Any collection, processing and use (hereinafter “use”) of data is solely for the purpose of providing our services. The services of Kinematics GmbH have been designed to use as little personal information as possible. For that matter, “personal data” is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called “affected person”).
The following statements on data protection describe what types of data are collected when using our Apps „Tinkerbots Blockly“, „Tinkerbots World“ and „My First Robot App“, what happens with these data and how you may object to data usage.
Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:
Kinematics GmbH
Address: Spreeallee 2
16321 Bernau
Telephone: +49 (0) 3023546440
Email: hello@tinkerbots.com
Homepage: https://www.tinkerbots.de/
We have taken technical and organizational measures to ensure that the requirements of the GDPR are met.
When working with other companies to provide our services, we do so only after a comprehensive selection process. During selection, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection process will be documented in writing and a contract Art. 28 para. 3 GDPR on the processing of personal data on behalf of a contract (Data Processing Agreement) is only concluded if it complies with the requirements of Art. 28 GDPR.
Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons.
We would like to emphasize the protection of the data of underage users within the meaning of the GDPR and the US Children’s Privacy Protection Act. Please note that for this protection, consent must be given to the processing of data of minors under the age of 16 by the parents. We urge parents to monitor the use of all digital media by their children.
We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.
Our apps “Tinkerbots Blockly”, “Tinkerbots World” and “My First Robot App” are completely offline.
There is a robot firmware download from one of our servers (http://firmware.tinkerbots.com/) to the tablet / smartphone that has one of the three apps installed. However, this only becomes active if the tablet / smartphone is connected to the internet. No user data is sent to this server but only the existing firmware version is requested and then possibly initiated a firmware download.
Our apps do not collect any user data. A forwarding to third parties does not take place.
We point out that when using the Android version of our apps, the so-called “Fine Location Permission” can be requested by the user.
This is one of the confidential Android permissions. This permission must be given by the user to enable the respective Android app to scan for Bluetooth Low Energy devices (the Tinkerbots robots). This scan is necessary for our customers to connect their tablet / smartphone to their Tinkerbots robot.
This authorization request is displayed graphically within the respective Tinkerbot app with a system dialog and must be issued / confirmed by the user. This is a security feature from Google. This authorizes a Bluetooth scan to determine the approximate user location.
We do not use this permission to determine the approximate location of the user but only for the Bluetooth scan.
However, it is possible for Google to process this data.
The possible data processing for the European Economic Area and for Switzerland
is carried out by:
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google’s Privacy Policy can be found at https://www.google.com/policies/privacy/.
The processing of these data is based on Art. 6 para. 1 p. 1 lit. a) GDPR.
The processing of data by Google is for the purpose of enabling the use of the app. It serves the system security with Google.
The personal data will be deleted, according to Google, as soon as they are no longer necessary for the above purposes.
The collection of data for the provision of the app (Android) is intended for the operation of the app by Google as a security feature. For privacy issues, you can contact Google using the following contact form: https://www.google.com/contact/.
Via our app it is possible to contact us via e-mail (support@tinkerbots.com). This will require different data to answer the request, which will be automatically saved for processing.
A transfer of the data to third parties does not take place.
Your data will not be passed on to third parties, unless you have given your consent.
The legal basis depends on what the reason for your request is: Therefor data processing will be based on Art. 6 para. 1 s. 1 lit. a) GDPR or Art. 6 para. 1 s. 1 lit. b) GDPR.
The processing of personal data from the input form is used solely handling the contact request.
The data will be deleted as soon as we answer your request. There might occur rare cases when legal or contractual retention periods interfere with the erasure of your personal data. In this case your data will be deleted after these periods.
The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.
Via our app it is possible to contact us via e-mail.
The e-mail provider we use is Domain Factory:
domainfactory GmbH, Oskar-Messter-Str. 33, 85737 Ismaning, Germany.
A transfer of the data to third parties does not take place.
For more information about Domain Factory data protection, please see the following link:
https://www.df.eu/de/datenschutz/
The legal basis used here is Art. 6 para. 1 p. 1 lit. f) GDPR. Our legitimate interest is to allow contact via email with the app users.
The data will be processed to forward your contact request to us.
Your data will be deleted as soon as the purpose of the data processing has been fulfilled and no legal, official or contractual retention periods preclude a deletion. This is the case regularly after 25 days.
The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.
When contacting us via e-mail, personal data is collected. These data are stored on our behalf via the ticket system Zendesk, a customer service platform, to be used by us.
The ticket system we use is:
Zendesk Inc. 989 Market Street # 300, San Francisco, CA 94102, United States.
The following data can be transmitted:
For more information about privacy at Zendesk, please visit the following link: https://www.zendesk.com/company/customers-partners/privacy-policy/
The legal basis for data processing is Art. 6 para. 1 p. 1 lit. f) GDPR. Our legitimate interest lies in the internal organization and structuring of customer transactions.
The purpose of the data processing is to answer your request and the associated technical administration of storage and use.
The data will be deleted, provided that no official, legal or contractual regulations preclude deletion. This is done regularly after …. days / months / years.
If you want to exercise your rights, especially the right to object, you can contact us. For privacy issues with Zendesk, contact Zendesk at the following email address: privacy@zendesk.com.
In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each – carefully selected – service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR). Below you may find our categories of processors, the country they are located at and the safeguards or guarantees they provide:
We use the support of the following providers:
EU-US Privacy Shield: The Privacy Shield is an agreement between the United States of America and the European Union to ensure compliance with European privacy standards. For more information, see:
Google, Android-Play Store, USA, member of the EU-US Privacy Shield:
Zendesk, service provider, USA, member of EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG
EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see:
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF
Zendesk, service provider, USA, EU standard contract clauses
Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR. Further information can be found here:
Zendesk, service provider, USA, binding corporate rules: https://d1eipm3vz40hy0.cloudfront.net/pdf/ZENDESK%20-%20BCR%20Processor%20Policy.pdf
You have the following rights with respect to the personal data concerning you:
If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.
You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:
In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.
You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.
You may also request the erasure of your personal data if any of the following applies to you:
Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
These rights shall not apply to the extent that processing is necessary:
You shall have the right to obtain from us restriction of processing where one of the following applies:
Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.
If you have asserted us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.
You also have the right to know which recipients have received your personal data.
You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where
the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and
the processing is carried out by automated means.
In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.
Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).
In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.
The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.
To exercise these rights, please contact:
Kinematics GmbH
Address:
Spreeallee 2
16321 Bernau
Telephone: +49 (0) 3023546440
Email: hello@tinkerbots.com
Homepage: https://www.tinkerbots.de/
We reserve the right to change this privacy policy in compliance with legal requirements.
August 2019
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