Privacy policy for the data processing of our customers Art.12-14 GDPR

In the following privacy policy, we provide information in accordance with the legal requirements of Art. 12-14 GDPR on the data processing of our customers’ personal data that is collected and processed when registering and using our app.

I. Contact details of the controller / its representative

straightlabs GmbH & Co. KG

Tölzer Str. 12

82031 Grünwald

Managing Director: Prof. Dr. Peter F.-J. Niermann

phone: +49 89 6425 6831


II. Important definitions of terms

II.1. personal data, Art. 4 No. 1 GDPR

means any information relating to an identified or identifiable natural person. Reference is made to the further content of the provision.

II.2. Special categories of personal data, Art. 9 GDPR

personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation

II.3. Processing of personal data, Art. 4 No. 2 GDPR

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

III. data processing operations in detail

Below we explain the individual data processing processes according to their purpose, the data categories affected by them and the legal bases

III.1. Registration, service provision, communication, billing

  1. We initially process your personal data as part of the registration process, software use and communication with you so that we can record you as a user, address you, manage you, communicate with you, provide you personally with our services and bill you (if paid services are booked)
  2. Data categories concerned: Name, address, e-mail address, payment service provider information, invoice and payment data (personal master data)
  3. Legal basis:
    6 para. 1 b) GDPR = fulfillment of a contract

III.2. Setup and use of the software by the customer

  1. We process extensive personal data (content data) when setting up the software to the individual characteristics, needs and settings of the customer, which in some cases already takes place during registration, as well as when using the software and all its functions in accordance with the contract. On the one hand, we need this data to enable you to use the full range of services of our software with all its functions. On the other hand, this data is automatically generated by the individual nature of your use of the software and processed in our IT systems. Data processing also includes the evaluation and use of this data by the AI software integrated by us, as well as by the third-party providers commissioned by us (see below). Without this information, we will not be able to support you in achieving your desired goals via the software, or only to a very limited extent.
  2. Data categories concerned: Content data, usage data (data that is entered into the software and/or generated by it as a result of use). This includes the customer’s own information/input, such as the movement and text data generated during training. These data inevitably also include special categories of personal data (see definition above), for example information on health, gender or origin that can be inferred from their recorded voice, as well as all the data listed in III.2. listed data types.
  3. Legal bases:
    6 para. 1 b) GDPR = fulfillment of a contract
    Art. 6 para. 1 a), Art. 7 GDPR = consent to data processing for special categories of personal data

III.3. Data acquisition

Statistical and analytical data on usage times, frequency of use, profile and session settings, linked VR devices, metadata, training data, crash reports and error messages

III.4. Fulfillment of legal obligations

As part of our legal obligations in the context of operating a company, we are obliged to process personal data in part for official purposes within the scope of the relevant legal bases.
The legal basis for this is subordinate to corresponding special legal bases Art. 6 para. 1 c) GDPR (fulfillment of a legal obligation)

III.5. Data transfer to third parties (e.g. technical service providers, marketing companies, AI providers)

  1. In order to be able to provide you with our services, the data is transferred to the following third-party companies and processed there on our behalf:
    Hetzner Online GmbH
  2. Data concerned: All personal data processed in the context of the data processing described here.
  3. Legal basis:
    6 para. 1 lit. a, lit. b, lit. F. GDPR (depending on the data processing according to III.1.-IIII.4.
    Art. 28 GDPR (order processing = data processing by external third parties as processors on the instructions of the controller)

IV Storage period of personal data

We store your data required for the execution of the contractual relationship and use of our services (IV.1. to IV.3.) for the duration of the existing user relationship and beyond that for a further maximum period of two full calendar months in order to enable the processing of the user relationship, in particular the disclosure of data to you. Irrespective of this, your data will be deleted immediately if this is required by Art. 6 para. 1a, 7 GDPR are processed on the basis of consent and this consent is withdrawn by you.

We store your data as part of the data processing in accordance with Section IV.4. Until IV.7. Processed data until your objection, provided that this is in accordance with Art. 6 para. 1 lit. f (legitimate interest) GDPR and until their revocation, insofar as these are processed in accordance with Art. 6 para. 1a, 7 GDPR are processed on the basis of consent

In addition, the processed data will only be stored for as long as the purpose of the processing requires or as long as this is necessary to fulfill our legal commercial and tax obligations.

V. Rights as a data subject of data processing

  1. Information: Within the framework of the statutory provision (Art. 15 DSGVO) a right to information about your personal data processed by us.
  2. Rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you within the scope of the statutory provisions (Art. 16 GDPR). GDPR).
  3. Deletion: You can request us to delete your personal data if the legal requirements are met (Art. 17 GDPR). GDPR).
  4. Restriction of processing: Under the legal requirements (Art.18 DSGVO) to demand the restriction of data processing.
  5. Right to data portability: Under the conditions and in accordance with Art.20 GDPR, we will transfer your data to another controller if you have provided it to us.
  6. Revocation of consent: If you have consented to data processing in accordance with Art.6 para.1 a) GDPR or in the processing of special categories of personal data pursuant to Art.9 a) GDPR, you can revoke your consent at any time without affecting the legality of this data processing up to the time of revocation.
  7. Right to object: You have the right to object to data processing under the conditions of Art. 21 GDPR
  8. Right to lodge a complaint with supervisory authorities: If you believe that the data processing operations described in this declaration or other data processing operations violate the GDPR, you have the right to lodge a complaint under Art. 77 GDPR. GDPR to a supervisory authority.
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