Legal notice and note on data protection and Privacy Policy for BRIO Smart Tech

A. Legal notice

BRIO AB
Skeppsbron 1
BOX 305
211 20 Malmö
SWEDEN

E-mail: [email protected]
Tel: +46 40 619 40 00
Fax: +46 40 619 40 00

Company management:
Clemens Maier (Chair of the Board), Erik Hansson, Michael Heun

Registration number:
556951-7153

Sales tax number:
DE154720975

Information:
The European Commission provides a platform for online dispute resolution, which you can find at http://ec.europa.eu/consumers/odr/. We are neither obliged nor willing to participate in a dispute resolution procedure before a consumer arbitration board.

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B. Data protection declaration

As of: June 2020

§ 1 Information on the collection of personal data

(1) In the following, you will find information on the collection of personal data during use of our mobile app. Personal data is all data that can be linked to you personally, e.g. name, address, email address, user behavior.

(2) Responsible pursuant to Art. 4 Section 7 of the EU General Data Protection Regulation (GDPR) is BRIO AB (please see the legal notice for our contact address). Should you have questions, comments, or criticism about data protection, or if you wish to assert your rights described below, please contact us at [email protected].

(3) If you contact us by email or using a contact form, we save the data you give us (your email address, if applicable your name, and your phone number) so that we can answer your questions. We erase the data collected in this context when it is no longer necessary to save it, or limit its processing if statutory data storage regulations apply.

(4) If we use service providers for individual functions of our offer, or if we wish to use your data for advertising purposes, we will inform you in detail below about the processes involved here. We also inform you below about the storage duration criteria that apply. We also inform you below about the storage duration criteria that apply.


§ 2 Your rights

(1) You have the following rights in relation to your personal data:

– Right to request,
– Right to rectification or erasure,
– Right to restriction of processing,
– Right to object to processing,
– Right to data portability.

(2) Furthermore, you have the right to complain to a data protection supervisory authority about our processing of your personal data.


§ 3 Download and subsequent offline use of our mobile app

(1) Download from the app store

When you download the app, the required information is transferred to the app store, in particular the login data of your account, if applicable payment information, individual device ID and information about your download (e.g. time of the download). We have no influence on this data collection and are not responsible for it. We only process the data in as far as it is necessary for downloading the mobile app to your mobile terminal device. It is not saved beyond this extent. The legal basis is Art. 6 Section 1 p. 1 lit. b of the GDPR.

(2) Subsequent (offline) use

The app is downloaded to your mobile terminal device and can generally be used without internet access, possibly with a restricted range of functions. No personal data is collected during offline use.


§ 4 Special functions and use in online mode

(1) If you use the app in online mode, i.e. when connected to the internet, or you use special functions, additional data processing may take place. We explain this in more detail below.

(2) In some cases, we use external service providers to process your data. We select these service providers carefully and commit them to observe our instructions. We regularly check their compliance.

(3) If our service provider or partner is based in a country outside the European Economic Area (EEA), we inform you below about the consequences of this.


§ 5 Access to Connect/Bluetooth and the microphone

The first time you use the corresponding functionality in our app, a popup asks you for permission to use Connect/ Bluetooth and your microphone.
Connect/Bluetooth is necessary to establish a connection between your phone and the train.
Access to the microphone is necessary to record sounds which you can transfer to the train. Please note that these sounds will at no point be transferred or stored online, but online via Bluetooth between the app on your mobile device and the train.
If you permit access, the app only accesses it to the extent necessary for providing the functionality. We treat your data with strict confidentiality. As soon as you revoke permission for use, the app can no longer access your microphone. In this case, the additional functionality is no longer available.
If you do not give permission or revoke your permission in your device’s operating system settings, you may not be able to use all the functions of our app.
The legal basis for processing is Art. 6 Section 1 p. 1 lit. a, b GDPR.


§ 6 Objection or revocation of the processing of your data

(1) If you have issued your consent to the processing of your data, you can withdraw this consent at any time. Once you have issued this revocation, it affects the admissibility of the processing of your personal data by us.

(2) If we base the processing of your personal data on the balancing of interests (Art. 6 (1) lit. f GDPR), you can object to this processing. This is the case when processing the data is especially not necessary for fulfilling a contract with you. We describe this in the following description of functions. If you express such an objection, we request that you give us the reasons why you do not wish us to process your personal data as we normally do. After you have submitted your objection with reasons, we will examine the circumstances and will either cease or alter the data processing, or explain to you our compelling legitimate grounds for continuing to process the data.


(3) Of course you can object to the processing of your personal data for the purposes of advertising and data analysis at any time. You can inform us about your objection of processing for advertising purposes using the contact data given in § 1 (2).

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