English

Collapse

Bonsy App Privacy Policy (translation*)

Updated: May 2026
Latest updates: Change overview

The following privacy policy applies to smartphone application “Bonsy” (“online product”).

We participate in the IAB Europe Transparency & Consent Framework and adhere to its specifications and guidelines. We enable you to manage your consents and objections in our consent management platform with identification number 5 (“CMP”). The CMP can be found in the Bonsy app (My Profile/Privacy settings).

* The English translation is provided for information purposes only. The original German version (available at https://www.bonsy.com/datenschutz-app) is the official privacy policy and, in case of any discrepancy, shall prevail.

1. Who are we? (controller)

Collapse

marktguru Deutschland GmbH, Sendlinger Straße 23, 80331 Munich, office@marktguru.de, hereinafter referred to as “marktguru” or “we” or “us”, is the controller within the meaning of data protection law.

Any exceptions are explained in this privacy policy.

You can find our contact details and those of our Data Protection Officer in section 15 Contact“.

2. Which categories of personal data do we process?

Collapse

2.1 General

Personal data is any information relating to an identified or identifiable natural person. Processing personal data means collecting, storing, using, transferring it to others, or deleting it, among other things.

The categories of personal data we process about you depend on how you use our online product. We have listed possible categories for you below.

2.2 Categories of personal data

Master data: When you register on our online product, we process the following data: name, address, email address, password, opt-out status. 

Contact data: When you contact us (e.g., via a contact form or email), we process the data you provide (usually your first and last name, email address and/or phone number, and the content of your inquiry) as well as any subsequent communication.

Purchase data: When you upload your receipts in the app, we process purchase data (such as shop information and discounts) and product data (such as the EAN/GTIN code of a receipt line item) that you provide. 

App configuration data: When you use our contractual services (i.e. features such as setting the language, app colour scheme, (shopping) categories, labels, or country), we process the data required for the relevant service or app configuration. 

Additional data that is part of uploaded or scanned receipts: If additional data (such as delivery address, membership number, contact details, etc.) is visible on the uploaded receipt, it is collected along with the purchase data.

Manual entries (data relating to manual entries): When you enter your one-off or regular expenses or income manually in the app, these entries are processed.

Consent declarations for direct marketing: If you have granted us your consent, we process your consent declarations for direct marketing (e.g., consent to newsletters, consent to other forms of direct marketing by electronic means, consent to the personalisation of newsletters and other direct marketing).

Push notification data: User ID, device information, consent status or information on whether push notifications are permitted.

In-app message data: User ID, device information, messages sent.

Giveaway data: If you are participating or have participated in one of our giveaways or raffles whilst using another marktguru service, and provided that you have consented to us using this data for other specified purposes, we will process the relevant data, such as participation details.

Sociodemographic data: If you participate in a voluntary survey or market survey, we process information provided by you such as age group, gender, level of education, household size, household income, nationality, employment status, main contributor in the household.

Study data: If you take part in one of our studies (user interviews, focus groups, surveys), we will process the data collected during these activities.

Log data from third-party surveys: If you participate in a market survey arranged by us and conducted by a third party, we receive information from that third party as to whether the survey has been completed (however, we do not receive any information regarding the details you provided in the respective market survey conducted by a third party).

Chat data: If you use our AI assistant, we process your prompts and chat history. 

‍Online usage data: Every time you communicate via the Internet, online usage data is generated. This includes data such as your IP address, search queries, timestamps, browser data, device information, app identifier, device ID, referrer URL, geolocation/location data, user ID, click history.

Log files: Whenever you use an online product, your device automatically transmits what is known as online usage data. This data is temporarily stored in log files to ensure technical security and functionality. The IP address is also processed to determine the country code and is not stored alongside user identifiers.

Ad blocker data: Information on whether ad blockers are present.

2.3. Data processed in connection with app identifiers

The following data is processed in connection with app identifiers and similar technologies (“app identifiers”):

  • Online usage data and email address
  • Consent to the use of app identifiers (and related data processing operations)

3. Who receives your personal data and why?

Collapse

3.1 Transfer of data to third parties

We only disclose your personal data to third parties if this is necessary for the fulfillment of the contract, if we or a third party have a legitimate interest in the disclosure, if you have granted your consent for this, or if this is necessary to fulfill a legal obligation.

Details on third parties can be found in section 4 “Why do we process your personal data, on what legal basis, what are our legitimate interests, who receives your personal data?” that follows.

We may disclose personal data to a third party in particular

  • if we are required to do so in individual cases due to legal requirements, orders by law enforcement or court orders; 
  • in connection with legal disputes (to courts or to our lawyers) or tax audits (to auditors);
  • in connection with possible criminal offenses to the competent investigating authorities;
  • in the event of a sale of the business (to the purchaser and their legal and tax advisors).

In the case of a transfer based on consent, the explanation may also be provided when consent is obtained.

3.2 Transfer of data to service providers

We reserve the right to deploy service providers when collecting or processing data. Service providers only receive the personal data required for their specific activities from us. For example, your email address may be passed on to a service provider so that they can deliver a newsletter you are subscribed to. Service providers may also be commissioned to provide server capacity. Service providers are generally deployed as so-called processors who may only process the personal data of users of this online product in accordance with our instructions. 

Details on the service providers we deploy can be found in section 4 “Why do we process your personal data, on what legal basis, what are our legitimate interests, who receives your personal data?” that follows.

4. Why do we process your personal data, on what legal basis, what are our legitimate interests, who receives your personal data?

Collapse

We process your data for the following purposes and – to the extent required by applicable law – on the basis of the legal grounds specified below. Explanations of the data categories can be found in section 2 “Which categories of personal data do we process?” In the event that data processing is based on the legal basis of legitimate interest, we also explain our legitimate interest in the respective data processing. In addition, we indicate with which recipients or categories of recipients we share your personal data.


4.1 General purposes of data processing

1.   Provision of this online product. This includes in particular:
1.1   Enabling registered users to use the login area of the online product for the purpose of contract fulfillment in accordance with our Terms and Conditions (such as storing scanned receipts, automated and manual bookkeeping)
  • Categories of personal data: master data, contact data, purchase data, additional data that is part of uploaded or scanned receipts, manual entries, log files, app configuration data
  • Legal basis for processing: 
    • contract fulfilment (Art. 6(1)(b) GDPR); 
    • legitimate interest (Art. 6(1)(f) GDPR): If additional data (such as delivery address, membership number, contact details, etc.) is visible on the uploaded receipt but is not required for the fulfilment of the contract, we collect this data along with the purchase details for commercial and technical reasons. We have a legitimate interest in enabling our users to upload receipts in various formats, so that they can, on the one hand, gain a better overview of their household expenses and, on the other hand, find their receipts in the Bonsy app at any time.
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (receipt scanner), EU/EEA area, USA
      • IT service provider (AI receipt scanner), EU/EEA area, USA
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • IT service provider (product support), Armenia
1.2   Ongoing automated evaluation of spending behaviour (cross-device)
  • Categories of personal data: log files, master data, purchase data, additional data that is part of uploaded or scanned receipts, manual entries
  • Legal basis for processing: 
    • contract fulfilment (Art. 6(1)(b) GDPR); 
    • legitimate interest (Art. 6(1)(f) GDPR): If additional data (such as delivery address, membership number, contact details, etc.) is visible on the uploaded receipt but is not required for the fulfilment of the contract, we collect this data along with the purchase details for commercial and technical reasons. We have a legitimate interest in enabling our users to upload receipts in various formats, so that they can, on the one hand, gain a better overview of their household expenses and, on the other hand, find their receipts in the Bonsy app at any time.
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • IT service provider (product support), Armenia
1.3   Linking multiple user accounts (“My household”) so that receipts from multiple users can be taken into account collectively when bookkeeping and analysing spending behaviour
  • Categories of personal data: log files, master data, purchase data, additional data that is part of uploaded or scanned receipts, manual entries
  • Legal basis for processing: 
    • consent (Art. 6(1)(a) GDPR); 
    • legitimate interest (Art. 6(1)(f) GDPR): If additional data (such as delivery address, membership number, contact details, etc.) is visible on the uploaded receipt but is not required for the fulfilment of the contract, we collect this data along with the purchase details for commercial and technical reasons. We have a legitimate interest in enabling our users to upload receipts in various formats, so that they can, on the one hand, gain a better overview of their household expenses and, on the other hand, find their receipts in the Bonsy app at any time.
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • IT service provider (product support), Armenia
1.4   Providing a channel for contact and responding to enquiries sent via this channel
  • Categories of personal data: contact data, log files
  • Legal basis for processing: 
    • contract fulfilment (Art. 6(1)(b) GDPR); 
    • legitimate interest (Art. 6(1)(f) GDPR): We have a legitimate interest in responding to customer and contact enquiries. 
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • customer support (email, phone), EU/EEA area
      • customer support (ticket system), Israel, EU/EEA area, USA
1.5   Country detection for receipts
  • Categories of personal data: log files (IP address)
  • Legal basis for processing: 
    • legitimate interest (Art. 6(1)(f) GDPR): Detecting a receipt’s country is essential for the accurate classification, analysis and presentation of country-specific market information. It enables us to improve the regional relevance of the content and analytics within the app, thereby helping to tailor the service to users’ needs and ensuring quality assurance.
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • IT service provider (product support), Armenia
      • IT service provider (geolocation), EU/EEA area, USA
1.6   Provision of an interactive AI assistant (“Bonsy Assistant”) for analysing spending habits, providing budget advice and categorising expenses
  • Categories of personal data: chat data, app configuration data, purchase data, additional data that is part of uploaded or scanned receipts, manual entries, Ausgabenanalysen, log files
  • Legal basis for processing: The data is processed on the basis of:
    • usage of the interactive AI assistant: consent (Art. 6(1)(a) GDPR); 
    • limited storage of chat data: legitimate interest (Art. 6(1)(f) GDPR) in the quality control and optimisation of our AI assistant
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (provider of AI infrastructure), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
2.   Consent and opt-out management
  • Categories of personal data: master data, consent declarations for direct marketing, consent to the use of app identifiers
  • Legal basis for processing: 
    • compliance with a legal obligation (Art. 6(1)(c) GDPR)
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (CMP provider), EU/EEA area
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
3.   Direct marketing, in-app messages, push notifications, surveys, market surveys, user interviews
3.1   Sending communications such as email newsletters or other direct marketing via electronic means (e.g. email, SMS, MMS, messengers)
  • Categories of personal data: contact data, consent declarations for direct marketing
  • Legal basis for processing: 
    • Where the requirements for contacting existing customers without consent are met: Art. 13(2) ePrivacy Directive in conjunction with Section 7(3) Act against Unfair Competition (UWG) (Art. 95 GDPR);
    • in all other cases: Art. 13(1) ePrivacy Directive in conjunction with Section 7(2)(2) UWG (Art. 95 GDPR) (consent) 

Please note that you have the right to object to the processing of data for direct marketing purposes or on personal grounds (see section 14.7 “Your right to object to direct marketing” and section 14.8 “Your right to object for personal reasons”).

  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA 
      • IT service provider (email dispatch), EU/EEA area, USA
      • customer support (email, phone), EU/EEA area, USA
3.2   Sending information emails and notifications
  • Categories of personal data: contact data
  • Legal basis for processing: 
    • legitimate interest (Art. 6(1)(f) GDPR): We have a legitimate interest in sending important information to app users (e.g. regarding unsolicited data and other matters that require clarification).
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
      • IT service provider (email dispatch), EU/EEA area, USA
      • customer support (email, phone), EU/EEA area, USA
3.3   Sending push notifications
  • Categories of personal data: push notification data
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA 
      • IT service provider (push notifications), EU/EEA area
3.4   Sending in-app messages
  • Categories of personal data: in-app message data
  • Legal basis for processing: contract fulfilment (Art. 6(1)(b) GDPR)
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
3.5   Conducting surveys, including collecting feedback.

We may also invite users to take part in a survey via electronic means outside of the app (e.g. email, SMS, MMS, messengers) if we have obtained separate consent to do so.

  • Categories of personal data: depending on the survey/feedback: personal data (e.g. name, email address if specified by you), survey responses and feedback, online usage data (such as IP address, device information, browser data, timestamps), log files, app configuration data, sociodemographic data
  • Legal basis for processing: The data is processed on the basis of:
    • For communication via electronic means outside of the app: Art. 13(1) ePrivacy Directive in conjunction with Section 7(2)(2) UWG (Art. 95 GDPR) (consent)
    • For the processing of surveys:
      • legitimate interest (Art. 6(1)(f) GDPR), as we have a legitimate interest in conducting and evaluating surveys to improve our services (e.g., to optimise our apps based on user interactions and to develop new services), or
      • consent (Art. 6(1)(a) GDPR)

Please note that you have the right to object to the processing of data for direct marketing purposes or on personal grounds (see section 14.7 “Your right to object to direct marketing” and section 14.8 “Your right to object for personal reasons”).

  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (survey tool), EU/EEA area, USA
      • IT service provider (email dispatch), EU/EEA area, USA
      • customer support (email, phone), EU/EEA area, USA
3.6   Conducting market surveys:

Market research surveys are conducted within the app. We may also invite users to take part in surveys and market research via electronic means outside of the app (e.g. email, SMS, MMS, messengers) if we have obtained a separate consent to do so. Where applicable, we may also invite you to take part in market surveys conducted by third parties; in this case, you will be redirected via a link to a page belonging to the third party that conducts the market survey under their sole responsibility. We use log data from third-party surveys for billing purposes.

Market surveys serve to measure customer sentiment/satisfaction, to adapt marketing strategies based on customer feedback, or to enable the adaptation of marketing strategies based on emerging trends.

Data collected from market surveys is shared with third parties (e.g. product manufacturers or retailers) only in an anonymised format within a controlled self-service environment for market research and statistical analysis.

  • Categories of personal data: master data, sociodemographic data, purchase data, log files, app configuration data; log data from third-party surveys, giveaway data, online usage data
  • Legal basis for processing: The data is processed on the basis of:
    • For contacting via electronic means outside of the app: Art. 13(1) ePrivacy Directive in conjunction with Section 7(2)(2) UWG (Art. 95 GDPR) (consent)
    • For processing of market surveys:
      • consent (Art. 6(1)(a) GDPR) insofar as master data, giveaway data, online usage data or sociodemographic data is also processed;
      • legitimate interest (Art. 6(1)(f) GDPR) if only purchase data, app configuration data and log data from third-party surveys is processed:
        We have a legitimate business interest in expanding our product portfolio for further clients, so that they can statistically analyse the purchasing behaviour of specific consumer groups, assess gaps in their offering or the impact of price changes, and thereby make improvements to their products and services.
        The processing also supports the legitimate business interests of our product clients in continuously adapting their product placement to meet consumer needs, thereby also serving the general economic interest of market efficiency. Furthermore, we have a legitimate interest in billing for the market surveys we arrange based on their performance.
        You have the right to object to the processing of your personal data at any time and without providing any reason; please use the contact details in section 15 for this purpose.
        Given the significantly reduced processing of personal data, the fact that this data is provided exclusively in an anonymised format (see Purpose 5.2 below) and the unconditional right to object that has been granted, we have concluded that your interests do not override ours.
        Please also note your right to object to the processing of data for direct marketing purposes or on personal grounds (see section 14.7 “Your right to object to direct marketing” and section 14.8 “Your right to object for personal reasons”).
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA 
      • IT service provider (survey tool), EU/EEA area, USA
      • IT service provider (email dispatch), EU/EEA area, USA
3.7   Personalisation of communications, including newsletters and other direct marketing via electronic means, which may include analysis of interaction with the communication (e.g. open rates, clicks on links)
  • Categories of personal data: master data, contact data, online usage data
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA 
      • IT service provider (email dispatch), EU/EEA area, USA
3.8   User interviews: scheduling and coordinating interview appointments, conducting interviews (including recording and transcribing them), and analysing the interview results to improve our products
  • Categories of personal data: contact data (scheduling), study data
  • Legal basis for processing: 
    • consent (Art. 6(1)(a) GDPR); 
    • legitimate interest (Art. 6(1)(f) GDPR), as we have a legitimate interest in inviting our app users to take part in interviews in order to improve our services.
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (email dispatch, online meeting, transcription), EU/EEA area, USA
      • IT service provider (storage tool), EU/EEA area, USA
      • IT service provider (product support), Armenia
3.9   User studies (surveys, one-on-one interviews, focus groups): registration for and scheduling user studies, conducting user studies (including recording and transcription), analysing study results to improve our products (including anonymising study data prior to analysing)
  • Categories of personal data: purchase data, app configuration data; master data, contact data (scheduling), sociodemographic data, study data
  • Legal basis for processing: 
    • consent (Art. 6(1)(a) GDPR); 
    • legitimate interest (Art. 6(1)(f) GDPR), as we have a legitimate interest in inviting our app users to take part in user studies for the purpose of marketing and improving our services.
  • Recipients or categories of recipients:
    • Processors:
      • Service provider (conducting and analysing user studies), EU/EEA area
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (email dispatch, online meeting, transcription), EU/EEA area, USA
      • IT service provider (storage tool), EU/EEA area, USA
4.   Sign-in services
4.1   Provision of a login via third-party providers (sign-in services)
  • Categories of personal data: log files, master data, obtained from the third-party provider used
  • Legal basis for processing: contract fulfilment (Art. 6(1)(b) GDPR)
  • Recipients or categories of recipients:
    • Third parties:
      • Meta Platforms Ireland Ltd., Merrion Road Dublin 4, Dublin D04 X2K5, Ireland
      • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland 
      • Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland 
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
5.   Market research, personalisation
5.1   Processing pseudonymised user profiles:

Merging (aggregation) of data collected through the product use to create pseudonymised user profiles based on which target group segments can be formed and used for market research and statistical purposes. This also includes the anonymisation of this data and its subsequent transfer to third parties in an exclusively anonymised format for the aforementioned purposes.

“Target group segments” are subgroups of a larger target group that are formed based on shared characteristics such as demographics (age, gender), interests or behaviour (usage patterns, purchase history) in order to gain insights that are as specific as possible.

“Pseudonymised” means that your data has been modified in such a way that it can no longer be linked to you without the use of additional information. This additional information is stored separately, thus ensuring that your data is particularly securely protected.

“Anonymised” means that your data has been modified in such a way that it is no longer possible to identify you.

  • Categories of personal data: master data, sociodemographic data, purchase data, giveaway data, log data from third-party surveys; app configuration data; online usage data
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA 
5.2   Where you have not given us your consent to the data processing referred to in purpose 5.1, the following processing will take place:
Reduced merging (aggregation) of data collected through the product use to create pseudonymous user profiles for market research purposes and for statistical purposes. 

In the case of market research, we provide third parties (product manufacturers, retailers, etc.) with a reduced dataset in an anonymised format within a controlled self-service environment for market research and statistical purposes.

  • Categories of personal data: purchase data, app configuration data; log data from third-party surveys
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR):
    We have a legitimate business interest in expanding our product portfolio for further clients, so that they can statistically analyse the purchasing behaviour of specific consumer groups, assess gaps in their offering or the impact of price changes, and thereby make improvements to their products and services.

    Our legitimate interest lies, in particular, in generating new sources of revenue through the new product and in establishing a broader market presence by expanding our product portfolio.

    The processing also supports the legitimate business interests of our product clients in continuously adapting their product placement to meet consumer needs, thereby also serving the general economic interest of market efficiency.

    You have the right to object to the processing of your personal data at any time and without providing any reason; please use the contact details in section 15 for this purpose.

    Given the significantly reduced processing of personal data, the fact that this data is provided exclusively in an anonymised format and the unconditional right to object that has been granted, we have concluded that your interests do not override ours.

    Please also note your right to object to the processing of data for direct marketing purposes or on personal grounds (see section 14.7 “Your right to object to direct marketing” and section 14.8 “Your right to object for personal reasons”).

  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
5.3   Where you have given us your consent to conducting market surveys (see purpose 3.6) and to process pseudonymous user profiles (see purpose 5.1), we may make the data processed on the basis of this consent available to third parties (market research companies, product manufacturers, retailers, etc.) in an anonymised format for market research and statistical purposes.
  • Categories of personal data: purchase data, sociodemographic data
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR):
    We have a legitimate business interest in expanding our product portfolio for further clients, so that they can analyse the purchasing behaviour of specific consumer groups, assess gaps in our offering or the impact of price changes, and thereby conduct market research.

    Our legitimate interest lies, in particular, in generating new sources of revenue through the new product and in establishing a broader market presence by expanding our product portfolio.

    The processing also supports the legitimate business interests of market research companies and, directly or indirectly, of product manufacturers in conducting market research, thereby also serving the general economic interest of market efficiency.

    You have the right to object to the processing of your personal data at any time and without providing any reason; please use the contact details in section 15 for this purpose.

    Given that only a subset of exclusively anonymised data processed with your consent is made available, and in view of the unconditional right to object that has been granted, we have concluded that your interests do not take precedence.

    Please also note your right to object to the processing of data for direct marketing purposes or on personal grounds (see section 14.7 “Your right to object to direct marketing” and section 14.8 “Your right to object for personal reasons”).

  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA
5.4   Providing personalised content and offers via our own channels (our own portals, newsletters and other communication channels), personalising surveys and our advertising activities on third-party channels
  • Categories of personal data: master data, sociodemographic data, purchase data, giveaway data, app configuration data; log data from third-party surveys, online usage data, log files
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA
      • IT service provider (product support), Armenia
      • IT service provider (provider of usage analytics and technical monitoring tools), EU/EEA area, USA 
6.   IT security
6.1   Identification and, if necessary, blocking of users who have an ad blocker installed and are therefore blocking advertisements
  • Categories of personal data: log files, ad blocker data
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in making our wholly or partially ad-supported offerings available only to users who do not block advertising
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
6.2   Identification of malfunctions and ensuring system security, including detection and tracking of unauthorised access and access attempts to our web servers
  • Categories of personal data: log files, online usage data
  • Legal basis for processing: 
    • fulfillment of our legal obligations (Art. 6(1)(c) GDPR) to comply with data security requirements; and
    • legitimate interest (Art. 6(1)(f) GDPR) in eliminating malfunctions, ensuring system security, and detecting and tracking unauthorised access attempts or accesses
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
      • IT service provider (hosting), EU/EEA area, USA 
      • IT service provider (product support), Armenia
7.   Legal purposes
7.1   Compliance with statutory retention requirements and other legal obligations (e.g., in connection with tax audits)
  • Categories of personal data: master data
  • Legal basis for processing: 
    • fulfillment of our legal obligations (Art. 6(1)(c) GDPR), in particular with regard to the retaining of certain information and in connection with tax audits;
    • legitimate interest (Art. 6(1)(f) GDPR) in fulfillment of requirements necessary for compliance with legal obligations
  • Recipients or categories of recipients:
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
7.2   Safeguarding and defending our rights
  • Categories of personal data: details from legal disputes in which you are involved, information necessary for the processing of legal disputes
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in asserting and defending our rights
  • Recipients or categories of recipients:
    • Third parties:
      • our legal advisors (EU/EEA area, United Kingdom), courts, authorities
    • Processors:
      • IT service provider (technical support), EU/EEA area, USA
7.3   Sale of the business, in full or partially
  • Categories of personal data: all information relevant to the sale, e.g., master data, declarations of consent for direct marketing
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in transferring customer data to the purchaser in connection with a sale of our business; as a rule, this requires that customers have consented to a transfer of contract or have not objected to a transfer after receiving sufficient information
  • Recipients or categories of recipients:
    • Third parties:
      • our legal advisors (EU/EEA area, United Kingdom), (potential) acquirer of the business (or its part)
    • Processors:
      • IT service provider (technical support), EU/EEA area
      • IT service provider (hosting), EU/EEA area, USA

4.2   Purposes of processing in connection with app identifiers

This online product incorporates processes based on app identifiers. We participate in the IAB Europe Transparency & Consent Framework and adhere to its specifications and guidelines. Below you will find information about the purposes for which we or our partners use app identifiers. Further details can be found in our CMP which you can access in the Bonsy app (My Profile/Privacy settings).

‍1.   Store and/or retrieve information on a device
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Section 25 TDDDG in conjunction with Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
2.   Use limited data to select advertising. Ads may be displayed to you based on the content you are viewing, the app you are using, and your approximate location or device type.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in displaying ads that are as interesting as possible to our users and thus offer them added value; or consent (Art. 6(1)(a) GDPR). The specific legal basis used for this purpose can be found in our CMP. 
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
3.   Create profiles for personalised advertising. A profile about you may be created based on your interests in order to display personalised ads that are relevant to you.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
4.   Select personalised ads. Personalised ads may be displayed to you based on a profile created about you.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
5.   Create profiles to personalise content. A profile about you may be created based on your interests in order to display personalised content that is relevant to you.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
6.   Select personalised content. Personalised content may be displayed to you based on a profile created about you.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
7.   Measure advertising performance. The performance and effectiveness of ads displayed to you or ads that you interact with may be measured.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in the efficient display and billing of advertisements, or consent (Art. 6(1)(a) GDPR). The specific legal basis used for this purpose can be found in our CMP. 
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
8.   Measure content performance. The performance and effectiveness of content displayed to you or content that you interact with may be measured.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in displaying content that is as interesting as possible for our users and thus offers them added value, or consent (Art. 6(1)(a) GDPR). The specific legal basis used for this purpose can be found in our CMP.
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
9.   Use market research to gain insights into target audiences. Market research can be used to find out more about the target audiences who use services or applications and view ads.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in better understanding target groups and optimising our own product; consent (Art. 6(1)(a) GDPR). The specific legal basis used for this purpose can be found in our CMP. 
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
10.   Develop and improve products. Your data may be used to improve existing systems and software and to develop new products.
  • Categories of personal data: online usage data
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in developing and improving our products
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
11.   Ensure security, prevent fraud, and fix errors. Your data can be used to detect and prevent fraudulent activities, and to ensure that systems and processes operate correctly and securely.
  • Categories of personal data: online usage data
  • Legal basis for processing: legitimate interest (Art. 6(1)(f) GDPR) in ensuring security, preventing fraud, and troubleshooting
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
12.   Deliver and display ads or content. Your device may receive and transmit information that is necessary for you to view and use content and ads.
  • Categories of personal data: online usage data, sociodemographic data
  • Legal basis for processing: contract fulfilment (Art. 6(1)(b) GDPR): provision of content; legitimate interest (Art. 6(1)(f) GDPR) in the provision of ads
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
13.   Link different devices. To enable use for one or more processing purposes, we may determine whether different devices belong to you or your household.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
14.   Receive and use automatically transmitted device properties for identification. Your device can be distinguished from other devices based on information it transmits automatically, such as its IP address or browser type.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
15.   Use precise location data. Your precise location data may be used for one or more processing purposes. This means that your location can be determined with an accuracy of just a few metres.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.
16.   Actively retrieve device properties for identification. Your device can be identified by retrieving its specific properties.
  • Categories of personal data: online usage data, consent to the use of app identifiers
  • Legal basis for processing: consent (Art. 6(1)(a) GDPR)
  • Recipients: Details regarding the recipients of personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on which of our service providers receive your personal data for this purpose.

4.3   Push notifications

You may receive push notifications from us, even when you are not using this online product at the moment. These may be messages that we send you in connection with the performance of a contract (e.g., notification of service outage due to maintenance work), but they may also contain promotional information. You will only receive push notifications of any kind if you have expressly consented to this. You can stop receiving push notifications at any time via the device settings on your end device.

4.4   In-app messages

You may receive so-called in-app messages from us, but only when you are using the app. These may be messages that we send you in connection with the performance of the contract (e.g., notification of service outages due to maintenance work), but they may also contain advertising information. If you do not wish to receive in-app messages, you should not use the app.

5. Note on data processing by app store operators

Collapse

Before you can install this app, you may need to enter into a user agreement with an app store operator (e.g., Google, Apple) regarding access to their portal (e.g., Google Play, App Store). In its capacity as the data controller, the app store operator collects and processes data such as user name, email address, and individual device identification number in connection with the use of the app store. We are not a party to the user agreement with the app store operator and have no influence on how it processes data. In this respect, the privacy policy of the respective app store operator applies.

6. When do we transfer data to countries outside the european economic area?

Collapse

We also transfer personal data to third parties or processors based in non-EEA countries.
Prior to such data transfers, we ensure that the recipient maintains an adequate level of data protection – for example:

  • on the basis of an adequacy decision by the European Commission (Art. 45 GDPR),
  • by entering into EU Standard Contractual Clauses (Art. 46 GDPR, Module 1 or 2), including carrying out a transfer impact assessments (TIA), and, where necessary, by implementing additional technical or organisational safeguard measures.

Where possible, we specifically select providers that operate data centres in the EU or the EEA for the processing and storage of personal data.

This involves third parties, or data processors, in the following countries: USA; Israel; Armenia.

With regard to the USA, the European Commission has concluded that an adequate level of data protection exists there, provided that the data recipient participates in the Data Privacy Framework (DPF) and holds a valid certification. Where the recipients of your personal data are based in the USA and participate in the DPF, we therefore rely on this adequacy decision (Art. 45 GDPR).

To which countries outside the European Economic Area (if you are located within the EEA) do we disclose data?

We disclose personal data to third parties or processors in the following countries with an adequate level of data protection under applicable law: USA (if the recipient is certified under the EU-U.S. Data Privacy Framework), Israel (Data Processing Addendum).

Furthermore, we disclose personal data to third parties or processors in the countries listed below in which, under applicable law, there is no adequate level of data protection. The transfer or disclosure is based on the respective security measure or exemption provision specified: USA (based on Standard Contractual Clauses if the recipient is not certified under the EU-U.S. Data Privacy Framework), Armenia (Standard Contractual Clauses).

You can request that we provide you with an overview of the recipients in third countries and a copy of the specific arrangements agreed to ensure an adequate level of data protection. Please use the contact details provided in section 15 “Contact” for this purpose.

7. How long do we store your data?

Collapse

We store your data for as long as is necessary to provide our online product and the associated services, or for as long as we have a legitimate interest in further storage (e.g. due to an ongoing legal dispute). In all other cases, we delete your personal data with the exception of data that we must retain in order to comply with statutory retention periods (e.g., tax or commercial law).

Personal data that is subject to a retention period is blocked until the retention period expires.

Specifically, the following retention periods apply to the personal data processed within the scope of this online product:

  • Provision of this online product: For the duration of the registration; if the user requests the deletion of their user account, it will be permanently deleted within 10 days; any statutory retention periods shall be observed.
  • Country detection for receipts: The data processed for this purpose (IP addresses) is stored by our service provider for 14 days after transmission and subsequently deleted. We only store information about the country, together with the receipt.
  • Providing a channel for contact, sending information emails and notifications: Until the communication finishes and then for a further three years, beginning at the end of the calendar year.
    Data will be stored until it is no longer required to fulfil the purpose for which it was collected and there are no legal retention obligations to the contrary.
    In the case of enquiries that have not led to a contractual relationship, this is generally the case when the circumstances indicate that the specific matter has been conclusively resolved.
  • Providing the AI assistant: 90 days after the chat history has been closed for error analysis and quality control
  • Sending newsletters, in-app messages and push notification: Data will be stored until it is no longer required to fulfil the purpose for which it was collected and there are no legal retention obligations to the contrary.
    In the case of newsletters, this is generally the case when you withdraw your consent or object to the processing.
  • Conducting surveys/obtaining feedback; user interviews; user studies: Until the survey/interview is completed and then for a further six months, beginning at the end of the calendar year (where the processing is based on your consent: until the consent is withdrawn). 
  • Conducting market research and market surveys: 
    • If you have granted us your consent:
      • Data will be stored until it is no longer required to fulfil the purpose for which it was collected and there are no legal retention obligations to the contrary. 
      • In the context of conducting market research and market surveys, this is usually the case if you withdraw your consent or object to the processing.
    • If we process pseudonymous data based on our legitimate interest: 
      • We store this data in pseudonymised form for a maximum of two years. We also store this data in an anonymised format for further analysis for internal statistical purposes.
  • IT security: log files: depending on the system (from 7 days to 13 months) and as long as there has been no security incident that requires longer storage.
  • Legal purposes: Data will be stored until it is no longer required to fulfil the purpose for which it was collected and there are no legal retention obligations to the contrary.
    In the context of legal disputes, this is the case when the disputes have been permanently settled.
  • Consents to the use of app identifiers (and data processings associated with them): Details regarding the storage periods for personal data can be found in our CMP that can be accessed in the Bonsy app (My Profile/Privacy settings). Under “Vendors”, you will find information on how long collected personal data is processed.

8. Are you obliged to provide us with personal data?

Collapse

In principle, you are not obliged to provide us with your personal data. However, you might be required to provide personal data to be able to use certain services of this online product, e.g., if you want to to register or to participate in a giveaway. If this is the case, we will inform you accordingly. Mandatory fields are usually marked with an asterisk (*). If you do not wish to provide us with the necessary data, you will unfortunately not be able to use the corresponding services.

9. App identifiers

Collapse

This online product uses app identifiers.

App identifiers are randomly generated identifiers assigned by the operating system of your device. They are shared with the servers of our apps that you use to enable recognition of your device.

You can find detailed information about app identifiers on our consent management platform (also known as CMP) that can be accessed in the Bonsy app (My Profile/Privacy settings). Where processes involving the processing of personal data based on these technologies are concerned, you will also find further details there regarding the purposes for which they are used.

Certain app identifiers are absolutely necessary so that we can securely provide our online product in the manner you expect –  we are allowed to use such app identifiers without your consent. For all other app identifiers, we ask for your consent in our CMP. You can give your consent via our CMP and revoke it at any time with future effect by adjusting the privacy settings. You can delete app identifiers in your device’s settings. Please note that this online product may not function or may only function to a limited extent without essential app identifiers.

If you use our online product as a registered user while logged in, we will apply the privacy settings stored in your user profile. This data is taken from your CMP settings prior to your first login to one of our services and is updated each time you change your privacy settings in the respective CMP while logged in. Please note that updates in other products will only take effect after you reload the respective online products, e.g., by opening the app. Please also note that any consent decision you have made while logged out will only apply while you are logged out, as we are unable to assign it to your user profile. If you wish to change your privacy settings in your user profile, please log in first.

10. Share functions

Collapse

Your mobile device allows you to share content from the app with third parties (e.g., via email, SMS, or the share functions of social networks). We have no influence on the data processing associated with the respective third party, e.g., by social network providers. In this context, the respective third-party providers are the sole controllers.

11. Use of the online product with or without registration

Collapse

We offer you the option of using our online product both as an unregistered user (in a “guest mode”) and as a registered user, by creating a personal user account.

If you use the app without a user account, the receipt data and statistics recorded are technically linked only to your device’s unique identifier. This means that your data is stored locally on the respective device. If you switch devices or reinstall the online product, this information cannot be transferred to a new device, as our system will create a new profile that cannot be technically linked to your previous data. Therefore, it is not possible to restore your data in the guest mode.

On the other hand, when you register a user account, your data is linked to your user account. This offers you the advantage of easily transferring your receipts and statistics when changing devices and synchronising them across devices. Furthermore, as a registered user, you benefit from an extended range of features.

You can find more detailed information about the features of the online service in the FAQs: https://www.bonsy.com/en/faq.

12. Sign-in services (registration via third-party providers)

Collapse

12.1 Registration/login via Facebook („Facebook Connect“)

We offer you the option of registering or logging in with us via your Facebook account. If you make use of this option, we will receive the data required for registration or login from Meta Platforms Ireland Ltd., Merrion Road Dublin 4, Dublin D04 X2K5 Ireland (“Facebook”) (e.g., email address, name).

We have no influence on the scope of data collected by Facebook via the Facebook login. If you do not want Facebook to collect data about you in connection with your use of our online offering and use it for its own purposes, you should not use the Facebook Connect service. 

For more information about the purpose and scope of the collection, further processing, and use of your data by Facebook, as well as your rights and settings options for protecting your data, please refer to Facebook’s privacy policy.

12.2 Registration/login via Google („Google OAuth“)

We offer you the option of registering or logging in with us via your Google account. If you make use of this option, we will receive the data required for registration or login from Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland (“Google”) (e.g., email address, name).

We have no influence on the scope of data collected by Google via Google login. If you do not want Google to collect data about you in connection with your use of our online services and use it for its own purposes, you should not use the Google OAuth service. 

Further information about the purpose and scope of the collection and further processing and use of your data by Google, as well as your rights and settings options for protecting your data, can be found in Google’s privacy policy.

12.3 Registration/login via Apple („Sign in with Apple“)

We offer you the option of registering or logging in with us via your Apple ID. If you make use of this option, we will receive the data required for registration or login from Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland (“Apple”) (e.g., email address, name).

As part of the Apple ID service, Apple offers a “Hide Email Address” feature that allows you to create a unique, random email address, ensuring that your personal email address remains private.

We have no influence on the scope of data collected by Apple via Apple ID. If you do not want Apple to collect data about you in connection with your use of our online product and use it for its own purposes, you should not use the Sign in with Apple service. 

Further information about the purpose and scope of the collection and further processing and use of your data by Apple, as well as your rights and settings options for protecting your data, can be found in Apples’s privacy policy: https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/.

13. Newsletters and other direct marketing by electronic means

Collapse

13.1 Newsletters with registration and other direct marketing by electronic means

We offer you the option of subscribing to a newsletter or consenting to receive other forms of direct marketing by electronic means (e.g., via email, MMS, messengers or SMS). You can revoke your corresponding consent at any time with effect for the future. Further details in this regard can be found in section “Your right to withdraw consent”.

13.2 Newsletters without registration and other direct marketing by electronic means

If we receive your email address in connection with the sale of a product or service and you have not objected to this, we reserve the right to regularly send you offers for similar products or services from our portfolio by electronic means. You can object to this at any time without incurring any costs. Further details in this regard can be found in section “Your right to object to direct marketing”.

13.3 Personalised direct marketing

We offer you the option of receiving personalised newsletters or other forms of direct marketing by electronic means that are specifically tailored to your interests. For the processing of your data for personalisation purposes a separate dedicated consent is obtained. The data categories we wish to process for personalisation are described in the declaration of consent. You can revoke your corresponding consent at any time with effect for the future. Further details in this regard can be found in section “Your right to withdraw consent”.

14. Your rights (rights of the data subject)

Collapse

14.1 How can you exercise your rights?

To assert your rights, please use the contact details provided in section 15 Contact. Please ensure that we are able to clearly identify you. 

Alternatively, you can also use the settings options in your user account to correct the data you provided during registration or to object to advertising. In addition, you can use the “Unsubscribe” link at the end of each email to object to advertising.

Your settings for app identifiers and the data processing based on them can be adjusted at any time in our consent management platform that can be found in the Bonsy app (My profile/Privacy settings).

You can also delete your user account yourself by following these steps: Click on the “Profile” button in the “My profile” section to access your account settings. To delete your account, simply click on the red “Delete account” link.

14.2 Your right of access and right to rectification

You have the right to request that we confirm whether we process personal data relating to you, and you have a right to information regarding the data we process. If your data is incorrect or incomplete, you can request that your data be corrected or completed. If we transfer your data to third parties, we will inform them of the correction, insofar as this is required by law.

14.3 Your right to erasure (“right to be forgotten”)

Provided the legal requirements are met, you have the right to request that we delete your personal data immediately. This is particularly the case if

  • your personal data is no longer required for the purposes for which it was collected;
  • the legal basis for processing was solely your consent and you have revoked this;
  • you have objected to processing for advertising purposes (“objection to direct marketing purposes”);
  • you have objected to processing on the basis of legitimate interest for personal reasons, and we cannot demonstrate compelling legitimate grounds for this processing;
  • your personal data has been processed unlawfully; or
  • your personal data must be deleted to comply with legal requirements.

Should your data be shared with third parties, we will inform them of the deletion, insofar as this is required by law.

Please note that your right to erasure is subject to restrictions. For example, we are not required or allowed to erase data that we are still required to retain due to statutory retention periods. Data that we require to assert, exercise, or defend legal claims is also excluded from your right to erasure.

14.4 Your right to restriction of processing

Provided the legal requirements are met, you have the right to request that we restrict processing. This is particularly the case if

  • the accuracy of your personal data is disputed by you, and then until we have had the opportunity to verify its accuracy;
  • the processing is not lawful, and you request restriction of use instead of erasure (see previous section);
  • we no longer need your data for the purposes of processing, but you need it to assert, exercise, or defend your legal claims;
  • you have objected on personal grounds, and until it is determined whether your interests prevail.

If the right to restrict processing is confirmed, we will mark the data concerned accordingly to ensure that it is only processed within the narrow limits that apply to such restricted data (namely, for the defense of legal claims or with your consent).

14.5 Your right to data portability

You have the right to receive personal data that you have provided to us for the performance of a contract or on the basis of consent in a structured, commonly used, and machine-readable format. In this case, you may also request that we transmit this data directly to a third party, provided this is technically feasible.

14.6 Your right to withdraw consent

If you have given us your consent to process your data, you can revoke this consent at any time with effect for the future. The lawfulness of the processing of your data until revocation remains unaffected. 

14.7 Your right to object to direct marketing

You also have the right to object to the processing of your personal data for advertising purposes at any time (“objection to direct marketing”). Please note that for organisational reasons, there may be an overlap between your objection and the use of your data in the context of an ongoing campaign.

14.8 Your right to object for personal reasons

You have the right to object to our processing of your data for reasons arising from your particular situation, insofar as this is based on the legal basis of legitimate interest. We will then stop processing your data unless we can demonstrate compelling legitimate grounds for further processing in accordance with legal requirements that outweigh your rights, or the processing serves to assert, exercise, or defend legal claims.

14.9 Your unconditional right to certain processing activities

Where data processing is based on the legal basis of legitimate interest, you have the right, at any time and without giving reasons, (i) to object to the conducting of market surveys (see purpose 3.6 in section 4.1), (ii) the merging of your personal data collected through product use to create pseudonymous user profiles for market research and statistical purposes (see purpose 5.2 in section 4.1), and (iii) the provision of your data, which we process on the basis of your consent to the conducting of market surveys (see purpose 3.6 in section 4.1) and to the processing of pseudonymous user profiles (see purpose 5.1 in section 4.1), to third parties in an anonymised format for market research and statistical purposes (see purpose 5.3 in section 4.1).


14.10 Your right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection authority. In particular, you can contact the data protection authority responsible for your place of residence or federal state, or the authority responsible for the place where the violation of data protection law occurred. Alternatively, you can also contact the data protection authority responsible for us.

15. Contact

Collapse

For information and suggestions on the subject of data protection, please contact us or our data protection officer at datenschutz@bonsy.com.

You can also contact our data protection officer at the following postal address:

Maximilian Hartung
eDSB – Datenschutzbeauftragter
SECUWING GmbH & Co. KG | Datenschutz-Agentur.de
Frauentorstraße 9
86152 Augsburg, Germany
epost@datenschutz-agentur.de

T +49 (0) 821 90786450

If you would like to contact us by other means, you can also reach us as follows:

marktguru Deutschland GmbH
Sendlinger Straße 23
80331 Munich, Germany