1. Preface
In the following we would like to inform you about our privacy policy. Here you will find information about the collection and use of personal data when using the software REFLEX XTR². In doing so, we comply with the privacy law applicable in Germany. You can call up this declaration at any time through the menu item Privacy Policy (? menu).
We expressly point out that data transmission on the internet (e.g. when activating the software or downloading updates) has security gaps and cannot be completely protected from access by third parties.
In particular, participation in flight conventions involves a potential security risk that cannot be avoided by principle.
2. Name and contact data of the person responsible
This privacy policy applies to data processing by:
REFLEX XTR²
Owner Stefan Kunde
Emil-Nolde-Straße 19,
25336 Elmshorn,
Germany
Phone: +49 4121 72887
Email: kunde@reflex-sim.netWe are not obliged to appoint a company privacy officer. We accept inquiries about privacy under the above-mentioned numbers and addresses.
3. Collection and storage of personal data as well as type and purpose of their use
3.1 When you start the free trial period
When you start the free trial period, the following information is transferred to our non-european licensing service provider:
- One-way hash, a code number generated from certain details of your computer using a special one-way hash function. The one-way hash is unique to just your computer. It is not possible to ever retrieve the original details of your computer from the one-way hash. Only the one-way hash is sent to our licensing service provider, not the individual details of your computer.
- Computername/ID. This information simplifies communication with the support, when it comes to understanding which computers are activated when using multi-user licenses.
This information is transmitted in encrypted form to our licensing service provider and stored there permanently. The information is stored in order to ensure that the trial period can only be conducted once on your computer. The legal basis for the data processing is performed in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntary consent.
For further information on the processing of your personal data in the context of licensing the software, please refer to the privacy commitment of our licensing service provider softWORKZ Innovation Inc.
3.2 When activating the software with activation code for the first time
When you activate the software for the first time by entering an activation code, the following information will be sent to our non-european licensing service provider:
- One-way hash (for explanation refer to 3.1.a),
- Computername/ID (for explanation refer to 3.1.b),
- The activation password you have specified. The activation password is used to prevent a fraudster from taking over your activation by guessing your activation code and hence making it invalid for you.
- Your email address, if you have given it voluntarily. Specifying your email address is highly recommended in order to be able to receive a forgotten activation password by email if necessary. Note that reinstalling the software (e.g. on a new computer) is not possible without having the correct activation password.
- If applicable, your FastSpring order ID.
- If applicable, the email address that you have provided during the order process at FastSpring.
This information is transmitted in encrypted form to our licensing service provider and stored there permanently. The information is used to ensure that with your activation code the software can only be activated concurrently on a single computer. The legal basis for the data processing is performed in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntary consent.
The information e and f only apply if you have purchased the activation code from our shop partner FastSpring. For information on the processing of your personal data in the context of contract conclusion and contract processing, please refer to FastSpring's privacy policy.
For further information on the processing of your personal data in the context of licensing the software, please refer to the privacy commitment of our licensing service provider softWORKZ Innovation Inc.
3.3 When reactivating the software with activation code upon reinstallation
If you reinstalled the software after the initial activation, e.g. on a new computer, and reactivate by entering your activation code, the following information will be sent to our non-european licensing service provider:
- One-way hash (for explanation refer to 3.1.a),
- Computername/ID (for explanation refer to 3.1.b),
- The activation password you have specified most recently. (for explanation refer to 3.2.c),
- The new activation password you have specified.
This information is transmitted in encrypted form to our licensing service provider and stored there permanently. The information is used to ensure that with your activation code the software can only be activated concurrently on a single computer. The legal basis for the data processing is performed in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntary consent.
For further information on the processing of your personal data in the context of licensing the software, please refer to the privacy commitment of our licensing service provider softWORKZ Innovation Inc.
3.4 When creating a new flight convention
When you create a new flight convention, the following information is sent to our flight convention server and is stored there for the duration of the flight convention:
- The name that you have specified for the flight convention,
- The name of the currently loaded scenery,
- Your IP-address. The IP address is required because the flight convention is implemented as a peer-to-peer network, which means that each participant sends its data in parallel to all other participants involving the minimal amount of delay possible.
- The user name you have specified as the host of the flight convention. This information serves the purpose of finding in the list of available flight conventions those in which friends or known model flight colleagues are currently participating.
- The name of the currently loaded model.
The information is stored on our flight convention server so that potential participants can access this information in order to join the flight convention The information c, d and e is automatically deleted as soon as you leave the flight convention, at the latest, however, 5 hours after your last activity in the flight convention. The information a, b, c, d and e is automatically deleted as soon as the flight convention is terminated, which means that the last user has left the flight convention. The legal basis for the data processing is performed in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntary consent.
3.5 When joining an existing flight convention
When you join an existing flight convention, the following information is transferred to our flight convention server and is stored there for the duration of your participation:
- Your IP-address (for explanation refer to 3.4.c),
- The user name you have specified for the flight convention (for explanation refer to 3.4.d),
- The name of the currently loaded model.
The information is stored on our flight convention server so that potential participants can access this information in order to join the flight convention. The information is automatically deleted as soon as you leave the flight convention, at the latest, however, 5 hours after your last activity in the flight convention. The legal basis for the data processing is performed in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntary consent.
3.6 When retrieving information via the internet
For the above mentioned program functions 3.1 to 3.5 as well as for the following operations, data is transmitted via the internet: During validation, which is executed once after activation via activation code, when checking if new updates are available, when downloading software updates, when querying the list of available flight convention servers, when querying the list of available flight conventions, continuously during the participation in a flight convention, when sending text messages via the chat window while participating in a flight convention, when leaving a flight convention, when querying the URL of the REFLEX XTR² shop, when visiting the website of the REFLEX XTR² shop, when visiting the REFLEX XTR² website, when visiting the website of the manufacturer of the currently loaded model and when visiting the website of the currently loaded scenery.
During data transmission, information is automatically sent to the relevant servers. This information is temporarily stored in a so-called log file. The following information is recorded without your intervention and stored until it is automatically deleted:
- Your IP-address,
- if applicable, date and time of request,
- if applicable, name and URL of the requested file,
- if applicable, website from which the request was sent (referrer URL),
- if applicable, the browser used and the operating system of your computer as well as the name of your access provider.
The mentioned data will be processed by us for the following purposes:
- Ensuring a flawless connection and data transmission,
- if applicable, ensuring comfortable use of the website involved,
- evaluation of system security and stability as well as
- other administrative purposes.
The legal basis for the data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes listed above for data collection as well as for the realization of the respective program functions mentioned above. Under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.
4. Information disclosure
Your personal data will not be transmitted to third parties for purposes other than those listed below. We will only transfer your personal data to third parties if:
- you have given your explicit consent pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR,
- the transmission pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is necessary to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
- in the event that a legal obligation exists for the transfer pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR, as well as
- this is legally permissible and is necessary for the processing of contractual relationships with you in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.
5. Rights of persons concerned
You have the right:
- to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you may request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data, if these have not been collected by us, and the existence of automated decision-making including profiling and, if applicable, request meaningful information on their details.
We may only refuse to provide information to you if and to the extent that the disclosure would reveal information which must be kept secret in accordance with a legal provision or its nature, in particular because of the overriding legitimate interests of a third party (§ 29 Para. 1 sentence 2 BDSG), the responsible public authority has stated to us that the disclosure of the data would endanger public security or order or otherwise be detrimental to the welfare of the federation or a country (§ 34 Para. 1 No. 1 BDSG in conjunction with § 33 para. 1 No. 2 lit. b BDSG), or if the data are stored only because they may not be deleted due to legal or statutory storage regulations, or because they serve exclusively purposes of data backup or data protection control and the provision of information would require a disproportionate effort and processing for other purposes is excluded by suitable technical and organisational measures (§ 34 Paragraph 1 No. 2 BDSG).
- to immediately request the correction of incorrect or incomplete personal data stored by us in accordance with Art. 16 GDPR;
- to request the deletion of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary to allow us to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
- pursuant to Art. 18 GDPR, to restrict the processing of your personal data if you dispute the accuracy of the data, if the processing is unlawful but you refuse to delete it and we no longer need the data, but if you need it to assert, exercise or defend legal claims or if you have lodged an objection against the processing pursuant to Art. 21 GDPR;
- to receive your personal data provided to us in a structured, common and machine-readable format in accordance with Art. 20 GDPR or to request the transmission to another person responsible;
- in accordance with Art. 7 para. 3 GDPR, to revoke your consent to us at any time. As a result, we are no longer allowed to continue processing data based on this consent in the future,
- if your personal data are processed on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence 1 letter f GDPR, to object to the processing of your personal data pursuant to Art. 21 GDPR, if there are reasons for this which arise from your particular situation or if the objection is directed against direct advertising. In the latter case, you have a general right of objection, which will be implemented by us without the need to specify a specific situation.
In addition, you have a general right of appeal to the data protection supervisory authority responsible for you. The authority responsible for us is the "Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein".
If you wish to exercise your right of revocation or objection, simply send an email to kunde@reflex-sim.net.