Privacy Policy
01.09.2023
This Data Privacy Statement applies for the offering and use of the "STG App" (hereinafter referred to as "The App"), which is provided to you by GAMI GRUP TREID, 5800 Pleven (hereinafter referred to as "we" or "us") for use on your mobile device.
When using "STG App" , personal data will be collected, processed and used by us. Because the protection of your privacy when using "STG App"" important to us, we would like to inform you with the following information about what personal data we collect when you use "STG App"" and how we handle this data.
You can access this Data Privacy Statement at any time under the "Privacy Policy"" (Datenschutz) heading within the app or at https://stgtrading.de/hadeya/privacy-policy
Data Controller
GAMI GRUP TREID, 5800 Pleven (you will find exact contact details at https://stgtrading.de/hadeya/impressum) is the "controller" in accordance with the applicable data protection law, in particular the EU General Data Protection Regulation (GDPR).
Should you have any questions or comments about data privacy when using "STG App" , please feel free to contact us by email to stg@stgtradind.de
"Personal data" is information, or parts thereof, by means of which you can be identified either directly (e.g. by your name) or indirectly (e.g. by pseudonymised data such as a unique ID). This means that personal data includes, for example, email addresses, addresses, mobile phone numbers, user names, profile pictures, personal preferences and use behaviour regarding the apps used on your end device, user content, financial information and health-related information. However, this could also include one-time identifiers such as the IP address of your end device or the browser you use, and other specific information about your mobile device.
This Data Privacy Statement covers all personal data that is stored and processed by you when using "STG App".
Collection and Use of Your Data
In some cases, you will provide us with immediate access to the data (e.g. when creating a user account and contacting us) and in some cases we will collect the data automatically during the use of "STG App" (e.g. in order to offer our services and understand how you use our services and your apps).
We will use your data to perform and process the contract on the use of "STG App". Within this framework, we will use your data primarily for the calculation and payment of the bonuses acquired by you in the course of your use of "STG App" and inform you about apps participating in "STG App". Other use will only take place due to other statutory obligations or authorisation, if you have granted us permission, or if the use is for legitimate interests of GAMI GRUP TREID as the provider of "STG App".
The legal basis for the processing of your data may be the following:
" your consent to data use within the framework of "STG App"" in accordance with Art. 6(1)(a) GDPR;
" he fulfilment of our service obligations resulting from the contract on the use of "STG App" , in order to provide you with the desired services, in accordance with Art. 6(1)(b) GDPR;
" our legitimate interest in accordance with Art. 6(1)(f) GDPR;
" our commercial interests in the improvement of our services, so that we can better understand your needs and expectations and therefore improve our services for you;
" for the prevention of fraud and to guarantee that the use of "STG App"" takes place completely and without fraudulent conduct and in accordance with the terms and conditions of use of "STG App" : We reserve the right to exclude certain users and their end devices from the services, in the event of impermissible use behaviour, without specifying the exact reason (impermissible behaviour includes, for example, the use of multiple end devices from one IP address [if this is not customary at the respective location or in the respective country], multiple use of user accounts that are linked to payment service providers, furthermore, the use of several mobile phone numbers (which are used to validate the identity of the user), and certain changes to the mobile operating systems, such as the granting of unrestricted admin access, installation of malware or a specific modification of the operating system etc.);
" in order to guarantee the security of our services and ensure that our offering (apps and web server) is technically safe and works properly;
" to secure and implement our contractual entitlements and claims.
You have the right at any time to receive free information about the extent and content of the processing of your personal data by us. You also have the right to request from us the rectification, restriction of processing, or erasure of your personal data.
In the event of data privacy violations, you also have the right to lodge a complaint with the competent supervisory authority.
Further information can be found further down in this Data Privacy Statement, in the following section: "Your Rights as a Data Subject".
When using "STG App"" for the first time, you first have to accept our terms and conditions of use (GTC) during the registration and agree to the processing of your personal data by "STG App" . For this purpose, you have to confirm the following declaration of consent by clicking on the "ACCEPT" button underneath (if you do not want to give consent, please click on "REJECT"; the use of "STG App" will then not be possible):
I hereby agree that by using "STG App" may use the following personal data:
Registration data (email address, date of birth, gender)
Installed apps (including the use duration and use history)
The data is linked to your device via the device ID (GAID or IDFA) ransmitted to our servers in encrypted form. So that app providers can finance our app proposals, your device ID must be transferred to them for billing purposes. In order to measure the usage time as well as the installed apps, users can voluntarily upload screenshots from their mobile phone via the "STG App"" , after which they will be automatically processed, evaluated, and stored in our system for your membership.
The processing of the above data is required in order to be able to suggest apps available in the "STG App""" that match your interests, propose their installation via system notifications, and allow the bonuses earned from using said apps to be calculated. I am aware that the above data results in an interest profile, which, depending on the type of apps I use, may contain particularly sensitive personal data (such as health data or data on my sexual orientation as well as any other data from special categories defined in Art. 9 para. 1 of the European General Data Protection Regulation (GDPR).
Information about Withdrawing Consent
The withdrawal of your consent and the termination of the use of "STG App""" is possible at any time with future effect, and can be sent to GAMI GRUP TREID via email at stg@stgtrading.de or by . Special fees (beyond the regular transmission fees of your telephone or internet service provider, or letter postage) do not apply for the withdrawal of consent. If you withdraw your consent, your data will be deleted from the "STG App" database; if deletion is not possible, the processing of your data will be restricted instead of its being deleted. Further use by "STG App" is no longer possible after the withdrawal of your consent.
Registration
you can log in with your Google login. Additional registration for "STG App" will then not be necessary. For the registration, you will be directed to the Google page where you can register with your user data and therefore link your Google profile to our app. We will hereby automatically receive the following information from Google:
" Google ID;
" your user names (nickname) entered in Google;
" your email address entered in Google;
" your profile and title picture entered in Google;
This information is absolutely necessary to be able to identify you. We will collect and use this data to set up and provide "STG App" on your mobile end device. We require your date of birth to check that you are of legal age, because the use of "STG App" is only permitted for people from the age of 18 years.
We will store the profile image used by you on Google and use it to personalise the display within on your end device.
Your data will be sent encrypted in the SSL process and will therefore be safely sent from the servers of Google.
and the password will be stored with SHA encryption in order to protect your data.
Further Information:
Google's services are provided by Google, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Which personal data containing the above-mentioned information is sent to us depends on the settings selected by you within your Google profile. Please find the corresponding information in the data privacy terms and conditions of Google: https://policies.google.com/privacy?hl=de&gl=de.
The use of the Google login can lead to your personal data being collected by Google and potentially sent outside the EU/EEA, and being stored and used there. This data collection and use is within the area of responsibility of Google. The precise use of the data by Google is not known to us and we have no influence on what data is collected by Google and how it is used by Google.
Please see the above privacy policy and terms of use of Google you agreed to when you registered with them.
Registration/Setting Up a User Account
Registration/Setting Up a User AccountTo be able to use all functions of "STG App"" and in particular to benefit from the bonus payments, you have to register for the use of "STG App"" by setting up a user account. The registration therefore serves to provide the services of "STG App"" and calculate the bonuses generated by you.
During the registration process, we will collect and store certain other personal data about you for the setting up of a customer account, if necessary. This includes (if we have not already collected and stored this in accordance with the steps described above, see above) the following information:
Payment data: Email address of a PayPal account or details for other payment providers that are supported by "STG App".
Phone Number: The "STG App" will request your real mobile phone number linked to a SIM in order to verify that you are not using fake or temporary numbers.
During the use of "STG App", we log and store certain data automatically.
To be able to recommend to you other apps that participate in "STG App" based on your current app preferences, a list of apps currently installed on your end device, as well as apps that you have already installed (but that you have deinstalled) in the operating system installed on your end device, including a use history of all these apps, will be sent to us during the installation of "STG App" .
In order to know your long-term preferences and continue to offer you interesting apps, after the installation of "STG App" and permanently during the use of "STG App" , other apps installed by you on your end device will be automatically recognised by "STG App"" and the name of each newly installed app will be sent to us.
In addition, we will log data about the use of the apps running in the foreground of your end device and the temporal extent of the use (date, time and duration of the use of all apps).
For the logging of the use data within "STG App", we measure the so-called "customer journey". For this purpose, each click or typing of a key within "STG App" will be logged and linked to your profile or stored on the server.
The processing of this data takes place based on the consent granted by you (see above) and serves to perform the contract on the use of "STG App" by you.
We also use the data about your use of the apps running in the foreground of your end device to calculate the bonuses generated by you, if you have obtained and installed these apps via "STG App". For this purpose, we also log and use data about your purchases of services and virtual items within the framework of the apps used by you (in-app purchases), and about relevant in-app occurrences relevant for the calculation of the bonuses, such as level increases.
The processing of this data takes place based on the consent granted by you (see above) and serves to perform the contract on the use of "STG App" by you.
Use Data about the End Device Used by You
In order to be able to identify you beyond any doubt during the use of "STG App" and allocate you for the purpose of the recommendation of new apps, and the calculation and payment of the bonus payments, we store other data about the use of "STG App" and the end device used by you for this purpose. This includes the so-called Google Advertiser ID ("GAID" for Android) and the so-called Apple Identifier for Advertisers ("IDFA" for Apple iOS), the Widevine ID, the model and product name of your end device, the version of the operating system, the browser type used and its display resolution, as well as the IP address allocated to your end device and information about when which content from our offering was accessed, the names of the files requested, and their dates and times of access. We require this data to determine the content requested by you (e.g. text, images, games and product information as well as files provided for download etc.), in order to enable the offering of our services in accordance with the terms and conditions of use, and for the optimal display of "STG App" on your end device. In order for app providers to finance our app suggestions, they must be sent the device ID for billing purposes.
The processing of this data takes place based on the consent granted by you (see above) and serves to perform the contract on the use of "STG App" by you.
If our server logs also automatically log your IP address, this will take place solely for the purpose of guaranteeing the security of our systems, or for fraud prevention, and the IP address will be automatically erased after 30 days at the latest.
The processing of this data therefore takes place to safeguard legitimate interests of GAMI GRUP TREID as the provider of "STG App".
Anonymised Use Data to Improve Our Services
Otherwise, the above-mentioned use data will be prepared, and we will process it in a general and anonymised manner in order to generally analyse the use of "STG App". This data includes the models and product names of the end devices employed for the use of "STG App", the version of the operating system, the browser types used and their display resolutions, as well as general details about when which content from our offering is accessed, the names of the files requested or which data is accessed most frequently, and their dates and times of access. This data is solely for the needs-based design of "STG App" and therefore to constantly improve our services, and detect and rectify any security flaws.
This data does not enable matches to be made to you personally.
The processing of this data takes place based on your permission and to safeguard legitimate interests of GAMI GRUP TREID as the provider of "STG App".
Note: Authorisation to Access Functions and Data on the End Device
In order to be able to use all functions of "STG App", you may have to grant "STG App" permission to access certain functions and data on your device (such as access to your camera or your app library), but this depends on your device and the operating system, over which we have no influence. We will use all authorisation granted by you solely for the above-named purposes, even if authorisation granted (e.g. for technical reasons) theoretically enables other possible uses. You can normally (in other words, depending on your device and the installed operating system) cancel granted authorisation in your device settings at any time.
In the contact section of the app, you can contact us via Chat or ticket system. Your data will thereby be collected by us.
In this case, we will only use your data to respond to your query.
The processing of this data takes place based on your permission and to safeguard legitimate interests of GAMI GRUP TREID as the provider of "STG App".
We will only store your personal data for as long as we need it for the performance of the contract on the use of "STG App", for the fulfilment of your wishes, or for our legitimate interests for the purposes of which we have logged your personal data, or for as long as is permitted or required by law:
When we no longer require your personal data, we will erase it from our systems and records, or anonymise it so that it can no longer be identified.
We can retain certain personal data in order to comply with our statutory and regulatory obligations, and to enable us to manage our rights (e.g. the assertion of our rights in court), or for statistical purposes.
The passing on of your personal data without your explicit prior permission will only take place in the following cases, in addition to the other cases named in this Data Privacy Statement:
We consistently ensure the strict data protection made legally binding in the European Union. In some cases, particularly for technical reasons, it may transpire that your data entrusted to us is stored on servers outside of your country (even outside of the European Union) in which you originally entered your data. In this case and in the case of a risk that countries to which your data are sent are not subject to data protection law that is just as strict as that in your home country and in the country from which you use our services, we ensure that your data is handled in accordance with the provisions of this Data Privacy Statement.
As a data subject in the data processing by "STG App", you have the following rights listed in this section.
If you would like to exercise one of your rights named below, please contact us using the contact details named in the following "Contact" section.
Please note that we may request proof of your identity and extensive information about your query before we can process it.
Within the framework of the applicable statutory provisions, you have the right at any time to obtain free information about the data stored about you personally, its origin and recipients, and the purpose of the data processing. On presentation of the respective prerequisites, you may also have the right to the rectification of incorrect data, the restriction of the processing, and the erasure of data.
Some forms of data processing are only possible on the basis of your explicit consent. You can withdraw consent already given at any time. The legitimacy of the data processing carried out until the withdrawal will remain unaffected by the withdrawal.
Regarding the data that we process automatically on the basis of your consent or in the performance of a contract, you generally have the right to access it yourself or have it provided to a third party in a customary, machine-readable format. If you require the direct transfer of this data to a third party, this will only take place if this is technically possible with reasonable effort.
Contact
Should you have any questions or comments about the handling or use of your personal data, should you require information about the personal data stored about you, or should you wish to exercise your other rights named above, you can contact us via this support form, by sending an email to stg@stgtrading.de
Links to Third-party Websites
On our website, there are links to websites of other service providers and these websites may use cookies. When activating these links, you will be forwarded directly to the websites of the other service providers. You will notice this by the change of URL, amongst other things.
We cannot accept any responsibility for the confidential handling of your data on these websites of third-party companies, as we have no influence on the compliance of these companies with the data protection regulations. Please inform yourself about the use of your personal data by these companies directly on these websites.
Changes to this Data Privacy Statement
We always keep this Data Privacy Statement up-to-date. Therefore, we reserve the right to change it from time to time and update it with changes during the collection, processing and use of your data. Therefore, please read through this Data Privacy Statement regularly. You can access the current version of this Data Privacy Statement at any time under the "privacy policy" (Datenschutz) heading within the app or at https://stgtrading.de/hadeya/privacy-policy/