Privacy Policy of Primlo UG (haftungsbeschraenkt)

1. About PRIMLO, its Service Provider and Responsible Party

1.1. PRIMLO is a service for learning the Chinese language, made available in form of a mobile app, to be downloaded onto mobile devices.

1.2. Service provider in terms of §13 TMG (Telemediengesetz) as well as responsible party in terms of §3 Abs.7 BDSG (Bundesdatenschutzgesetz) is:

PRIMLO UG (with limited liability)
Hirschbergstraße 21
50939 Cologne
Germany
Tel.: +49 221 86 94 874
Email: privacy@primlo.com

2. General principles of data protection and data security

2.1. Personal data is any information concerning personal or material circumstances of an identified or identifiable natural person, i.e. data allowing for conclusions regarding a person’s identity, e.g. name, date of birth, address, telephone number and email-address.

2.2. When visiting our SITE or using the APP your personal data is collected, processed and used only to the extent necessary for accessing the services of PRIMLO as well as for making PRIMLO more user-friendly, more efficient and more secure. In this we strictly abide by the relevant data protection regulations, in particular by the Federal German Data Protection Act (Bundesdatenschutzgesetz) and the Federal German Telemedia Act (Telemediengesetz).

2.3. The collection, processing and usage of your personal data shall only be effected on the basis of a statutory provision or, in the absence of such, with your prior express consent.

2.4. Forwarding your personal data to third parties only occurs if required for handling or contract processing purposes or in case we have received your prior consent. For the rest disclosure and transmission will only be effected on the basis of statutory exceptions, e.g. upon request by courts or authorities.

2.5. We maintain up-to-date technical measures to ensure data integrity and confidentiality, in particular for protecting your personal data against risks arising from data transfers and unauthorized acquisition by third parties. Appropriate adaptions will be made to keep such measures always correspondent to the current state of technology.

3. Personal information directly collected whilst using the PRIMLO-Website

3.1. The SITE serves solely for general information about PRIMLO. The use of PRIMLO and its functions, features and services is currently possible through the APP only. When visiting the SITE, no personal information other than those listed below, which is automatically transferred by your browser in order to enable you to visit the SITE at all, is collected:

4. Personal information directly collected, processed or used whilst using the APP

4.1. If you download the APP from Apple’s App-Store, information and data insofar necessary will be transferred to the App-Store. If you download the APP from Google’s Play-Store, information and data insofar necessary will be transferred to the Play-Store. We have no influence over such data-collection and therefore can not assume any responsibility for it. We only process the data provided to the extent necessary for downloading the App onto your device. No such data will be stored beyond this.

4.2. When using PRIMLO on your phone, the following information, automatically transferred by your device in order to enable you to use the APP at all, is collected:

5. Inquiry, Contact

All personal information voluntarily provided with user’s consent will be stored and used by PRIMLO only to answer your request. As far as such personal information relates to means of communication, like e-mail-addresses and/or telephone numbers you implicitly agree to us contacting you by using the respective means of communication. Here too, you may revoke your consent at any time with future effect by sending an e-mail to: privacy@primlo.com.

6. Usage of cookies

6.1. In order to render its services more user-friendly, efficient and attractive and also to recognize you the next time you use PRIMLO, we may collect certain information using cookies, i.e. small text files stored on your device, resp. a technology with similar functions. Most of such files are deleted automatically as soon as you end your visit, others remain on your device. Neither will programs be executed nor will viruses be transferred herewith. However, you may deactivate the application of Cookies at any time changing the settings in your browser. For details please refer to the operation instructions of your browser.

7. Right to information, data portability, rectification, deletion and revocation

7.1. You are at any time entitled to free-of-charge information about your personal data stored with us, the origin, the recipient or categories of recipients to which such data is forwarded, if at all, about the purpose of the storage as well as the right to correct, block or delete such data.

7.2. You are at any time entitled to receive personal data held by us in a machine readable format.

7.3. You are at any time entitled to the rectification of your personal data.

7.4. You may revoke your consent to the collection, processing, use and transfer of your personal information at any time with effect for the future.

7.5. If you have any questions regarding the collection, processing or use of your personal data, and for information, correction, blocking and deletion of data as well as for revocation of your consents please refer to privacy@primlo.com or the address mentioned in clause 1.2. hereinabove.

8. Changes to this Privacy Policy

8.1. PRIMLO reserves the right to change or otherwise alter its privacy policy at any time in accordance with the relevant applicable data protection regulations. This will be reflected by the date below. You are advised to check this page from time to time to inform yourself of any such changes. Continued use of PRIMLO will constitute agreement to any amendments.

Last Updated: 9th May 2018