Last Updated: Mar 17, 2022

### General information

The protection of your personal data when using our app is important to us. Here you can find out what data is collected and used. This data protection declaration informs you about the type, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our application and the services, functions and content connected with it.

Personal data is any data with which you can be personally identified. Regarding the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).



### Exclusion

We cannot accept any liability for links to external content or services.



### Contact details of the responsible

The provider of the application and responsible for data protection is:

l3montree UG (haftungsbeschränkt).
Managing directors: Tim Bastin & Sebastian Kawelke
Professor-Neu-Allee 1
53225 Bonn
Germany

You can contact our data protection officer at the following e-mail address: [datenschutz@l3montree.com](mailto:datenschutz@l3montree.com)

Statutory data protection officer:

Sebastian Kawelke
Professor-Neu-Allee 1,
53225 Bonn
Germany


### Data collection when using our app

When using our app, data inevitably accumulates that must be stored or processed to be able to offer the basic functions of the app at all. We do not analyse or process your user behaviour or data for advertising purposes.

When we collect data, it is so-called usage, meta, and communication data. When you use our app (e.g., open it without registering), there is data that our IT systems have to process automatically (e.g., IP address and port of the connection). This mainly technical data is only processed by us during the connection, but is generally not stored for a longer period of time.

In the following, we explain which data we collect, process and possibly also store for a longer period of time.

#### Types of data maybe collected - overview:

- Basic/ personal data (e.g., Wallet-ID)
- Contact data (e.g., e-mail when contacting us)
- Content data (e.g., text entries, name changes of the koi)
- Meta/communication data (e.g., IP address, device information)

#### Reasons for collection - overview:

- Providing our offer, functions, and content.
- Responding to contact requests and communicating with users
- Security measures 
- Improvement of our offers


#### Indirect data collection (server logs)

In addition to the data processed during specific operation or processing, our servers may collect and store so-called server log files. However, only accesses that are not legitimate, i.e., do not represent normal use of our service, are stored for longer. This is done to avert danger and to ensure the IT security of our systems.

**Specifically, such data could be**

- Operating system used
- App version used
- date and time of the server request
- IPv4 address and subnet, IPv6 address and prefix

This data is not merged with other data sources.

The collection of this technical data is absolutely necessary for the provision of our app and for the operation of the offer, so that you as a user have no possibility to object. Of course, this does not affect your right of inspection or deletion (see “Your rights”).

The legal basis for the collection of this data and its storage in log files is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest here is to ensure the smooth operation of our offer, to provide you with a good experience with our product.



### Collection of personal data when using our app

In addition to the technical data mentioned above, we collect so-called inventory, content and contact data. This data includes all data that you generate and store yourself as a user. For example, your Wallet-ID when connecting it or the data representing your entries (like a custom name for your koi).

When using our service, the following data is collected by us:

- A unique randomly generated ID, stored on your device and our servers to identify you (deleted, when the app is deleted, not the unique device ID).
- Your Wallet-ID, if you connect your existing wallet to our app.
- The custom name of your koi. You agree that you noticed that the name of your koi is publicly visible in the leaderboard of the app.
- Your name you have entered during registration.
- Your E-Mail-Adress your have entered during registration.

We only use this data to provide our service. Your E-Mail is used as a way of contact if necessary (e.g. inform you about changes of terms or technical maintanence). This data is not used for any other purpose. In particular, it will not be used for advertising or similar purposes.

As a matter of principle, all data that is no longer necessary for the fulfilment of our tasks is deleted at regular intervals.

The basis for data processing is Art. 6 para. 1 lit. b DSGVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.



#### Push notifications

If you want to use (Android) or agree (iOS) to the option of receiving so-called push notifications, you must give us permission to do so (request by the operating system during initial installation, iOS only). Notifications can be subsequently activated or deactivated in the app settings. We use the services Firebase Cloud Messaging by Google for push notifications. In order to be able to deliver the notifications correctly, Apple and Firebase generate keys which are made up of the identifier of your device and the identifier of the app. These are stored with us and linked to your individual notification settings. Firebase and Apple always serve as transmitters, but do not receive any information about the content of the requests or notifications.

We only store and process this data in order to be able to offer you the benefits of push notifications. We cite Art. 6 (1) (f) DSGVO and Art. 6 (1) (b) DSGVO as the legal basis for this.



#### Code Push

In order to send you technically necessary updates as quickly as possible, e.g. if a basic functionality of the app does not work or there is a security problem, we use the Code Push service from Microsoft. This will automatically update your app in the background and you can use the app as usual. To use this service, we need to send your device ID and the version of the app to Microsoft. We do not pass on other data such as your email address. Information on the purpose, scope, type and use of your data by the operator of the service can be found at the following address:

[Microsoft](https://privacy.microsoft.com/en-us/privacystatement)

We only pass on this data to this third party in order to be able to offer you a good experience with our product and to be able to guarantee smooth operation. We cite Art. 6 (1) lit. f DSGVO and Art. 6 (1) lit. b DSGVO as the legal basis for this.

#### Usage and diagnostic data

If you have agreed to the collection and transmission of usage and diagnostic data such as crash reports, certain data will be sent to Apple or Google. We receive this data in an anonymised and aggregated form, which does not allow us to identify individuals. 

We only use this data to improve our app, features and services.

**Apple**: Information collected may include hardware, operating system, speed statistics, and device and app usage ([Apple Privacy](https://www.apple.com/privacy/approach-to-privacy/)). Apple's collection of usage and diagnostic data applies device-wide. You can opt out at any time: [Apple Support](https://support.apple.com/en-us/HT202100)

**Google**: Google collects information such as battery level, frequency of use of your apps, quality and duration of your network connections (mobile, Wi-Fi and Bluetooth). The setting for whether you want to send usage and diagnostic data to Google applies device-wide. You can change it at any time: [Google Support](https://support.google.com/accounts/answer/6078260?hl=de)

In addition to the collection of diagnostic data by Google or Apple, we use the Sentry service - which we run ourselves on our servers (no data is sent to Sentry). Sentry is a service that helps us to detect serious and critical errors in the app (e.g. errors that cause the app to crash). To do this, your device may send error messages in the background to our Sentry instance. We only use these error messages to improve the app. These error messages contain data that could possibly be associated with you, such as your app version, information about your device (e.g. Android version) and a unique anonymised ID (usage data such as your name or your registered times are never transmitted). Before a message is sent, we remove your email address and IP address from the message.

We collect this data only to be able to offer you a good experience with our product and to ensure smooth operation. The legal basis for this is Article 6 (1) (a) DSGVO and Article 6 (1) (b) DSGVO.

#### Contact by e-mail

When you contact us, e.g. by e-mail, we record your contact data until the reason for the contact loses its relevance and, for example, a reply from our side is no longer necessary. Of course, this does not affect your right of access or deletion (see "Your rights"). When contacting us by e-mail, please note that the confidentiality of e-mails or other electronic forms of communication on the internet cannot be guaranteed. For confidential information, we recommend contacting us in encrypted form (info@l3montree.com) or by post.

#### Contact via WhatsApp

In order to contact us via WhatsApp, you must be registered with WhatsApp and have agreed to the [Privacy Policy](https://www.whatsapp.com/legal/updates/privacy-policy/?lang=de) of WhatsApp. We ask you to contact us by email if possible, as WhatsApp is not safe from a privacy perspective. We are available via WhatsApp because we want to offer you an easy and convenient way to contact us. We use the WhatsApp service under the following conditions: https://www.whatsapp.com/legal/business-data-processing-terms-20210927 

#### Contact via Telegram

To contact us via Telegram, you must be registered with Telegram and have agreed to Telegram's [Privacy Policy](https://telegram.org/privacy?setln=de). We ask you to contact us by email if possible, as Telegram is not secure from a privacy perspective. We are reachable via Telegram because we want to offer you an easy and comfortable way to contact us.



### How we protect your data

This app uses TLS encryption for security reasons and to protect the transmission of confidential content, such as requests you send to our server. This procedure is implemented for all communication between the app and our servers.

If TLS encryption is activated, the data that you transmit to us cannot be read by third parties.

In addition to encryption during transmission, we also protect your data on our servers using current procedures.

Furthermore, our employees are also obliged to maintain the confidentiality of your data.

Even though we use all available security mechanisms, we would like to point out that data transmission on the Internet can have security gaps. Complete protection of data against access by third parties is not possible.



### Your rights

##### Revocation of your consent to data processing

By using our offer, you agree to the processing of the data collected for the provision of the offer. You have no direct right of objection here. However, you can of course request the deletion of all data.

Many data processing procedures are only possible with your express consent. You can revoke your consent at any time. All you need to do is send us an informal e-mail. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

##### Right of appeal to the competent supervisory authority

In the event of violations of data protection law, the data subject has a right of appeal to the competent supervisory authority. The competent supervisory authority in matters of data protection law is the State Data Protection Commissioner of the federal state in which our company is based. A list of data protection officers and their contact details can be found in the following [link](https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html).
##### Right to data portability

You have the right to have data that we process on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible. 

##### Information, blocking, deletion and correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of the data processing and, if applicable, a right to correction, blocking or deletion of this data. You can contact us at any time at the address given in the imprint with regard to this and other questions on the subject of personal data. 

You can request a data export and the deletion of your account in the app.



### Further information

##### Criteria for determining storage periods

Your personal data will be stored by us until the contractual relationship is finally terminated, no further mutual claims can arise from it and the statutory or internal retention periods have expired.

Privacy Policy for the CryptoKoi App