Obligation to be informed when collecting personal data in accordance with Art. 13 GDPR

With the following information, we inform you about the processing of personal data when using the Light Admin and Light User apps.

Status: 15.01.2024

1. Name and Contact details of the Controller; Data controller for the Light Admin and Light User App (the company)

Operator of the apps:

Herbert Waldmann GmbH & Co. KG

Peter-Henlein-Straße 5

78056 Villingen-Schwenningen

2. Data Protection Officer

If you have any questions regarding Data protection; protection of personal data, please contact our data protection officer at datenschutz@waldmann.com.

3. App functions, scope, purposes and legal bases of the Processing of Personal data and recipients

3.1 Data collection for downloading the app

We do not use any tracking components in the Light User and Light Admin apps and do not carry out any usage analyses. The apps can be used without registration and without providing any personal information. However, you must register in the app marketplace of the respective provider (Apple Inc., Cupertino, USA for iOS devices or Google LLC, Mountain View, USA for Android devices) in accordance with their terms and conditions in order to download the desired app to your end device.

3.2 App functions and scope of Data processing

Our apps require access to your approximate location data. This access is necessary so that the respective app can find the Waldmann lights via Bluetooth that are not yet known to the app. The location data is neither stored in the app nor transmitted by the app to a server.

Our app requires access to your device's camera to scan QR codes and to take photos of floor plans and building plans. When using the app, we recommend that you ensure that you only take photos of our products. Above all, avoid taking photos of colleagues. Also think about documents with personal data that may be nearby and your internal rules on secrecy and confidentiality.

Our app requires access to the internal memory of your device. However, all stored data is non-personalised. The app saves alias names and parameter profiles of the lights on your device. Log data is also saved.

The app uses links (e.g. legal notice, data protection information) that point to the website of the Controller; Data controller (https://www.waldmann.com). When these links are called up, the content of the target page is loaded and displayed in the app. The following personal data is transmitted: IP address, timestamp, user agent.

Processing of the data described here takes place to provide the expected functionality of the application. Legal basis is Art. 6 para. 1 lit. b insofar as the use is used for the setup of our products. It is not mandatory for you to use the app. It is only necessary for you to use the app if you configure and learn the products yourself. We do not have access to personal data that is processed through the use of the app.

3.3 Registration (Light Admin App only)

Registration is required to use the Light Admin app. You will then receive a personal password by email, which you can use to unlock the app. To do this, please use our registration form at https://www.waldmann.com/registration. The following data is collected:

  • Company / Company
  • E-mail address

Data entered there will only be used to check authorisation for access and will be deleted by our service team after your password has been checked and sent to you. Legal basis for Processing is Art. 6 para. 1 lit. b (pre-contractual or contractual measures for the use of our products) and f (legitimate interest). We use the data to validate the request in order to restrict the configuration of the lamps to authorised persons with the help of the Light Admin App.

3.4 Send log files (Light Admin app only)

If technical problems occur when using the app or with regard to its functions that you would like to report to us for further analysis and rectification, you can send log files directly to us from the application. The log files contain the following parameters:

  • User Agent String
  • Operating system
  • App version
  • Timestamp

It is not possible for us to establish a personal reference from the log files unless you expressly contact us via another channel (e.g. by telephone or e-mail).

3.5 Logging in to the LTX Cloud (Light Admin App only)

The Light Admin app can be connected to the LTX Cloud using an existing account. You can obtain such an account from your organisation. When you log in to the LTX Cloud, the user name and password you enter are validated by the Auth0 authentication service. Auth0 is a subcontractor of our subsidiary LIZ Smart Office GmbH, which in turn is responsible for operating the LTX Cloud hosted by AWS and your user account stored there. The servers are located in Frankfurt and Ireland.

When using the LTX Cloud, the processing of your data takes place on the basis of Art. 6 para. 1 lit. b (contractual measure). In this case, the contractual partner is our subsidiary LIZ Smart Office GmbH. You may also have your own contract with us for our products. If you log in to your LTX account in the Light Admin app, Herbert Waldmann GmbH is jointly responsible with LIZ Smart Office GmbH within the meaning of Art. 26 GDPR with regard to the associated Processing of your personal data. We have concluded an agreement on joint controllership with LIZ Smart Office GmbH, which covers the implementation of joint customer projects and the addition of each other's products to the range of products offered to customers. The party from which the data concerned is collected always fulfils the obligation to be informed in accordance with Art. 13 and 14 GDPR.

You can also assert your rights as a data subject against both of our companies. We work closely together as affiliated companies to process your requests and protect your rights. In addition, the responsibility for the LIZ Workspace Manager lies with LIZ Smart Office GmbH, while we assume responsibility towards you for the Processing in the Light Admin App.

3.6 Use of cookies and similar technologies

When using our apps, we use cookies, tokens and similar technologies that are stored on your device to provide the function. We only use technically or functionally necessary cookies that do not require prior Consent. The basis for this storage is Art. 6 para. 1 lit. f GDPR. The cookies are necessary for the operation and troubleshooting of our app.

4. Storage period

The personal data stored in the cache of the apps is deleted when you uninstall the application or clear the cache via your smartphone or within the app.

5. Data subject rights

If we process your personal data, you have the following Data subject rights:

  • Right of access to the processed data and to a copy,

  • a right to rectification if we are processing incorrect data about you,

  • a right to erasure, unless exceptions apply as to why we still store the data, for example retention obligations or limitation periods

  • a right to restriction of Processing,

  • the right to withdraw Consent to Data processing at any time,

  • a right to object to Processing for reasons of public or legitimate interest,

  • a right to data portability,

  • Right to lodge a complaint with a supervisory authority if you believe that we are not processing your data properly. The State Commissioner for Data Protection and Freedom of Information in Baden-Württemberg is responsible for our company. However, if you are in another federal state or not in Germany, you can also contact the Data protection authority there.

6. Receiver

When logging in to the LTX Cloud (Light Admin App only), our subsidiary LIZ Smart Office GmbH and, if applicable, its subcontractors are the recipients of the data entered.

7. Third country transfer

We transmit data to the LTX Cloud if you use it to log in. The data may also be transferred to third countries by sub-processors. There is an EU adequacy decision for these countries.

8. Automated decision

Automated decision making does not take place.