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: [email protected]

 

This Privacy Policy was last modified on October 2, 2021.