PRIVACY POLICY ACTIGY® APP

Privacy Policy (GDPR) for the ACTIGY® App

Status: 01 December 2025

1. Controller

Aspiria Informationstechnologie GmbH represented by Managing Director Peter Postruznik kontakt@aspiria.com Phone: 0816140551-0 (hereinafter: “we” or “us”)

2. General Information on Data Processing

The ACTIGY® App is used exclusively to trigger alarms on an ACTIGY® Server and to receive alarm notifications generated by the ACTIGY® Server.

The App only functions in connection with the ACTIGY® Cloud. A permanent, highly encrypted connection exists between the ACTIGY® App and the ACTIGY® Cloud.

The processing of personal data is carried out in accordance with the GDPR, the BDSG, and other relevant data protection regulations.

3. Categories of Personal Data

3.1 Technical Data

The following data is processed to provide the app and alarm functions, among others:

  • Device information (model, OS version)
  • App version Connection status to the ACTIGY® Cloud
  • Pseudonymized device identifiers
  • Timestamps of alarm events
  • IP address (shortened where possible)
  • Error and diagnostic log files

3.2 Usage

  • Data Triggering an alarm
  • Receipt of alarm messages
  • Usage and interaction data within the app
  • Status information (e.g., “alarm triggered,” “alarm received”)

3.3 Camera Access (QR Code Scan)

The camera is used exclusively to scan QR codes for registration or authentication with the ACTIGY® Cloud.

  • No images are stored or transmitted
  • Processing takes place locally on the device.

3.4 Bluetooth Data

Bluetooth is used when required for certain alarm or localization functions (e.g., connecting to devices or sensors). Processed data includes:

  • Bluetooth device identifiers (pseudonymized)
  • Signal strength
  • Connection status

3.5 Location Data

Location data may be used when required for alarm- or Bluetooth-related features.

  • GPS or network location
  • Location data is not stored permanently
  • Use only with user consent

4. Purposes and Legal Bases of Processing

4.1 Alarm Function (Core Purpose of the App)

  • Triggering an alarm via the ACTIGY® Server
  • Receiving and displaying alarm notifications
  • Ensuring alarm communication
  • Synchronization with the server via the ACTIGY® Cloud

Legal basis: Art. 6(1)(b) GDPR (performance of a contract)

4.2 Access Requiring Consent

  • Camera (QR code scan)
  • Bluetooth
  • Location

Legal basis: Art. 6(1)(a) GDPR (consent)

4.3 Operation, Security, and Optimization

  • Maintaining the highly encrypted connection
  • Technical monitoring and error analysis
  • Stability and performance improvements

Legal basis: Art. 6(1)(f) GDPR (legitimate interests)

5. Disclosure of Data to Third Parties

5.1 ACTIGY® Cloud (German Provider)

The ACTIGY® App communicates exclusively with the ACTIGY® Cloud, hosted by a German cloud provider with multiple locations and redundant, high-security data centers in Germany.

All data processing takes place within Germany or the EU.

Data is transmitted exclusively in encrypted form.

5.2 Processors

We use processors in accordance with Art. 28 GDPR to provide cloud and alarm functions. There is no sale or disclosure of data for advertising purposes.

5.3 App Stores

Payment data (if applicable) is processed only by Google or Apple.

6. Data Processing in Third Countries

There is no transfer of data to countries outside the EU/EEA. The ACTIGY® Cloud is operated exclusively in Germany.

7. Retention Periods

  • Alarm events are retained only as long as necessary for the respective purpose.
  • Technical log data is stored for a maximum of 30 days.
  • QR, Bluetooth, and location data is not stored permanently

8. Rights of Data Subjects

You have the right to:

  • Access (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Objection (Art. 21 GDPR)
  • Withdrawal of consent (Art. 7(3) GDPR)

Please address your requests to the contact information provided above.

9. Data Security

The connection between the ACTIGY® App and the ACTIGY® Cloud uses strong end-to-end encryption (e.g., TLS with modern cipher suites).

The cloud provider’s data centers are:

  • ISO/IEC 27001 certified
  • Built with redundancy
  • Fully GDPR-compliant
  • Located exclusively in Germany

10. Changes to This Privacy Policy

Updates to this privacy policy are made available through the app.