1. General information
2. Personal data processed by Apps
3. Purpose of the processing and legal basis
4. Data transfers
5. Data storage
6. Your rights as data subject
7. Changes to the privacy policy

1. General Information

Anyline GmbH, Zirkusgasse 13/2b, 1020 Vienna, Austria („Anyline, we, us, our“) respects the privacy of its users and created this privacy policy to inform you how we process personal data with our Apps. This privacy policy covers the use of the following Apps (the „Apps“):

• Anyline Document Scanner
• Anyline Keyboard
• Anyline Energy & Water
• Anyline Scanner
• Anyline Collector

Anyline is the data controller for all Apps in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) („GDPR“). Anyline’s data protection officer may be contacted at [email protected].

IF YOU SCAN PERSONAL DATA, WHICH IS NOT YOUR OWN PERSONAL DATA (SUCH AS THE FOREIGN ID CARD OF A FRIEND OR A METER READER IN YOUR NEIGHBOR’S FLAT), YOU WARRANT THAT YOU HAVE FULL RIGHT AND PERMISSION TO PROVIDE ANYLINE WITH SUCH PERSONAL DATA OF THE RESPECTIVE PERSON.

You must not use our Apps or process data

• in any way that causes, or may cause, damage to the App or impairment of the availability or accessibility of the App,
• in any way that is unlawful, illegal, fraudulent, deceptive or harmful,
• in connection with any unlawful, illegal, fraudulent, deceptive or harmful purpose or activity or
• to process pictures or data which (i) are obscene or indecent, (ii) infringe any copyright, moral right, or other intellectual property right, confidentiality obligations, right of privacy or right under data protection legislation; (iv) constitute a crime, instructions for the commission of a crime, the promotion of criminal activity or a breach of any local law obligations (such as the German Passport Act).

Please read the following information carefully before using our Apps. If you have any questions, please email us at [email protected].

2. Personal data processed by Apps

Personal data is any information that relates to an identified or identifiable natural person. There are also special categories of personal data such as health data, data related to political opinions, religious or philosophical beliefs or biometric data.

You are not obliged to provide personal data by statutory or contractual requirement. For downloading an App it is necessary to provide personal data. Many data capture use cases effectively require the processing of personal data. This means that you may not be able to digitize physical characters without processing of personal data (Art 13 para 2 (e) GDPR). However, if you use your device without internet connection the data processing will be performed on your device only.

None of the Apps aims to process any special categories of personal data. If you decide to use an App to process any special categories of personal data, you explicitly consent to the processing of special categories of personal data. You may withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent please email us at [email protected].

2.1 Data processed during the download of an App

For reasons of transparency please note that when you download an App from an app store the relevant app store (such as Google Play Store, Apple App Store) processes your account data such as your name, email address, account number, the time of the download or individual device identification numbers. Anyline is neither responsible for this processing nor does it receive any data.

2.2 Data processed during the installation of an App

Apps can be used without registration. Anyline (and its service providers) hardly ever receive personal data which is directly connected to an individual. Anyline does not know your name, telephone number or address. Personal data processed via Apps is linked to a so called UUID, which is an individual number which is unique for your device. Without any additional information neither Anyline nor its service providers may be able to identify you personally (pseudonymization and data protection by design and by default).

2.3 Data processed during the use of

3. Purpose of the processing and legal basis

The purpose of the processing of personal data in our Apps is the

• performance of its functions such as digitalization of characters from a physical object via the
  camera on a mobile device,
• fraud prevention (face detection),
• enhancement of usability,
• prevention and early correction of malfunctions (debugging),
• understanding of our users’ needs and dissemination of our Apps (user statistics),
• license management and
• ongoing development, presentation, improvement and safety of data capture technology.

The legal basis for the processing is

• your express consent for processing of special categories of data Art 6 para 1 (a) and Art 9 para 2 (a)
  GDPR,
• the app user agreement concluded by downloading an App from an app store Art 6 para 1 (b) GDPR
  and
• our vocation to meet our users’ needs for any physical data digitization use case by providing one of
  the world’s best data capture technology for flawless character recognition Art 6 para 1 (f) GDPR.

4. Data transfers

Anyline uses external service providers (e.g. for webhosting and our IT systems) who gain access to personal data. We carefully select our service providers and oblige them to process personal data only in accordance with our instructions and applicable data protection laws. If a service provider processes the data under its own responsibility, we take care to ensure that the transfer of personal data is kept to a minimum.

Anyline works with the following categories of recipients:

File hosting service, cloud services, web application for error management, problem handling and operational project management, statistical service providers, IT development and support providers or the data protection officer. More precisely we work for example with Google Ireland Ltd, 4 Barrow St, Dublin, Ireland, for the creation of usage analyses with the help of the Google Analytics service.

Anyline strives to engage service providers based in the European Union or any country offering guarantees ensuring an adequate level of data protection essentially equivalent to that ensured within the European Union. Our server is located in Frankfurt, Germany. International service providers like Google, IBM or Atlassian transfer data also outside the European Union – with such service providers we conclude standard data protection clauses or investigate their binding corporate rules to ensure appropriate data protection safeguards for data transfers.

5. Data storage

Personal data will be stored as long as it is required to provide the Apps. Within the Anyline Scanner you have the possibility to delete your scans in the rider “My Scans”. You can also uninstall or delete the App on your device to remove the locally stored random IDs.

6. Your rights as data subject

Each data subject has a right to know which personal data is processed by Anyline. This means that you can address us anytime with your right to

• be informed and gain access to your personal data,
• rectification,
• erasure („right to be forgotten“),
• restrict processing,
• data portability,
• object to processing, and
• the right to withdraw consent.

For any questions and requests please contact us at [email protected].

Kindly note that we are required to receive additional information in order to determine if you are authorized to submit a particular request and subsequently answer your request, since your personal data is pseudonymized.

We are here to help! If you believe that the processing of your personal data by Anyline does not comply with applicable data protection laws, please contact us immediately at [email protected]. Apart from that you may file a complaint with the Austrian data protection authority.

7. Changes to the privacy policy

We reserve the right to amend this privacy policy as necessary, due to technical developments or legal changes, or updates and further functionalities of our Apps. The updated privacy policy will be available in the Apps. Please check the privacy policy regularly.