Data Protection Policy

General information about the guest relation platform ‘tweebie’
This data protection policy provides information about which personal data ipeak Infosystems GmbH (hereinafter ‘ipeak’) collects when you use the ‘tweebie’ platform, and how this data is used by ipeak. Use of the platform also includes use of the associated apps, touchscreens and websites.
In all processes, we comply strictly with the provisions of the Swiss Federal Act on Data Protection (DSG) and the EU General Data Protection Regulation (GDPR).
The guest relation platform ‘tweebie’, which is operated by ipeak, can generally be used without logging in; i.e. you do not have to send us any personal details, such as your surname, first name or email address. ipeak does not collect any data that can be used to identify individual users, unless you send ipeak your personal data yourself.
Some of the information stored by ipeak on the web server is data that you have provided to us voluntarily by completing forms (e.g. profile data such as surname, first name, email address, or a profile picture). Other data on the web server is collected automatically. For example, we store the navigation history in the app; i.e. which items you have clicked and when. This helps us to present content in which you might be interested. Such content is presented in the app via the pinboard, for example. The app can thus adapt increasingly to your requirements and navigation behaviour. In addition, this data allows us to identify which navigation items are the most widely used and enables us to better present this content to you in the future.

Collection of non-personal data

We collect data in a form that taken alone cannot be associated directly with a specific person. We may collect, use, share and disclose non-personal data for any purpose. Below are a few examples of non-personal data and the type of data that we collect and how we might use it:
  • We collect data such as unique device identifiers, source URLs, and the time zone and location in which the app is used. This gives us a better understanding of the behaviour of our customers and enables us to make our product more user-friendly.
  • We may also collect and store more specific details of how you use our services. This may include search queries via search fields offered in certain areas of the app. This information enables us to increase the relevance of the results provided by our services.
In the event that we combine non-personal data with personal data, this combined data is treated as personal data for as long as it remains combined.

Collection and use of personal data
Personal data is information that can be used to identify and contact a person. You will be asked to enter personal data when you use the app. However, this is on a voluntary basis, as the app and the platform can also be used without provision of such data.
We collect data about customer activities within the app. This data is aggregated and helps us to provide our customers with useful information. The data also helps us to understand which parts of our app, products and services are the most interesting to our customers. When you create a profile, the aggregated data is linked to the profile and is therefore classed as personal data. If you use the app without a profile, your aggregated data may still allow information that you are interested in to be shown as a preference. In such cases, however, the data will be linked only to the app on your device, not to you as a person.
Here are some examples of the different types of personal data that ipeak collects, along with explanations of how it is used:
  • If you want to create a profile (voluntarily, as the app can also be used without a profile), you can enter data such as gender, surname, first name, date of birth, language and country of origin. Based on the language and date of birth, the pinboard in the app can highlight specific age and language-related content. We can use your first and last name to address you personally in the app.
  • If you have selected a destination in the app, our pinboard will provide you with news from that destination. To enable the pinboard to provide you with extra, personalised content, in addition to the information in your profile, you may be asked to answer questions voluntarily, such as whether you like skiing. This data will not be shared with third parties or published. It serves as an in-app filter to provide you with personalised content (advertising, information, etc.).

Google Analytics and Google Inc.
The ‘tweebie’ app and ‘tweebie’ platform (including touchscreens, tablets and websites) use Google Analytics, a web analysis service provided by Google Inc. (‘Google’). Google Analytics uses what are known as ‘cookies’. Cookies are text files stored on your computer that enable analysis of your use of the website.
The information created by the cookie about your use of the platform is usually transmitted to a Google server in the US and stored there. If IP anonymisation is enabled on this website, your IP address is first truncated by Google within member states of the European Union or in countries that are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the USA and truncated there.
Google uses this information on behalf of the ‘tweebie’ platform’s operator to evaluate your use of the ‘tweebie’ platform, to compile reports about app/touchscreen activity and to provide the platform operator with further services relating to the use of the app/platform and internet use. According to Google, the IP address transmitted as part of the Google Analytics service is not combined with any other Google data. Furthermore, ipeak has activated IP anonymisation for Google Analytics.
The ‘tweebie’ platform is a publicly accessible system. If you reveal personal information on the platform via the internet, you do so voluntarily and at your own risk. Normal emails that you send to ipeak and the platform are not encrypted. Such information may be lost at any time or fall into the hands of unauthorised third parties. All personal information and data is therefore provided voluntarily and at your own risk.

Email addresses that have been entrusted to us will be used only to respond to enquiries if the user of the platform has given us their explicit consent.

Data sharing
To protect the privacy of the platform’s users, ipeak treats the received personal data as strictly confidential. Personal data will be used only for the intended purpose and will not be shared with or sold to third parties.

Data security and data hosting
Ipeak takes appropriate measures to protect its databases against unauthorised access, loss, misuse or fraud. All online services use encryption methods to protect your personal data during transmission. If ipeak stores your personal data, this is done using computer systems in facilities where access is restricted by means of physical security measures. We host data in certified data centres based in Germany.

Right to access and erasure
Users may request that their data is erased. There is no link between the email address entrusted to us and the data from named log files.
For questions about the processing of personal information, for access or erasure enquiries, or to request a copy of the processing policies for individual data collections, please contact ipeak’s data protection officer by post and include a copy of your official ID.
Ipeak Infosystems GmbH
Hinterbergstrasse 32
6330 Cham
Cham, May 2018