CrewLine App Privacy Policy
GENERAL
This is the privacy policy for CrewLine
App (“App”). The App is a free to
use service provided through the Google Android Playstore
which functions as a toolkit for calling up duty rosters, confirming
notifications, archiving of old rosters etc. We value the privacy and data rights of all
the App Users (“You, your”) and therefore to affirm our commitment of
protecting the privacy of our users and to make our users completely informed
about the various data rights that they have, we have created this Privacy
Policy (the "Privacy Policy"). Your privacy is very important
to us, and we take it very seriously.
This Privacy Policy explains in detail how we collect, use and process
information that we may get through your usage of the App. Please read our Privacy Policy below and let
us know if you have any questions or other feedback regarding it through the
Contact Us section of this Privacy Policy.
By continuing the use of our App, you acknowledge that you
have had the chance to review and read through this Privacy Policy and your
usage shall be taken as your consenting to the terms and conditions mentioned
herein in totality. If you do not agree to any terms as present in this Privacy
Policy, You must stop usage of this App immediately.
Article 1: Interpretation
& Definitions
The words of which the initial letter is capitalized shall have the
meanings defined hereinunder Article 1 of the Privacy Policy. The following
definitions shall have the same meaning regardless of whether they appear in
singular or in plural. For the purposes of this Privacy Policy the following
terms are defined as follows:
a)
“App” shall be taken to mean only the CrewLine
App, downloaded by You on any electronic device. The App to which this Privacy
Policy pertains to is available at the hyperlink:<https://play.google.com/store/apps/details?id=de.homgsa.crewline&hl=de&gl=US> is also available at the Apple Appstore with the same name;
b)
“App
User/You” shall be taken to mean the
individual accessing or using the Service being provided through the App, or
the company, or other legal entity on behalf of which such individual is
accessing or using the App and its Services, as applicable. App User/You shall
be the Data Subject as enumerated under the GDPR;
c)
“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;
d)
“Device” means any device that the App User uses to access the App or
the Website such as a computer, a cellphone or a digital tablet;
e)
“Data
Controller”, shall be taken to mean the natural
person who is the publisher, owner and operator of the App and is the Party
responsible for the collection of information described herein, which alone or
jointly with others determines the purposes and means of the processing of
Personal Data the pronouns used for the same is (“Us, We, Our”);
f)
“Effective
Date” shall be taken to mean the date this Privacy
Policy comes into effect;
g)
“GDPR”
shall mean the General Data Protection
Regulation or Regulation (EU) 2016/679;
h)
“Parties”
The Parties to this Privacy Policy are the Data Controller and the App User, as the user of this App. Hereinafter, the
parties will individually be referred to as “Party” and collectively as
“Parties”;
i)
“Personal
Data” means any information relating to an identified or identifiable
natural person (“Data Subject”); an identifiable natural person is one who can be identified,
directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person , this
definition is same as provided under Article 4 (1) of the GDPR;
j)
“Processing” means any
operation or set of operations which is performed on personal data or on sets
of personal data, whether or not by automated means, such as collection,
recording, organization, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or
destruction, this definition is same as provided under Article 4(2) of the
GDPR;
k)
“Service” refers to all the functions provided by either the App or the
Website or both including but not limited to calling up duty rosters, archiving
old rosters etc;
l)
“Service
Provider” means any natural or legal person
who processes the data on behalf of the App. It refers to any third-party
companies or individuals employed by the App to facilitate the Service, to
provide the Service on behalf of the App, to perform services related to the
Service or to assist the App in analyzing how the Service is used. For the
purpose of the GDPR, Service Providers are considered Data Processors.
m)
“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);
n)
“Website”
shall mean to be the url
which shall host the website of the App mentioned herein, accessible at https://homgsa.de/crewline/;
Article 2: Information that we collect from App User/You
The App in its present form and as on the Effective Date DOES NOT collect any Personal
Information like name, phone number, address, location, child's name etc., from
the App Users. If we do happen to inadvertently obtain any personal
information, including emails or phone numbers obtained through support
requests or other correspondence, it will be treated with the strictest
confidentiality and deleted at the earliest. Any such personal information will
never be shared with any other entities. Any such personal information will NEVER
be retained. We will delete the login data anytime on your request. The App
also DOES NOT retain or store any Usage Data.
Like all websites and other mobile
applications, we also make use of log files that store some automatic
information when an App User visits our App or Website. The different type of
log data can include -Internet Protocol (IP) address, type of browser and
device parameters used to connect to the APP or Website, date and time of visit
and possibly web page origin of App User and number of clicks. This Log data is
never shared with any third party. However, the App User has the discretion to send
the Log data to the Data Controller’s server as and when demanded. The App uses
a server located at dienstplankonverter.de only to read and parse
the duty plan pdf to extract the duties and times from the duty plan and sync it
with the duties of the App User in their local calendar. This information is
processed according to the legitimate interests of the Data Controller as per
the GDPR. For security purposes, the spam filters and virus detection may
automatically include Personal Data such as IP address which could be used in
accordance with the applicable laws in order to block attempts at damage to the
Website or damage to other App Users or in the case to prevent harmful activities
or crime. Such data shall never be used for identification or profiling of the
App User but only for the protection of the App, Website and the App Users
which make the processing of such data, as a legitimate interest of the Data
Controller.
Article 3:
Purpose of Processing of collected data
The sole
purpose of processing of any collected data is to provide the Services of the
App or the Website to the App User. As enumerated before we do not process any
Personal Information of Usage Data of the App User, barring for what is
automatically collected for the security and maintenance purpose of the App.
Any collected data by the App is collected under the legitimate interests of
the Data Controller.
Article 4: Data Protection Procedure
In view of the prevailing Cybersecurity environment, the App
has implemented reasonable physical, technical and administrative security
measures to protect information from loss, misuse, alteration or destruction.
However, since no method of transmission over the Internet,
or method of electronic storage is 100% secure, there might be a very small
chance that the nonspecific information collected by us may be compromised, if
you believe that any data has been compromised, please contact us as set forth
in the Contact us section. If we learn of a security systems breach, we will
inform you and the authorities of the occurrence of the breach in accordance
with applicable law.
All
information you provide to us is stored on our secure servers or your Airline’s
servers. Where we have given you (or where you have chosen) a password that
enables you to access the App, you are responsible for keeping this password
confidential. We ask you not to share a password with anyone and not to share
your mobile device with anyone. You are responsible for logging off the
services at the end of a transaction and we remind you not to leave your device
accessible to anyone when you are logged on to the services, for in the event
you do so and your data is accessed this will be your sole responsibility. It
is reiterated that we have put in place appropriate security measures to
prevent your personal data from being accidentally lost, used or accessed in an
unauthorized way or improperly altered or disclosed.
Article 5:
Data Processing Location
The App does
all of its processing operations only in the territory of the European Union
and the European Economic Area as on the Effective Date of this Privacy Policy,
if there is any change to this arrangement in the future, the App shall take
into consideration and implement all such steps necessary and obligated by law
to transfer the data to any third country outside the EU with appropriate
technical safeguards as necessitated by the applicable law. As on the Effective
Date only some analytics specific data may be processed outside the union as
per the procedure mentioned in Article 6.
Article 6: Advertising & Analytics
There is no advertisement shown in the
App and therefore no data is shared with any third party for this purpose. If
there is any change in the decision to have advertisement in the App, then the
Privacy Policy shall be updated to accommodate the same. App Users are thereby
advised to keep abreast of any change or update in the Privacy Policy of the
App.
The App uses third party services for
the purposes of crash analytics and analytics to understand the pattern of App
usage and crashes only. The App shall not be sharing any Personal Information for
the same other than the ones mentioned in Article 2. The Service Providers
shall be only helping the App to track some Usage data such as dates and times
of requests, and App crash data etc. For the time being, the App shall be using
the services of “Sentry.io” and “Google Analytics” to provide the support for
crash analytics and analytics for improving App Services. The Data Controller
shall enter into appropriate Data Processing Agreements with the Service
Providers since some of the data collected may be processed outside the
European Union. The Data Processing Agreement shall take into consideration the
new Standard Contractual Clauses approved by the European Commission so as to
conform to the standards set for international transfers of data as per the
procedure and safeguards provided for the same under the GDPR.
Article 7: Social Media
The App does not interact with any
social media sites. The App also does not support any plugin for signing in
with any prevailing Social Media apps in the market.
Article 8: Use and Disclosure of Your
Information
The anonymous data that we get for
analytics purposes is visible only to our developer team and is strictly for
internal analysis to make your app-experience better over time. The usage of
such data is only to improve the app and is never shared with any third party.
If any data is asked to be shared for fulfillment of legal obligations of the
Data Controller or to bring legal action against any App User for violation of
any law, such exceptions shall be made according to the applicable laws.
Article 9: Data Subjects Rights
The "GDPR" gives certain rights to
individuals in relation to their personal data. Accordingly, we are happy to
explain these rights so as to help you take advantage of those rights. As
available and except as limited under applicable law, the rights afforded to
individuals are:
·
Right of
access - the right to be informed of, and request access to, the personal data
we process about you;
·
Right to
rectification - the right to request that we amend or update your personal data
where it is inaccurate or incomplete;
·
Right to
erasure - the right to request that we delete your personal data;
·
Right to
restrict - the right to request that we temporarily or permanently stop
processing all or some of your personal data;
·
Right to
object -
o
the right,
at any time, to object to us processing your personal data on grounds relating
to your particular situation;
o
the right to
object to your personal data being processed for direct marketing purposes;
·
Right to
data portability - the right to request a copy of your personal data in
electronic format and the right to transmit that personal data for use in
another party's service; and
·
Right not to
be subject to automated decision-making - the right to not be subject to a
decision based solely on automated decision making, including profiling, where
the decision would have a legal effect on you or produce a similarly
significant effect.
To exercise any of these specific
rights, you can get in touch with us using the details set out below in the
Contact Us section. If you have unresolved concerns, you have the right to
report them to an EU or other data protection authority where you live, work or
where you believe a potential violation may have occurred
Article 10: Changes to Privacy Policy
We reserve the right to modify our
Privacy Policy at any time simply by posting such modification on this site and
without any other notification. Any such modification will be effective
immediately upon posting on this site. The use of the information we collect is
always subject to the Privacy Policy that is in effect at the time when this
information is collected. You are advised to refer to the Privacy Policy from
time to time so that you are always in sync with our current privacy practices.
Article 11: Contact Us and Data
Protection Officer
The Data Controller and the operator of the App and Website
are one and the same and therefore the following person shall be the Data
Protection Officer for the purposes of exercising any rights under this Privacy
Policy.
If there are any questions regarding this privacy policy,
you may contact us or the Data Protection Officer using the information below:
-
Data Protection Officer: Marius Hoppmann
Address: Freundstr. 5
42579 Heiligenhaus,
Germany
Email Id: crewline@homgsa.de
This Privacy Policy was last modified
on October 2, 2021.