1. Introduction

In the following, we provide information about the collection of personal data when using our mobile app (hereinafter only "App"). Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 (7) EU General Data Protection Regulation (GDPR) is combyne GmbH, Oskar-von-Miller-Ring 20, c/o WeWork, 80799 München, Germany, email: contact [at] combyne.com. We are legally represented by Dr. Jan Stefan Roell.
Our data protection officer is heyData UG (haftungsbeschränkt),
Gormannstr. 14, 10119 Berlin, www.heydata.eu, e-mail: info@heydata.de.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art.6 para.1s. 1it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art.6 para.1s. 1lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of acontract, e.g. if a user purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case ofinquiries about our products or services.
  • Art. 6 para. 1s. 1lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1s. 1lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. if we reply to requests sent to us.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. forCanada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

The transfer of data to third parties in the United Kingdom of Great Britain and Northern Ireland is currently based on the transitional arrangement in the trade and cooperation agreement between the European Union and the United Kingdom.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contractor to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us(e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at anytime without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

We send newsletters with Rocket Science Group, LLC, 675 Ponce De LeonAve NE #5000, Atlanta, GA 30308, USA ("Mailchimp" and/or "Mandrill", privacy policy: https://mailchimp.com/legal/privacy/). The provider processes content, usage, meta/communication data and contact data.

3. Data processing in the app

3.1. Downloading the app

Our app is ready for download at Apple's App Store und Google's PlayStore (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the 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 process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.

3.2. Hosting

Our app is hosted by Amazon AWS. The provider thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para.1 s. 1 lit. f GDPR.

The provider hosts the app on servers in the US and Ireland.

3.3. Informative use of our app

When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para.1 s. 1 lit. f GDPR.

The data processed to this extent are:

  • IP address
  • Date and time of the request
  • Timezone difference to Greenwich MeanTime (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Operating system and its interface

3.4. Access to functions or data

The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.

The functions or data processed to this extent are the camera, contacts and stored photographs.

3.5. Data processing for the provision of functions

In the app, we process the Universal Unique Identifier of the end device (UUID) in order to provide the user with functions of the app. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

3.6. User account

Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 s. 1 lit. bGDPR. We delete the data when users delete their user account.

3.7. Single sign-on

Users can log in to our app using one or more single sign-on methods. In doing so, they use the login data already created for a provider. The prerequisite is that the user is already registered with the respective provider. When a user logs in using a single sign-on procedure, we receive information from the provider that the user is logged in to the provider and the provider receives information that the user is using the single sign-on procedure in our app. Depending on the user's settings in his account on the provider's site, additional information may be provided to us by the provider. The legal basis for this processing is the usage agreement between the user and the provider. Providers of the offered method(s) are:

  • Apple Inc., Infinite Loop, Cupertino, CA 95014, USA (Privacy policy: https://www.apple.com/legal/privacy/de-ww/).
  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Privacy policy: https://policies.google.com/privacy).
  • Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland (Privacy policy: https://twitter.com/de/privacy).
  • Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook"). Which data we receive from Facebook is communicated to users by Facebook as part of the registration process. Information about Facebook and the contact details of the data protection officer, as well as further information about how Facebook processes personal data, including the legal basis and the options for exercising rights as a data subject vis-à-vis Facebook, can be found at https://www.facebook.com/about/privacy. We are jointly responsible with Facebook for the data processing taking place through Facebook in the context of the use of the procedure and have concluded a joint responsibility agreement (Art. 26 GDPR) with Facebook. There we have defined the respective responsibilities for the fulfillment of the obligations under the GDPR with regard to joint processing. We are obliged to provide the above information and Facebook has assumed responsibility for the further data subject rights pursuant to Art. 15-20GDPR.

3.8. Purchase of products or services

We offer to purchase goods or services via our app. In the ordering processor shipping, we involve the following service providers, who receive only the personal data required in each case to provide a service. The processing of the data takes place for the performance of the contract concluded with the respective user (Art. 6 para. 1 s. 1 lit. b GDPR).

3.9. Third-party tools

We use the following third-party tools or services in our app, each of which processes the specified data:

3.9.1. Google Analytics

We use the Google Marketing Platform from Google Ireland Limited,Gordon House, Barrow Street, Dublin 4, Ireland, ("Google") for GoogleAnalytics to better understand our users. In doing so, we submit the following marketing data to Google:

  • Number of users in the app, their characteristics and origin
  • Actions of the users
  • Data on in-app payments and revenue
  • User navigation paths

The legal basis for the processing is the consent of the users (Art. 6 para. 1s. 1 lit. a GDPR). Consent can be revoked at any time, e.g. via the contact details provided above. The revocation does not affect the lawfulness of the processing until the revocation.

3.9.2. Google Firebase

We use services of the Google Cloud Platform, a developer platform operated by Google Ireland Limited , Gordon House, Barrow Street, Dublin4, Ireland, ("Google") to, among other things, find errors in the app via the Firebase service. The data processing is based on our legitimate interests in the technically error-free and optimized provision of our services. The legal basis is therefore Art.6 para.1 s. 1 lit. f GDPR. Google receives user data such as mobile ad IDs, installation UUID (universally unique ID), Android IDs andIP addresses for error analysis.

3.9.3. Mongo DB Atlas

We use the Mongo DB Atlas cloud database. The provider is MongoDB, Inc, 3 Shelbourne Building, Crampton Avenue Ballsbridge, Dublin 4, Ireland("MongoDB"). The data processing is based on our legitimate interests in the technically error-free and optimized provision of our services. The legal basis is therefore Art. 6 para.1 s. 1 lit. f GDPR. We process User-ID, username, name, email address or mobile phone number for securing the user account, installation UUID (universally unique ID) and IP adresses in the MongoDB database.

3.9.4. Rubylight Analytics

We process Number of users in the app, Actions of the users, their characteristics and origin, User navigation paths, User-ID, username, name, email address or mobile phone number, installation UUID in Rubylight Analytics. Provider is Rubylight Technology Limited, a company duly incorporated and existing under the laws of Cyprus with registration code 289768, and having its registered domicile in Georgiou Kariou, 6B,Flat/Office 6B, Dasoupoli, Strovolos, Nicosia, Cyprus.

3.9.5. Productboard

We use Productboard Inc, USA, to improve our product. In this process, the provider may receive user IDs, emails, documents, presentations, images, calendar entries, tasks and other data. The legal basis for the processing is the consent of the users (Art. 6 para. 1s. 1 lit. a GDPR). The consent can be revoked at any time, e.g. via the contact details provided above. The revocation does not affect the lawfulness of the processing until the revocation.

3.9.6. Intercom

We use the chat tool of Intercom R&D Unlimited Company, 2nd FloorStephen Court, 18-21 St. Stephen's Green, Dublin 2, Ireland ("Intercom") to more easily respond to user requests. Intercom processes usage data. The legal basis of the processing is the consent of the users (Art. 6 para. 1 s. 1lit. a GDPR). Consent can be revoked at any time, e.g. via the contact details provided above. The revocation does not affect the lawfulness of the processing until the revocation.

4. Hosting

We are hosting the content of our website at the following provider:


The provider is the Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter referred to as “Webflow”). When you visit our website, Webflow records various logfiles, including your IP address.

Webflow is a tool for the creation and hosting of websites.  Webflow stores cookies or other recognition technologies that are required for the depiction of the site, for the provision of certain website functions and to guarantee its security (necessary cookies).

For details, please consult the data privacy policy of Webflow: https://webflow.com/legal/eu-privacy-policy.

We use Webflow on the basis of Art.6(1)(f) GDPR. We have a legitimate interest in ensuring that our website is depicted as reliable as possible. 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.

The transfer of data to the United States is based on the standard contract clauses of the EU Commission. For details, please go to: https://webflow.com/legal/eu-privacy-policy.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future.A current version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.