This privacy notice informs you about how we treat your data. To make the processing of your data transparent, we would like to provide you with the following information to give you an overview of these processing operations. To keep things fair, we additionally want to inform you about your rights pursuant to the EU-General Data Protection Regulation (GDPR).

Table of contents

• 1. General Information ................................................................................................................................................... 1
• a. Contact ....................................................................................................................................................................... 1
• b. Representative in the EU ............................................................................................................................................ 1
• c. Legal Basis .................................................................................................................................................................. 2
• d. Period of Storage ....................................................................................................................................................... 2
• e. Recipients of data ....................................................................................................................................................... 2

• 2. Registration, login and use ......................................................................................................................................... 2
• 3. Google Firebase ......................................................................................................................................................... 3
• 4. Matomo ...................................................................................................................................................................... 4
• 5. Processing in the exercise of your rights .................................................................................................................... 5
• 6. Your Rights .................................................................................................................................................................. 5
• 7. Right of Objection ...................................................................................................................................................... 5
• 8. Subscriptions Automatically Renew Until You Cancel & How to Cancel Your Subscription ....................................... 5

1.    General Information

a.     Contact

TLEX GmbH is the controller of the data processing (hereinafter referred to as ‘we’ or ‘us’). If you have any questions or feedback concerning this information or wish to contact us to exercise your rights, please send your enquiry to

TLEX GmbH
Address: Renggstr. 33, 6052 Hergiswil NW, Schweiz

E-Mail: europe@tlexinstitute.com

The European Commission has the power to determine, on the basis of article 45 GDPR whether a country outside the EU offers an adequate level of data protection. The European Commission has so far recognised Switzerland as providing adequate protection (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32000D0518).   

b.    Representative

You can also contact our representative in the European Union in accordance with Art. 27 GDPR:

Vanessa Eble

E-Mail: v.eble@tlexinstitute.com

c.     Legal Basis

When using this app, personal data may be processed. The term "personal data" under GDPR refers to all information relating to a specific or identifiable person. The IP address or a device ID can also be personal data. An IP address is assigned to each Internet-connected device by the Internet provider so that it can send and receive data. When you use the App, we collect information that you provide yourself.  In addition, certain information is automatically collected by using the app.

We process personal data in compliance with the data protection regulations of the GDPR and the Swiss DSG. We solely process data based on law. When you use this app, we process personal data to the extent necessary to fulfill a contract of use to which you are a party or to take steps at your request prior to entering into a contract (Art. 6 section 1 letter b GDPR), or when the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, outweigh (Art. 6 section 1 letter f GDPR). In addition, processing operations may be carried out with your consent (Art. 6 section 1 letter a GDPR) or to comply a legal obligation (Art. 6 section 1 letter c) GDPR).

d.    Period of Storage

Unless otherwise stated in the following, we will only store your data for as long as required to achieve the intended processing purpose or to fulfil our contractual or statutory obligations. The storage is therefore at least for the duration of our contractual relationship. We delete the data about you when you cancel your account. Further requirements may result from regulations under commercial or tax law.

e.    Recipients of Data

We use processors as part of the processing of your data. Processing operations performed by such processors include hosting, maintenance and support of IT systems, customer and order management, order processing, accounting and billing, and marketing measures. A processor is a natural or legal person, authority, body or other entity that processes personal data on behalf of the data controller. Processors do not use the data for their own purposes but carry out the data processing exclusively for the controller and are contractually obliged to guarantee appropriate technical and organizational measures for data protection. In addition, we may transfer your personal data to bodies such as payment services, tax advisors/auditors or the tax administration.

Unless otherwise stated in the following notices, the data will be processed on systems of technical service providers hosted in the EU, the EEA or Switzerland.

For the further development of our app we use a processor from Argentina. The European Commission has the power to determine, on the basis of article 45 of Regulation (EU) 2016/679 whether a country outside the EU offers an adequate level of data protection. The European Commission has so far recognised Argentina as providing adequate protection (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32003D0490).

2.    Registration, login and use

Registration is required to use the app's features. The required information can be seen in the registration form. Providing the information is mandatory for the registration to be completed. If you are logged in via your account, we will also process additional data about your interaction with our offer, such as your challenges and your progress. The data provided will be processed for the purpose of providing the service. The processing is based on the legal basis of Article 6 sec. 1) letter b) GDPR.

3.    Google Firebase

To offer you our services, we use a real-time database of Google Firebase hosted in Germany and related functions and services of Google Ireland Limited (Ireland/EU). Google Firebase is a platform for developers of apps for mobile devices and websites. The functions include, but are not only, the storage of apps including personal data of the users, such as content created by them or information about interaction with the apps. Google Firebase also offers features that enable better user guidance, communication with users, optimization of performance or evaluation of crash causes in the apps. Google Ireland Limited processes personal data of our users on our behalf and only in accordance with our instructions.

Google Ireland Limited is a subsidiary of Google LLC (USA), which means that data transfer to the United States cannot be ruled out. Google LLC is certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield and therefore offers an adequate level of data protection in accordance with Article 45 GDPR: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

An app instance ID is used to identify individual devices, which is generated on app installation on the end devices. It is used as part of the respective functions for assigning the terminal device. If we delete the app instance ID in Firebase, the data will be removed from the live and backup systems within 180 days.

On the iOS operating system the iOS advertising ID to identify the device. If the iOS advertising ID is not available, the manufacturer ID is used. If the iOS advertising ID becomes available after the manufacturer ID is used, the manufacturer ID usage is stopped and instead the iOS advertising ID will be used. On the Android operating system the Android advertising ID is used. If this is not possible, the hardware ID of the device, such as the Android ID (SSAID), is captured instead.

By default, mobile IDs (such as the Android or iOS advertising ID) are collected through Firebase using technologies that work similarly to cookies. In the device settings, you can restrict the use of the advertising ID (iOS: Privacy/ Advertising/ No Ad Tracking; Android: Account/ Google/ Ads).

We use the following Firebase features in our app:

Firebase Crash Reporting: The function is used to aid stability and to improve the app. In the event of an app crash, information about the device used and the use of our app (e.g. the timestamp when the app was launched and when the crash occurred) is collected, allowing us to diagnose and resolve problems. It uses the app instance ID to measure the number of users affected by a crash. Data on the crash will be kept for 180 days. The processing serves our legitimate interest to ensure stable operation of the app and to avoid crashes. For more information on how Crashlytics works, please visit https://firebase.google.com/products/crashlytics/

Firebase Remote Config: The feature allows us to configure app settings so that we can modify the app on the devices on which it is installed without having to completely reinstall it from the app store each time it is changed. For this purpose, the device information, language settings and regional settings are transferred to Google in the USA and processed there. The app instance ID is used to select configuration values and return to the endpoints. The processing serves our legitimate interest to be able to make practical configurations on the app. For more information about how Remote Config works, see: https://firebase.google.com/products/remote-config/

Firebase Cloud Messaging: The function is used to deliver push messages or so-called in-app messages (messages that are only displayed within the app). A pseudonymized push reference is assigned to the mobile device via the app instance ID, which serves as a target for push messages or in-app messages. The push messages can be deactivated and activated again at any time in the settings of the mobile device. The processing serves our legitimate interest to be able to contact our users in a simple way. For more information about how cloud messaging works, click https://firebase.google.com/products/cloud-messaging/

Firebase Performing Monitoring: The function enables the analysis of the operating and performance characteristics of our apps. The feature collects information about the operation and performance of our apps, transmits them to Google and stores them there. The pseudonymous app instance ID is used to identify the device. For this purpose, general device information such as model, operating system and orientation and data about so-called performance events are collected. In addition, the IP addresses are used to map performance events to specific countries from which they originate. For an overview of data collection by the Firebase Performing Monitoring function, see https://support.google.com/firebase/answer/6318039#perfmon. Events associated with the app instance ID and IP address are stored for 30 days and the rest of the performance data for 90 days. Google will use this data on our behalf to evaluate the performance of our app offering and to provide us with reports and information about the operation and performance of our app. The processing serves our legitimate interest in the analysis of the performance of our app and the thus made possible technical optimization of our offer. For more information on how Firebase Performing Monitoring works, please visit:  https://firebase.google.com/products/performance/

For more information, see Firebase's Privacy Policy at https://www.firebase.com/terms/privacy-policy.html.

In the app, tracking of all Firebase services for the future can be prevented by setting the slide switch accordingly.

4.    Matomo

We analyze of the user's interactions by using the analysis service Matomo. Matomo is an open source software that operates on servers managed by us. The service allows an analysis of the use of our app offering. For this purpose, information about the use of our app is collected via so-called Software Development Kits (SDK), transmitted to our Matomo server and stored. For the identification of the end device pseudonymous IDs are used. For this purpose, additional usage data such as the number of users and sessions, the duration of the session and data about actions taken are collected in the app.

Further processing of personal data does not take place when using Matomo. The information about your use of this app will not be used for personal evaluation or profiling and will not be passed on to third parties.

This processing takes place only with your consent on the legal basis of Art. 6 sec. 1) letter f) GDPR. You can revoke your consent by going tot he settings section in the app and press on “opt-out” from user analytics.

5.    Processing in the Exercise of your Rights

If you exercise your rights pursuant to Art. 15 to 22 GDPR, we process the personal data transferred for us to grant you your rights and to acquire proof thereof. To providing information and preparing such information, we will process the stored data only for this purpose as well as for purposes of data protection control and otherwise restrict processing in accordance with Art. 18 GDPR. These processing operations are based on Art. 6 section 1 letter c) GDPR in combination with Art. 15 to 22 GDPR.

6.    Your Rights

As the data subject, you are entitled to exercise your rights against us. In particular, you have the following rights:

• Pursuant to Art. 15 GDPR, you have the right of access to information confirming whether and, if so, to what extent we are processing personal data concerning you.
• Pursuant to Art. 16 GDPR, you have the right to rectification of your data.
• Pursuant to Art. 17 GDPR, you have the right to erasure of your personal data.
• Pursuant to Art. 18 GDPR, you have the right to require us to restrict the processing of your personal data.
• Pursuant to Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transfer such data to another controller.
• Where you have granted us specific consent to a processing activity, you can withdraw such consent at any time pursuant to Art. 7 section 3 GDPR. Any such withdrawal of consent shall not affect the lawfulness of processing based on that consent prior to its withdrawal.
• If you are of the view that the processing of your personal data infringes GDPR provisions, you have the right to lodge a complaint with a supervisory authority pursuant to Art.77 GDPR.

7.    Right to Object

Pursuant to Art. 21 section 1 GDPR, you have the right to object to processing activities based on Art. 6 section 1 letter e) or letter f) GDPR on grounds relating to your particular situation. If we process your personal data for the purpose of direct marketing, you may object to such processing pursuant to Art. 21 section 2 and section 3 GDPR.

8.    Subscriptions Automatically Renew Until You Cancel & How to Cancel Your Subscription

All amounts are payable and charged: (i) for one-off purchase (e.g. lifetime Subscription), at the time you place your order; and (i) For monthly or yearly subscriptions, at the beginning of the subscription and, because each such subscription renews automatically for an additional period equal in length to the expiring subscription term until you cancel it, at the time of each renewal until you cancel. You must cancel your monthly or yearly Subscription before it renews to avoid the billing of the fees for the next Subscription period. If you purchase your Subscription via the Site, you can cancel the renewal of your subscription at any time by contacting us by email at app@tlexinstitute.com. If you purchase your Subscription via an App Provider, you can cancel the renewal of your subscription with the App Provider. You will not receive a refund for the fees you already paid for your current subscription period and you will continue to receive the Services ordered until the end of your current Subscription period.