startlean UG (haftungsbeschraenkt)

Schleissheimerstr. 244

80809 Muenchen

Kontakt Person:

Lucas Jacobson


E-Mail: [email protected]

YOUR PRIVACY IS IMPORTANT TO US 1. PARTIES 1.1. This Privacy Policy describes how startlean UG (haftungsbeschränkt) (startlean, “we”, or “us”) collects, uses, stores, shares and protects your information in connection with services offered by startlean as a data controller including, but not limited to, services provided at the app MindHappy (the App); tools or applications including, but not limited to, mobile and other software applications related to the App (the “Applications”); and images, text, playlists, metadata, and other material available through the Service (the “Content”) (collectively, the “Service”). 1.2. This Privacy Policy applies when you (“you”, “User” or “Respondent”) access, visit or use any portion of the Service. For the purposes of this Privacy Policy, a “User” is a person who creates and distributes startleans online (data controller of Respondents data and data subject for your own data, as direct client of startlean), and a “Respondent” is a person who answers those startleans (data subject of user). 1.3. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in the startlean Terms of Use. 2. AGREEMENT TO TERMS OF PRIVACY POLICY 2.1. Any Service provided by startlean is purely voluntary. You are not required to provide any personal information to us unless you choose to access features of the Service that require such information. If you do not agree with the terms of this policy or startlean’s Terms of Use related to the Service, then please do not provide us with personal information, exit the Applications immediately, and refrain from using the Service. 2.2. Accordingly, by creating a startlean Account (as defined in the Terms of Use), or by otherwise accessing, visiting or using the Service, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy and in the startlean Terms of Use. 3. CHANGES TO THE PRIVACY POLICY 3.1. We may amend this Privacy Policy from time to time. You may be required to accept the amended Privacy Policy upon logging in to your startlean Account in order to keep using the Service. Alternatively, we may post any material changes to this Privacy Policy on the App with a notice advising of the changes in advance of the effective date of the changes. We may also notify you of material changes to this Privacy Policy, before the effective date of the changes, by sending an email or in another conspicuous manner reasonably designed to notify you. If you do not agree to the new Privacy Policy, you may terminate using the Service within the applicable thirty (30) day period and you will not be bound by the new terms. Otherwise, the new terms will take effect after thirty (30) days. 4. RIGHTS TO ACCESS, RECTIFICATION OR ERASURE, RESTRICTION AND OBJECTION, OF PROCESSING 4.1. You have the right to access, rectification, opposition, erasure (“right to be forgotten”), and right to restriction of processing of your personal data by directing any such requests to startlean UG (haftungsbeschraenkt) registered at address Schleißheimerstr. 244 80809, Munich, Germany as stated in the Help Centre articles. In order to make things easier for you, and without prejudice to the legal requirements startlean must comply with under the laws, startlean allows you to exercise the above-mentioned rights by opening a support ticket via the Help Centre. Send a request via 5. PERSONAL INFORMATION ABOUT USERS AND RESPONDENTS startlean is used by startlean “Users” and by startlean “Respondents”. The information we receive from Users and Respondents and how we handle it differs, as set out below. 5.1. startlean USERS As a User, we collect information relating to you and your use of our Services from a variety of sources: (i) Information we collect directly from the User a) Registration information: information you provide to us when you register for an account. b) “My Account” settings: you can view and edit various preferences and personal details on “Account” settings. c) startlean data: We store your MindHappy data (entries you added) for you. d) Other data you want to share: We may collect your personal information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial, or when running a contest with startlean. (ii) Information we collect about the User indirectly or passively when interacting with us a) Usage data: startlean collects usage data about Users whenever they interact with our services, including information they have elected to make publicly available. b) Device and application data: startlean collects data from the device and application the User uses to access our services, such as the IP address and browser type. We may also infer the geographic location based on the User IP address. c) Information from third parties: startlean may collect User personal information or data from third parties if the User gives permission to those third parties to share such information with others or the data is extracted from publicly accessible sources. d) Information from cookies and page tags: startlean uses third party tracking services that employ cookies and page tags (also known as web beacons or web bugs) to collect aggregated and anonymized data about visitors to our webApps. This data may include usage and User statistics. You can obtain full information about our cookie policy here 5.2 startlean RESPONDENTS As a Respondent, when you respond to startleans hosted by startlean, we collect, on behalf and upon instructions of startlean’s Users, information relating to you and your use of our services from a variety of sources: (i) Information we collect directly from the Respondent: startlean responses We collect and store the startleans responses from Respondents. The startlean User is responsible for that data and manages it. The startlean User is usually the same person that invited the Respondent to take the startlean and sometimes they have their own privacy policy. When responding to a startlean you may provide personal information or data. Please note that startlean is not responsible for the content of that startlean, so if you have any questions about a startlean you are taking, please contact the startlean User directly. (ii) Information we collect about the Respondent from other sources on behalf of startlean’s Users a) Usage data: on behalf of startlean Users, startlean collects usage data about Respondents whenever they interact with our services. b) Device and application data: on behalf of startlean Users, startlean collects data from the device and application the Respondent uses to access our services, such as, among other, the IP address, browser type and operating system. We may also infer the geographic location based on the Respondent IP address. c) Referral data: on behalf of startlean Users, startlean records information about the source that referred the Respondent to a startlean (i.e. a link on a webApp or in an email). d) Information from cookies and page tags: startlean uses third party tracking services that employ cookies and page tags (also known as web beacons or web bugs) to collect aggregated and anonymized data about visitors to our webApps. This data may include usage and User statistics. You can obtain full information about our cookie policy as described in Section 7 below e) Email address: startlean records the email address if the User/Respondent provides it to us in order to send the Respondent a startlean notification email. (iii) startlean’S obligations as data processor when processing Respondents’ data on behalf of Users When startlean is processing Respondents’ Data on behalf of Users, the User who creates the startlean is the Data Controller in relation with the data of Respondents using such startlean, and startlean is the Data Processor of such Respondents data (hereinafter, User shall be referred to as the “Data Controller” and startlean as the “Data Processor”). 6. PURPOSES AND LEGITIMATE BASIS OF THE USE AND SHARING INFORMATION PURPOSES OF PROCESSING 6.1. We use the information we collect from you to perform the services requested in connection with the MindHappy Account” selected for the purposes described in the Terms of Use. 6.2. We also use your information to review, investigate and analyze how to improve the services provided. We may also collect and analyze your data to monitor, maintain and improve our services and features. 6.3. We may internally perform statistical and other analysis on information we collect (technical and meta data) to analyze and measure user behavior and trends, to understand how people use our services, in order to. Improve and optimize our performance of such services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. 6.4. We may use your information for internal purposes designed to keep our services secure and operational, such as testing purposes, troubleshooting, to prevent abusive activity (i.e. fraud, spam, phishing activities), and for service improvement, research and development purposes. 6.6. We’ll be sending you startlean product intro, tips and inspirational use cases and user stories by any means, including email and similar means of electronic communication like personalised advertisements as part of providing relevant content helpful to use our services effectively. In order to customize such information and commercial communications as much as possible, startlean may use statistical techniques that allow the creation of user profiles and data segmentation. 6.7. We do not sell your startlean data to third parties without your permission. We share your information with our service providers who help us to provide our services to you, in which case those third parties are required to comply with our privacy policy and any other adequate technical and organizational measures. We contractually bind these service providers by the corresponding Data Processing Agreements to keep your information confidential and to use it only for the purpose of providing their services and pursuant to the applicable privacy legislation in the EU. startlean is based in the EU and complies with the GDPR framework as set forth by the EU regarding the collection, use, and retention of personal data from EU member countries. If you are located outside the EU and choose to use the Service or provide your information to us, please note that your information may be transferred, processed and stored by our service providers in other non-EU countries. Privacy laws of the European Union and third countries may not be as protective as those in your jurisdiction. Your agreement to the terms of this Privacy Policy followed by your submission of information in connection with the Service represents your agreement to this practice. If you do not want your information transferred to or processed or stored in the EU or in the United States, you should not use the Service.If you are located in the EU, we guarantee that we will only transfer your data to companies that have signed our Data Privacy Agreement or that are registered with the Privacy Shield, to ensure a level of data protection compliant with the GDPR. 6.8. Your data is not disclosed to any third party except (i) for providing the services you requested and for which startlean collaborates with third parties, (ii) when we have your permission, (iii) when it is required by a competent authority in the exercise of its duties (for example in order to investigate, prevent or take action regarding illegal activities) or (iv) as otherwise required by law. 6.9 We do not use your startlean data other than as described in this Privacy Policy and the Terms of Use. 7. LEGITIMATE BASIS OF PROCESSING startlean use of your data for the purposes described above is based on the following legitimate basis: 7.1 Users’ Data If you are a User, we are entitled to use your data in order to fulfil our contractual obligations with you and, if you are acting on behalf of a legal person, we have a legitimate interest to use your data in order to maintain the relation with your company as a startlean client. In addition, we are entitled by law to use your data for direct marketing purposes, in order to send you commercial communications related with startlean products or services which are similar to the Services, since legislation on data privacy recognizes direct marketing to clients as a legitimate interest of use of personal data, and legislation on information society services expressly allows startlean to send you commercial communications by electronic means, provided that they are related with products or services which are similar to the Services. In any case, you are entitled to ask us, now or at any moment, not to send you any commercial communications. If you don’t want us to send you commercial communications, you can do it, now or at any moment, by changing the communication preferences in your account settings page Additionally, all commercial communications you might receive in the future, will include an easy and free-of-charge way for you to ask us not to receive further commercial communications. 8. COOKIES 8.1 A cookie is a small string of information that the webApp you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity throughout the startlean Service and that information helps us to understand your preferences and improve your experience. 8.2 For a detailed description of the types of cookies we use and on how you can control the use of cookies, please see our Cookie Policy. 9. CANCELING YOUR ACCOUNT, OPTING OUT OF EMAIL, AND MODIFYING PERSONAL INFORMATION 9.1 You may cancel your account and you may opt out of receiving any emails from startlean at any time by contacting us at [email protected] Deleting your account will cause all the startleans data in the account to be permanently deleted from our systems within a reasonable time period, as permitted by law and will disable your access to any other services that require a startlean account. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law). 9.2 You may modify your personal information by logging in and visiting your settings at “Account” page. 9.3 We encourage you promptly to update your personal information when it changes. Information concerning your past behavior with the Service may be retained by startlean as long as necessary for the purposes set out below. 10. RETENTION OF YOUR INFORMATION 10.1. We retain information for active startlean Accounts as long as it is necessary and relevant for our operations. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce the startlean Terms of Service and take other actions permitted by law. 10.2. The information we retain about you will be handled in accordance with this Privacy Policy during the maximum terms permitted by law, and will exclusively be used for the purposes described in section 9.1 above. After those terms, your information will be fully deleted or, alternatively, will be anonymized. 11. HOW TO CONTACT US Send a request via