Data protection

Effective Date: January 01, 2019

With GroupLotse, controlex GmbH offers a virtual group assistant for the digitization of decision-making processes, which can be used via various third-party services (collectively the "Service") and websites, in particular www.grouplotse.com (the "Website"). As you use the Service and interact with the Websites, GroupLotse collects and processes information from and about you to provide you with access to the Service, enhance your experience using the Service, and interact with you. This privacy policy (the "Privacy Policy") describes how GroupLotse collects, uses and shares information collected through the Service and the Websites, and the choices you have regarding that information. The first section below explains which privacy policy applies to you depending on what type of user you are.

References to “GroupLotse” in the Privacy Policy refer to the GroupLotse organization acting as data controller or processor of your information, as further explained below. If you do not agree to this Privacy Policy, do not access or use the Service, the websites or any other part of GroupLotse's business.

If you have any questions about this data protection declaration, please contact GroupLotse at: controlex GmbH – GroupLotse, Philosophenweg 31-33, 47051 Duisburg, Germany or by email to datenschutz@grouplotse.com.

This privacy policy includes the following sections:

1. What type of user am I and what privacy policy applies to me?
2. Subscriber Privacy Policy
3. Privacy Policy for Free Users
4. Privacy Policy for Website Visitors
5. Further data protection provisions for all users
6. GroupLotse contact details

GroupLotse distinguishes three different types of users depending on the GroupLotse products used. Please use the points below to determine what type of user you are and then click on the internal link to see the privacy policy that applies to you. It is possible that you can use GroupLotse in different ways. If so, you should read all relevant privacy policies. Be sure to also read Section E. This section describes the privacy policy that applies to all users.

We refer to users who use the Service as part of a paid GroupLotse subscription as “Subscribers”. The Service features and functions available to Subscribers are governed by the specific terms, pursuant to a separate regulation agreement concluded between GroupLotse and the Organization (e.g. your employer or another legal or natural person, referred to as “Customer”) providing, accessing and using the Service (for purposes of this Privacy Policy, the “Customer Agreement”). The Customer controls the Service at its end and is the data controller of the information collected through the Service about group and channel members and GroupLotse is the data processor of this information. Please click here to go directly to the Subscriber Terms.

Users using a free version of the Service are "Free Users". Free Users can access and use the Service, but their access to Service features and functions is more limited than that of Subscribers. GroupLotse is the data controller of the information collected through the Free Users Service. Please click here to go directly to the conditions applicable to free users.

We call the users of the websites "website visitors". Website visitors can be individuals who are simply browsing the websites but not using the GroupLotse service; However, website visitors can also be free users or subscribers who visit the websites to obtain additional information about GroupLotse. GroupLotse is the data controller of the information collected through the website about website visitors. Please click here to go directly to the Terms and Conditions applicable to website visitors.

Section II of this Privacy Policy applies only to Subscribers. If you are a Subscriber, the “Customer Agreement” governs the collection and processing of information that GroupLotse collects about you through the Service, including all messages, attachments, files, tasks, team names, channels and other content submitted through the Service. In the event of any conflict between this Privacy Policy and the Customer Agreement, the Customer Agreement shall govern. If you are a subscriber within the European Union, please note that you are the data controller for the processing of your group or channel content under the EU General Data Protection Regulation (“GDPR”). When processing group content of data subjects within the EU that is subject to the customer contract, GroupLotse is the processor, which means that we collect and process this information exclusively on behalf of the customer.

This section explains the information we collect from subscribers. We do not require subscribers to provide us with any information. However, certain information such as B. Customer login information is required to provide you with access to the Service and other information may be collected automatically when you use the Service.

Group Content will be collected, used and shared by GroupLotse in accordance with Customer's instructions, including any applicable terms of Customer's Agreement or applicable law. Not GroupLotse, but Customer establishes its own internal policies for access, modification, deletion, sharing and retention of Group and Channel Content that may apply to your use of the Service. For example, a customer can provide or remove messages from an IoT device, enable or disable third-party integrations.

To set up your GroupLotse account, you as a customer must provide us with the following information about yourself: username and telephone number. If you provide payment information in connection with your use of the Service, we use an external payment processing company. Payment information is also collected here, in the case of credit card payment also your credit card number and billing address. In this case, it is not GroupLotse that stores your payment information, but the third-party provider on our behalf.

As you use the Service, we collect information about how you use and interact with the Service ("Service Usage Information"). Such information includes, but is not limited to: Service usage metadata – when you interact with the Service, metadata is generated that provides high-level (non-content) data about how you interact with the Service. For example, we may record the number of groups you work in; the number of actions you have triggered; the features and embedded Service content that you interact with; the types of files you share; and, if applicable, what the third-party services and integrations you use log. We do not have access to content shared outside of the GroupLotse Service in the group or channel.

You may provide information to us when you interact with us in other ways, e.g. B. when you send us inquiries or questions via forms or email (e.g. support forms, sales forms, user research participation forms); information you provide in connection with beta testing; and provide customer support and technical assistance requests (collectively, “Other Information”).

If you choose to use or connect to third-party integrations (e.g., Slack, Microsoft Teams, Telegram, IFTTT) through the Service, those third parties may provide us with access to additional information related to your interaction with those Services associated with and store your use of the Service. You understand that when you make these connections, we will share information about you that is necessary to enable your use of third-party integrations through the Service. Do not initiate these connections if you do not want this information to be shared. By enabling those connections, you authorize us to connect to and access the information provided through those connections; You understand that the privacy policies of the relevant third parties apply to these connections.

If you use our service under Microsoft Teams, the Microsoft Bot Framework will be activated. Our GroupLotse service is enabled by Microsoft Bot Framework. The Microsoft Bot Framework is a set of web services that enable intelligent services and connections through conversational channels you authorize. As a service provider, Microsoft transmits content you provide to our service to enable the service. For more information about Microsoft privacy policies, see the privacy statement here. In addition, your interactions with this service are subject to the applicable conversation channel terms of service, privacy and data collection policies. To report abuse using a bot that uses the Microsoft Bot Framework, please visit the Microsoft Bot Framework website at www.botframework.com and use the Report Abuse link in the menu to contact Microsoft.

We generally only use the minimum data requirements required for third-party integration.

This section explains how GroupLotse uses information collected from subscribers.

• maintaining, providing and improving the Service
• Prevention or resolution of technical or security-related problems and resolution of support requests
• To investigate when we have a good faith belief, or have received a complaint, that content violates the customer contract or our Terms of Service.
• Complying with a valid court subpoena, request, or other lawful process consistent with the requirements of the customer contract and our enforcement policies.
• Insofar as this is otherwise stipulated in our customer contract or expressly approved in writing by the customer.

• maintaining, providing and improving the Service
• Responding to your requests for information
• Prevention or resolution of technical or security-related problems and resolution of support requests
• A good faith investigation of alleged violations of our Terms of Service
• Better understand the interests and needs of users and customize the service for our users
• Conducting analysis, research and reporting on the use of the Service
• Protection of the Service and our users
• Communicate with you via email and through the Service about important notices and updates related to the Service, e.g. B. to notify you about changes to the Service, our Service offerings and important Service-related notices, e.g. B. about security and fraud cases. Because these communications are an important part of the Service, you cannot opt out of them.
• Communicate with you in accordance with applicable legal obligations about promotions, offers and news about GroupLotse. You can opt out of such promotions.
• Offer cross-device management of your account. For example, we may find or attempt to find the same unique users across multiple browsers or devices (e.g., smartphones or tablets), or work with service providers who do this to store your preferences across devices and analyze use of the Service.

Subject to the applicable Subscriber Agreement, we may share the information we collect from Subscribers as follows:

1. Group and Subsidiaries: We may share the information we collect within the GroupLotse group of companies.
2. Service Providers: We may provide access to or share your information with selected third parties who will only use this information to perform services on our behalf. These third parties perform a variety of services for us, including but not limited to sales, marketing, content and feature delivery, analytics, data storage, security, anti-fraud and other services.
3. Business Transactions: If ownership of all or substantially all of our business changes, we may transfer your information to the new owner to enable the Service to continue operating. If so, the promises and commitments contained in this Privacy Policy will continue to apply to your information until the acquirer changes them. If such transfer is subject to additional mandatory restrictions under applicable law, GroupLotse will comply with them.
4. In accordance with your settings within the Service. Please note that the Group Content that you submit via the Service may be visible to other users in the Group or Channel.

We may aggregate and/or anonymize information collected through the Service so that such information can no longer be associated with you or your device ("Aggregated/Anonymized Information"). We may use aggregated/anonymized information for any purpose including, without limitation, research and analytics and may also share this information with third parties including partners, affiliates, service providers, etc.

We may combine the information we collect through the Service with information we receive from other online or offline sources and may use that combined information in accordance with this Privacy Policy and the Customer Agreement.

We store your information for the period necessary to fulfill the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law or when the customer contract requires or permits specific retention or deletion periods.

Please contact your Groups or Channel Administrator(s) to exercise any data subject rights you may have under applicable local law, including your ability to access, delete, rectify, transfer, or object under the GDPR.

Section III of this privacy policy only applies to free users of the service. If you are a free user within European Union, GroupLotse is the controller of your personal data according to the GDPR.

This section explains how we collect, process and use the data collected from free users. We do not require free users to provide information to us. However, as explained below, certain information such as B. Customer login information is required to provide you with access to the Service and other information may be collected automatically.

GroupLotse collects the following information submitted by Free Users directly through the Service:

• Messages, attachments, files, group and channel names, actions, and other content (collectively, the "Group Content"), files, and attachments transmitted through the Service are only stored until delivered to the third party providers (Slack Microsoft Teams, Telegram). and then immediately deleted;
• Information you provide as part of your account registration with GroupLotse, including your phone number, username and password (collectively, the "Account Information"); and
• Information you provide in other interactions with us, e.g. B. when you send us inquiries or questions via forms or email (e.g. support forms, sales forms, user research participation forms); Information you provide in connection with any GroupLotse sweepstakes, contest or research study in which you participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”).

As you use the Service, we collect various information about how you use and interact with the Service (“Service Usage Information”). Such information includes, among other things:

Metadata - when you interact with the Service, metadata is generated that provides high-level data (not content-related) about the way you work in your workspace. For example, we may record the number of groups and channels you work in; the number of tasks assigned to you; the features and embedded Service content that you interact with; the types of files you share; and, if applicable, what the third-party services and integrations you use log. We do not have access to content shared outside of the GroupLotse service in the group or channel.

If you choose to use or connect to third-party integrations (e.g., Slack, Telegram, Microsoft Teams, IFTTT) through the Service, those third parties may provide us with access to additional information about your interaction with those Services in the enable and store them in connection with your use of the Service. You further understand that if you make these connections, we will share information about you that is necessary to enable your use of third-party integrations through the Service. Do not initiate these connections if you do not want this information to be shared. By enabling those connections, you authorize us to connect to and access the information provided through those connections; You understand that the privacy policies of the relevant third parties apply to these connections.

If you use our service under Microsoft Teams, the Microsoft Bot Framework will be activated. Our GroupLotse service is enabled by Microsoft Bot Framework. The Microsoft Bot Framework is a set of web services that enable intelligent services and connections through conversational channels you authorize. As a service provider, Microsoft transmits content you provide to our service to enable the service. For more information about Microsoft privacy policies, see the privacy statement here. In addition, your interactions with this service are subject to the applicable conversation channel terms of service, privacy and data collection policies. To report abuse using a bot that uses the Microsoft Bot Framework, please visit the Microsoft Bot Framework website and use the Report Abuse link in the menu to contact Microsoft.

We generally only use the minimum data requirements required for third-party integration.

GroupLotse can e.g. B. from affiliated companies that are under common ownership and control and from third parties, such as business partners, marketers, researchers, analysts and other parties additional information such as e.g. B. receive demographic information about you, which we may use to supplement the information we collect directly from you.

GroupLotse may use the information collected from Free Users to:

maintaining, providing and improving the Service
Responding to your information requests
Prevention or resolution of technical or security-related problems and resolution of support requests
Good faith investigation of alleged violations of our Terms of Service
Complying with a valid court subpoena, request, or other lawful process that meets the requirements of our law enforcement policies
Better understand the interests and needs of users and customize the service for our users
Conducting analysis, research and reporting on the use of the Service
Protection of the Service and our users
Communicating with you via email or through the Service about important notices and updates related to the Service, e.g. B. to notify you about changes to the Service, our Service offerings and important Service-related notices, e.g. B. about security and fraud cases. Because these communications are an important part of the Service, you cannot opt out of them.
Communicate with you in accordance with applicable legal obligations about promotions, offers and news about GroupLotse. You can opt out of such promotions.
Provide cross-device management of your account. For example, we may find or attempt to find the same unique users across multiple browsers or devices (e.g., smartphones or tablets), or work with service providers who do this to store your preferences across devices and analyze use of the Service.

If you are located in the EU, please note that the EU General Data Protection Regulation (“GDPR”) legal bases for using the information we collect through your use of the Service as a Freelance User are as follows:

1. Where use of your information is necessary for us to perform our obligations under a contract we have with you (e.g. to comply with the terms of service you accept by using the Service).
2. When the use of your information is necessary for our legitimate interests or the legitimate interests of others (e.g. to secure or operate our Service; prevent fraud; analyze and improve the use of our Service and for similar purposes).
3. When the use of your information is necessary to comply with a legal obligation.
4. When we have your consent to process data in a certain way.

We share the information we collect about Free Users through the Service with the following people:

We may share the information we collect within the GroupLotse group of companies.

We may provide access to your information or share it with selected third parties who will only use this information to perform services on our behalf. These third parties perform a variety of services for us, including but not limited to sales, marketing, content and feature delivery, advertising, analytics, research, data storage, security, fraud prevention, and other services.

If ownership of all or substantially all of our companies changes, we may transfer your information to the new owner so that the websites can continue to operate. If so, your information will remain subject to the commitments and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or modified by the acquirer by notice to you. If such transfer is subject to additional mandatory restrictions under applicable law, GroupLotse will comply with them.

We may also share your information with third parties with your consent.

Please note that the groups and channel content that you submit via the Service may be visible to other users in those groups and channels, depending on the specific settings you have chosen.

We may aggregate and/or anonymize information collected through the Service so that such information can no longer be associated with you or your device ("Aggregated/Anonymized Information"). We may use aggregated/anonymized information for any purpose, including without limitation, research and marketing purposes, and may also share this information with third parties, including advertisers, advertising partners, sponsors, event organizers and/or others.

For the purposes set out in this Privacy Policy, we may combine the information we collect through the Service with information we receive from other online or offline sources and may use that combined information in accordance with this Privacy Policy.

We store your information for the period necessary to fulfill the purposes set out in this Privacy Policy, unless a longer retention period is required by law.

Local legal provisions (e.g. in the EU) may give you additional rights. If you would like further information in relation to your statutory rights under applicable law, or wish to exercise any of them, please contact us at any time using the information in the “GroupLotse Contact Information” section below. Your local law (e.g. in the EU) may allow you to require us to:

1. Granting access to and/or a copy of certain information we hold about you.
2. Prevent the processing of your information for direct marketing purposes (including the processing of direct marketing through profiling).
3. Updating outdated or incorrect information.
4. Delete certain information that we hold about you.
5. Restrict how we process and share certain information about you
6. Transmission of your data to an external service provider.
7. Revocation of your consent to the processing of your data.

We will consider all requests and provide our response within the time limit required by law. However, please note that in some cases certain information may be exempt from such requests, including where we need to continue processing your information for our legitimate interests or to comply with a legal obligation. We may ask you to provide us with information necessary to identify you before responding to your request.

Section IV of this Privacy Policy applies only to website visitors. The following rules apply to you when you visit the websites, whether or not you are also a user of the service. For the avoidance of doubt, please note that the terms in this section apply only to use of the GroupLotse Websites, not to use of the Service. If you are a website visitor within the European Union, GroupLotse is the controller of your personal data under the EU General Data Protection Regulation (“GDPR”).

When you use the websites, we collect the following information about you:

• Contact Information - if you submit a request for information or a question through the Sites, you may be asked to provide basic information such as your name, email address, telephone number and postal address. We will also keep a record of the communication, the question/request you made and how it was dealt with. If you choose to participate in a GroupLotse sweepstakes, contest or research study offered through the Sites, we will also collect basic contact information from you in connection therewith.
• Information about the use of the websites - while you visit the websites, we and our service providers (ie third party companies who operate and improve the websites on our behalf) use various technologies, including cookies and similar tools, to collect information about your use of the websites . For example, our servers automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks and how you interact with links on the websites, domain names, entry pages, pages visited, mobile operator identifiers mobile devices and information about the device you use to access the Sites, date and time stamp information, and other such information.
• Location Information - we collect and process general information about the location of the device from which you access the Service (e.g. approximate geographic position, which can be derived from an IP address).

We and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels and other similar tracking technologies to collect the aforementioned information about the use of the websites. A web server log is a file that stores website activity. An SDK is a piece of code that we embed into our applications and software to enable third parties to collect information about how users interact with the websites. A cookie is a small text file that is placed on your computer or mobile device when you visit a website, which enables us to (i) recognize your computer and login session, (ii) remember your preferences and settings, (iii) understand which pages of the Sites you have visited, (iv) improve your user experience by delivering content and advertising tailored to your interests and measuring their effectiveness, (v) perform analytics, and (vi) engage with security and support management functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online advertisements and/or emails that are used to measure usage information such as ad impressions or clicks , frequency of e-mail opening, measurements of the popularity of the websites and related advertising, and access to user cookies. If we use additional technologies, we may also collect information using other methods. Please note that you can change your settings to be notified when a cookie is set or updated, or to block cookies entirely. For more information, see the "Help" section of your browser (e.g. Internet Explorer, Google Chrome, Mozilla Firefox or Apple Safari).

We use information collected from website visitors for a variety of purposes, including:

• maintaining, providing and improving the Sites and the Service.
• Responding to your information requests.
• Communicate with you in accordance with applicable legal obligations about promotions, offers and news about GroupLotse. You can opt out of such promotions.
• Prevention or correction of technical or security-related problems.
• Good faith investigation of alleged violations of our Terms of Service.
• Better understand the interests and needs of website visitors and customize advertising and content you see on the websites.
• Conducting analysis and research about use of the Sites and the Service.

If you are located in the EU, please note that the GDPR legal bases for using the information we collect from your use of the Sites as a freelance site visitor are as follows:

1. Where the use of your information is necessary for us to perform our obligations under a contract we have with you (e.g. to comply with the terms of use which you accept by browsing the websites)
2. When the use of your information is necessary for our legitimate interests or the legitimate interests of others (e.g. to secure or operate our websites; prevent fraud; analyze and improve the use of our websites and for similar purposes) .
3. When the use of your information is necessary to comply with a legal obligation.
4. When we have your consent to process data in a certain way

We may aggregate and/or anonymize information collected through the Sites so that such information can no longer be associated with you or your device ("Aggregated/Anonymized Information"). We may use aggregated/anonymized information for any purpose, including without limitation, research and marketing purposes, and may also share this information with third parties, including advertisers, advertising partners, sponsors, event organizers and/or others.

You acknowledge that, for the purposes set out in this Privacy Policy, we may combine the information we collect through the Sites with information we receive from other online or offline sources and use that combined information in accordance with this Privacy Policy . However, where the collection of information about you is governed by a customer contract, information will only be combined and used in accordance with that customer contract and the sections of this Privacy Policy applicable to subscribers.

We may use third-party web analytics services on our websites to collect and analyze usage information through cookies and similar tools, to conduct audits, investigations or reports, and to provide you with certain features. Click here to prevent Google Analytics from using your data for analytics by installing the Google Analytics Opt-Out Browser Add-on.

(“Do Not Track”, “DNT”) is a privacy preference that users can set in certain web browsers. We strive to provide you with meaningful choices about the information collected on our websites for external purposes, and as such we offer you the various opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals. More information about Do Not Track can be found here.

We share the information we collect through the Sites with the following people:

We may share the information we collect within the GroupLotse group of companies.

Your content goes here

If ownership of all or substantially all of our companies changes, we may transfer your information to the new owner so that the websites can continue to operate. If so, your information will remain subject to the commitments and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or modified by the acquirer by notice to you. If such transfer is subject to additional mandatory restrictions under applicable law, GroupLotse will comply with them.

The websites allow you to upload comments or feedback and share them publicly with other users, e.g. B. in the GroupLotse Community Forum. Information that you transmit publicly in this way is not confidential and GroupLotse may use it for any purpose (eg in GroupLotse marketing materials). Information that you openly post in this manner will be available to the general public and may be accessible to third party search engines. Such information can be read, collected and/or used by other users and could be used to send you unsolicited messages. Accordingly, caution should be exercised when using these functions of the websites.

We may also share your information with third parties with your consent.

We store your information for the period necessary to fulfill the purposes set out in this Privacy Policy, unless a longer retention period is required by law.

Local legal provisions (e.g. in the EU) may give you additional rights. If you would like further information in relation to your statutory rights under applicable law, or wish to exercise any of them, please contact us at any time using the information in the “GroupLotse Contact Information” section below. Your local law (e.g. in the EU) may allow you to require us to:

1. Granting access to and/or a copy of certain information we hold about you
2. Prevent the processing of your information for direct marketing purposes (including the processing of direct marketing through profiling)
3. Updating outdated or incorrect information
4. Delete certain information that we hold about you
5. Restrict how we process and share certain information about you
6. Transmission of your data to an external service provider
7. Revocation of your consent to the processing of your data

We will consider all requests and provide our response within the time limit required by law. However, please note that in some cases certain information may be exempt from such requests, including where we need to continue processing your information for our legitimate interests or to comply with a legal obligation. We may ask you to provide us with information necessary to identify you before responding to your request.

The websites may contain links to external websites and functionalities. If you choose to use these third-party services, depending on how the services work, you may be disclosing your information not only to those third parties, but also to their users and the broader public, if applicable. Because these external websites and services are not operated by GroupLotse, GroupLotse is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information is governed by the privacy policies of the third party websites or services and not this Privacy Policy. Please be sure to read the privacy and security policies of the relevant third parties.

The following additional information about GroupLotse's privacy practices applies to all users of GroupLotse (subscribers, free users and website visitors).

We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the functionality of our Service or the websites, or advances in technology. As we will be making the revised Privacy Policy available through the Service and the Websites, you should review the Privacy Policy periodically. If we make a material change to the Privacy Policy, we will comply with applicable legal requirements for your notification and/or consent.

GroupLotse takes technical and organizational measures to protect your data against accidental or unlawful destruction or against accidental loss, alteration, unauthorized disclosure or access. However, there is no method of transmission over the Internet, or means of storage, electronic or physical, that is completely secure, so we cannot ensure or warrant the security of this information.

When you receive emails from us, we may use certain analysis tools, such as B. use clear GIFs to collect data, e.g. B. when you open our message or click on links or banners in our email. This data allows us to gauge the effectiveness of our communications and marketing campaigns. Contact us via the “GroupLotse Contact Information” section below if you do not want us to further use your contact information to contact you by email, post or phone about products, services, promotions and special events that may be of interest to you . In the case of promotional emails, you can also unsubscribe by following the instructions at the bottom of these emails. Please note that despite request to do so, we may continue to use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not unsubscribe from certain operational or service-related emails, e.g. B. if they reflect our relationship or transactions with you.

controlex GmbH – GroupLotse
Philosophenweg 31-33
47051 Duisburg
Germany

If you wish to contact us or have any questions or complaints in relation to this Privacy Policy, please email us at: privacy@grouplotse.com