Legal Notice
Privacy Policy
When you use this application FROMM Visual Assistance ("Service App") from FROMM System GmbH ("Fromm System" or "we"), various personal data that can be used to personally identify you and other affected parties ("Data Subjects") is collected. We take the protection of the personal data of the Data Subjects very seriously and treat personal data confidentially and in accordance with the statutory data protection regulations. The following notes provide a simple overview of the processing of your personal data within the scope of the intended use of this Service App (answering service requests by Fromm System Group employees). In addition, we would like to point out that data transmission over the Internet (e.g. when communicating with our server) can have to security gaps and that the Service App may be used contrary to its intended use. It is therefore not possible for us to completely protect the data from access by third parties.
Who is responsible for data collection within the Service App?
Data processing within the Service App is carried out by the publisher of the Service App. This is:
Fromm System GmbH
Neulandstraße 10
77855 Achern
Germany
As data protection officer has been appointed:
Peter Dippold, who can be contacted at datenschutz@frommsystem.de or at +49-7221-3577374
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This can be data that you enter directly into the Service App, such as chat messages.
On the other hand, data is collected after our Service App has been granted access to the data storage of your mobile device, e.g. in the context of the provision and storage of documents such as technical drawings or similar on your mobile device.
Finally, data is automatically collected by our IT systems when the Service App is used. This is mainly technical data (e.g. mobile device, operating system or time of use). This data is collected automatically as soon as you use our Service App.
What do we use your data for?
The data is primarily collected to enable you as a user to use the service and to bill you for our services.
When downloading our Service App, only the necessary information is transferred to the App Store, in particular
We have no influence on the collection, processing and use of this personal data in connection with your registration and the provision of downloads in the respective App Store and the App Store¬ Software. In this respect, the provider of the respective App Store is solely responsible. If necessary, please contact the respective App Store provider directly.
We do not pass on data to Apple or Google.
Calling up our Service App and communication with service technicians of the Fromm System Group
With our Service App, you as a user can communicate with service technicians of the Fromm System group of companies with sound and image support. However, it is not possible to establish initial contact with the Service App and this must be done by other means, e.g. by telephone. Before contacting a company of the Fromm System Group of Companies, please note the applicable data protection regulations, which can be found on the website of the respective company. The respective companies of the Fromm System Group of Companies are responsible for processing your data in cases of contact enquiries.
After an initial conversation by telephone, you can provide the Fromm System Group service technician with an individually created, non-reproducible session number / session ID to start the audio and video transmission. The Service App will only access the data storage / functionalities of your terminal device if you grant us access authorisation for this purpose (for further details, please refer to section 3 of this data protection notice). The Service App supports both audio and video communication, which is why other means of communication can be switched off during the call with the service technician of the Fromm System Group.
Using the Service App
Accordingly, the use of our Service App is only possible without registration and without creating a user account in the Service App. Nevertheless, during communication with our server, the Service App automatically transmits data, which are automatically stored by the server in so-called server log files. These data are:
The collection of this data is based on Art. 6. (1) (f) GDPR, provided that the data is personal data at all. We have a legitimate interest in the technically correct display and optimization of our Service App; for this purpose the server log files must be recorded. A consolidation of this data with data from other data sources is not carried out.
Data transmissions
The software and the IT infrastructure of the Service App are operated by an external service provider ("Partner"). The personal data collected when accessing these files is stored on the Partner's servers. Our partner will only process your data to the extent necessary to fulfil its service obligations and will follow our instructions in relation to such data. In order to ensure that the processing complies with data protection regulations, we have concluded a contract for commissioned data processing with our partner.
This Service App uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as requests that you send to us as the provider of the Service App. When SSL or TLS encryption is enabled, the information you submit to us cannot be read by third parties.
Storage of communication and content data of the Service App
Your communication with our service technicians is treated confidentially. A history of the session with
is stored on our server for accounting purposes and assigned to the respective business customer. In addition, the first and last names of the calling person are noted.
As far as a personal reference is given, the processing of the data takes place primarily for accounting purposes for the fulfilment of the concluded service contract; legal basis is insofar Art. 6 (1) (b) GDPR. In addition, Fromm System has a legitimate interest in the storage of service-related communication and content data. This results from the improvement of our service quality, the reduction of the administrative effort as well as the improved control of the communication with the service technicians. In this respect, the legal basis is Art. 6 (1) (f) GDPR.
No tracking / user profiling
The Service App does not use cookies or comparable technologies to track users, to control advertising or to create user profiles.
In order for the Service App to work properly, you need to grant access to certain smartphone features. For example, you will be prompted once at the beginning or when you use the function in question to grant the appropriate access permission:
If you allow access to these functions, the Service App will only access your data and transfer it to our server to the extent necessary to provide the functionality. We will treat your data confidentially and delete it if you revoke the rights of use or if it is no longer required for the provision or billing of services and if there is no legal obligation to retain it.
Revocation of access permission
You can revoke the access authorizations as follows:
If you use Android:
If you use iOS:
When you uninstall the Service App, the permissions are also automatically deleted.
You can voluntarily provide personal data when using our Service App or transfer this data to us. When using the services and functions described below, personal data is processed by us.
Image and sound transmission
If you allow a snapshot or video to be taken by your smartphone and transfer it to us, we cannot exclude the possibility that recordings of you or third parties as Data Subjects may be transferred to us. In such a case, physical characteristics such as size, hair colour or appearance may be processed.
We explicitly point out that we do not explicitly request or arrange for these physical characteristics to be requested or processed in order to answer your service request ("imposed data"). If data provided by you, such as physical characteristics of affected persons, are transmitted to us, the transmission is voluntary and without any initiation on our part.
By using the Service App, we can only record or evaluate your environment to the extent that you as a user grant us access to the image and sound transmission. We do not use technology to add context-specific information ("augmented reality") to your environment and, in particular, we do not use location-based or device-based tracking of affected persons.
Chat and translation function
If you communicate with us via the chat function, you have the option of having messages translated into another language either as text or as audio chat using an external translation service within the Service App.
We use Google Translate (operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland ("Google")) for this purpose. For data protection reasons, Google Translate is deactivated in the standard setting, recognisable by the grey display of the text "Select language". Only when you click on the text "Select language" is Google Translate activated and data is transferred to Google. For this purpose, your IP address is transmitted to Google servers. We have no influence on the collected data and data processing procedures.
The audio messages played back are used only for the translation of the message and are stored exclusively in text form. The data processing is used for communication with our service technician, e.g. in case of different native language of our service technician. In this respect, the legal basis is primarily Art. 6 (1) (b) GDPR. Fromm System has a legitimate interest in the processing of service-related chat content. This results from the improved productivity of all those involved, the reduction of administrative work and the improved control and communication with the service technicians. The legal basis in this respect is Art. 6 (1) (f) GDPR.
Within our company, only those persons who need to have access to personal data for the purposes stated in each case have access. We will only pass on your personal data to external third parties if this is necessary to process or handle your request, if another legal permission exists or if we have your consent.
The data will only be passed on to another company of the Fromm System Group of Companies if this is necessary to process your request or in connection with the processing and billing of the service request.
In addition, (external) recipients may also be contract processors, i.e. external service providers that we use to provide services, for example in the areas of technical infrastructure and the development and maintenance of our IT systems. Our external service providers have no direct access to the communication and content data of the Service App.
Personal data may be processed in the context of translation services or, in the case of cooperation with national companies of the Fromm System Group of Companies, in individual cases also in a third country. Before transferring data to external recipients in third countries, we ensure that an adequate level of data protection exists in the third country by means of suitable guarantees, e.g. certification under the EU-US Privacy Shield or EU standard contract clauses.
We only store personal data until the purpose for which it was collected ceases to apply; it is necessary in order to provide a service that you have requested or for which you have given your consent, or in the absence of any legal obligations to the contrary, such as storage periods under commercial or tax law.
As a data subject, you have numerous rights at your disposal. In particular:
Right of Access: You have the right to have access to your data that we store.
Right to Rectification and Erasure: You can demand that we rectify inaccurate personal data and - if the legal requirements are met - erase your data.
Right to Restriction of processing: You can demand that we restrict the processing of your data, provided the legal requirements are met.
Right to Data portability: If you have provided us with data on the basis of a contract or consent, you may, if the legal requirements are met, demand that you receive the data you have provided in a structured, common and machine-readable format or that we transfer it to another responsible party.
Right to object to data processing on the basis of Art. 6 (1 ) (e) or (f) GDPR: You have the right to object to data processing by us at any time for reasons arising from your particular situation, provided that this is based on the legal basis "legitimate interest". If you exercise your right of objection, we will stop processing your data unless we can prove- in accordance with the legal requirements - that there are compelling legitimate grounds for the processing which override your rights or unless we demonstrate the establishment, exercise or defence of legal claims.
Withdrawal of consent: If you have given us consent to process your data, you can withdraw this consent at any time with effect for the future. The lawfulness of the processing of your data until withdrawal remains unaffected.
Right to lodge a complaint with a supervisory authority: You can also lodge a complaint with the competent supervisory authority if you believe that the processing of your data violates applicable law. To do so, you can contact the data protection authority responsible for your place of residence or your country or the data protection authority responsible for us.
The current version of this privacy policy applies.
Last update: July 2020