Privacy Policy

PRIVACY POLICY FOR THE BREZELKÖNIG APP (HEREINAFTER “APP”)

Brezelkönig AG (hereinafter “Brezelkönig” or “we”) takes the protection of personal data very seriously. In this Privacy Policy, we endeavour to inform you about how we process your personal data in connection with your use of this app.

In the event of ambiguities or contradictions between the different language versions of the data protection regulations, the German version shall always prevail.

Controller and data protection officer

The controller responsible for the processing of your personal data in connection with this app is Brezelkönig AG, Neuenkirchstrasse 91, 6020 Emmenbrücke. You can contact our company data protection officer at dataprivacy@valora.com.

Types of data, purpose of processing and legal bases

Brezelkönig primarily uses the data you provide for the purpose of the proper operation of this app, as well as the provision and processing of app services. Details can be found in this section.

  • Data collected during the registration process: During the registration process, we ask you for your first name, surname, date of birth (optional), gender, email address and mobile telephone number. We then generate an individual user ID for you. The processing of this data takes place to fulfil the Terms of Use of this app, to enable you to access the app, to maintain your user account and to address you correctly in the event of direct communication. You may provide us with your date of birth if you wish us to send you a birthday message and a small birthday surprise.
  • Payment method data pertaining to payment within the app: If you choose to register a specific means of payment (e.g. a credit card) in the app, you will in future be able to collect stamps, points and other benefits as well as pay for your purchase on demand by showing the QR code in the app. In this case, we store the type of payment method (e.g. VISA, MasterCard etc.), if applicable your partially masked card number (e.g. XXX XXX XXX1 234) and the expiry date as well as a so-called pseudonymous card alias (an alphanumeric identification number created by the payment processor based on your card number). You can delete the stored means of payment in your customer profile at any time. In this case, your payment method data will also be deleted from our systems. Furthermore, the data will be deleted if you delete your entire customer account.
  • Data during app usage: Your individual user profile is comprised of the data you enter during registration (see above), your number of crowns, your crown cards, offers you have already collected (vouchers), your redemption of such offers and additional data on app usage (whether and when you have used the app, which functions you have accessed etc.). Based on the user profiles of all app users, we can carry out analyses which can provide information on consumer behaviour and consumer profiles. Such processing is carried out on the basis of our legitimate interest in achieving a better understanding of user acceptance and optimising this app and our offers on an ongoing basis. Depending on the analysis, your data is either aggregated (and thus anonymised) or pseudonymised.
  • Direct advertising: Based on the evaluation of your user profile, we can send you appealing offers and relevant information on products and offers on the app. When choosing your settings for the app, you can choose whether you wish to receive push notifications. You may change your selection at any time.

Personal data within the framework of the download of this app from the app store

When you download this app, the relevant app store processes certain data relating to the user and the user’s device, e.g.: IP address, device identification numbers (IMEI, UDID, IMSI, MAC address), mobile number (MSISDN), name of the device, user-specific app store registration data e.g. user name/password.

The use of third-party platforms connected to the Brezelkönig app takes place at the user’s own risk. We have not reviewed the third-party platforms and cannot accept any responsibility for how the providers process personal data. We recommend that you read third-party platforms’ privacy policies in advance.

Passing on of personal data

  • Passing on of your data to other Valora companies: Insofar as it is necessary for the provision of this app or for other legitimate interests of Brezelkönig, Brezelkönig shall pass on your data to other members of the Valora company group.
  • Passing on of personal data to third parties: Brezelkönig may certain transfer tasks and data to third parties commissioned by it (“service providers”) in order to ensure the proper operation (e.g. implementation of the registration process), the maintenance and the various functionalities of this app and in order to store the data. The service providers are processors for Brezelkönig and are contractually required to comply with the processing purposes set out here. They may only process your data in particular within the framework of the performance of their contractual duties to Brezelkönig and their duties pursuant to valid law.
  • Disclosure in connection with a corporate transaction: In the event we are involved in a fusion, joint venture, company acquisition or sale or sale of assets, we may pass your data on to any transaction partners for further processing by them.
  • Disclosure in connection with criminal proceedings: Insofar as legally permissible, we may disclose information which is required or beneficial to investigate or prevent an actual or suspected crime or other violation of our rights or the rights of a third party.
  • Aggregated and anonymised evaluation data: Brezelkönig may pass on aggregated or anonymised data to the public and other partners. For example, it is possible that Brezelkönig may publish such information in order to highlight trends in customer behaviour. However, you will no longer be identifiable as an individual from this data.

Place of processing and transmission to third countries

Your data is processed in Switzerland and in the member states of the European Union. We are also entitled to transmit your personal data to third-party companies abroad, in particular subsidiaries, insofar as this is necessary within the framework of the purpose of processing. In connection with this, the statutory requirements concerning the passing on of personal data to third parties are, of course, observed. These third parties are obliged to ensure data protection to the same extent as we are. If the level of data protection in a country does not correspond to Swiss data protection law, we contractually ensure that the protection of your personal data corresponds at all times to that in Switzerland. In order to achieve these, we either conclude the recognised standard contractual clauses with the recipient or implement other additional suitable guarantees.

Retention period for your personal data

All stored personal data shall only be stored by Brezelkönig (and/or by affiliated companies or third-party service providers on behalf of Brezelkönig) for as long as is necessary for the usage of the app or insofar as this is legally permissible or required by law.

  • Registration data shall be used for the period for which the user account exists. Without this being requested, user accounts will be deleted after two years of inactivity.
  • Analysis data will be used by Brezelkönig for a period of two years.

Data for which the specified maximum processing period has been reached will be automatically erased within one month.

However, aggregated or anonymised data which no longer relates to individual users may be processed beyond the specified period.

Your rights in connection with your personal data

  • Revocation of consent: You have the right to revoke your consent to data processing to which you have provided your consent at any time. You can amend your personal settings in the app. Since you can provide your consent to various functionalities, in the event of the revocation of your consent, only the functionalities for which you have revoked your consent (e.g. push notifications) will be deactivated or restricted. If you have subscribed to our newsletter, it is easy to unsubscribe by clicking the unsubscribe link in the newsletter.
  • Objection: You may object to data processing which we carry out on the basis of our legitimate interests at any time.
  • Right of access: You also have the right to receive information from us as to which data concerning you we are processing on which legal basis and for which purposes, as well as to request a free copy of your personal data.
  • Right to rectification: Should your data be incomplete or incorrect, you have the right to request the rectification of your personal data. You can correct some information yourself using the app’s customer centre.
  • Right to erasure: You have the right to the erasure of your personal data in some circumstances. The right to erasure may be excluded in individual cases. You have the right to delete your customer account and the data associated with it independently at any time. The final erasure of the customer account takes place 30 days after you request the erasure. Brezelkönig requires this period of time to review the legal permissibility of the deletion request and to prevent fraud. Please note that the uninstallation of the app does not automatically lead to the erasure of your customer account and your data remains stored should you decide to reinstall the app at a later point in time.
  • Automatic decision-making and profiling: Wherever, within the framework of this app, decisions are made exclusively on the basis of automated processing, including the creation of a customer profile (in particular personalised offers), you may reject such decisions which may impact you legally or in another significant manner.

How you can exercise your rights and get in contact with our data protection officer

If you wish to exercise your abovementioned rights or have other questions concerning the processing of your personal data, please contact our company data protection officer at dataprivacy@valora.com. In order to enable our data protection officer to assign your enquiry as quickly as possible, please ideally make reference to the “Brezelkönig app” in your message.

Right of complaint

If you have reason to believe that Brezelkönig is not processing your personal data in compliance with the valid laws and other provisions and/or if you do not agree to the granting of your rights with the answer to your enquiry, you may submit a complaint to the supervisory authority.

How we use analysis tools

We use the Google Firebase developer platform and the associated functions and services of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Firebase is a platform for app developers for mobile devices and websites. Google Firebase provides a variety of functions which are described on the following overview page: https://firebase.google.com/products/.

The functions include, for example, the storage of apps, including users’ personal data, e.g. content created by you or information concerning your interaction with the apps. Google Firebase also provides interfaces which enable interaction between the app users and other services.

The evaluation of users’ interactions takes place using the Firebase Analytics analysis service. This service helps us to record our users’ interactions. For example, it records events such as when the app is opened for the first time, when it is uninstalled, when it is updated, when it crashes or how often it is used. It also records and evaluates certain user interests.

The information processed by Google Firebase may be used in connection with other Google services, e.g. Google Analytics and Google marketing services. In this case, only pseudonymised information, e.g. the Android Advertising ID or the Advertising Identifier for iOS, is used to identify the users’ mobile devices. Users can find more information about Google’s use of data for marketing purposes on the overview page: https://www.google.com/policies/technologies/ads; Google’s privacy policy can be found at https://www.google.com/policies/privacy.

Updates to this Privacy Policy

Please note that we may amend this Privacy Policy at any time without prior notice. Please regularly review this Privacy Policy for the app for changes. We will mark changes with an additional label, such as “New” or “Update”. Any changes will be effective immediately upon the publication of the revised Privacy Policy for the app on this app.

Last updated May 2022