Privacy Policy for the Oberberg COGITO App

Information according to Art. 13, 14, 21 Data Protection Regulation (GDPR):
With the following privacy policy, we inform the users of the COGITO app about the type, scope and purposes of the collection, use and other processing of personal data when using our mobile app.

Responsible entity:

Oberberg GmbH
Hausvogteiplatz 10
10117 Berlin
Phone: +49 30 3198504-00
E-mail: info@oberbergkliniken.de
Website: https://www.oberbergkliniken.de/

represented by the managing directors
Prof. Dr. med. Dr. rer. nat. Dipl.-Psych. Matthias J. Müller
and Ilmarin B. Schietzel

Responsible for development, maintenance and update of the technical platform:

Clinical Neuropsychology Working Group
Prof. Dr. Steffen Moritz
Clinic and Polyclinic for Psychiatry and Psychotherapy, UKE
Martinistraße 52
20246 Hamburg
E-mail: moritz@uke.de

Data Protection Officers

Data Protection Officer of Oberberg GmbH is:

Stefan Strüwe (Lawyer)
CURACON GmbH
Audit firm
Am Mittelhafen 14
48155 Münster
Phone: +49 251 92208-209
E-mail: stefan.struewe@curacon.de

Data Protection Officer of the University Medical Center Hamburg-Eppendorf is:

Matthias Jaster
Martinistraße 52
20246 Hamburg
Phone: +49 40 7410-56890
E-mail: m.jaster@uke.de

The rights of users (“data subject rights”)

Users have the right to information (Art. 15 GDPR) regarding personal data concerning them. Furthermore, users have the right to rectification (Art. 16 GDPR), deletion (Art. 17 GDPR) or restriction (Art. 18 GDPR) of processing as far as the users are legally entitled to this and it can be implemented by the provider. A right to data portability (Art. 20 GDPR) also exists within the framework of data protection law.

Finally, users have a right to object (Art. 21 GDPR) to processing within the framework of the legal requirements.

However, the developers of the app itself do not collect or store any personal data of the app users. Therefore, the data subject rights can basically not be implemented by them, but only forwarded to the operators of the app stores.

No obligation on your part to provide personal data

If you decide, as a user, that you would like to benefit from the services of the COGITO app, it is necessary that the COGITO app saves information about the exercises performed. In addition, you can record further individual information (photos, individual notes) about the exercises performed in the app. If you do not want to save individual information about the exercises in the app, this will not affect the use of the other functions.

Processing of personal data when using the Oberberg COGITO App

The user can download the Oberberg COGITO app from the Google Play Store or the Apple App Store. When downloading apps from the Google Play Store or the Apple App Store, the information required for this is transferred to Google Ireland Limited or Apple Distribution International in Ireland, i.e., in particular username, e-mail address and customer number of your Google or Apple account, time of download and the individual device identification number. We have no influence on this data collection and, therefore, we are not responsible for it.

For more information, please refer to the respective privacy policy of Google (https://policies.google.com/privacy) and Apple (https://www.apple.com/legal/privacy/de-ww/).

When using our mobile app, the following data is processed by the Google Play Store or the Apple App Store, which is technically necessary to provide the functions of the mobile app and to ensure stability and security, provided that the user agrees to this processing (legal basis is Art. 9 Para. 2 lit. a GDPR):

• IP address
• date and time of the request
• time zone difference to Greenwich Mean Time (GMT)
• request content
• access status/HTTP status code
• amount of data transferred in each case
• version and patch status of the app
• operating system and its interface
• unique number of the terminal device (IMEI = International Mobile Equipment Identity)
• unique number of the network participant (IMSI = International Mobile Subscriber Identity)
• mobile phone number (MSISDN)
• MAC address for WLAN use
• name of your mobile device
• photos (of exercises created by user)
• history and results of performed exercises

Access to interfaces/functions of your end device

At the beginning of the use of our mobile app, we ask the user in a pop-up for permission to use the following interfaces:

• Photo album: The app needs access to your photo album to include pictures in exercises you create (optional).
• Camera: The app requires access to your camera to include photos in exercises you create (optional).

This processing and use of data take place exclusively for the provision of the above-mentioned functionalities. The user can revoke the permission later in the settings of the app or also in the operating system or, in the case of a successful revocation, also grant the functions to the app again.

Profiling

The app does not use the users' data for profiling or automated decision-making according to Art. 22 GDPR.

Push messages

Push notifications are messages that are sent from the app to the users’ device and are displayed there with priority. The Oberberg COGITO app uses push notifications if the user has activated this in the menu item "Set reminders". The legal basis is Art. 6 Para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR.

Processing in third parties

Processing in third countries, i.e., processing outside the European Economic Area (EEA), does not take place.

Duration of data storage

The data is stored exclusively within the app on the users’ mobile device and deleted as soon as the user uninstalls the app.

Change to the privacy policy

In the context of the further development of data protection law as well as technological or organizational changes, our privacy policy is regularly reviewed to determine whether it needs to be adapted or supplemented. Users will be informed of any changes.