Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration below.
2. Hosting and Content Delivery Networks (CDN)
We are hosting the content of our website at the following provider:
External Hosting
This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.
The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
We are using the following host(s):
BunnyWay d.o.o.
Dunajska cesta 165
1000 Ljubljana
Slovenia
Bunny.net is a distributed content delivery network. Technically, the transfer of information between your browser and our website is routed via that network. This enables us to increase the accessibility and performance of our website. The network records the IP address, but this is anonymized. It also collects personal data if it is entered by the user (e.g. by submitting a contact form on the website).
For this website the delivery is restricted to bunny.net edge locations within the European Union, and the storage region is Germany. No transfer of personal data to a third country takes place in connection with the hosting of this website.
You can find more information about bunny.net here: https://bunny.net/privacy/.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Supabase
The content database behind this website is operated using Supabase, a service provided by Supabase Pte. Ltd., 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513 (hereinafter “Supabase”). Our database instance is hosted within the European Union (region: Europe, Ireland).
In the regular operation of this website, Supabase stores the editorial content presented on the site (e.g., airline policy data). This does not involve personal data of website visitors. Insofar as personal data is processed, this is based on our legitimate interest in the reliable, secure, and efficient provision of our online services (Art. 6(1)(f) GDPR).
Supabase’s contracting entity is based in Singapore. Insofar as personal data is transferred to this third country, the transfer is safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. Further information can be found in Supabase’s privacy policy: https://supabase.com/privacy.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Cloudflare
We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).
We use Cloudflare as the authoritative DNS provider for our domain. Cloudflare answers the DNS queries your device makes in order to resolve our domain name into an IP address, and in doing so processes the requesting IP address. The traffic between your browser and our website is not routed through Cloudflare’s network: it is served directly by our hosting provider named under “External hosting” above. Cloudflare therefore neither filters nor analyses the content of your visit, and sets no cookies in this context.
The use of Cloudflare is based on our legitimate interest in the reliable and secure resolution of our domain name (Art. 6(1)(f) GDPR).
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
3Steps Media UG (haftungsbeschränkt)
Altrottstr. 31
69190 Walldorf
Deutschland
Phone: +49 6227 8991526
E-mail: hello@dogflightguide.com
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.
Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.
4. Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
If other cookies and services are used on this website, you can find this information in this privacy policy.
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
Pirsch Analytics
We use “Pirsch Analytics” on this website. The provider is Emvi Software GmbH, Nickelstraße 1b, 33378 Rheda-Wiedenbrück, Germany (hereinafter “Pirsch”). The data is processed exclusively on servers in Germany.
For web analytics, we use Pirsch Analytics. Pirsch Analytics is a cookie-free web analytics software that was developed according to the Privacy by Design principle. To analyze visitor flows, Pirsch Analytics uses a hashing algorithm to generate a 16-digit number as the visitor ID when the page request is received. The input values are the IP address, the user agent, the date and a salt.
The visitor’s IP address is not persisted in whole or in part, and is anonymized completely and non-reversibly by the hash. The inclusion of the date and the use of one salt per website ensures that website visitors cannot be recognized for more than 24 hours and cannot be tracked across multiple websites. A rough localization (country/city) is performed via a locally integrated database.
We record page views only; we do not track individual interactions on this website.
This analysis is based on Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in the statistical analysis of user behavior in order to optimize both the website and the operator’s advertising. Because Pirsch Analytics stores no information on your device and reads none from it, no consent is required for its use under § 25 TDDDG.
You can find more information about Pirsch Analytics here: https://pirsch.io/privacy.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Contact form
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
5. Plug-ins and Tools
Cloudflare Turnstile
We use “Cloudflare Turnstile” on this website. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Turnstile”).
Turnstile is used to check whether the data input on this website (e.g., in a contact form) is done by a human or by an automated program. For this purpose, Turnstile analyzes the behavior of the website visitor based on a number of characteristics.
This analysis starts automatically as soon as the website visitor enters a website that uses Turnstile. For the analysis, Turnstile evaluates various information (e.g., IP address, time spent on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Cloudflare.
The storage and analysis of the data is based on Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in protecting his web offerings from abusive automated spying and from Spam. If such consent has been obtained, the data will be processed exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, if the consent comprises the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined in the TDDDG. Such consent may be revoked at any time.
The processing of data is based on Standard Contract Clauses, which you can find here: https://www.cloudflare.com/cloudflare-customer-scc/.
For more information on Cloudflare Turnstile, please visit the privacy policy at: https://www.cloudflare.com/cloudflare-customer-dpa/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.
6. Online marketing and partner programs
Affiliate Programs on this website
We participate in affiliate partner programs. In conjunction with affiliate partner programs, ads of businesses are placed on websites or other media of other enterprises within the affiliate partner network. If you click on one of these affiliate ads, you will be transferred to the promoted offer. If you should subsequently engage in a certain transaction (conversion), the affiliate and, if applicable, the owner of the medium on which the advertisement is placed will receive a respective commission in exchange for the service. To be able to compute the commission amount, the affiliate network operator must be in a position to track the ad that has resulted in you seeing the offer and in you completing the predefined transaction. To make this possible, cookies or comparable recognition technologies are deployed (e.g., device fingerprinting).
Data is stored and analyzed on the basis of Art. 6(1)(f) GDPR. Participants in the affiliate program have a legitimate interest in the correct computation of the affiliate compensation. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Amazon Associates Program
The operator of this website participates in the Amazon EU Associates Programme and in the Amazon Associates Program for Amazon.com. The providers are Amazon Europe Core S.à r.l., 38 avenue John F. Kennedy, L-1855 Luxembourg (Amazon.de) and Amazon.com Services LLC, 410 Terry Avenue North, Seattle, WA 98109, USA (Amazon.com). This website, currently on the carrier pages, contains links to product pages on Amazon through which we may receive an advertising fee if you make a purchase there. As an Amazon Associate we earn from qualifying purchases. On the English pages the links go to Amazon.com, on the German pages to Amazon.de.
We do not set any cookies for this on our own website and do not embed any content from Amazon. Only when you click one of these links are you taken to the Amazon website. There, Amazon uses cookies or comparable recognition technologies to track that you came through our link and to calculate the commission. We receive no personal data in this process, only an aggregated overview of the orders placed through our links.
The affiliate links are used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in being able to determine the amount of its affiliate commission. Amazon is responsible for the processing on its own pages; insofar as Amazon requests consent there, the processing is carried out on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG. This consent can be revoked at any time.
For more information on how Amazon uses data, please see Amazon’s privacy notices for Amazon.com and Amazon.de.
7. Mobile application (Dog Flight Guide app)
Scope of this section
This section applies to our “Dog Flight Guide” mobile application for iOS and Android. The remaining sections of this Privacy Policy describe our website. Where the app retrieves content from our website, the sections on hosting and content delivery above apply in addition.
The app requires no user account and no registration. We do not ask you for a name, an e-mail address or any other contact details in order to use it.
Who is responsible for the app, and who distributes it
The controller for the processing described in this section is the operator of Dog Flight Guide, named under “Information about the responsible party (referred to as the ‘controller’ in the GDPR)” above. It decides which data is processed in the app and for which purposes.
The app is developed, published and operated on our behalf and on our instructions by fdmedia GmbH, Altrottstr. 31, 69190 Walldorf, Germany. Because the app is distributed through that company’s Apple Developer account, fdmedia GmbH is shown as the provider of the app in the App Store. fdmedia GmbH acts as a processor within the meaning of Art. 28 GDPR; a corresponding agreement is in place. Responsibility for the processing described here remains with the controller named above.
Data that remains on your device
The app stores the following on your device only: the airlines you have marked as favourites, your language and appearance settings, and a downloaded copy of the airline data so the app can be used without an internet connection.
This information is not transmitted to us and is not accessible to us. It is removed when you delete the app from your device.
Retrieving airline data
To keep its content current, the app downloads a data file from our website (dogflightguide.com). Technically this is an ordinary request to our content delivery network, during which the same data is processed as when you visit our website with a browser (in particular your IP address, the time of the request and technical information about your device). Details and the legal basis are described under “Hosting and Content Delivery Networks (CDN)” above.
The app transmits no personal data of its own in this process, and it does not connect to our content database directly.
Analytics in the app: TelemetryDeck
We use the analytics service TelemetryDeck to understand how our app is used, for example which screens are opened and which functions are used. The provider is TelemetryDeck GmbH, Von-der-Tann-Str. 54, 86159 Augsburg, Germany (hereinafter “TelemetryDeck”).
TelemetryDeck is designed so that individual users cannot be identified. In particular, no advertising identifier (IDFA or Advertising ID), no cookies and no device fingerprinting are used. So that returning use can be told apart from new installations, each signal carries a pseudonymous identifier that is derived from your device and hashed before it is transmitted. It stays the same for our app on your device, it cannot be used to identify you, and it does not allow you to be recognised in the apps of other companies or on websites. The signals we send contain information about the event itself (for example “an airline detail page was opened”), together with technical context such as operating system, app version and language, which the service adds automatically.
The use of TelemetryDeck is based on our legitimate interest in understanding and improving the use of our app (Art. 6(1)(f) GDPR). We have concluded a data processing agreement with TelemetryDeck. Information on data protection at TelemetryDeck, including the hosting locations used, can be found at https://telemetrydeck.com/privacy.
No cross-app tracking
We do not track you across apps or websites operated by other companies, and we do not pass data from the app to advertising networks. For this reason the app does not ask you for tracking permission under Apple’s App Tracking Transparency framework.
Links from the app to our website
The app contains links that open our website in your browser, for example the detail page of an airline, this Privacy Policy and our Legal Disclosure. We append parameters to these links (“utm_source”, “utm_medium” and “utm_campaign”) so that we can see in our website statistics that a visit originated in our app and on which platform. These parameters are identical for all users and contain nothing that relates to you or your device.
Links to the websites of airlines and to their official policy pages carry no such parameters. Once you follow a link to a third-party website, the privacy policy of the respective operator applies.
App stores
The app is distributed through the Apple App Store and the Google Play Store. When you download or update the app, the respective store processes data on its own responsibility, for example your store account and the fact of the download. We have no influence on this and receive only aggregated, non-personal statistics from the stores. Please refer to the privacy information of the respective provider.