Privacy Policy
FOCUS OF THE PRIVACY POLICY
tinydomo – a brand of Hybristar Deutschland GmbH, Kirchstraße 23, 03172 Guben, Germany (“tinydomo”), in conjunction with its partners (“we,” “our,” or “us”), respects your privacy. This Privacy Policy applies to the personal data we process through the website tinydomo.com (the “Website”), as well as other tinydomo websites, tinydomo accounts, our SmartHome services provided through our ThinQ app (collectively, the “Services”) and offered by tinydomo. It also applies to any other personal data you provide to your local tinydomo member.
OVERVIEW OF THE PRIVACY POLICY
In this Privacy Policy, we describe the types of personal information we collect through our Services, how we use that information, how long we retain it, and with whom we share it. We also explain the choices and rights you have regarding our use of your information, including the right to object to some types of processing we carry out (where permitted by applicable law). Further information about your rights and how to exercise them is set out in the “Your Rights” section. If you have any questions about this Privacy Policy and our data practices, you can contact us at dp@tinydomo.com.
PRIVACY POLICY
1. Who is responsible for your personal data?
tinydomo is responsible for operating the website or other tinydomo websites in your country, as well as for your data collected through the website. tinydomo is also responsible for any personal data you provide directly, for example, during customer service calls or via product registration cards. tinydomo is responsible for operating all other services and for the information about you collected through or in connection with those services. If you have any questions about personal data, you can contact us at dp@tinydomo.com.
2. Personal data we collect
When we refer to “personal information” in this Privacy Policy, we mean information that relates to an identifiable individual (for example, name, contact information, purchase information). The following types of personal information are collected in connection with our Services:
Information you provide to us directly or through third parties
Some Services allow us to collect information directly from you or from other companies with whom you have a connection. For example:
Information about using our services
In addition to the data you provide to us, we may collect data about your use of our services through the software on your devices and other electronic means (such as the use of cookies and sensors). We collect the following data:
Below we explain in detail what types of data and information we collect when you use our services:
Information you provide to us directly or through third parties
Some Services allow us to collect information directly from you or from other companies with whom you have a connection. For example:
- When you use our Services (for example, when you create a tinydomo account, register a device or product, make a purchase, review a product, or contact us), you provide us with information such as your name, email address, phone number, date of birth, gender, voice, photo, video, payment card information, shipping address (including postal code), purchase information, and your interactions with connected electronic devices.
- If you sign in with a third-party account or profile, we will have access to your information, such as your name, email address, and social media tags.
- If you communicate with our customer service or other staff, we will process this communication, including data we need to respond to your request.
Information about using our services
In addition to the data you provide to us, we may collect data about your use of our services through the software on your devices and other electronic means (such as the use of cookies and sensors). We collect the following data:
- Device information: Your device name, IMEI, UUID, OS version, country, location, language, IP address, MAC address, information about the connected modem, information about the internet router and device settings.
- Log Information: Application information, such as URL, redirect URL, performance timing, referrer, network type, network info, loading status, ad block info, and cookies. For more information about how we use cookies on our services, please refer to the cookie policies of the services you use.
- Location information: We process your location information based on your consent or when necessary to provide you with the services you have requested (for example, we ask for your location to give you directions).
- Other information about your use of our Services, such as the web pages you visit, typing behavior (autofill), connected device behavior and application history, power and power consumption information of the connected device, and how you interact with content offered through our Services.
Below we explain in detail what types of data and information we collect when you use our services:
Data collected via the website
– Data collected via the tinydomo account (see below), web registration form, survey form, demo or purchase request form, customer service contact form or online chat.
– Product and service information, including information about the products and services you purchase or use through the Site, including country code, product category, code and model number, device ID, billing and payment information, delivery information (e.g., shipping address, postal code), registration information, IP address, and firmware and software information.
– Website usage data: including data about how you interact with the website and the device you use. For more information, see our Cookie Policy.
– Image and voice data.
– Comments or similar postings on the website, including the time of posting, your email address and pseudonym, as well as any attached images or files.– Comments or similar postings on the website, including the time of posting, your email address and pseudonym, as well as any attached images or files.
– Product and service information, including information about the products and services you purchase or use through the Site, including country code, product category, code and model number, device ID, billing and payment information, delivery information (e.g., shipping address, postal code), registration information, IP address, and firmware and software information.
– Website usage data: including data about how you interact with the website and the device you use. For more information, see our Cookie Policy.
– Image and voice data.
– Comments or similar postings on the website, including the time of posting, your email address and pseudonym, as well as any attached images or files.– Comments or similar postings on the website, including the time of posting, your email address and pseudonym, as well as any attached images or files.
Data collected through the tinydomo account
– Identity data, including your display name, country code, language, name, date of birth, address, contact details, profile picture, and user authentication by name. If you are a business customer or an employee of one of our business customers, this also includes all data related to your business, such as contact details, company tax number, job title, and sector of activity.
– Device data, including device identification data such as the IMEI number, product serial number, UUID, advertising identifier and IP address
– Device data, including device identification data such as the IMEI number, product serial number, UUID, advertising identifier and IP address
Other information we collect
If we obtain your consent, we will explain in advance and on a case-by-case basis what data we will collect and how we will use it.
Sometimes we receive information about you from third parties; these are other companies, such as Facebook, Google, Amazon, or Line. For example, we receive your information from social network operators if you choose to connect to our services using a social network account.
To protect against fraud, we compare certain information you provide with third parties, such as identity verification providers.
We also process information about you that we receive from third parties, such as distributors and data brokers, to better understand your interests and, where appropriate, offer you services and advertising that are more tailored to you. For example, we receive aggregated data about the lifestyle or purchasing patterns of certain demographic groups to better understand your likely interests.
In addition, we may process other data about you, your devices or your use of our services where required to do so by law (for example, where we are legally required to collect internet search logs) or where you have consented to such processing.
Sometimes we receive information about you from third parties; these are other companies, such as Facebook, Google, Amazon, or Line. For example, we receive your information from social network operators if you choose to connect to our services using a social network account.
To protect against fraud, we compare certain information you provide with third parties, such as identity verification providers.
We also process information about you that we receive from third parties, such as distributors and data brokers, to better understand your interests and, where appropriate, offer you services and advertising that are more tailored to you. For example, we receive aggregated data about the lifestyle or purchasing patterns of certain demographic groups to better understand your likely interests.
In addition, we may process other data about you, your devices or your use of our services where required to do so by law (for example, where we are legally required to collect internet search logs) or where you have consented to such processing.
Links to other websites, devices, apps and features
Some of our Services allow you to connect to other websites, devices, apps, or other features that are not operated by tinydomo and that have their own privacy information or policies. We encourage you to review these before connecting. Tinydomo is not responsible for the content, use of personal information, or privacy practices of these providers.
3. How we use this information
In this section, we set out the legal bases that allow us to process your personal data. Under each of these legal bases, we explain the purposes for which we collect and use your personal data.
If you use more than one of our services, including the services described in this Privacy Policy and our Smart TV/Media Product Services, we will combine personal information we collect from you in connection with each of those services and use it for the purposes listed below or as described in the privacy policy for the services you use. This will, among other things, prevent you from having to sign up for different services multiple times.
If you use more than one of our services, including the services described in this Privacy Policy and our Smart TV/Media Product Services, we will combine personal information we collect from you in connection with each of those services and use it for the purposes listed below or as described in the privacy policy for the services you use. This will, among other things, prevent you from having to sign up for different services multiple times.
Providing services based on your contractual relationship with us
We process your personal data if this is necessary to perform a contract with you, for example to:
To facilitate installations and registrations, resolve technical issues, provide you with customer support, and provide you with necessary information regarding our services.
- Services and specific features that you choose when using our Services and which may require personalizing the content of our Services.
- To process orders and payments and to provide you with our products or third-party products that you purchase through our Services, and to enable you to exercise your warranty rights or other rights provided to you under this Agreement.
- To identify and authenticate you so that you can use certain of our services.
To facilitate installations and registrations, resolve technical issues, provide you with customer support, and provide you with necessary information regarding our services.
Legitimate interests of tinydomo and/or third parties
We process personal data in our legitimate interests only to the extent necessary to fulfill our legitimate interests (or the legitimate interests of third parties) (unless we are legally required to obtain your consent to do so under local law), for example to:
Where we rely on our legitimate interests, we have conducted a balancing test to identify the impact of processing on your rights and freedoms and to determine whether your interests override ours in the processing underway. You can obtain further information about these balancing tests using the contact details at the end of this privacy policy.
- To effectively manage our relationship with our customers, including communicating with you and responding to your enquiries;
- Conduct direct marketing activities, including sending you marketing communications via email, phone calls, posts, text messages, social media channels, or push notifications through our mobile apps; presenting you with online advertising both on our Services and on third-party websites; creating marketing profiles and personalizing recommendations and advertising content presented to you by us and others; and conducting promotions, contests, and prize draws. You have the right to opt out of the use of your data for direct marketing at any time – see the “Your Choices” section for more information.
- to protect our business from fraud, to detect and prevent fraud and other unlawful activities, as well as activities that are prohibited by our Terms of Use.
- to protect the security, availability and integrity of our services and information systems, for example by using authentication mechanisms and other security measures, to check our systems for security threats, to retain backups, to anonymize data and to perform system maintenance services.
- to protect our legal rights and the safety of end users, including by handling complaints, obtaining legal advice and investigations, enforcing legal claims against us or other companies in our group, and asserting and defending our Services;
- To improve your user experience, including by providing you with tailored features such as auto-fill, a quick search function based on your most visited web pages and by offering you additional content tailored to your interests;
- to improve our services and customer service, including by asking for your feedback, conducting surveys and market research, conducting data analysis regarding the use of our services, analyzing customer behavior, creating usage patterns and profiles of our customers to identify regional and global user trends and optimize our offerings for customers worldwide;
- to effectively manage our business activities, including by preparing reports and analyzing the performance of our services (through the use of aggregated information), and to review our business processes using statistics to make informed business decisions.
Where we rely on our legitimate interests, we have conducted a balancing test to identify the impact of processing on your rights and freedoms and to determine whether your interests override ours in the processing underway. You can obtain further information about these balancing tests using the contact details at the end of this privacy policy.
Your consent
Unless otherwise authorized or where required by law, we ask for your consent to process your personal data. For example, we ask for your consent to:
On other occasions where we ask for your consent, we will use the data for the purpose we communicated to you at that time.
If you give us your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we conducted before you withdrew your consent. Please see the “Your Rights” section for details on how to exercise this right.
- To place cookies and use similar technologies in accordance with our Cookie Policy. For more information, please refer to the cookie policy of the service you use.
- To send you marketing communications (where your consent is required by law or we decide to obtain your consent to do so).
- We offer you recommendations and customized advertising content, products, and services that we or others think you might like, based on our analysis of data related to your use of the Services, combined with various information you have provided to us through other means, for purposes consistent with this Privacy Policy. This may include sending advertisements through various channels, including via email, your tinydomo account, on our websites, or on third-party platforms (including social media).
On other occasions where we ask for your consent, we will use the data for the purpose we communicated to you at that time.
If you give us your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we conducted before you withdrew your consent. Please see the “Your Rights” section for details on how to exercise this right.
Legal obligations
We process personal data to the extent necessary to:
If we need your data to perform our contract with you or to comply with our legal obligations, you are obligated to provide that data to us. Otherwise, you are not obligated to provide your personal data. However, if you do not do so, it may affect or prevent you from using our services.
- to comply with our legal requirements under applicable laws (e.g. tax and accounting obligations, obligations regarding product safety, warranties and customer protection).
- comply with court orders and subpoenas and respond to legally binding requests from government, law enforcement, public authorities and/or regulatory agencies.
If we need your data to perform our contract with you or to comply with our legal obligations, you are obligated to provide that data to us. Otherwise, you are not obligated to provide your personal data. However, if you do not do so, it may affect or prevent you from using our services.
4. Sharing information
We transfer, disclose or make available your personal information to third parties as described below:
For example, we share your personal information with your local tinydomo member for product development and improvement for marketing purposes.
- tinydomo and her staff: We share personal information with tinydomo members, including contractors, agents and other companies in our group, to the extent necessary or appropriate to provide our services and fulfill the purposes set out in Section 3 above or described in the privacy policies relating to our services.
For example, we share your personal information with your local tinydomo member for product development and improvement for marketing purposes.
- Service provider: We only transfer your data to carefully selected companies and individuals who work on our behalf; for example, companies that help us develop and operate systems for our services; providers of IT services, security, hosting, website maintenance, data maintenance and analytics, customer service and communications, order processing and fulfillment, mailing, billing, market and market research services; authorized service and repair centers; other administrative services; and companies that run contests, sweepstakes, and other promotions on our behalf. These companies are authorized to access and use your personal data only to the extent necessary to provide the service we have commissioned them to provide. They are also contractually obligated not to use your data for any other purpose. Some of our service providers are located in other countries outside of Europe/the EEA.
- Third-party IoT providers:When you enable third-party connectivity features, for example, when you connect Home IoT devices to our Services, we share personal information with the service providers of those IoT devices to enable you to use those features in our Services.
- Authorized Resellers: In certain countries, the products on our website are sold by authorized resellers. If you purchase products from our website in those countries, we will share your personal information with those resellers.
- Advertising partners: We share personal information, including how you interact with our services, the ads you see, and the purchases you make, with social media and other advertising partners to analyze the effectiveness of our advertising, improve our marketing practices, and send you more relevant ads. In accordance with your market preferences, we may also share your personal information with third parties who offer products or services we believe may be of interest to you or who otherwise conduct market research and analytics. These advertising partners may use your personal information to contact you about offers or advertisements.
- Other business partners: We will disclose your personal information to other business partners as necessary to provide you with access to the services you have requested through our Services or promotional materials related to our Services.
- Visitors to our website: Messages you post online in some areas of the Site, including product review forums, chat rooms, message boards, or other public areas, may be viewed by other visitors to our Site. [We explain on our Site where information you post online will be visible to others.]
- Business consultant: For example, our lawyers, accountants, management consultants, insurers, auditors, to the extent necessary to provide the respective service. Government authorities, legal authorities, regulatory bodies or other third parties where necessary: We will disclose personal information to government agencies, legal authorities, regulatory bodies and other third parties where we are legally required to do so or where we believe it is necessary: – to comply with laws or legal processes (such as a warrant, subpoena or court order); – to verify or enforce compliance with the terms of use and policies governing our Services and to investigate and prevent fraud or other unlawful activities related to the use of our Services or which affect our business, to the extent that such disclosure is permitted by applicable data protection laws; and – to protect and defend our rights, property and the safety of our business and those of our respective subsidiaries, personnel, business partners, customers or members of the public.
- Corporate transactions: We will disclose your information, where necessary, to third parties (and their advisors) as part of a merger, transfer, reorganization, acquisition or sale (including in connection with negotiations), dissolution or other transaction, or in the event of bankruptcy.
- Other parties with your consent or at your request : In addition to the transfers described in this Privacy Policy, we may share your personal information with third parties if you separately consent to or request such sharing (for example, when you register to receive press releases through one of our websites).
- Analytics:We may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. We may use third-party analytics services, such as Google Analytics, Firebase, and others. The information we receive may be shared directly with or collected by these providers and other relevant third parties. They may use the information, for example, to evaluate use of the services. For more information about Google Analytics, see “How Google uses data when you use our partners’ websites or apps” (at https://www.google.com/policies/privacy/partners/), „Protecting your data“ (under https://support.google.com/analytics/answer/6004245#zippy=) and “Google Analytics Opt-out Browser Add-on” (at https://tools.google.com/dlpage/gaoptout).
5. Storage of personal data
We take reasonable steps to ensure that we process and store data in accordance with the following principles:
- at least for the duration for which this data is used to provide you with our services;
- if storage is required by law (e.g. tax laws), as part of a contract;
- as long as reasonably necessary to deal with an actual or threatened complaint, investigation or legal dispute;
- only for as long as necessary for the purpose for which the data is collected and processed, or longer if required by contract, by applicable law, or in anonymized form, for statistical purposes, and with appropriate safeguards. For example, if a dispute arises between you and IE or you fail to pay for our services, we will retain the relevant data until the dispute is resolved or payment is made. If you delete your entire tinydomo account, your data will be deleted immediately thereafter, unless otherwise required by applicable law.
- Where we process your data, we store it until you request its deletion. We also store revocations of consent and objections to individual processing operations so that we can comply with your requests in the future.
6. Your options
Where permitted, we may contact you via email, phone call, text message, or push notifications through our mobile apps. To submit a request to receive such communications from us, please contact us using the details provided in the “Contact Us” section below.
You can unsubscribe from our marketing communications at any time by clicking the “unsubscribe” link at the bottom of emails, or by contacting us directly (see the “Contact Us” section below). As noted in the section on Your Rights below, regardless of the legal basis we rely on in each specific case, you have the right to object to the use of your data for direct marketing purposes at any time.
Please note that if you opt out of our marketing communications, we will process your opt-out as quickly as possible. However, please be aware that you may still receive marketing communications for a short period while we process your request. We will also continue to send you service communications to provide you with necessary information regarding your contract and the services you use (for example, to inform you about changes to our terms of use).
You can unsubscribe from our marketing communications at any time by clicking the “unsubscribe” link at the bottom of emails, or by contacting us directly (see the “Contact Us” section below). As noted in the section on Your Rights below, regardless of the legal basis we rely on in each specific case, you have the right to object to the use of your data for direct marketing purposes at any time.
Please note that if you opt out of our marketing communications, we will process your opt-out as quickly as possible. However, please be aware that you may still receive marketing communications for a short period while we process your request. We will also continue to send you service communications to provide you with necessary information regarding your contract and the services you use (for example, to inform you about changes to our terms of use).
7. Your rights
To the extent permitted by law, you can request a copy of the personal data we hold about you from tinydomo. You can also ask us to delete personal data or correct any inaccuracies, restrict or limit the processing of your personal data, withdraw your consent, and provide you with personal data you have provided to us under a contract or with your consent in a structured, machine-readable format, or transfer (port) that data to another controller.
In addition, you may object to the processing of your personal data under certain circumstances, where permitted by applicable law (in particular, where we process the data in our overriding interest). You also have the right to object at any time to the use of your personal data for direct marketing purposes, including profiling in connection with direct marketing.
However, these rights may be limited, for example, if fulfilling your request would disclose personal data about another person, if it would infringe the rights of a third party (including our rights), or if you ask us to delete information that we are legally obliged to keep or have a compelling legitimate interest in keeping. Relevant exceptions are contained in both the General Data Protection Regulation (GDPR) and national law. We will inform you of any relevant exceptions we will rely on when responding to your request. To make a request regarding your rights or to make a query, please use the contact details in the “Contact Us” section. In some cases, you may also be able to exercise your rights directly through the website.
In addition, you may object to the processing of your personal data under certain circumstances, where permitted by applicable law (in particular, where we process the data in our overriding interest). You also have the right to object at any time to the use of your personal data for direct marketing purposes, including profiling in connection with direct marketing.
However, these rights may be limited, for example, if fulfilling your request would disclose personal data about another person, if it would infringe the rights of a third party (including our rights), or if you ask us to delete information that we are legally obliged to keep or have a compelling legitimate interest in keeping. Relevant exceptions are contained in both the General Data Protection Regulation (GDPR) and national law. We will inform you of any relevant exceptions we will rely on when responding to your request. To make a request regarding your rights or to make a query, please use the contact details in the “Contact Us” section. In some cases, you may also be able to exercise your rights directly through the website.
8. How we protect your personal data
We take your privacy seriously and have safeguards in place to protect the information we collect through our Services. However, please be aware that while we take reasonable steps to protect your privacy, no website, internet transmission, computer system, or wireless connection is completely secure.
9. International transfer of information
Your use of our Services, in accordance with this Privacy Policy, involves the transfer, storage, and processing of your personal information within and outside of your country of residence. Please be aware that the data protection and other laws of the country to which your information may be transferred may not be as comprehensive as those in your home country.
[For European residents]
If you are a resident of the EEA (European Economic Area, which is part of the European Union, plus Iceland, Liechtenstein, and Norway), the United Kingdom, or Switzerland: Your personal data will be transferred to recipients outside the EEA, the United Kingdom, or Switzerland, including recipients in the Republic of Korea and the United States. The European Union Data Protection Commission has determined that the Republic of Korea provides an adequate level of protection for personal data. If we transfer your personal data to a recipient in a third country whose level of data protection is not considered adequate, we will take appropriate measures, in accordance with applicable laws, to ensure that your personal data remains protected.
These measures include, for example, the use of standard data protection clauses approved by the EU, the UK, and Switzerland. In exceptional cases, we may request your explicit consent to transfer your personal data to recipients in third countries. To request further information or to receive a copy of the contractual agreements or other safeguards in place, please use the contact details provided in the “Contact Us” section.
[For European residents]
If you are a resident of the EEA (European Economic Area, which is part of the European Union, plus Iceland, Liechtenstein, and Norway), the United Kingdom, or Switzerland: Your personal data will be transferred to recipients outside the EEA, the United Kingdom, or Switzerland, including recipients in the Republic of Korea and the United States. The European Union Data Protection Commission has determined that the Republic of Korea provides an adequate level of protection for personal data. If we transfer your personal data to a recipient in a third country whose level of data protection is not considered adequate, we will take appropriate measures, in accordance with applicable laws, to ensure that your personal data remains protected.
These measures include, for example, the use of standard data protection clauses approved by the EU, the UK, and Switzerland. In exceptional cases, we may request your explicit consent to transfer your personal data to recipients in third countries. To request further information or to receive a copy of the contractual agreements or other safeguards in place, please use the contact details provided in the “Contact Us” section.
10. Updates to our Privacy Policy
We reserve the right to update this Privacy Policy if we change how we use your personal information or if we are required to do so by data protection laws. We will notify you of any material changes to our Privacy Policy by reasonable means (for example, by posting a notice on the websites and apps through which we offer our services, indicating at the top of the notice when the most recent update was made).
11. Contact
To exercise your rights or for further information about how we use your personal data, please contact us.
For questions and inquiries regarding your personal data collected via the website or otherwise by tinydomo, you can contact us at dp@tinydomo.com.
For questions and inquiries regarding your personal data collected via other services, you can contact us at dp@tinydomo.com.
You can contact our EU representative for data protection in the EEA and our data protection officer by email at dp@tinydomo.com.
If you are not satisfied with the way we use your personal data or believe that it is not in accordance with data protection laws, you have the right to inform and complain to the data protection authority in your place of residence, work or place where you believe a breach of data protection laws has occurred.
For questions and inquiries regarding your personal data collected via the website or otherwise by tinydomo, you can contact us at dp@tinydomo.com.
For questions and inquiries regarding your personal data collected via other services, you can contact us at dp@tinydomo.com.
You can contact our EU representative for data protection in the EEA and our data protection officer by email at dp@tinydomo.com.
If you are not satisfied with the way we use your personal data or believe that it is not in accordance with data protection laws, you have the right to inform and complain to the data protection authority in your place of residence, work or place where you believe a breach of data protection laws has occurred.
12. Personal data of children
Our Services are designed for a general audience and are not directed to children. In connection with our Services, we may, without our knowledge, collect or store personal information from minors (children under 18 years of age) or enable minors to use our Services without our knowledge. Therefore, please do not provide us with personal information from anyone under 18. If you are under 18 years of age, do not attempt to register for our Services or provide us with your personal information. If we discover that someone under 18 has provided us with personal information, we will promptly delete that personal information.
If you believe that a child under 18 has provided us with their personal information, please contact us. See section 11.
In some countries, we may have more or less restrictive age guidelines. For more information, please see the supplementary information for your country below this Privacy Policy.
If you believe that a child under 18 has provided us with their personal information, please contact us. See section 11.
In some countries, we may have more or less restrictive age guidelines. For more information, please see the supplementary information for your country below this Privacy Policy.
Supplementary Terms to the Privacy Policy: Jurisdiction-specific – Germany
Because data protection laws vary from region to region, the following additional terms apply exclusively to users residing in Germany. They ensure compliance with local regulations and enhance the protection of your personal data. In the event of a conflict between the following additional terms and the provisions of the main body of the Privacy Policy, the following terms shall prevail.
A. In Section 3 of the Privacy Policy, this sentence is deleted and replaced with the following:
3. How we use this information
Legitimate interests of tinydomo and/or third parties
We process personal data in our legitimate interests only to the extent necessary to fulfill our legitimate interests (or the legitimate interests of third parties) (unless we are legally required to obtain your consent to do so under local law), for example to:
Where we rely on our legitimate interests, we have conducted a balancing test to identify the impact of processing on your rights and freedoms and to determine whether your interests override ours in the processing underway. You can obtain further information about these balancing tests using the contact details at the end of this privacy policy.
- To effectively manage our relationship with our customers, including communicating with you and responding to your enquiries;
- To send you personalized marketing messages by email if you provided us with this email address when purchasing goods or services from our range. If you initially objected to the use of your email address for direct marketing purposes, we will not send you marketing messages by email. You can object to the use of your email address for direct marketing purposes at any time with effect for the future. You will only incur transmission costs according to the basic rates. Upon receipt of your objection, the use of your email address for direct marketing purposes will be stopped immediately. More information can be found in the “Your Options” section.
- to protect our business from fraud, to detect and prevent fraud and other unlawful activities, as well as activities that are prohibited by our Terms of Use.
- to protect the security, availability and integrity of our services and information systems, for example by using authentication mechanisms and other security measures, to check our systems for security threats, to retain backups, to anonymize data and to perform system maintenance services.
- to protect our legal rights and the safety of end users, including by handling complaints, obtaining legal advice and investigations, enforcing legal claims against us or other companies in our group, and asserting and defending our Services;
- To improve your user experience, including by providing you with tailored features such as auto-fill, a quick search function based on your most visited web pages and by offering you additional content tailored to your interests;
- to improve our services and customer service, including by asking for your feedback, conducting surveys and market research, conducting data analysis regarding the use of our services, analyzing customer behavior, creating usage patterns and profiles of our customers to identify regional and global user trends and optimize our offerings for customers worldwide;
- to manage our business activities effectively, including by preparing reports and analyzing the performance of our services (through the use of aggregated information), and to review our business processes using statistics to make informed business decisions.
Where we rely on our legitimate interests, we have conducted a balancing test to identify the impact of processing on your rights and freedoms and to determine whether your interests override ours in the processing underway. You can obtain further information about these balancing tests using the contact details at the end of this privacy policy.
B. The following is inserted in Section 3 of the Privacy Policy:
3. How we use this information
Your consent
Unless otherwise authorized or where required by law, we ask for your consent to process your personal data. For example, we ask for your consent to:
In addition, we use the data from your user profile to predict future events, potential risks and outcomes, using algorithms and methods of statistical predictive modeling (a mathematical method for developing predictive models based on historical data).
You can cancel your newsletter subscription at any time in the future using the unsubscribe link in the newsletter, by sending us a message, or by deactivating the subscription in your online account. To verify the authenticity of the email address you provided when subscribing to the newsletter, you will receive an automatically generated email after submitting your order, requesting your reconfirmation (double opt-in). Your consent to receive the newsletter is only deemed to have been given after your confirmation. If you do not subscribe to the newsletter via your online account, the email address you provided when subscribing to the newsletter will be deleted; otherwise, the address will remain stored in your online account, but without triggering the newsletter and the associated processing of personal data described here. Upon revoking your consent, the data in your user profile will also be deleted (anonymized).
To regularly send you personalized marketing messages at your request as a registered user. To personalize the messages, we collect, sort and analyze your interactions via email, social media, contact forms and services on our websites, newsletters, your online account with IE and evaluate this information in order to send you messages tailored to your personal interests. By ordering marketing messages, you agree that we may collect and analyze this information and store it personally in a user profile. To collect this data, we use technologies such as cookies, web beacons or tracking pixels, to whose use you also agree when you give your consent. We use this information, including browser type, time of use and your IP address as well as a unique ID, to tailor the information we send you via marketing message to your interests and thus send you advertising content that is as relevant to you as possible. In addition, we use the data from your user profile to predict future events, potential risks and outcomes, using algorithms and methods of statistical predictive modeling (a mathematical method for developing predictive models based on historical data).
You can revoke your subscription to marketing messages at any time in the future using the unsubscribe link in the message. Upon revoking your consent, the data in your user profile will also be deleted (anonymized).
- To regularly send you our newsletter by email upon your request. If you order our newsletter via the contact form on our website, via email or via your online account with IE, the personal data you transmit to us will be processed for this purpose. By ordering the newsletter, you also agree that we may collect and analyze information about your newsletter usage and store it in a user profile related to you. To collect this data, we use technologies such as cookies, web beacons or tracking pixels, the use of which you agree to when you order the newsletter. We use this information, including browser type, time of use and your IP address as well as a unique ID, to tailor the information we send you via newsletter to your interests and thus to provide you with advertising content that is as relevant to you as possible.
In addition, we use the data from your user profile to predict future events, potential risks and outcomes, using algorithms and methods of statistical predictive modeling (a mathematical method for developing predictive models based on historical data).
You can cancel your newsletter subscription at any time in the future using the unsubscribe link in the newsletter, by sending us a message, or by deactivating the subscription in your online account. To verify the authenticity of the email address you provided when subscribing to the newsletter, you will receive an automatically generated email after submitting your order, requesting your reconfirmation (double opt-in). Your consent to receive the newsletter is only deemed to have been given after your confirmation. If you do not subscribe to the newsletter via your online account, the email address you provided when subscribing to the newsletter will be deleted; otherwise, the address will remain stored in your online account, but without triggering the newsletter and the associated processing of personal data described here. Upon revoking your consent, the data in your user profile will also be deleted (anonymized).
To regularly send you personalized marketing messages at your request as a registered user. To personalize the messages, we collect, sort and analyze your interactions via email, social media, contact forms and services on our websites, newsletters, your online account with IE and evaluate this information in order to send you messages tailored to your personal interests. By ordering marketing messages, you agree that we may collect and analyze this information and store it personally in a user profile. To collect this data, we use technologies such as cookies, web beacons or tracking pixels, to whose use you also agree when you give your consent. We use this information, including browser type, time of use and your IP address as well as a unique ID, to tailor the information we send you via marketing message to your interests and thus send you advertising content that is as relevant to you as possible. In addition, we use the data from your user profile to predict future events, potential risks and outcomes, using algorithms and methods of statistical predictive modeling (a mathematical method for developing predictive models based on historical data).
You can revoke your subscription to marketing messages at any time in the future using the unsubscribe link in the message. Upon revoking your consent, the data in your user profile will also be deleted (anonymized).
C. In Section 4 of the Privacy Policy, this sentence is deleted and replaced with the following:
4. Sharing Information
We transfer, disclose or make available your personal information to third parties as described below:
– to comply with laws or legal processes (such as a warrant, subpoena or court order);
– to verify or enforce compliance with the terms of use and policies governing our Services and to investigate and prevent fraud or other unlawful activities related to the use of our Services or which affect our business, to the extent that such disclosure is permitted by applicable data protection laws; and
– to protect and defend our rights, property and the safety of our business and those of our respective subsidiaries, personnel, business partners, customers or members of the public.
- Government authorities, courts, regulatory bodies or other third parties where necessary: We will disclose personal information to government agencies, legal authorities, regulatory bodies and other third parties where we are legally required to do so or where we believe it is necessary:
– to comply with laws or legal processes (such as a warrant, subpoena or court order);
– to verify or enforce compliance with the terms of use and policies governing our Services and to investigate and prevent fraud or other unlawful activities related to the use of our Services or which affect our business, to the extent that such disclosure is permitted by applicable data protection laws; and
– to protect and defend our rights, property and the safety of our business and those of our respective subsidiaries, personnel, business partners, customers or members of the public.
D. Additional clause: Inquiries via customer service
- Inquiries via email, chat, or telephone
Telephone calls may be recorded for training and quality control purposes. However, this will only occur with your express prior consent in accordance with Art. 6 Para. 1 a GDPR. The recording of your consent, as well as the recording of your telephone call, will be deleted after three months. If there is a specific reason for doing so, the recordings of the telephone calls will also be retained for evidentiary purposes during the relevant legal proceedings.
- Inquiries via video telephony
If you send us a video call request via our customer service, we will record and store the video and audio data with your express prior consent in accordance with Art. 6 Para. 1 a GDPR, as well as your contact details (email address, telephone number), device data, the OS version of the smartphone used, the browser name of the web browser used, and the server log data, including the IP address, for the execution of the contract in accordance with Art. 6 Para. 1 b GDPR. For video calls, we use the “Telespresence” web service published by IE. The video call with tinydomo customer service and the technicians hired by IE will be recorded and assigned to your support case. We use the data to further process your request and check for warranty claims. Furthermore, the recording of the call serves to process your request more precisely and efficiently. This allows the transmitted image or sound to partially identify the critical technical problem, which can be resolved more quickly during post-processing. If your error description contains technically or legally important information about our products, we will also use your description in our interest in accordance with Article 6 (1) (f) GDPR to eliminate errors or improve our products.
To provide our tinydomo customer service, we use computers that can view the records for the purpose of providing the requested services, in accordance with the Privacy Policy.
The recordings are deleted after 6 months. Further data will be deleted once the support case is legally closed.
You can withdraw your consent to the retention of video and audio data at any time with future effect at dp@tinydomo.com.
- You can object to the processing we carry out on this legal basis. You can find further information about this under “Your Rights”.
Last update: 06-2025
