1. Introduction
In the following, we provide information about the collection of personal data when using our website https://menty.me.
1.1. Contact details
The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Menty Health UG (haftungsbeschränkt), Mikula Jung, Korsörer Straße 23, c/o Wangerin, 10437 Berlin, Deutschland, email: info@menty.de, legally represented by Mikula Jung as Managing Director.
1.2. Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
1.3. Data processing outside the EE
AInsofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4. Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
1.5. Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
1.6. Obligation to provide data
Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship. Mandatory data is marked as such.
1.7. No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision- making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law. In case of registration for the Menty application - either as test version or a fully productive version - no business relationship is automatically established as long as no payment scheme is implemented by us. In no case, we have an automatic decision making for individual users to access and use our app.
1.8. Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in herin after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
1.9. Customer surveys
From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.
2. Data processing on our website
2.1. Informative use of our website
During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.These data are:
To collect such data we use third party services like Google Analytics and Hotjar. These services may transfer your your data to the United States and store it according to their terms & conditions (https://policies.google.com/technologies/partner-sites, https://www.hotjar.com/legal/policies/privacy/).
2.2. Web hosting and provision of the website
This website is hosted by Webflow. The provider is Webflow, Inc., a Delaware corporation located at 398 11th Street, Floor 2, San Francisco, CA 94103, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://webflow.com/legal/privacy. It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
2.3. Contact and signup forms
When contacting us via the contact form or signing up for a test or productive version of our app on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We use the third party service Airtable to store and use the data provided through such forms. Airtable may store and process data in United States in accordance to their privacy policy (https://www.airtable.com/privacy). We delete the data collected through such forms after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
2.4 App signup
When being invited to the Menty app - either as a test or productive version - you agree that we collect personal data on the use of and interaction with the web app. Collected data may include the type and style of interaction with the app, displayed contents and exercises. When providing responses to exercises within the app, we store those responses on our servers. For the app provision and storage of user data, we use services by Amazon Web Services (“AWS”) in accordance to their terms and conditions for European healthcare applications. AWS stores and transmits data within their Cloud infrastructure in The European Union. Read more on AWS’ healthcare policy for applications in Germany: https://aws.amazon.com/blogs/publicsector/supporting-customers-in-the-context-of-digav-compliance/
3. Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
4. Questions and comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.
