PRIVACY STATEMENT RELIEVED APP
This privacy statement was last modified on 29th September 2023
Relieved, part of Cinnux BV, (hereinafter referred to as Relieved) processes personal data. This is privacy-sensitive data that can be linked to you as a person. Your privacy is of great importance to us. We therefore adhere to the requirements of privacy and cookie legislation, the General Data Protection Regulation (GDPR) and the Telecommunications Act. This means your data is safe with us and that we handle your data with care.
In this privacy and cookie statement we explain what we do, via the app, with information we learn about you. This means, among other things, that:
- we clearly state for what purposes we process personal data. We do this via this privacy statement;
- we limit our collection of personal data to only the personal data necessary for our legitimate purposes;
- we first ask you for explicit permission to process your personal data in cases where your permission is required;
- we take appropriate security measures to protect your personal data and require the same from parties that process personal data on our behalf;
- we respect your right to access to, correct or delete your personal data, upon your request.
Personal data
What personal data
In order to be of service to you, we need some information from you. Below, we describe what personal data we process about you.
- Registration
To use the app, you need to log in with a QR code or login code. This allows us to know which organisation or organisational unit the installed app belongs to, but we cannot trace this back to you as a person. This is because all users of an organisational unit use the same code. We use this code to report on app usage, but only if there are 10 or more users per code.
- Chat messages and notifications
Our app makes it possible to chat with confidential advisors. We understand that sometimes you want and/or need to share sensitive information when chatting. The content of these chat messages is part of our data processing. These chat messages are never visible to anyone else. Only your confidential advisors have access and can read your messages. Nor will we share the content of these messages with your employer.
When sending a message via the app, we ask you to create a username. You only need to do this once. For example, you can use a nickname or pseudonym or enter your name. The username gives the confidential advisor an idea of who started the chat and makes it easier for the confidential advisor to distinguish between the different chats. You can also let us know in which age category you fall and your gender, but you don’t have to. So, we process the following data for registration purposes:
- username,
- gender,
- age category.
- Information about usage
We also collect personal data whilst you use the app and/or our service. When you install the app on your phone or another device, we attach a unique device code (also called a UUID) to you as user. This device code is unique for each installation and we can only link to the information you provide in the app, such as your username, age and gender. All device codes are part of a group, for example, your department or company. We keep statistical usage records per group. This way, we can only see which parts of our app are used per group, which topics are clicked per group and, for example, which articles are read per group. We therefore never attach this data to you as a user, nor to the UUID. In addition, we register a session code and UUID when you send a chat message or when you complete the feedback form. We cannot trace these codes directly back to you either.
- Information collected automatically
In addition to the above personal data, we also collect data that is stored automatically, namely device type, screen size, app version and any error messages.
Use of personal data
We use the above personal data to support you in situations involving undesirable behaviour in the organisation for which the app is offered. We collect your personal data on the basis of four purposes. First, you may give us your explicit consent to process the data. Second, we may need your personal data for the implementation of an agreement that we enter into with you. Third, in certain cases, we are by law obliged to process your personal data.
Finally, we may use your data for scientific research or statistical purposes. In that case, we will take extra measures to guarantee your privacy as much as possible. In the case of statistical purposes, it is not relevant to know who it concerns. We therefore ensure that the personal data is pseudonymised or, if possible, anonymised.
Based on your explicit consent to process your personal data, we may also use this data to communicate with you about the use of our app/software and/or service, to notify you of updates and to respond to requests from you as a user.
If you give us permission for processing, you can withdraw this permission at any time. If you install the app on your device, you can remove it at any time and we will only retain the data that is necessary, for example, because we are by law obliged to do so.
Sharing personal data
As a controller, we ensure your personal data is only processed under our conditions. This means that third parties will only process your personal data in accordance with our instructions and obligations.
We offer an app to support you in situations involving undesirable behaviour in the organisation for which the app is offered. In the Relieved app, we offer an information section and a chat solution, among other things. We maintain this app and provide technical services for use of the app in various ways. For example, a management environment for the articles shown in the app. We do this as an IT service provider/app supplier on behalf of a company/organisation. Relieved is not (ultimately) responsible for the protection of personal data processed by its customers. That is why we make clear and suitable agreements with the controller as part of a processing agreement. In this agreement, we record which data we process on behalf of the controller and how we will protect this data processing activity.
To process your personal data based on your explicit consent, we need the assistance from third parties. These are service providers who assist us in the implementation of the service. We use third-party services to maintain and manage this app, for hosting, for e-mail communication and to make it technically possible to collect the data.
We also pass on your personal data if we believe this is necessary to maintain this app/software and/or this service. This includes cases in which we suspect that our Conditions of Use have been violated or other illegal activities. Your personal data is also transferred when this is required on the basis of a statutory obligation. For example, we report suspected fraud to the police. We may also have to pass on your personal data in connection with, for example, a merger, bankruptcy or reorganisation at Relieved. If this is the case, your personal data will only be passed on to third parties subject to this privacy statement.
Retention period
We will store your personal data for as long as you give us permission to do so. We must keep some information for longer periods due to a statutory retention obligation, for example, the retention periods under tax laws or under the Medical Treatment Contracts Act. We store chat messages and usernames for a maximum of 31 days. After 31 days, this data is automatically deleted from our servers.
You can remove the app from your device at any time. From that moment on, we will no longer collect new information and it means your explicit consent for the processing of your personal data is withdrawn. We will no longer process your personal data after that.
Certain information may be of great importance to us. For example, we may be able to improve our business operations based on your personal data. If we come across data which we deem to be of great value, we may store this data permanently. In that case, we will anonymise all your personal data, so this data can never be traced back to you as a person.
Security
The security of personal data is of great importance to us. We take appropriate security measures to limit misuse and unauthorised access to personal data. This way, we ensure only authorised people have access to your data. Confidential advisors, for example, always log in with an additional authentication method. This way, we can be certain as to which confidential advisor it concerns. We also take extra security measures to protect your sensitive data as much as possible. We store this sensitive data encrypted and separately and use secure connections to send this data. To prevent the content of a message from going through your Google or Apple account, and to prevent e.g. family members from reading private messages, notifications about new messages never contain or show the content of the message itself.
The content of chat messages and associated usernames are encrypted in such a way that only confidential advisors can read them. Messages with feedback on the app sent via the appropriate form can be read by us, Relieved (developer of the app).
In addition, access to the data is protected and we regularly check our security measures. For our services we only use the services from independent and certified hosting providers in the Netherlands and Germany.
Third-party websites
This privacy statement does not apply to third-party websites that are connected to our website or app through links. We cannot guarantee that these third parties will handle your personal data in a reliable or secure manner. We recommend reading the privacy statement of these websites before using these websites.
Changes to this privacy statement
We reserve the right to make changes to this privacy statement. We recommend consulting this privacy statement regularly so you are aware of these changes.
Inspecting and changing your data
If you have any questions or if you would like to know what personal data we hold about you, you can always contact us. You can contact us for this using the details below. You have the following rights:
- to receive an explanation about what personal data we hold on record and what we do with it,
- access to the precise personal data we hold on record,
- to have errors corrected,
- to have personal data deleted,
- withdrawal of consent, and
- to object to a particular use of data.
Please note that you always clearly state who you are, so we can be sure that we do not change or delete data from the wrong person.
Filing a complaint
If you are not satisfied with how we handle (a complaint about) the processing of your personal data, you have the right to file a complaint with the Dutch Data Protection Authority.
Contact details
If you have any questions or if would like to know exactly what data we hold about you, please contact us.
Contact details
Cinnux B.V.
Boterdiep 69-1
9712 LK Groningen
The Netherlands
info@opgelucht.app
Dutch Chamber of Commerce 75979683
