Controller
The controller within the meaning of the General Data Protection Regulation (GDPR) is RiCharge GbR, represented by Rico Klatte, Steibisberger Weg 20, 88239 Wangen im Allgäu, Germany. Email: hello@klatterico.de.
There is no data protection officer; there is no obligation to appoint one.
This website
This website sets no cookies, uses no analytics or tracking services, has no forms and embeds no third-party content. The fonts are served from the site’s own server. That is why there is no cookie banner either.
When you open a page, the host’s server processes the data your browser sends for technical reasons and stores it in log files: your IP address, the time of the request, the resource requested and your browser’s user agent. Without this data the page cannot be delivered.
The purpose of this processing is to operate the website and to defend against attacks. The legal basis is Art. 6(1)(f) GDPR; the legitimate interest lies in delivering the website securely and reliably. The data is not combined with other data and is not used to identify you.
The website is hosted by Hostinger International Ltd.. The host processes the log files on behalf of the controller as a processor under Art. 28 GDPR; this applies by virtue of the hosting contract and the host’s Data Processing Addendum (https://www.hostinger.com/legal/dpa). There are no other recipients.
The log files are deleted after the period the host sets for its servers; beyond that they are not stored. They are not passed on to third parties unless a law requires it.
There is no automated decision-making and no profiling. There is no obligation to provide this data; it arises technically as soon as you open the page.
The app
Riima collects nothing about you. There is no account, no sign-in, no advertising and no statistics — and the app does not open a connection to the internet on its own.
Which words you have marked as known and how often you have listened to an episode is kept in a file on your device. It is not transmitted anywhere. If you delete the app, that file is gone with it.
“Send feedback” opens your mail app with a ready-made draft to hello@klatterico.de. It contains the version of the app and your iOS version. Nothing is sent before you tap “Send”. What you send is processed in order to answer your message (Art. 6(1)(f) GDPR) and deleted once the matter is settled.
Purchases, should there ever be any, are handled by Apple, not by Riima. When restoring, Apple asks for your sign-in; the app learns only what you have purchased.
This text describes the app as it is delivered today. It will be changed in the same step as the first line of code that sends anything.
The TestFlight link
The app is currently available as a beta through TestFlight, a service by Apple. The link on this website takes you to Apple. From there on, Apple’s privacy policy applies, not this one.
Whoever takes part in the beta test transmits their email address to Apple. Apple provides the app’s provider with information for the beta test, such as crash reports and the feedback you send through TestFlight. Riima itself transmits nothing in the process.
Your rights
Towards the controller you have the right of access to the data processed about you (Art. 15 GDPR), to rectification (Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18) and to data portability (Art. 20).
Insofar as processing is based on Art. 6(1)(f) GDPR, you may object to it at any time on grounds relating to your particular situation (Art. 21 GDPR).
For all of these rights, an email to hello@klatterico.de is enough. As for the log files, note that an IP address there cannot be attributed to a person; information about a specific address is therefore usually not possible.
Right to lodge a complaint with a supervisory authority
If you consider that the processing of your data infringes the GDPR, you may lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for instance the authority of your place of residence or the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg (Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg), which is competent for the controller.