Data Protection Policy for EASE 5 - Early Adopter Software

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Introduction

With the following information we like to provide you with details in connection with the processing of personal data when participating in the EASE 5 - Early Adopter Program (”EASE 5 EAP”) and your rights in this regard.

You can participate in the EASE 5 EAP by registering for the EASE 5 EAP and thereby ordering the Early Adopter Version of EASE 5 (“Software”) in our online shop (https://www.afmg-support.eu/afmgonlineshop/shop.aspx) and downloading the Software from the AFMG Download Portal (http://downloads.afmg.eu). This privacy policy applies specifically to data processing within the scope of using the Software. For the use of our online shop, the general privacy policy of our online shop applies, which you can retrieve here.

1. Responsible and data protection officer

The controller responsible for collection, processing, and use of personal data in connection with the use of the Software is

AFMG Technologies GmbH
Borkumstr. 2
13189 Berlin, Germany
Phone: +49 (0)30 467 092 - 30
Fax: +49 (0)30 467 092 - 27
Email: @email

For any questions or requests in this regard, please feel free to contact our Marketing and Sales department via email to @email or by phone at +49 (30) 467 092 - 30.

 

2. Definitions

Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

GDPR means the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

 

3. Data processing to activate the software

a)    Scope and purpose of processing

As part of the activation process for the Software, we collect a number of personal data of the user to generate a license key, which is stored on the respective computer of the user to verify the proper licensing of the Software.

  • The following data is collected for this purpose:
  • Log-in credentials of the user (email and password)
  • Time of log-in and license activation
  • License selected by the user for activation (if several are available under the user's account)
  • Hardware information (BIOS version, CPU information, etc.) to generate a hardware key on which the license is based
  • Possibly further information voluntarily provided by the user during the licensing process

This data will only be used to generate the license key and for support purposes with regard to licensing and will not be further stored. It can not be reconstructed from the license key.

b)    Legal basis

The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. b GDPR. Data processing is necessary for the purpose of fulfilling the contract in order to ensure proper licensing of the software used.

 

4. Automatically collected data to analyze software usage and improvement activation levels

a)    Scope and purpose of processing

To analyze the use of the software and for improving the software within the EASE 5 EAP, we collect the following data, which is automatically sent to our server.

  • Session start and end (i.e. the runtime of the program)
  • A random ID that uniquely identifies the PC to us, but is not assigned to individual users
  • Version number of the software
  • Information about program errors that occur during runtime

b)    Legal basis

The above data processing takes place on the basis of your consent given in the course of downloading the software. The legal basis for this data processing is Article 6 (1) sentence 1 lit. a GDPR. You have the right to revoke your consent at any time with effect for the future. Please note that further participation in the EASE 5 EAP is then no longer possible, as analyzing the use of the software in order to improve the software is the core objective of the EASE 5 EAP.

The above data will be stored by us in pseudonymized form until you revoke your consent or until the EASE 5 EAP expires.

 

5. Recipients of personal data

We have concluded contracts with third-parties that are processing personal data on our behalf as processors according to Art. 28 GDPR, which are recipients of personal data according to Art. 4 No. 8 GDPR):

  • Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (Server Hosting)
  • IP-Projects GmbH & Co KG, Am Vogelherd 14, 97295 Waldbrunn (Server Hosting)

The hosting of the data takes place exclusively on servers within the European Union.

 

6. Your rights

a) You have the right to request confirmation from us as to whether we are processing personal data concerning you. If this is the case, you have the right to access the personal data and the information specified in Art. 15 GDPR in conjunction with § 34 BDSG. This shall not apply if

  • the data is only stored because it may not be deleted due to legal or statutory storage obligations, or
  • exclusively serves the purpose of data security or data protection control

and the provision of information would require a disproportionate effort and processing for other purposes is excluded by appropriate technical and organizational measures.

b) You also have the right to request the rectification of any inaccurate personal data concerning you and, if necessary, the completion of any incomplete personal data, also by means of a supplementary statement, taking into account the purposes of the processing (Article 16 GDPR). In the cases specified in Article 17 (1) lit. a to f GDPR, you also have the right to have your personal data deleted, unless there is an exception pursuant to Article 17 (3) GDPR, and in the cases specified in Article 18 (1) GDPR you have the right to restrict the processing. In the cases covered by Article 20 (1) GDPR, there is also a right to data transferability.

c) You have the right to complain to the competent supervisory authority if you are of the opinion that the processing of your personal data violates the GDPR.

d) Right to object to processing on the basis of legitimate interest

If the processing of the data is based on Art. 6 para. 1 lit. f GDPR ("legitimate interest"), you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation. The exercise of the right of objection may lead to the fact that the Software as a whole or individual services or functions can only be used to a limited extent or no longer at all by you.

 

We may review and, where necessary, update this data protection policy. If we plan to use the Personal Data for a new purpose, that is incompatible with the original purposes for which consent has been provided, we will update this policy and request consent for the new purpose.

Berlin, September 17, 2021
Version: 1.1