Privacy policy for the app

of PiNCAMP GmbH, Munich, for the use of the app: ADAC Camping / Stellplatz from edition 2022 onwards

1. general information on data processing

a) The controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the Member States as well as other data protection regulations is

PiNCAMP GmbH

Managing Director: Uwe Frers

Hansastrasse 19

80686 Munich

Munich, Germany

E-mail: service@pincamp.de

Website: www.pincamp.de

b) The data protection officer of the controller is

ePrivacy GmbH

Represented by Prof. Dr Christoph Bauer

Burchardstraße 14 20095 Hamburg Germany

Contact: datenschutz@pincamp.de

c) In the following, we provide information about the collection of personal data when using our app. Personal data is all data that can be related to you personally, e.g. name, address, email addresses, user behaviour.

d) When you download the app, the required information is transferred to the App Store (iOS app) or Google Play Store (Android app), in particular your user name, email address and customer number of your account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We only process the data to the extent necessary to download the app to your mobile device.

e) We collect and use our users' personal data only to the extent necessary to provide a functional and user-orientated app, as well as our content and services, and to advertise these in a targeted manner. In addition to the purely informational use of our app, we offer various services that you can use if you are interested. To do so, you must generally provide additional personal data that we use to provide the respective service and for which the data processing principles stated herein apply (see the section on reviews, newsletters and email contact).

f) In some cases, we use external service providers to process your data, for example to send our newsletter (Newsletter section) and to reply to your service emails (Email contact section). These have been carefully selected by us and contractually bound, e.g. as processors in accordance with Art. 28 GDPR.

g) If our service providers or partners are based in a country outside the European Economic Area (EEA), we have ensured with appropriate guarantees that the data processing complies with the principles of the GDPR, for example by concluding EU standard clauses or working with companies in countries for which the European Commission has confirmed an adequate level of data protection by means of an adequacy decision. We will inform you about this in detail below.

h) When collecting and using the personal data of our users, we rely on the following legal bases:

Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR), the initiation or performance of a contract with you (Art. 6 para. 1 lit. b) GDPR), the fulfilment of legal obligations (Art. 6 para. 1 lit. c) GDPR), the implementation of our legitimate interests (Art. 6 para. 1 lit. f) GDPR)

Legitimate interests

The purpose of processing your data is to safeguard the following legitimate interests

  • the improvement of our offer,
  • protecting our systems from misuse,
  • the compilation of statistics,
  • marketing purposes,
  • the storage of our correspondence with you,

i) We store your data,

if you have consented to the processing, at most until you withdraw your consent; if we need the data for the performance of a contract, at most for as long as the contractual relationship with you exists; if we use the data on the basis of a legitimate interest, at most for as long as your interest in erasure or anonymisation does not outweigh this; if statutory retention obligations exist, until the end of the retention periods.

j) Requirement or obligation to provide data Unless expressly stated, the provision of your data is not required or obligatory.

2. use of Apple App Store or Google Play Store - statistical collection of user data and ratings of the app

a) The use of the platforms (iOS App - Apple App Store from Apple Inc. or Android App - Google Play Store from Google LLC) is based on the contractual relationship between the user and the respective platform operator, based on its terms of use and data protection provisions accepted by the user.

b) When the app is downloaded, information, including personal data, is collected by these platforms.

c) We only receive anonymised data from the platforms, which is evaluated to optimise the distribution of the app.

d) The user also has the option of rating the app on the platforms and submitting a written review. These can be viewed by PiNCAMP GmbH in the public area of the platform.

e) PiNCAMP GmbH has the possibility to comment publicly on the ratings on the respective platform.

3) Statistical collection of user data on app usage

When using the app, we collect statistical data that is evaluated to optimise and further develop the app. The data is made available to us in anonymised form via third-party providers with whom PiNCAMP GmbH has a contractual relationship.

3.1 Firebase

We use Firebase from Google for our mobile app. The information generated about your use of the online offer is transmitted to Google servers in anonymised form as described above and stored there.

We use Google's Firebase solution for this. This automatically activates the anonymisation of IP addresses. This means that the IP address of users is truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

In addition, user assignments are made via the advertising ID for Android or via the Apple Ad-ID.

Android users can object to the use of the advertising ID in the settings of their Google account "Disable interest-based ads" https://adssettings.google.com/authenticated. iOS users can object to the use of the Apple Ad-ID here via the setting "No ad tracking" https://support.apple.com/de-de/HT202074 .

3.2 Google Analytics for Firebase

With Firebase, we use the Google Analytics for Firebase service from Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google analyses your use of the app on our behalf in order to compile reports on activities within the service. In addition, the link between Google Analytics and Firebase (see 3.2 below) is activated.

The following data is collected, for example

  • Abbreviated IP address in anonymised form
  • Demographic user data
  • Number of users and sessions
  • Session duration
  • Operating systems
  • Device models
  • Region
  • First-time launches
  • App executions
  • App updates
  • Pages visited

We use Google Analytics with the extension "_anonymiseIp()". This means that IP addresses are further processed in abbreviated form so that they cannot be traced back to individuals. The IP address of users is truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

Detailed information on data collection by Google Analytics for Firebase can be found at: https://support.google.com/firebase/answer/6318039

The data collected is stored for 14 months after the last visit and then automatically deleted.

We use Google Analytics for Firebase to regularly improve our app and our services and to make them more interesting for you. The data processing takes place with your consent on the basis of Art. 6 para. 1 lit. a GDPR.

3.3 Firebase Crashlytics

In addition, Firebase Crashlytics sends real-time crash reports to PiNCAMP GmbH with precise details of codes and device information (device status, device type, operating system, app version, time of crash) in order to report errors in the event of app crashes, also based on the aforementioned Google services (3.1 and 3.2), which are intended to simplify maintenance and improve the resulting stability of the app. The transmitted information does not contain the IP address or any other personal or relatable data or any other data from the mobile device.

4 Firebase Cloud Messaging

We use push messages to send information about products from PiNCAMP GmbH, related companies of the ADAC Group and companies with which we are in partnership. You can only use these functions after you have given your consent via a pop-up/dialogue. The legal basis is therefore Art. 6 para. 1 lit. a GDPR (your consent).

If you have given your consent, a unique identification number will be created for your ADAC Camping app installation and communicated to the service. This service returns a so-called identifier ("Push Notification Identifier"), which no longer allows any conclusions to be drawn about you as a user. This identifier is used exclusively to enable the messaging functions of the ADAC Camping app. It is not passed on to third parties. We use the Cloud Messaging service from Google Firebase to send push notifications. You can find more information on this and on data protection for Google products at https://firebase.google.com and in the Google privacy policy https://policies.google.com/privacy.

You can revoke or re-enable the function in the device settings at any time.

5. in-app messages - Firebase in-app messaging

We also use Firebase in-app messaging to display information about products of PiNCAMP GmbH, related companies of the ADAC Group and companies with which we are in partnership within the ADAC Camping App. The service works on the basis of data from Google Analytics for Firebase (see section 3.2). You can find more information on this and on data protection for Google products at https://firebase.google.com and in the Google Privacy Policy https://policies.google.com/privacy.

6. use of your address book

When you start using our app, we ask you for permission to use your address book/contacts in a pop-up. If you give us permission, you can add the contact details of a campsite/pitch to your address book. The legal basis is Art. 6 para. 1 lit. a GDPR. In this case, you may not be able to use all the functions of our app. You can grant or revoke permission later in the settings of your device. Under no circumstances will address data be transferred to the ADAC.

7. collection of your location data

Our offer includes so-called location-based services, with which we offer you special offers that are tailored to your respective location (display of data in relation to your location). You can only use these functions after you have agreed via a pop-up that we can collect your location data using GPS and your IP address in anonymised form for the purpose of providing the service. The legal basis is Art. 6 para. 1 lit. a GDPR (consent). You can authorise or revoke the function in the settings of the device or app at any time. Your location will only be transmitted to us if you use functions when using the app that we can only offer you if we know your location.

8. ratings of places

The app uses the ADAC e.V. rating portal as an external platform. Members of the ADAC e.V. have the opportunity to write ratings and reviews of individual campsites via this rating portal, which are published in the app. The ratings submitted by clear name or pseudonym are visible to all users of the app. This data is collected and processed via the ADAC e.V. rating portal on the basis of its terms of use [https://www.adac.de/der-adac/verein/corporate-news/mein-adac/]. Prior registration at https://www.adac.de/mein-adac/ is required. This can also be done via the app. You can find details on data protection at ADAC e.V. at https://www.adac.de/datenschutz-dsgvo/.

9. e-mail contact

a) When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, your name and telephone number if applicable) will be stored by us in order to answer your questions.

b) For the targeted processing and answering of your requests, we use the order processor Freshworks Inc, 1250 Bayhill Drive, Suite 315, San Bruno, CA 94066, United States, for some e-mail inboxes, which is effectively integrated and bound by an agreement in accordance with Art. 28 GDPR and EU Standard Contractual Clauses.

c) The processing of personal data from the establishment of contact serves us solely to process the establishment of contact. This also constitutes the necessary legitimate interest in processing the data. The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f GDPR (legitimate interest). If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR (contract).

d) The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected, but at the latest after 2 years. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation is deemed to have ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

e) Objection and cancellation options

f) If you contact us by email, you can object to the storage of your personal data at any time by sending an email to datenschutz@pincamp.de. In such a case, the conversation cannot be continued.

g) All personal data stored in the course of contacting us will be deleted in this case.

h) Further information can be found in Freshworks privacy policy here. Freshworks is also ISO 27001:2013 certified.

10. newsletter

a) With your consent, you can subscribe to our PiNCAMP newsletter, with which we inform you about our current interesting offers. Our advertised goods and services are those from the camping sector, e.g. our app, the PiNCAMP website, the PiNCAMP magazine, ADAC products and services, recommendations on special camping topics and travel destinations.

b) We use the so-called double opt-in procedure to register for our newsletter. This means that after you have registered, we will send you an e-mail to the e-mail address you have provided in which we ask you to confirm that you wish to receive the newsletter. In addition, we store the IP addresses used and the times of registration and confirmation. The purpose of this procedure is to prove your registration and, if necessary, to be able to clarify any misuse. The legal basis is Art. 6 para. 1 lit. a GDPR (consent).

c) The only mandatory information for sending the newsletter is your email address. The provision of further, separately marked data is voluntary and is used to address you personally. After your confirmation, we will save your e-mail address for the purpose of sending you the newsletter.

d) To send the newsletter, we use the European-based processor Episerver GmbH, which is effectively integrated and bound by an agreement in accordance with Art. 28 GDPR. Data processing takes place exclusively in Europe. The information collected is not passed on to third parties.

e) The purpose of collecting and processing the personal data collected is to enable the pincamp.de newsletter to be sent and delivered. The newsletter provides information about news, products and services of PiNCAMP GmbH, companies of the ADAC Group (ADAC e.V. and ADAC SE as well as their affiliated companies) and other advertising partners. We also use your email address to personalise our advertising offer on our social media channels. With this help, we want to ensure that our social media ads correspond to the potential interest of users and are not annoying (see details in the Facebook marketing services [Custom Audiences] section).

f) If you do not confirm your registration via the double opt-in procedure, your data will be marked for deletion and automatically deleted after 7 days. The information collected in this process will be stored until you withdraw your consent.

g) You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can declare your cancellation by clicking on the link provided in every newsletter email, by sending an email to datenschutz@pincamp.de or by sending a message to the contact details provided in the legal notice.

11 Facebook marketing services (Custom Audiences)

a) We use the remarketing function "Custom Audiences" of Facebook Inc, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook") in connection with the registration for our PiNCAMP newsletter. This allows subscribers to the newsletter to be shown interest-based adverts ("Facebook ads") when they visit the Facebook social network or other websites that also use the process. In this way, we pursue the interest of showing you adverts that are of interest to you. If we transmit data to Facebook for the purpose of synchronisation, this data is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done for the sole purpose of creating a comparison with the data that is also encrypted by Facebook.

b) The data processing, in particular the setting of cookies, is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR.

c) We have no influence on the scope and further use of the data collected by Facebook through the use of this tool and therefore inform you according to our level of knowledge: Through the integration of Facebook Custom Audiences, Facebook receives the information that you are using one of our products or have clicked on an advert from us. If you are registered with a Facebook service, Facebook can assign the visit to your account. Even if you are not registered with Facebook or have not logged in, it is possible for the provider to find out and store your IP address and other identifying features.

d) The processing of data by Facebook takes place within the framework of Facebook's data usage guidelines. Accordingly, general information on the display of Facebook ads can be found in Facebook's data usage policy: https://www.facebook.com/policy.php. Specific information and details on Facebook Custom Audiences and how it works can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616. Further information on data processing by Facebook can be found at https://www.facebook.com/about/privacy.

e) Objection and removal options You can object to the data processing of your data for the display of Facebook ads in the following ways or set which types of adverts are displayed to you within Facebook:

f) Via the settings of your Facebook user account https://www.facebook.com/settings?tab=ads. The settings directly on Facebook are platform-independent, i.e. they are adopted for all devices, such as computers or mobile devices.

g) About the revocation of your consent for the use of your e-mail address in connection with the "Custom Audiences" function of Facebook Inc. by PiNCAMP GmbH. You can declare your cancellation by e-mail to datenschutz@pincamp.de or by sending a message to the contact details given in the imprint.

12. your rights under the GDPR

In addition to the above-mentioned rights to revoke consent and object to data processing (see section FOLGT), you have the following rights vis-à-vis us as the controller with regard to your personal data in accordance with the provisions of the GDPR:

  • Right of access
  • Right to rectification
  • Right to restriction of processing
  • Right to erasure
  • Right to information
  • Right to data portability

You also have the right to complain to a data protection supervisory authority about the processing of your personal data in our company.

We will adapt the information if our processes change.

Status of this privacy policy: December 2022