Updated: July 2023
Relayr GmbH Elsenheimer Str. 47, 80687 München (“relayr”, “we” or “us”) recognizes that your privacy is important, and we take it seriously. This Privacy Policy describes the collection, use and disclosure of your information when you access or use the following:
(a) Our website – relayr.io (the “Site”)
(b) Software (such as apps, reference tools, libraries and widgets) that we make available (the “Software”) which may be installed on your phone, tablet, wireless device, computer or server (“Device”)
(c) The Sites, Software, relayr platform and any services we provide in connection with one or more of the foregoing are collectively referred to as the “Services”. This Privacy Policy also applies to information that may be transmitted to us by our customers through software provided by them or other third parties (“Third Party Software”), through Onboarded Machines (described below) or through other means. This Privacy Policy does not apply to how third parties collect, use, disclose or retain information.
You understand that by activating an appliance or other machine that is enabled to communicate with the relayr platform (“Onboarded Machine”), you will be deemed to be using the relayr platform. Similarly, if you or your software transmits information to us through the relayr platform or other means, you are subject to this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not access or use the Sites, Software or relayr platform, do not activate any machine to communicate with the relayr platform, and do not otherwise transmit any information to us through other means.
We reserve the right to update or make changes to this Privacy Policy from time to time in our sole discretion, and we may notify you of changes by any reasonable means, including without limitation, by notifying you at the email address (if any) we have for you in our systems and/or by posting the revised version of this Privacy Policy on the Sites and/or by making the revised version of this Privacy Policy available through the Software, which revisions will become effective immediately upon the posting on www.relayr.io. You can determine when this Privacy Policy was last revised by referring to the “Updated” legend at the top of this Privacy Policy. Please return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.
Link to this heading # INFORMATION WE COLLECT
Personal Information: Personal information identifies you or another person as an individual and includes such items as your name, address, phone number and email address. We collect personal information through your use and interaction with our Services, such as when you transmit communications through the Software, Sites or Third-Party Software, when you register for an account with us, when you post messages and content through the Software, Sites or Third-Party Software, when you send us an email or other communication or when you transmit to us personal information through the relayr platform, through an Onboarded Machine or through other means. Also, personal information may be collected automatically through the Software, Third Party Software and directly from an Onboarded Machine to the relayr platform. Please be aware that certain Software installed on your Device may access other files on your Device, such as your contacts, photographs, audio and video clips and your contact information. If you activate your machine through Third Party Software, personal information may be transmitted to us by such Third-Party Software in addition to, or instead of, directly through your Onboarded Machine. Please be aware that the collection, use, disclosure, retention and other practices of any third party who collects your information is subject to the privacy policy of such third party, which we do not control. If you are a customer of relayr (such as a manufacturer of machines which are enabled to be activated on the relayr platform), we collect personal information (about you and your end users) that you transmit to us through Third Party Software, Onboarded Machines, data feeds or other methods agreed by you and relayr.
Non-Personal Information: Non-personal information does not personally identify you or another person as an individual and includes such items as aggregated information, demographic information and any other information that does not reveal your or another individual’s specific identity. We and our third-party service providers may collect non-personal information from you, your Onboarded Machine, the Software, Third Party Software and other means. Non-personal information includes, in particular, the following: (a) OS type and version, browser type and version, push notice identifier, and mobile network information of your Device; (b) traffic data, location data, logs, communication data, and data about the resources you use through the Software, Sites or Third Party Software; (c) real-time location information about your Device and Onboarded Machine; (d) usage, performance and diagnostic information about your Onboarded Machine; (e) information that has been aggregated in a manner such that it does not personally identify you or any other individual; and (f) metadata and other information associated with other files stored on your Device, such as photographs, audio and video clips.
Cookies and Other Technologies: When you visit the Sites, we may send one or more “cookies,” which are small data files, to your Device to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. If you use Third Party Software, the provider thereof may send one or more cookies to your Device. Cookies help us measure, for example, the total number of visitors to our Sites, the number of visitors to each page of our Sites, how our users use and interact with the Services, and the domain names of our visitors’ internet service providers. In general, you can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. If you do not want cookies to be installed on your Device, there is a simple procedure in most browsers that allows you to decline the use of cookies. Please be aware that some features of the Sites and Services will not function properly if the ability of your Device to accept cookies is disabled. You can control the use of cookies on out Sites via our cookie settings page that is available in the Site’s footer.
Other: We may also use clear GIFs or web beacons to track usage patterns of users of the Services. Additionally, we may use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting and make the Services better for our users.
IP Address and UDID: Your IP address is a number that is automatically assigned to your Device by your Internet service provider, your UDID (or similar ID) is the unique identification number associated with your Device, and your MAC address is the unique number assigned to your machine. Your IP address, UDID and/or MAC address are identified and logged automatically in our server log files whenever you visit the Sites, use the Software or Third-Party Software to connect to the relayr platform, or when your Onboarded Machine communicates with the relayr platform, along with the time(s) of such visit(s), the page(s) on the Sites that were visited, the features within the Software and relayr platform that were accessed and used. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites.
Tracking: We honor do-not-track signals or similar technologies that our systems detect and identify. We do not track, plant cookies, or use advertising when such do-not-track (DNT) browser mechanism is in place on your Device.
Requirement to provide your Personal Information: You are not required to provide us with your personal information. However, there are Services for which we need personal information from you. Without this data, we cannot provide the requested services to you. We collect only the data that is required in a particular case.
Link to this heading # HOW WE USE/PROCESS YOUR INFORMATION
Personal Information: We may use your personal information in the following ways
- To create an account when you register with us.
- To contact you to offer help based on diagnostic information about your Onboarded Machine.
- To fulfill your requests, respond to your inquiries, provide services, or complete transactions you have requested.
- To inform you about services that we believe may be of interest to you. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature.
- To send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications.
- To resolve problems or issues with the Services or other users.
- For our internal business purposes, such as data analysis, audits, developing new products or services, enhancing and improving the Services and identifying usage trends.
- As we believe to be necessary or appropriate: (a) in any manner permitted under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Non-Personal Information: Because non-personal information does not identify you in any way, we may use and share with third parties’ non-personal information for any purpose, including our own internal business purposes. If non-personal information is combined with any of your personal information, then such combined information will be treated by us as personal information for so long as such information is combined.
Please note that not all processing activities may be applicable to your personal information since this depends on how you use the Site, the relayr platform or Third Party Software and interact with us.
Information You Post or Share: We cannot control the actions of other users of the Service with whom you share your personal information, including any information you post or share on any public area of the Services or other area of the Services where you post or share information with third parties. Please be aware that any information that you share or post on an area of the Services intended to be viewed and accessed by third parties may be viewed, collected and used by others. We do not control how others will use or share any information shared or posted by you. No automated decision making: We do not apply any automated decision making, including profiling, on your personal information.
Link to this heading # LAWFUL BASIS FOR PROCESS YOUR INFORMATION
Consent: If required by applicable law, we will obtain your consent to process your personal information.
Contract: We may process your personal information in context of a contractual relationship if and to the extent it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.
Legitimate Interest:
In addition, we may process your personal information based on the legal grounds of our legitimate interests which are set out in section HOW WE USE/PROCESS YOUR INFORMATION.
Personal Information: We do not sell your personal information for marketing purposes. We limit disclosure of your personal information as listed below. We may disclose your personal information:
- To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer service, e-mail delivery services, and other similar services to enable them to provide services to us.
- To our customers and other business affiliates who provide you, directly or indirectly, with your Onboarded Machine, Third Party Software, and/or networks and systems through which you access and use the Sites, Software and/or relayr platform and/or through which you transmit information to us.
- To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
- As we believe to be necessary or appropriate: (a) in any manner permitted under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- Except for the third parties described above, to third parties only with your consent. Please note that we do not control any third parties’ use or disclosure of your information.
Non-Personal Information: Because non-personal information does not identify you in any way, we may share non-personal information with any third party for any purpose.
Link to this heading # THIRD-PARTY SERVICES
The Services may contain links to other web sites or services not operated or controlled by relayr (“Third Party Services”). The privacy practices of Third Party Services may vary from this Privacy Policy, and we recommend that you contact the Third-Party Services directly for information about their privacy practices. Any links from the Services to Third Party Service do not imply that relayr endorses or has reviewed the Third-Party Services.
The Third Party Services used on this website include but may not be limited to:
Our website makes use of content (e.g., JavaScript/images) provided by the following 3rd party domains:
Google:
googletagmanager.com (Analytics Insights & User Tracking)
*.google-analytics.com (Analytics Insights & User Tracking)
Hotjar:
static.hotjar.com (Analytics Insights & User Tracking)
Leadfeeder
tr.lfeeder.com (Analytics Insights & User Tracking)
snap.licdn.com (Analytics Insights & User Tracking)
lftracker.leadfeeder.com (Analytics Insights & User Tracking)
Matomo:
cdn.matomo.cloud (Analytics Insights & User Tracking)
relayr.matomo.cloud (Analytics Insights & User Tracking)
Please review the privacy policies of these Third-Party Services.
Link to this heading # DATA PROTECTION OFFICER
relayr GmbH is headquartered in Munich, Germany and we have offices around the globe. Our US HQ is registered in Wilmington, Delaware. We have appointed a data protection officer for you to contact if you should have any questions. Any data protection correspondence should be directed to the following email address:
Link to this heading # DATA SECURITY
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your personal information. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the security of any information you transmit or provide to us or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, administrative and/or technical safeguards. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
Link to this heading # YOUR DATA PRIVACY RIGHTS
Opting Out of Receiving Communications: You may opt out from receiving marketing-related emails or other communications from us on a going-forward basis by contacting us in accordance with the “Contacting Us” section below. We will comply with your request to opt-out as soon as reasonably practicable. Please note that if you opt out as described above, this will apply to marketing messages from us only. We will not be able to remove your personal information from the database of any other party with whom you have shared such information or from third parties to whom you have previously authorized us to share such information (i.e., to which we have already provided your personal information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
Correcting or Deleting Your Personal Information: If you believe that any information, we are holding on you is incorrect or incomplete, please email us at dataprotection@relayr.io. We will promptly correct any information found to be incorrect. You may also request that we delete the information which we hold about you at any time. To do so, please contact us at dataprotection@relayr.io.
Accessing and Changing Your Personal Information and other statutory data privacy rights: If the statutory requirements are met, you will have certain additional rights in relation to your personal information. These rights include the right to (i) request access to your personal information, (ii) request the restriction of the processing of your personal information, (iii) request the transfer of your personal information to a third party (commonly known as “right to data portability”), (iv) withdraw your consent, and (v) object to the processing of your personal information where we rely on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms unless we demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you would like to exercise these rights, please contact us in accordance with the “Contacting Us” section below. In your request, please make clear what information you would like to have changed, whether you would like to have your personal information deleted from our database or otherwise let us know what limitations you would like to put on our use of your personal information. In order to comply with your request, we will first need to authenticate your identity and thereafter, we will try to comply with your request as soon as and to the extent reasonably practicable. Again, we cannot remove your personal information from the database of any other parties with whom you have shared such information or from third parties to whom you have previously authorized us to share such information. We may need to retain certain information for record keeping purposes, and there may also be residual personal information that will remain within our databases and other records even after you have requested the removal of your personal information from our databases. In addition, you have a right to complain with the statutory supervisory authority. The supervisory authority that is competent for us is the Data Protection Authority of Bavaria for the Private Sector (Bayerisches Landesamt für Datenschutzaufsicht).
Your California Privacy Rights: California Civil Code Section 1798.83 permits users of the Software that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us in accordance with the “Contacting Us” section below. We do not disclose personal information to third parties for their direct marketing purposes without your consent.
Link to this heading # DATA RETENTION
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy or to otherwise fulfill a legal obligation, unless a longer retention period is required or permitted by law.
Link to this heading # CHILDREN’S PRIVACY
Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide any personal information to us. We do not knowingly collect personal information from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected personal information from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information.
Link to this heading # INTERNATIONAL DATA TRANSFERS
Data Transfers outside the EU/EEA: Whenever we transfer your personal information to a party located out of the European Union or European Economic Area (e.g., if we store and back-up personal information within databases located within and outside of the United States) we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards such as the following are implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in the European Union (so called standard contractual clauses).
Please contact us as indicted in the “Contacting Us” section below if you want further information on or a copy of the specific mechanism used by us when transferring your personal information out of the jurisdiction.
Jurisdictional Issues: We do not represent or warrant that the Services, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.
Contacting Us: If you have any questions about our practices or this Privacy Policy, please contact us by email at dataprotection@relayr.io.
Link to this heading # CUSTOMER DATA PROCESSING
In order to process your orders and carry out our business relations, we process the following personal data to the extent necessary to fulfill our contractual relationship as well as to comply with our obligations in this regard and to exercise any rights: – Contact data (name, e-mail address, company, and job title, if applicable). – Content and communication data – Contract and billing data Your data will be processed specifically in connection with: – Electronic communication by e-mail for the purpose of passing on information and maintaining business operations – Processing of customer orders, deliveries, and payments – Documentation of quotation, order confirmation, and delivery bill & processing of cash invoices for the sale of goods to the customer – Invoice delivery to the customer and claiming of receivables – Dispatch of customer correspondence to maintain customer relationships and announcement of news – If applicable, lists of participants for customer events for tracking attendance, invoicing for customer events, and planning the event
The collection and processing are thus carried out for the purpose of pre-contractual measures as well as for the implementation of our contractual relationship based on Article 6 (1) lit. b) DSGVO. Failure to provide this data may result in the discontinuation of business processes. The transfer of your personal data takes place exclusively within the company. Further processing will only take place if you have consented within the meaning of Art. 6 para. 1 lit. a) DSGVO or if there is legal permission.
To protect our legitimate interests, we also take the liberty of occasionally informing you about innovations to our products and services. The legitimate interest is based on the continuation of the customer relationship. The legal basis for this is Art. 6 para. 1 lit f) DSGVO. If we do not process your contact data for operational purposes, we will store your contact data for 10 years after the termination of the contractual relationship. After this period, the collected data will be deleted or blocked if deletion is not possible.