Data protection
Privacy Policy
This privacy policy applies to all tracking devices we manufacture.
Location through satellite-based positioning
The tracking devices we manufacture in the home care sector collect their data using satellite-based positioning. This procedure does not constitute a deprivation of liberty, but rather enables, among other things, the nursing staff to determine whether the person concerned is leaving the home without permission. The function of alarming as a technical measure does not directly deprive people of their freedom. Rather, it is simply a warning device that triggers an alarm electronically when the patient leaves the defined range of motion with the tracking device.
Data ascertainment
In principle, technical means of personal supervision can be used in care facilities. However, the collection, processing and use of personal data are prohibited until the person concerned gives their consent or the law or another legal regulation allows or requires this (Article 6 GDPR). Consent is only effective if it is based on the free decision of the person concerned and is in writing. If consent is to be given in writing together with other declarations (e.g. living will), it must be particularly highlighted (Art. 7 GDPR (2)). We advise nursing facilities and hospitals to integrate consent for data collection, processing and use into the patient's directive. If the person affected suffers from dementia syndrome and is no longer able to carry out business independently, the consent of the carer is necessary! In the private sector, a verbal agreement between the person concerned and the people they trust is sufficient. However, we advise you to record this in writing. The tracking function of our tracking devices in the home care sector, using satellite-based positioning, is openly communicated through information on the sales packaging, the instructions for use and in sales discussions. By purchasing one of our tracking devices from the home care sector, the buyer consents to the data collection. If the buyer is not also the user, the above conditions apply. Movement data, status reports (e.g. alarm messages) and limited personal data are collected.
Data protection and data backup
The collected movement data is stored exclusively and pseudonymously in the data centers of Deutsche Telekom AG in accordance with the highest German data protection standards (GDPR). The data is always stored in parallel so that if one data center fails, uninterrupted access can be granted by the other data center. Limited personal data such as email address, first and last name and telephone number, which are required to activate our tracking devices, are also stored by cibX GmbH. The storage takes place in accordance with the guidelines of the European General Data Protection Regulation. Only the user of the connected portal has access to and insight into the data! To activate the SIM card, the IMEI number and an activation code are required, which are only accessible after purchasing a tracking device. After successful activation by telephone or online, the caller will receive their access data (user name and password) for the portal by email. The connection to the portal is SSL protected. When you log in for the first time, you will be asked to change your password. Collected movement data is automatically and irrevocably deleted after 3 months.
Right of providing information
The owner/buyer has the right to receive information about his stored data at any time (Article 15 GDPR). He can also insist on deletion of certain data (Article 17 GDPR). As already mentioned above, the collected movement data is automatically deleted after 3 months. The assigned access data is passed on exclusively by the owner himself. cibX GmbH, Ossenberg GmbH and Deutsche Telekom AG are not permitted to pass on the data to third parties without the owner's consent.
Information about mobile communications
Mobile network:
An M2M SIM card from Deutsche Telekom AG is installed in our tracking devices for the home care sector.
Contractual commitment:
When purchasing a tracking device for the home care sector, there is no contractual obligation with Deutsche Telekom AG.
Extension of functions:
The functions of our tracking devices for the home care sector (alarming, localization and geofence) are all mobile-connected. In order to be able to continue using this after the 2-year term has expired, a timely extension is necessary. The support team will proactively contact the user stored in the portal approximately 4 months before the end. Mobile phone usage can be extended by one or two years if desired.
Operation area:
In addition to Germany, the functions of our tracking devices for the home care sector can also be used without restrictions in European countries in tariff zone 1. Country group 1 includes the following countries: Belgium, Bulgaria, Denmark, Estonia, Finland, France, French Guiana, Gibraltar, Greece, Great Britain, Guadeloupe, Ireland, Iceland, Isle of Man, Italy, Channel Islands, Croatia, Latvia, Liechtenstein, Lithuania , Luxembourg, Malta, Martinique, Mayotte, Netherlands, Northern Ireland, Norway, Austria, Poland, Portugal, Réunion, Romania, Saint-Barthélemy, Saint-Martin (French part), San Marino, Sweden, Slovakia, Slovenia, Spain, Czech Republic , Hungary, Vatican City, Cyprus. Outside these countries, mobile data collection is automatically separated. It is no longer possible to use the location function (GPS via GSM). Data collection is automatically activated again after entering one of the above-mentioned countries. After activation, the functions of our tracking devices for the home care area can be used again without restrictions.
Data protection
General
Data protection has a high priority for cibX GmbH. In this data protection declaration we would like to inform you about the type, scope and purpose of the personal data we collect, use and process. cibX GmbH also informs affected persons about their rights. When using special services from our company, processing of personal data may be necessary. If this is the case and there is no legal basis, we generally obtain the consent of the person concerned. The processing of personal data (e.g. name, address, email address or telephone number) of a data subject is always carried out in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to cibX GmbH. As the data controller, cibX GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. However, internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
Explanation of terms
The data protection declaration of cibX GmbH is based on the terms used by the European legislator for directives and regulations when issuing the General Data Protection Regulation (GDPR). An explanation of the terms can be found below:
a) Personal data
Personal data is any information that relates to an identified or identifiable natural person (hereinafter “data subject”). A natural person is considered to be identifiable if he or she 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 special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the data controller.
c) Processing
Processing is any operation or series of operations carried out on personal data, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or modification, reading, querying, use, disclosure by transmission, distribution or other form of provision, alignment or association, restriction, deletion or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.
e) Profiling
Profiling is any type of automated processing of personal data which consists in using these personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or movements of that natural person.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not be assigned to an identified or identifiable natural person.
g) Controller
The person responsible or responsible for processing is the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data. If the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller.
i) Recipient
The recipient is a natural or legal person, public authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, public authorities which may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
j) Third party
Third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
k) Consent
Consent is any voluntary, informed and unambiguous expression of wishes given by the data subject for a specific case, in the form of a statement or other unambiguous confirmatory act, by which the data subject indicates that he or she agrees to the processing of personal data concerning him or her is.
Name and address of the person responsible for processing
The person responsible within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:
cibX GmbH
Weitkampweg 87
D-48161 Münster
Phone: +49 2571 95777 01
Mail: info@cibx.de
Website: www.cibx.de
Data protection officer: Ralf Drüge
Phone: +49 2571 95777 01
Mail: r.druege@cibx.de
Cookies
The Internet pages of the cibX GmbH use cookies. Cookies are text files that are filed and saved on a computer system via an Internet browser. Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID, a unique identifier of the cookie. The cookie ID consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID. By using cookies, cibX GmbH can provide the users of its website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized for the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is done by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in the online shop. The online shop uses a cookie to remember the items that a customer has placed in the virtual shopping cart. The data subject can prevent the setting of cookies through our website at any time by means of an appropriate setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
Collection of general data and information
CibX GmbH collects a series of general data and information every time the website is accessed by a data subject or an automated system. This general data and information is stored in the log files of the server. They can be recorded
- Browser types and versions used,
- the operating system used by the accessing system,
- the website from which an accessing system accesses our website (so-called referrer),
- the sub-websites, which are controlled via an accessing system on our website,
- the date and time of access to the website,
- an Internet protocol address (IP address),
- the internet service provider of the accessing system and
- other similar data and information that serves to avert danger in the event of attacks on our information technology systems.
When using this general data and information, cibX GmbH does not draw any conclusions about the data subject. Rather, this information is needed to
- to deliver the content of our website correctly,
- to optimize the content of our website and the advertising for it,
- to ensure the long-term functionality of our information technology systems and the technology of our website and
- to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack.
These anonymously collected data and information are therefore evaluated by cibX GmbH both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by an affected person.
Subscription to our newsletter
On the cibX GmbH website, users are given the opportunity to subscribe to our newsletter. Which personal data is transmitted to the person responsible for processing when ordering the newsletter results from the input mask used for this purpose. In principle, the cibX newsletter can only be received by persons who
- have a valid email address and
- have registered to receive the newsletter.
For legal reasons, a confirmation email will be sent using the double opt-in procedure to the email address entered by a data subject for the first time to receive the newsletter. This confirmation email is used to check whether the owner of the email address as the data subject has authorized receipt of the newsletter. When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to understand the (possible) misuse of the e-mail address of a data subject at a later point in time and therefore serves to provide legal protection for the person responsible for processing. The personal data collected when registering for the newsletter is used exclusively to send our newsletter. Furthermore, subscribers to the newsletter could be informed by email if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or a change in technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The data subject can cancel the subscription to our newsletter at any time. The consent to the storage of personal data that the data subject has given us for sending the newsletter can be revoked at any time. For the purpose of revoking your consent, there is a corresponding link in every newsletter. It is also possible to unsubscribe from the newsletter at any time in another way.
Newsletter tracking
The cibX GmbH newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, cibX GmbH can see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects. Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the person responsible for processing in order to optimize the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the person concerned. This personal data will not be passed on to third parties. Affected persons are entitled at any time to revoke the relevant separate declaration of consent given via the double opt-in procedure. After a revocation, this personal data will be deleted by the person responsible for processing. The cibX GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.
Contact option via the website
In accordance with legal regulations, the website of cibX GmbH contains information that enables quick electronic contact to our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If an affected person contacts us by e-mail or via a contact form, the personal data transmitted by the affected person will be automatically saved. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. This personal data will not be passed on to third parties.
Routine deletion and blocking of personal data
The person responsible for processing processes and stores personal data of the person concerned only for the period necessary to achieve the purpose of storage or if this is required by the European directive and regulation giver or another legislator in laws or regulations which the person responsible for processing is subject to. If the purpose of storage no longer applies or if a storage period stipulated by the European legislator for directives and regulations or another responsible legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.
Rights of the data subject
a) Right to confirmation
Every data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning him or her is being processed. If a data subject would like to exercise this right of confirmation, they can contact an employee of the person responsible for processing at any time.
b) Right to information
Every person affected by the processing of personal data has the right granted by the European legislator to obtain free information from the person responsible for processing at any time about the personal data stored about him and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
- the processing purposes
- the categories of personal data that are processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
- if possible, the planned period for which the personal data will be stored or, if this is not possible, the criteria for determining that period
- the existence of a right to rectification or deletion of personal data concerning you or to restriction of processing by the controller or a right to object to this processing
- The existence of a right to lodge a complaint with a supervisory authority if the personal data is not collected from the data subject: All available information about the origin of the data The existence of automated decision-making including profiling in accordance with Article 22 Paragraph 1 and 4 GDPR and - at least in In these cases - meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject.
The data subject also has the right to information as to whether personal data has been transmitted to a third country or to an international organization. If this is the case, the data subject also has the right to receive information about the appropriate guarantees in connection with the transfer. If a data subject would like to exercise this right to information, they can contact an employee of the person responsible for processing at any time.
c) Right of rectification
Every person affected by the processing of personal data has the right granted by the European legislator to request the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of the processing. If a data subject would like to exercise this right to rectification, they can contact an employee of the data controller at any time.
d) Right to deletion (right to be forgotten)
Every person affected by the processing of personal data has the right granted by the European legislator to request that the person responsible delete the personal data concerning him or her immediately if one of the following reasons applies and if the processing is not necessary:
- The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
- The data subject revokes their consent on which the processing was based in accordance with Article 6 Paragraph 1 Letter a GDPR or Article 9 Paragraph 2 Letter a GDPR and there is no other legal basis for the processing.
- The data subject objects to the processing in accordance with Article 21 (1) of the GDPR and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing in accordance with Article 21 (2) of the GDPR processing.
- The personal data was processed unlawfully.
- The deletion of personal data is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data was collected in relation to information society services offered in accordance with Article 8 Para. 1 GDPR.
If one of the reasons mentioned above applies and a data subject wishes to have personal data stored at cibX GmbH deleted, they can contact an employee of the data controller at any time. The employee of cibX GmbH will ensure that the deletion request is complied with immediately. If the personal data has been made public by cibX GmbH and our company, as the person responsible, is obliged to delete the personal data in accordance with Article 17 Para. 1 GDPR, cibX GmbH will also take appropriate measures, taking into account the available technology and the implementation costs of a technical nature, in order to inform other data controllers who process the published personal data that the data subject requires these other data controllers to delete all links to this personal data or copies or replications of this personal data has requested, provided that processing is not necessary. The employee of cibX GmbH will arrange the necessary measures in individual cases.
e) Right to restriction of processing
Every person affected by the processing of personal data has the right granted by the European legislator to request that the controller restrict processing if one of the following conditions is met:
- The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.
- The controller no longer needs the personal data for the purposes of processing, but the data subject needs them to assert, exercise or defend legal claims.
- The data subject has objected to the processing in accordance with Article 21 Paragraph 1 of the GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.
If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by cibX GmbH, they can contact an employee of the data controller at any time. The employee of cibX GmbH will arrange for the processing to be restricted.
f) Right to data portability
Every person affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which the data subject has provided to a person responsible, in a structured, common and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent in accordance with Article 6 Paragraph 1 Letter a of the GDPR or Article 9 Paragraph 2 letter a GDPR or on a contract in accordance with Article 6 paragraph 1 letter b GDPR and the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task that is in the public interest or is carried out in the exercise of official authority, which has been transferred to the person responsible. Furthermore, when exercising his or her right to data portability in accordance with Article 20 (1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one person responsible to another person responsible, to the extent that this is technically feasible and provided that This does not affect the rights and freedoms of other people.
To assert the right to data portability, the data subject can contact an employee of cibX GmbH at any time.
g) Right to object
Every person affected by the processing of personal data has the right granted by the European legislator to object at any time, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her based on Article 6 Paragraph 1 Letter e or f GDPR, to lodge an objection. This also applies to profiling based on these provisions. cibX GmbH will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate reasons for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend of legal claims. If cibX GmbH processes personal data in order to conduct direct advertising, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is connected to such direct advertising. If the data subject objects to cibX GmbH processing for direct advertising purposes, cibX GmbH will no longer process the personal data for these purposes. In addition, the data subject has the right, for reasons arising from his or her particular situation, to object to the processing of personal data concerning him or her that is carried out by cibX GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 Para. 1 DS- GMOs take place, unless such processing is necessary to fulfill a task carried out in the public interest. To exercise the right to object, the data subject may contact any employee of cibX GmbH or another employee directly. Furthermore, in connection with the use of information society services, the data subject is free, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by means of automated procedures using technical specifications.
h) Automated decisions in individual cases including profiling
Every person affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him, provided the decision
- is not necessary for the conclusion or performance of a contract between the data subject and the controller, or
- is permitted by Union or Member State law to which the controller is subject and such law contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject or
- with the express consent of the person concerned.
Is the decision
- necessary for the conclusion or performance of a contract between the data subject and the controller or
- If it takes place with the express consent of the data subject, cibX GmbH shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the person responsible and to express one's own point of view and heard on appeal of the decision.
If the data subject would like to assert rights with regard to automated decisions, he or she can contact an employee of the data controller at any time.
i) Right to revoke consent under data protection law
Every person affected by the processing of personal data has the right granted by the European legislator to revoke consent to the processing of personal data at any time. If the data subject would like to exercise their right to withdraw consent, they can contact an employee of the data controller at any time.
Legal basis for processing
Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance details or other vital information would then have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the above-mentioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, he was of the opinion that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).
Legitimate interests in processing pursued by the controller or a third party
If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and our shareholders.
Duration for which the personal data is stored
The criterion for the duration of storage of personal data is the respective statutory retention period. After the deadline has expired, the relevant data will be routinely deleted unless it is no longer required to fulfill the contract or initiate a contract.
Legal or contractual requirements for the provision of personal data; Necessity for the conclusion of the contract; Obligation of the data subject to provide the personal data; possible consequences of non-provision
We would like to clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). In order to conclude a contract, it may sometimes be necessary for a data subject to provide us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the person concerned could not be concluded. Before the data subject provides personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the non-provision of the personal data would have.
Existence of automated decision making
As a responsible company, we do not use automatic decision-making or profiling.
Further information
Your trust is important to us. We would therefore like to be available to answer your questions at any time regarding the processing of your personal data. If you have any questions that this data protection declaration could not answer or if you would like more detailed information on a point, please contact us at any time using the contact details listed above.
This data protection declaration was created by the data protection declaration generator by the external data protection officer Dresden in cooperation with RC GmbH, which recycles used notebooks, and the file sharing lawyers from WBS-LAW.
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