Rebels Privacy Policy

 Last Updated: July 2018

This Privacy Policy shall apply to the Rebels mobile App (the “App”) and the website https://rebels-app.com/ (the “Website”, the app and website together, the “Services”).

1. GENERAL

Regarding the Services the Rebels Technologies GmbH, Tannenstrasse 7, 9000 St. Gallen (“Rebels”, “we”, “us” or “our”) is the controller within the meaning of the General Data Protection Regulation (“GDPR”).

This privacy policy shall inform you on how we collect, process and use (“Use”) your Personal Data in connection with the Services.

2. DATA WE COLLECT, PROCESS AND USE

a. In general, you can use the Services by creating an account with your first name, university email address and a profile photo. Your first name and profile photo, as well as the name from your university that we deduct from your email, are visible by other users in proximity. This basic information helps build trust in the community and makes it more likely that meaningful interactions happen among users over the app.

b. Regarding the Website: if you visit the Website your browser automatically transfers certain data so that it can access the Website, in particular:

  • the IP address
  • the date and time of the request
  • the browser type
  • the operating system
  • the language and version of the browser software

Such data is processed, in particular, as without such data the Website cannot be accessed.

c. In connection with the use of the App a random anonymous user ID string is generated for you that allows us to allocate your Rebels activities (status, hangouts, messages, etc.) to your account. The use of such an ID is required for the registration of your account (as without such value we cannot connect your activities within the App to your account and therefore a use of the App would not be possible). Furthermore, we also store data on the language in which you use the App in order to to provide to you the App and respective content in your preferred language.

d. In addition, regarding the App certain data transmitted by your mobile device is collected, namely your IP address, the periods of time in which you use the App, the date of the registration of your account, the operating system of your device (Android or iOS) and the type of device you use (e.g. iPhone, Samsung Galaxy). Such data is collected, in particular, in order to be able to distinguish actual App users from bots, prevent abusive behaviour and block abusive content that is reported by other users.

e. In addition, the full functionalities of the App are only accessible to you if you grant access to your mobile device’s geo location. To this end, when you use the App for the first time you will be asked by your device whether location data may be used. If you do not allow this or if you allow this, but later deactivate this functionality in the settings of your mobile device, please note that the App or at least certain features and functionalities of the App might not work or might not be accessible to you.

f. If you provide to us information on the Website via a request form contained on the Website or on another way then we will process your data in order to answer your respective (information) requests.

g. We might disclose your Personal Data where such disclosure is required by law (for example, upon request of a court or of law enforcement authorities).

h. We might disclose certain (anonymous) user data (such as information about hangouts and information about activity) to universities in order for them to further analyse use patterns of our users and help us classify content created by our users. The respective data disclosed to such universities cannot be traced back by such universities to a specific user.

i. The legal basis for the processing of personal data described above in

  • section 2.b (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests to Use such data arises from the fact that without such data the Website cannot be accessed).
  • section 2.c (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures).
  • section 2.d (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests are that we need a way to distinguish users from bots, prevent abusive behaviour and block abusive content when users report it).
  • section 2.f is Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures) and Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interest is that we can only provide the App services with all its functionalities, if respective geo location data is processed). For the avoidance of doubt: we will not process your geo location data if you choose to not allow your device to share such data with regard to the App (cf. also above under 2.e).
  • section 2.f is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests are that we need to process the respective data in order to being able to answer your (information) requests.
  • section 2.g is Art. 6 (1) sentence 1 lit. c GDPR (legal obligation).
  • section 2.h (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the universities have a legitimate interest to analyze respective data from a scientific point of view and this analysis is not trivial for us to reproduce as we use the results of such analysis to further our understanding of our user base and its preferences).

3. USE OF ANALYZING, ADVERTISING AND OTHER TOOLS

We also use the following tools to better understand user preferences through user actions:

a. We use a self-developed tool with regard to the App that evaluates and stores user activity (in particular what features are used, what features are not used) and derive conclusions from that data to give us a better picture of how the App is used by our users. We use that data to improve the usability of the App for the users and to develop new features.

b. We also use the Facebook Software Development Kit (“Facebook SDK”) of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”) with regard to the App. The Facebook SDK allows for analyzing anonymized behavioral data, in particular the counting of active users and activity events (e.g. create a status, join a hangout, send messages). For further information regarding the Facebook SDK please refer to https://developers.facebook.com/docs/ios?locale=en_GB and https://developers.facebook.com/docs/android?locale=en_GB. This does not give us any access to data from Facebook or a user’s Facebook account by any means. Certain (pseudonymized) data of you might be submitted to Facebook servers in the USA. To our best knowledge Facebook complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU member countries. Facebook has certified that it adheres to the relevant Privacy Shield Principles. The European Commission qualifies the US to provide an adequate legal protection for personal data transferred from the EU to self-certified organisations in the US that are certified under the Privacy Shield programme. Further information can be found at: https://www.privacyshield.gov/EU-US-Framework.

c. In addition, we also use Mixpanel, an analytics software, to better understand the user journey on our app. Further information about Mixpanel's privacy policy can be found here: https://mixpanel.com/legal/privacy-policy/

d. We also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyze how you use the Website. The information generated by the cookie about your use of the Website will normally be transmitted to and stored by Google on servers in the United States. In case IP-anonymization is activated on the Website, your IP address will be truncated within the area of member states of the European Union or within other contracting states to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of the Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services for the Website operator relating to Website activity and internet usage. The IP-anonymization is active on the Website. The IP address that your browser transfers within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use all functions of the Website. You can also opt-out from the storage by Google of the data that is created by the cookie and is related to the use of the Website (including your IP address) and the processing of such data by Google by downloading and installing the Google Analytics opt-out Browser add-on available under https://tools.google.com/dlpage/gaoptout?hl=en. As an alternative to the browser add-on or within browsers on mobile devices, you can click this link in order to opt-out from being tracked by Google Analytics within this Website in the future (this opt-out option applies only for the browser in which you set it and with regard to the Website). In this case an opt-out cookie is put on your device. In case you delete your cookies, you will have to use the aforementioned link again. For further information on Google Analytics please refer to: http://www.google.com/analytics/terms/gb.html, https://support.google.com/analytics/answer/6004245?hl=en, http://www.google.de/intl/en-GB/policies/privacy/. To our best knowledge Google complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU member countries. Google Inc. (and its wholly-owned US subsidiaries) has certified that it adheres to the relevant Privacy Shield Principles, including for Google Analytics. The European Commission qualifies the US to provide an adequate legal protection for personal data transferred from the EU to self-certified organisations in the US that are certified under the Privacy Shield programme. Further information can be found at: https://www.privacyshield.gov/EU-US-Framework.

e. We use Mailchimp from The Rocket Science Group, LLC to manage our user emails in organized lists according to country, city and university campus. More information on Mailchimp's privacy policy can be found here: https://mailchimp.com/legal/privacy/

f. Further we use AWS from Amazon Inc. to process file uploads (e.g. user profile photos). More information on AWS privacy policy can be found here: https://aws.amazon.com/privacy/

g. We use Mailgun from Mailgun Inc. to automize the email verification process by sending out the login code. More information on Mailgun privacy policy can be found here: https://www.mailgun.com/privacy-policy

h. We use the Graphcool framework from Graphcool, Inc. for our data base. More information about Graphcool's privacy policy can be found here: https://prisma-ai.com/privacy.html

i. If you decide to deactivate (some of) the tools described in this section 3 (to the extent this is possible), please note that certain features and functionalities of the Services might not work or might not be accessible to you.

The legal basis for the processing of the data described in the sections 3 (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests to Use such data is that we use and analyze the respective data (i) to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services, (ii) to help personalize your user experience, (iii) to recognize user patterns in order to protect the App against bots, abusive members and abusive content, and (iv) to provide you with certain features of the Services (without us using such data some of the functionalities of the Services might not work or might not be accessible (this applies, in particular, to the tools mentioned above; with regard to item (iv) such processing of data is also based on Art. 6 (1) sentence 1 lit. b GDPR (fulfilment of contract and pre-contractual measures)).

4. TECHNICAL IMPLEMENTATION OF THE SERVICES BY SUBCONTRACTORS

We partly use service providers who process Personal Data on behalf of us to operate the technical platform for the Services. These service providers process the data exclusively according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).

5. DURATION OF STORAGE OF PERSONAL DATA

Unless no shorter storage period is indicated in this privacy policy, we, in general, store Personal Data as long (i) as required for the provision of the Services to you, and/or (ii) as it is necessary with regard to the contractual relationship with you, thereafter only if and to the extent that we are obliged to do so by mandatory statutory retention obligations. If we no longer require the respective Personal Data for the purposes described above, such Personal Data will only be stored during the respective legal retention period and not processed for other purposes.

6. YOUR RIGHTS

You have the right to request information from us at any time about your Personal Data stored by us. If the legal requirements are met, you also have rights vis-à-vis us to request from us access to and rectification or erasure or restriction of processing concerning your Personal Data or to object to the processing of your Personal Data as well as the right to receive from us your Personal Data provided to us in a structured, established and machine-readable format (you can transfer this data to other parties or have it transferred; data portability).

If you have given your consent to the use of personal data, you can revoke such consent at any time (for the future).

If you believe that the processing of your Personal Data by us is in breach of the applicable data protection laws, you can issue a complaint with the competent supervisory authority for data protection.

7. CONTACT; DATA PROTECTION OFFICER

You can contact us, for example, via the address indicated above in section 1., via juliette@rebels-app.com and/or by using the contact info contained in the App or on the Website.

For all questions regarding data protection at Rebels (including the assertion of your rights further describe above under section 6.), you can also contact Rebels’s Data Protection Officer directly. The contact details of the data protection officer are:

  • Data Protection Officer, Rebels Technologies GmbH, Tannenstrasse 7, 9000 St. Gallen
  • juliette@rebels-app.com

8. KEEPING YOUR PERSONAL DATA SECURE

We place great importance on the security of all Personal Data associated with the use of our Services. We have security measures in place to attempt to protect against the loss, misuse and alteration of Personal Data under our control. Our security and privacy policies are periodically reviewed and enhanced as we consider it appropriate and only authorised personnel have access to Personal Data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

We have taken additional extensive security precautions relating to our Services and its use. However you should bear in mind that in spite of such security measures, submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our Services whilst it is in transit over the internet.

 
Last updated: July 19, 2018