Privacy Policy

This privacy policy informs you, pursuant to Art. 13 of Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”), about the processing of personal data in connection with the use of the Trace application (“the App”).

In principle: G&P Innovations GbR collects no personal data through the App, stores none on its own systems, and transmits none to third parties. The content you create remains on your device and, if you so choose, in your private iCloud.

1. Controller

The controller within the meaning of Art. 4(7) GDPR is G&P Innovations GbR (“we”), Torstraße 105, 10119 Berlin, Germany, represented by its partners Ben Grunden and Mark-Michael Portnow.

Email: kontakt@gp-innovations.de

These contact details also apply to data protection matters.

2. Data protection officer

No data protection officer has been appointed, as the conditions of Art. 37 GDPR in conjunction with § 38 BDSG are not met.

3. Content you create in the App

The App processes solely the content you enter yourself: the titles of your goals, your contributions, milestones and notes, together with the associated dates and timestamps.

This content is stored in a database on your device. No user account exists with us; there is no registration and no email address or password is requested.

Processing of this content is carried out by you alone, on your own device. Where you use the App exclusively for personal purposes, that processing falls outside the scope of the Regulation pursuant to Art. 2(2)(c) GDPR. We obtain no access to this content at any time.

4. Storage on your device

The App stores the aforementioned content, together with technically necessary settings, on your device. This storage is permissible without consent pursuant to § 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG), as it is strictly necessary in order to provide the digital service you have expressly requested. No storage takes place for analytics, advertising or audience measurement purposes.

5. Syncing through iCloud

If you are signed in to iCloud on your device and iCloud Drive is enabled, the App synchronises your content through the private iCloud database of your Apple Account.

This processing takes place on the basis of the contractual relationship between you and Apple Inc. or Apple Distribution International Ltd. In this respect Apple acts as an independent controller and not as a processor on our behalf; no data processing agreement pursuant to Art. 28 GDPR exists between us and Apple.

We have no access to the content held in your private iCloud database. We can neither view, export, restore, rectify nor erase it. Please note that processing by Apple may also take place in third countries, in particular the United States of America. Apple’s privacy terms are authoritative in that respect.

Syncing is optional. The App is fully usable without iCloud; only the exchange of data between several devices is unavailable.

6. In-app purchases

Trace Plus is unlocked exclusively through Apple’s in-app purchase system. The contracting party to the purchase, and responsibility for billing, management and cancellation, lies with Apple.

We receive from Apple no payment data, no billing address, no card details and no account data. The App checks solely on your device, locally, whether a valid entitlement exists.

7. Diagnostic and crash data

If you have consented in your device’s system settings to sharing analytics and diagnostic data with developers, Apple may make aggregated or pseudonymised crash and performance reports available to us. Those reports contain none of the content you have created. The legal basis is the consent you gave to Apple, which you may withdraw at any time with future effect in system settings.

8. No analytics, advertising or profiling

The App contains no analytics tooling, no advertising networks, no tracking technologies and no third-party software development kits for such purposes. No profiling takes place. No usage data is transmitted to us. No server operated by us holding content exists.

9. Recipients and categories of recipients

No transfer of personal data to third parties takes place on our part. Where you use iCloud syncing or the in-app purchase system, Apple is involved within the separate contractual relationships described in sections 5 and 6. Data is not sold.

10. Retention period

Your content is retained for as long as you keep it. Individual contributions, milestones and goals can be deleted in the App at any time. Uninstalling the App removes the locally stored data. Data held in iCloud can additionally be managed and deleted through your device’s system settings. As we store no data, no retention periods apply on our part.

11. Obligation to provide data

The provision of personal data to us is required neither by statute nor by contract. You are under no obligation to provide it; the App can be used without supplying any personal data.

12. Automated decision-making

No automated decision-making, including profiling, within the meaning of Art. 22(1) and (4) GDPR takes place.

13. Your rights as a data subject

You have the right, as against the controller, of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR), as well as the right to object to processing (Art. 21 GDPR).

Please note that we store no personal data about you and are therefore unable to provide information about, rectify or erase your content. That content is directly at your own disposal, within the App and through your device’s system settings.

14. Right to lodge a complaint

Without prejudice to any other remedy, you have the right under Art. 77 GDPR to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement.

15. Amendments to this privacy policy

This privacy policy will be revised where changes to the App or to the legal position so require. The version contained in the installed build of the App is the one that applies.