Information pursuant to Art. 13 GDPR
(as of 07.2022)
Halocline collects and processes various data in order to make the provided software as available as possible and to provide support accordingly.
Halocline collects these data especially in the following situations:
Insofar as the data processed is personal data, we have listed below the legal basis for the processing. In addition, we have named the service providers who support us in offering our product and also process data for this purpose. We have concluded the necessary data protection agreements with all service providers.
Categories of personal data
Technical data
Contract performance Art. 6 lit.b GDPR
Justified interest to ensure the necessary data security Art. 6 lit f GDPR
Service provider used: Keygen LLC
Usage data
Data collection and processing only takes place with the consent of the user (Opt-In), Art. 6 Abs. 1 S. 1 lit a DSGVO
Service provider used: Google (Google Analytics)
The personal data collected is used for the following purposes
Technical Data
Usage data
Multi-User
As part of our multi user functionality voice data may be sent to our server. You can choose to activate or deactivate the voice transmission prior to entering the session.
When the voice transmission is activated the data are only forwarded by the server. Theses data are not persisted and proceed or analysed in another way.
The chosen name (must not be the real name) and avatar are visible to other participants. There data can be changed for every session and are not persisted on the server.
Use of third-party tools for data collection and evaluation
Unity
Our software integrates components of the third-party software Unity from Unity Technologies ApS, Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark (hereinafter “Unity”). Unity collects user data and processes it in a third country. Unity’s privacy policy can be found at the following link https://unity3d.com/legal/privacy-policy.
Google Analytics
If you have given your consent during installation (opt in), Halocline uses Google Analytics, an analysis service of Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
Halocline sends usage behaviour data to Google Analytics, which enables analysis of the use of our application. The information sent by Halocline to Google Analytics about your use of the application is usually transferred to a Google server in the United States and stored there. Legal basis and revocation possibility for this data processing is your consent is necessary, Art.6 para.1 p.1 lit.a DSGVO. You can revoke your consent at any time with effect for the future by calling up the settings in Halocline and changing your selection for collecting data there. Further information on the terms of use of Google Analytics and on data protection at Google can be found at https://marketingplatform.google.com/about/analytics/terms/us/ and https://policies.google.com/?hl=en. See also: https://www.dr-datenschutz.de/fachbeitraege/google-analytics-datenschutzkonform-einsetzen/
Microsoft Azure
The data processing of the data listed under “Technical Data” is carried out by Azure from Microsoft. The data is processed, stored and deleted exclusively in the EU after the periods listed under “Storage and deletion of data”. The contract for commissioned data processing (DPA) and the data protection regulations can be found within the regulations for online services (OST) of Microsoft under the following link: https://www.microsoft.com/en-us/licensing/product-licensing/products?rtc=1
Keygen
Date necessary for licensing listed under “Technical Data” are processed by the service Keygen. These data are transferred to the United States for processing. The appropriate level of data protection is ensured by concluding EU standard contractual clauses.
Storage and deletion of data
Personal data that is processed for the purpose of fulfilling the contract will be retained for the duration of the contractual relationship and then deleted if the statutory retention periods of 10 years according to §257 HGB (German Commercial Code) does not conflict with this.
Rights of the persons concerned (users whose personal data is stored in the software)
Data subjects have the right to be informed about the personal data relating to them and to have incorrect data corrected or deleted if one of the reasons stated in Art. 17 GDPR applies, e.g. if the data are no longer required for the purposes pursued. There is also the right to restrict processing if one of the conditions stated in Art. 18 GDPR is met and in the cases of Art. 20 GDPR the right to data transferability. If data are collected on the basis of Art. 6 Paragraph 1 S. lit. e (data processing for the performance of official duties or for the protection of the public interest) or lit. f (data processing to safe-guard legitimate interests), the data subject has the right to object to the processing at any time for reasons arising from his or her particular situation. Halocline shall then no longer collect personal data unless there are demonstrably compelling reasons for processing which are worthy of protection and outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. Every data subject shall also have the right to complain to a supervisory authority if he/she considers that the processing of data relating to him/her is in breach of data protection provisions. The right of appeal may in particular be lodged with a supervisory authority in the Member State in which the data subject is resident or in which the suspected breach is committed.
Changes to this privacy policy
We will occasionally make changes to this privacy policy.
We will notify you (via e‑mail to key users) of any material changes to this privacy statement.
Contact
Responsible authority:
Halocline GmbH & Co. KG, Netter Platz 3, 49090 Osnabrück, Germany
E‑Mail: privacy@halocline.io
The Halocline GmbH & Co. KG has appointed the following data protection officer:
Mr. Oliver Stutz, datenschutz nord GmbH,
Konsul-Smidt-Str. 88, 27217 Bremen, Germany
Phone: +49 421 69 66 32 0
E‑Mail: office@datenschutz-nord.de
