("GDPR"), the Austrian Data Protection Act ("DSG") and the Telecommunications Act ("TKG") concerning the protection, lawful processing and confidentiality of personal data as well as data security.
    2. This Privacy Policy explains to you the nature, extent and purposes of the processing of your personal data within the scope of our Online Services in our Application ("App"). In the following you will especially be informed which personal data we potentially collect, process and use when you use our App.
  2. Which of your data do we collect, for which purposes and on which legal basis do we process it?
    1. Contacting us

      When contact with us via e-mail or through other electronic channels (such as social media platforms), we process the data you voluntarily provided us with (name, e-mail address, nature of the enquiry respectively the subject of your message and the content of your message).

      We process the data provided within the course of contacting us solely for processing your enquiry, to get in contact with you if desired and to provide you with the requested information. This data processing is therefore necessary for the fulfilment of our (pre)contractual obligations.

    2. Access data and log files

      We collect and process the following data when you use our App and the connected services, that means accessing the respective server which contains the specifically requested service (so called server log files): name of the accessed site, date and time of access, transmitted quantity of data, server status codes, username, processing time, browser and client type alongside the version, your operating system, referrer URL (the previously visited site), IP-address and the requesting provider, reverse DNS, location data, connection data, source and target (network discovery or address, port numbers, protocol, e-mail address, e-mail subject, connecting server, protocol details, reputation data, reverse DNS, obvious labelling, connected servers), authentication details and e-mail meta information.

      This data is generated automatically through our servers when you use our App and is necessary so that we can provide you with the desired services. We therefore process server log files solely to be able to operate our App and the connected services, to identify you as a user authorized to access, to distribute web server requests in our server pool as well as for security reasons (e.g. for clarification of abusive and fraudulent activities). Thus, this data processing activity is necessary to ensure our legitimate interests in operating a user friendly and secure App.

    3. Usage data / Tracking

      Based on your consent declaration, we collect and process the following data about your use and interaction with our App: IP-address of your device, your operating system, the requested files from our App, screen resolution, phone model, your click behaviour in the App (time of access, clicks) as well as the source you install the App from. If the app crashes a crash report is sent to us.

      This data is collected through Tools (see point 3 below). We use this usage data for (i) analysis, (ii) improvements of our services and our App, (iii) increasing usability. This data processing takes place on the basis of your consent to the use of tools in our App. You can withdraw this consent at any time with effect for the future and free of charge.

    4. Newsletter

      On the basis of your consent declaration, we process the personal data that you provided us with voluntarily in the course of the registration for the newsletter in our App (your e-mail address and potentially your name) (i) for sending you e-mail newsletters about our current projects, marketing and product information as well as (ii) for tracking your reading habits of our newsletter.

      Performance measurement: Our newsletters contain a mechanism for the tracking of your reading habits. With that we can determine whether our newsletter is opened, when it is opened and what links are clicked. These statistical evaluations are serving solely the detection of the reading habits of our newsletter recipients and to adjust our contents to them.

      You can withdraw your consent to the receipt of our newsletter at any time (e.g. via e-mail to [email protected] or through the unsubscribe link in our e-mail newsletters) with effect for the future and free of charge.

    5. Registration and User Account

      When you are registered in our App and have a user account for the use of our Online Services, we process the following personal data: name, e-mail address, billing data, IP address as well as your access data.

      We process the data of your user account solely for operating your account, the provision of our Services as well as for the billing of our services. This data processing is therefore necessary for the fulfilment of our (pre)contractual obligations.

      To be able to use our services, we ask you about your current state of health. We process this health data only with your prior consent in accordance with Art 6 para 1 lit a in conjunction with Art 9 Para 2 lit a GDPR. You can revoke this consent at any time without giving any reason. However, without this consent, the use of our app is not possible, since its main focus is to help you.

  3. Tools
    1. We use several tools in our App. Such tools allow us to store important data in order to provide you with our services and to make the use of our App more comfortable for you.
    2. In addition, based on our legitimate interests, we use tools that are technically absolutely required to provide our service through the App. For example, to recognize you when you visit us, to make your data available to you, to monitor incoming and outgoing payments or to ensure the security of our App. In the following, we provide you with more transparent details on each of our tools:
      1. We use the tool Firebase to monitor the security and safetiness of the app and be aware of potential problems that we may wish to fix, such as crashes. This also provides us with analytics and reporting in aggregated form. More information is available here: https://firebase.google.com/support/privacy.
      2. We use the RevenueCat tool to manage the in-app purchase functionality of the app. If you make an in-app purchase, RevenueCat will receive a receipt containing information about that purchase. RevenueCat does not receive or process your payment information, such as a credit card number. More information is available here: https://www.revenuecat.com/privacy.
      3. We use the tool Sentry to monitor the functionality of the app and track bugs and crashes in order to fix them more efficiently. This also provides us with analytics and reporting in aggregate. More information is available here: https://sentry.io/privacy/.
      4. We also use the tool Codepush from Microsoft to ensure the correct function of your app in case of updates. You can find more information about this here: https://www.microsoft.com/de-de/trustcenter/privacy/where-your-data-is-located.
      5. Appsflyer

        We use Appsflyer, an analysis service of AppsFlyer Inc. (111 New Montgomery St, San Francisco, CA 94105, United States) in our App. We use this tool, based on our legitimate interests, to measure the success of our marketing campaigns and improve them. To do this, the tool compares your activities (clicks and impressions) outside our app with the activities inside our app. To do this, the tool records installation- and post-installation events, using the device identifier based on your consent given to the relevant app store (GAID, ADID, IDFA, IP, UA).

        We do not process your personal data in this context at any time. We receive anonymous statistical evaluations from Appsflyer that show the overall, anonymized success rates of our marketing measures, only. The data is stored on a server of AppsFlyser Ltd. in Dublin, Ireland. Depending on the campaign the data is shared with Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. More information is available here: https://www.appsflyer.com/privacy-policy/.

        Google uses the advertising ID of the end device for this purpose. Google will use this information to evaluate the use of our App. More information is available here: https://firebase.google.com/support/privacy.

      6. Amplitude

        Based on your consent, we use Amplitude, an analysis service of Amplitude Inc. (501 2nd Street, Suite 100 San Francisco, CA 94107, United States) to analyse your user behaviour in our App. This data tells us how you interact with our App. When you open our App, information (device related data, such as device type, model operating system, browser type and version of Amplitude, device groups Usage-related information (such as geographical location, language, pages used) is gathered. The Privacy Policy of Amplitude can be found here: https://amplitude.com/privacy.

  4. Social Media Login
    1. You can log in to our app with your Facebook account. Facebook receives the data about your login behaviour in our app. You can find more information here: https://www.facebook.com/about/privacy/.
  5. Is your data transmitted to third parties?
    1. We entrust your personal data in the extent necessary to the following external service providers (data processors) that support us with the performance of our services:
      • IT-service providers and/or providers of data hosting solutions or similar services;
      • Other service providers, providers of tools and software solutions that support us with the download of our App, performance of our services as well and operate on our behalf (including providers of marketing tools, marketing agencies, communication service providers)
      All our data processors process your data only on our behalf and on the basis of our instructions so that we can provide you with our Online Services.
    2. Apart from that, we transmit your personal data in the extent necessary to the following recipients (controllers):
      • Potential third parties that are participating in the provision of services to you for the fulfilment of our contractual obligations (e.g. login-services, banks for processing of the payment, payment service providers);
      • External third parties on the basis of our legitimate interests in the extent necessary (e.g. auditors and tax consultants, insurances in case of insured events, legal representatives in case of incidents);
      • Authorities and other public entities in the extent legally necessary (e.g. financial authorities).
    3. If we process your data in a third country outside the European Union (EU), or respectively the European Economic Area (EEA) or this happens within the scope of using services of third parties, this only occurs, if necessary for the fulfilment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. We have implemented suitable and appropriate guarantees to develop a way of transmission of your data to the respective third country compliant with data protection (e.g. for the US through the "Privacy Shield" or the conclusion of so called "Standard Data Protection Clauses"). Upon your enquiry we can transmit a copy of those suitable guarantees to you, provided that we process or let your data be processed in third countries.
  6. Retention period
    1. We store your personal data just as long as necessary for the purposes for which they are processed. Beyond that, we are potentially obligated to store your data for longer in accordance to legal retention periods.
    2. Specifically, we store your data in connection with the establishment of contact with us in accordance with legal retention periods for a time period of usually seven years.
    3. Access data and log files are stored for a maximum time period of 500 days and are erased subsequently.
    4. We store data about your user behaviour for a time period of usually three years, or respectively at the latest until the withdrawal of your consent.
    5. Provided that you have only registered for our newsletter and are, apart from that, no client of us, we store your data until the withdrawal of your consent and beyond that for a maximum of three years.
    6. We store data in connection with your registration and your user account until the end of your client relationship with us, or respectively beyond that until the expiry of the respective legal retention periods (usually for a time period of seven years).
    7. Apart from that, we also store your personal data after an incident beyond the above mentioned time periods as long as legal claims out of the relationship between you and us can be enforced, or respectively until the definitive clarification of an incident or legal dispute. This longer storage occurs for the ensuring of our overriding legitimate interests to the enforcement, clarification and defence of our legal claims.
  7. Rights of Data Subjects
    1. You have the right to access your personal data that is being processed by us (Art 15 GDPR). Apart from that, you have the right to rectification of inaccurate or incomplete data and – under certain circumstances – the right to erasure (Art 16 and Art 17 GDPR). Additionally, you have the right to restriction of processing (Art 18 GDPR) as well as the right to data portability concerning the data you have provided us with (Art 20 GDPR).
    2. Moreover, you have the right to object on grounds relating to your particular situation (art 21 GDPR). Such an objection can in particular occur relating to processing of data for the purposes of direct marketing.
    3. Additionally, you have the right to withdraw your consent at any time with effect for the future.
    4. Finally, you have the right to lodge a complaint with the responsible supervisory authority (Art 77 GDPR). The responsible supervisory authority for Austria is the Österreichische Datenschutzbehörde, Barichgasse 40-42, 1030 Vienna (www.dsb.gv.at).
    5. If you have questions relating to this or any other questions, you can contact us at:

      Pocketcoach GmbH

      Kandlgasse 19-2,

      1070 Vienna,

      [email protected]

  8. Data security

    We comply with appropriate technical and organisational security measures pursuant to Art 32 GDPR to, considering the risks, guarantee an appropriate data protection level, especially to protect your personal data against accidental or unlawful destruction, alteration or against loss and against unauthorised disclosure or unauthorised access.

  9. Amendments of our Privacy Policy

    Within the course of internet development, we will amend our Privacy Policy regularly. We will disclose amendments in our App. Therefore, you should visit this Privacy Policy regularly to be informed about the current status.

Version: April 2020