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Privacy PolicyLinguiny App

This privacy policy provides you with all the information you need regarding the use of the "LINGUINY" app within the CMS "CONTENTFUL" of CONTENTFUL GmbH, Max-Urich-Straße 3, 13355 Berlin, Germany (hereinafter: CONTENTFUL), within the meaning of Art. 13ff DSGVO, in order to make an informed decision about the use of LINGUINY in your CONTENTFUL installation. In addition, the respective data protection provisions of CONTENTFUL apply, which you can access at https://prismic.io/legal/privacy.

Section 1 — General Information

1.1 Provider

The provider of LINGUINY is Becklyn GmbH, Bahnhofstrasse 29, 71638 Ludwigsburg, Germany (hereinafter: BECKLYN). BECKLYN will act exclusively as a processor within the meaning of Art. 28 DSGVO for the operator of your CONTENTFUL instance.

1.2 Responsible party

The responsible party within the meaning of Art. 4 No. 7 DSGVO for the operation of LINGUINY within your CONTENTFUL instance is the operator of your CONTENTFUL instance in which LINGUINY is installed as an app via the CONTENTFUL Marketplace.

1.3 Information collected from the CONTENTFUL Marketplace during the installation of LINGUINY.

When installing LINGUINY, your user name, the customer number of your CONTENTFUL account, the time of installation, payment information, the IP address of your end device will be transmitted to the CONTENTFUL Marketplace. This data is processed exclusively by the CONTENTFUL Marketplace and is beyond our control. We do not receive this data.

1.4 Provision of LINGUINY and creation of log files

When using LINGUINY, LINGUINY automatically collects data and information from the end device used. The following data is collected:

Which personal data do we process when operating LINGUINY and creating log files and what are they used for?

(1) Information about LINGUINY and the LINGUINY version used
(2) The operating system, the system version and the device ID as well as the manufacturer and model of the retrieval device
(3) The IP address as well as the MAC address of the retrieval device
(4) Date and time of access
(5) A unique ID to recognise the user.

This data is stored in the log files of our LINGUINY server system. This data is not stored together with personal data of a specific user, so that individual app users are not identified. The data is also anonymised after the deletion period so that it is no longer possible to draw conclusions about an individual person. The anonymised data enables us to improve the stability and availability of LINGUINY. The temporary (automated) storage of the data is necessary for the use of LINGUINY in order to enable the delivery of the contents of LINGUINY.

The storage and processing of this personal data is also carried out to maintain the compatibility of LINGUINY with the respective runtime environments for as many users as possible and to combat misuse and eliminate malfunctions. For this purpose, it is necessary to log the technical data of the retrieving terminal device in order to be able to react as early as possible to display errors, attacks on our IT systems and/or errors in the functionality of LINGUINY.

What is the legal basis for this processing?

Art. 6 para. 1 lit. f DSGVO (legitimate interest): Our legitimate interest is to ensure the achievement of the purpose described above. LINGUINY cannot be operated without collecting the above-mentioned data, as the collected data is necessary for the delivery of the content. The creation of log files is necessary to ensure the stable operation of LINGUINY and, in the event of program errors, to correct existing errors on LINGUINY.

How long will your data be stored?

Data is deleted when it is no longer needed to ensure the compatibility of LINGUINY for all visitors. This is the case at the latest 3 months after the last use of LINGUINY.

Possibility of objection and deletion

You can object to this processing at any time in accordance with Art. 21 DSGVO and demand deletion of your data in accordance with Art. 17 DSGVO. You can find out which rights you have and how to exercise them in section 12 of this data protection declaration.

Section 2 — Functions of LINGUINY

2.1 Use of LINGUINY

What personal data is collected when using LINGUINY and what is it used for?

LINGUINY can only be used with a registered CONTENTFUL account.

The complete user administration and - when using a fee-based tariff of LINGUINY - the payment are handled by CONTENTFUL.

BECKLYN receives from CONTENTFUL only those master data which are necessary for the fulfilment of the underlying purpose and the operation of LINGUINY. The technical connection of LINGUINY with your CONTENTFUL account is made by activating the LINGUINY app within a CONTENTFUL account.

Content translated by you through LINGUINY will only be forwarded and returned by LINGUINY to the connected translation services - during the BETA phase "DeepL". This content will only be forwarded and processed in your CONTENTFUL instance and at the translation services for the purpose of providing LINGUINY's functionality. BECKLYN stores and processes this Content Data on its own IT systems only for a short period of time in the context of the forwarding and delivery and deletes it immediately after delivery of the translation. BECKLYN does not process the content data for its own purposes.

What is the legal basis for the processing of CONTENTFUL master data and content data?

Art. 6 para. 1 lit. b DSGVO (implementation of (pre)contractual measures): LINGUINY cannot be used without the installation and activation of the CONTENTFUL app.

Who receives access to your master data and content data?

CONTENTFUL will only share required master data with BECKLYN for the operation of LINGUINY and, if applicable, for billing purposes. BECKLYN receives Content Data from CONTENTFUL only for the purpose of providing the services of LINGUINY.

How long are master data and content data stored?

The Master Data provided by CONTENTFUL will be stored by BECKLYN for as long as LINGUINY is installed in one of your CONTENTFUL accounts or for as long as you maintain a contractual relationship with BECKLYN. BECKLYN complies with the statutory retention requirements for business correspondence and billing data under German law. This means that we have to keep some data for up to ten years due to legal retention obligations (e.g. in the case of chargeable bookings and orders) within the framework of tax law obligations, even if you have uninstalled LINGUINY. This data will then be deleted immediately as soon as there are no longer any legal retention periods to the contrary.

Your rights

You can find out what rights you have and how to exercise them at the end of this privacy policy.

Necessity of processing master data and content data

The processing of Master Data and Content Data is necessary to provide you with the features of LINGUINY.

2.2 API verification by depositing API tokens in LINGUINY

What personal data do we process when depositing API tokens and what is the purpose of this processing?

In LINGUINY, you have the option of activating translation services via API connection (during the BETA phase initially DeepL). To do this, you need an API token from the respective supported provider. This will be provided individually for your company by the respective provider. It cannot be ruled out that individual providers will additionally request further data (e.g. an email address) for verification purposes, which you must deposit in LINGUINY.

What is the legal basis for the processing?

Art. 6 para. 1 lit. b DSGVO (implementation of (pre)contractual measures): Without the deposit of API tokens and, if applicable, further verification data, it is not possible to use LINGUINY due to a lack of access authorisation to the respective translation services.

How long will your data be stored?

The verification data stored in LINGUINY will be kept by BECKLYN for as long as you keep LINGUINY installed. Please note, however, that we must retain some data for up to ten years after termination of the contract due to statutory retention obligations (e.g. in the case of orders placed) within the framework of the retention obligations under tax law. The data will then be deleted if there are no longer any legal time limits to the contrary.

Your rights

You can find out what rights you have and how to exercise them at the end of this data protection declaration.

Necessity of the information and consequences of failure to provide it

The deposit of the API tokens and, if applicable, further verification data is mandatory for the provision and operation of LINGUINY. If no valid user token has been deposited in LINGUINY, you will not be able to use LINGUINY to the extent licensed.

2.3 Error reporting

What personal data is processed in the context of error reporting and what is it used for?

Within the scope of the use of LINGUINY a continuous error reporting takes place, which collects and processes recorded data (model and operating system of the accessing device, version number of LINGUINY, a time specification and crash reporter key). This data is used to ensure the functioning of LINGUINY and to optimise the functionality of LINGUINY. The detection and processing of errors of LINGUINY is required in order to be able to provide LINGUINY permanently in CONTENTFUL even in the event of a changing runtime environment and to be able to react to security problems with the required speed.

What is the legal basis for processing for the purpose of error reporting?

Art. 6 para. 1 lit. f DSGVO (legitimate interest): Our legitimate interest is to ensure the stability of LINGUINY within changing software environments.

How long will your data be stored?

Error reports and related data are deleted immediately after the corresponding errors have been corrected, unless there are legal retention periods.

Your rights

You can find out what rights you have and how to exercise them at the end of this data protection declaration.

Necessity of the information and consequences of not providing it

The provision of bug reports is not required by law but is necessary for the stable operation of LINGUINY. Failure to provide will result in BECKLYN not providing LINGUINY to your business as error reporting is not optional.

2.4 Processor

When deploying LINGUINY, BECKLYN engages the following processors:

Hosting

In order to provide the functions of LINGUINY, we work together with the external hosting provider named below, who provides us with the server capacity and storage facilities required for the functions of LINGUINY. Insofar as LINGUINY carries out server accesses, the data collected thereby is processed for this purpose on servers of the company Vercel Inc, 440 N Barranca Ave #4133, Covina, CA 91723, USA, privacy@vercel.com. Please note that the data may also be processed in a country for which there is no EU adequacy decision, so that an equivalent level of protection is not guaranteed.

Your data is processed on the basis of a contract for commissioned processing in accordance with Art. 28 DSGVO, which is the legal basis for the transfer of data to this company.

Technical system

LINGUINY is provided via the CMS "CONTENTFUL" of CONTENTFUL GmbH, Max-Urich-Straße 3, 13355 Berlin, Germany, Amtsgericht Berlin-Charlottenburg HRB 155607 B. You can integrate LINGUINY into your Contentful account. Insofar as you use fee-based functions of LINGUINY, we receive information from CONTENTFUL in order to be able to issue a proper invoice to you.

In order to enable automated translation, the content data you enter will be automatically transmitted to your DeepL account by DeepL SE, Maarweg 165, 50825 Köln, Germany Amtsgericht Köln, HRB 104617 on the basis of the API token you entered. In this context, we ourselves will technically transmit the data to be translated exclusively for the purpose of automated translation and store it temporarily for a short time. We do not evaluate this data. We do not pursue our own purposes with the transmission and forwarding to DeepL.

2.5 Payment methods and credit assessment

Payment is made exclusively via CONTENTFUL. In addition, the respective data protection regulations of CONTENTFUL apply.

Section 3 — Your rights

3.1 Right to information

You have the right to request confirmation as to whether we are processing personal data about you. If this is the case, you have the right to be informed about the information named in Art. 15 (1), (2) DSGVO. We will also be happy to provide you with a copy of the data, provided that the rights and freedoms of other persons are not affected (cf. Art. 15 (4) DSGVO).

3.2 Right to rectification

Pursuant to Art. 16 DSGVO, you have the right to have any incorrect personal data (e.g. address, name, etc.) stored with us corrected at any time. You can also request that the data stored with us be completed at any time. A corresponding adjustment will be made immediately. Some data, such as your address data, billing address, registration data, etc., can also be adjusted at any time by you as a registered customer in your user profile.

3.3 Right to deletion

Pursuant to Art. 17 Para. 1 DSGVO, you have the right to demand that we delete the personal data we have collected about you if

  • the data is no longer required;

  • the legal basis for the processing has ceased to exist due to the withdrawal of your consent;

  • you have objected to the processing and there are no overriding legitimate grounds for the processing;

  • your data is processed unlawfully;

  • a legal obligation requires this

  • a collection pursuant to Art. 8 (1) DSGVO has taken place.

Pursuant to Art. 17 (3) DSGVO, this right does not apply if

  • processing is necessary for the exercise of the right to freedom of expression and information;

  • your data has been collected on the basis of a legal obligation;

  • processing is necessary for reasons of public interest;

  • the data are necessary for the assertion, exercise or defence of legal claims.

3.4 Right to restriction of processing

Pursuant to Art. 18 (1) DSGVO, you have the right in individual cases to demand the restriction of the processing of your personal data. This is the case, for example, if

  • the accuracy of the personal data is disputed by you;

  • the processing is unlawful and you do not consent to its erasure;

  • the data is no longer needed for the purpose of processing, but the collected data is used for the assertion, exercise or defence of legal claims;

  • an objection to the processing has been lodged pursuant to Art. 21 (1) DSGVO and it is still unclear which interests prevail.

3.5 Right of revocation

If you have given us express consent to process your personal data (Art. 6 para. 1 lit. a DSGVO), you may revoke this consent at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.

3.6 Right to object

You have the right to object at any time on grounds of a special situation to the storage and processing of your data which we have collected on the basis of Art. 6 (1) f DSGVO (legitimate interest) in accordance with Art. 21 DSGVO.

3.7 Right to data portability

We will provide you or a responsible person named by you with the following data in a common machine-readable format upon request pursuant to Art. 20 (1) DSGVO:

  • Data collected on the basis of explicit consent pursuant to Art. 6 (1) lit. a DSGVO or Art. 9 (2) lit. a DSGVO;

  • Data that we have received from you in accordance with Art. 6 Para. 1 lit. b DSGVO within the framework of existing contracts;

insofar as the data has been processed within the framework of an automated procedure.

3.8 How do you exercise your rights?

You can exercise your rights at any time by contacting us at the contact details below:
Becklyn GmbH, Bahnhofstrasse 29, 71638 Ludwigsburg, Germany.
Email: datenschutz@becklyn.de, Phone: +49 7141 4888 660

3.9 Right to complain to the supervisory authority pursuant to Art. 77 (1) DSGVO

If you suspect that your data is being processed illegally on our site, you can of course bring about a judicial clarification of the issue at any time. In addition, any other legal option is open to you. Irrespective of this, you have the option of contacting a supervisory authority in accordance with Art. 77 (1) DSGVO. The right of complaint pursuant to Art. 77 DSGVO is available to you in the EU Member State of your place of residence, your place of work and/or the place of the alleged infringement, i.e. you can choose the supervisory authority to which you turn from the places mentioned above. The supervisory authority to which the complaint has been submitted will then inform you of the status and outcome of your submission, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.