We take data protection at instingo very seriously and would like to inform you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as "data") when using our instingo services.
Our privacy policy is based on the terminology used by the European directive and regulatory authorities when issuing the General Data Protection Regulation (GDPR).
Through the operation of our digital platform, we process personal data. These are treated confidentially by us and in accordance with applicable laws - especially the General Data Protection Regulation (GDPR).
Provider and Contact Person (hereinafter: "Provider")
Responsible for the collection, processing, and use of personal data in connection with the provision of the instingo platform:
Instingo UG (limited liability), Bergstraße 12, 82131 Gauting,
Munich District Court HRB 266014
VAT No.: DE343733791
www.instingo.de
Data Protection Officer: Andreas Lenge
Email: info@instingo.de
Type of Service:
The aim of our movement platform (hereinafter: "Service") is to promote low-threshold movement in companies and thus support corporate health management. For this purpose, we offer companies and institutions the opportunity to launch an action/challenge via our digital platform.
For this purpose, your company has decided to use the movement platform from instingo.
On the movement platform, physical activities online and offline are combined with a gamified web presentation.
Participation and providing information in the action/challenge is voluntary. Your data will only be processed after your explicit consent. With consent, each user creates a personal user profile.
After registration, each user is given the opportunity to connect their fitness tracker/smartphone to the movement platform and transfer their steps.
Existing fitness trackers from third-party providers can be connected to the instingo platform.
Subsequently, each user can link with the instingo app.
Instingo supports systems from Garmin, Fitbit, Polar, and Samsung, whose devices are controlled via an app. The instingo platform receives the step counter values from the fitness tracker provider's app.
This happens automatically depending on the device type or when the user performs a synchronization of their step counter.
When synchronizing the step counter, the provider records steps taken.
Furthermore, activities such as cycling, swimming, etc. can be converted into steps. The minutes of the performed activities are manually and personally entered on the platform by each user. Based on a conversion factor, these minutes are automatically converted into steps.
Participants consent that for the purpose of the action, only data about the number of steps they have taken will be collected over the participation period, which then provides the company with results on how many steps were taken.
No Processing of GPS or Location Data
Instingo does not process GPS data or other location information in connection with its services. There is no collection, storage, or other processing of location-related data. Participation in our step challenges is based exclusively on step counts provided by the end devices or connected fitness trackers of users. Location determination or movement profile creation does not take place at any time.
What Data Does the Participating Company Receive?
Your company does not receive individual data that allows identification of a person.
Through the instingo platform and the administrator area for the respective participating company, we offer an overview with daily updated information and evaluations about the steps. We exclude the sharing of data of individual employees with third parties.
The data is provided for the entire company and for individual teams and includes:
- Number of participating individuals during the challenge duration
- Total step count and team step count of all participating individuals
- Ranking of teams
- Ranking of individuals with usernames
- Ranking of individual steps (anonymized)
- Ranking of performed activities
- Ranking of performed activity steps
The steps are transferred to the instingo movement platform from the start of the challenge. The steps are recorded, stored, and processed by instingo. With the fitness tracker/fitness app, we exclusively record steps taken, no location coordinates or location-based movement profiles.
Handling of Personal Data During Registration
We collect personal data on our digital platform as soon as you register via a domain in the input mask of the registration form provided for this purpose. The collection, storage, and processing of the data listed below only takes place when you register to participate in a movement offer. The collection, processing, and forwarding of your data only occurs if you have given the corresponding declaration of consent by confirming by checking the box in the corresponding input field and confirming again by submitting the web form (by using the "Submit" button or the enter key). The following data is collected, stored, and processed by us when you register for our service:
- Email address
- Username
- Password (not in plain text, but only as a "hash")
- Date and time.
We do not store IP addresses in connection with registration.
This data is not shared with or sold to third parties. A comparison of the collected data with data that may be collected by other components of our site does not take place either. Please make sure not to use elements of your real first or last name when choosing your username. Otherwise, you allow other users (possibly also your employer) to draw conclusions about your person. But you can also consciously decide differently.
Consent for Data Transfer for Winners:
If you as a participant are among the winners of the challenge, you consent that your data (first/last name, team steps or individual steps) may be published within the company/authority.
Handling of Personal Data During Use
The following data is collected and stored by us when using our service as part of the action (counting steps):
- Email address
- Username
- Password (not in plain text, but only as a "hash")
- Date and time
- As long as you carry a fitness tracker or smartphone: all your recorded steps during the duration of the action (from the start at 00:00 to the end date at 23:59).
- Date and time of the last login
- The action you are participating in
We process this data continuously by adding your counted steps and showing you the sum of the steps recorded so far.
By registering to participate in a declared action and submitting your consent by confirming the consent declaration, you consent to the storage of the specified data and its processing by us, as well as to the forwarding of the sum of all steps to the company calling the action. For this purpose, we log your consent declaration and store it. You can view the privacy policy and terms of use that you have agreed to at any time at the bottom of each page of the competition. You have the right to withdraw your consent at any time. This is done by logging in to the movement platform with your username and password, clicking on "Delete user profile" at the bottom of the "Your Profile" page, and confirming the following security prompt. From the time of revocation, we will immediately delete all data stored by us from you, unless this claim conflicts with a legal retention period.
Rights of the Data Subject: Information, Correction, Deletion and Blocking, Right to Object
according to EU-GDPR:
Right to information: According to Art.15 EU-GDPR, you have the right to request information from the controller about the processing of personal data regarding processing purposes, data categories, recipients or categories of recipients, storage duration, correction of your data, complaints to a supervisory authority, origin of the data, and the existence of automated decision-making.
Right to rectification: According to Art.16 EU-GDPR, you have the right to demand the immediate rectification of inaccurate personal data concerning you.
Right to erasure: According to Art.17 EU-GDPR, you have the right to demand the immediate erasure of your personal data.
Right to restriction of processing: According to Art.18 EU-GDPR, you have the right to demand the restriction of processing of your personal data.
Notification obligation regarding rectification or erasure of personal data or restriction of processing: According to Art.19 EU-GDPR, the controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
Right to data portability: According to Art.20 EU-GDPR, you have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
To exercise your rights, please address your request in writing to:
Instingo UG, Bergstr. 12, 82131 Gauting or by email to: info@instingo.de
Deletion of Data
All collected data will be completely deleted at the latest four weeks after the end of the action, unless the deletion conflicts with a legal retention period.
In addition, your data will be deleted if you wish to exercise your right to revocation and deletion, unless this conflicts with legal retention periods.
By using the "Delete user profile" button in your profile, you have the option to irreversibly delete all personal data.
Use of Artificial Intelligence (AI) for Notifications
As part of our challenges, we use Artificial Intelligence (AI) to provide personalized notifications. This serves to encourage user motivation and improve participation in the challenges.
The AI processes exclusively the data relevant to the challenge, such as step counts, progress within the challenge, and individual settings. This data is not used for other purposes or shared with third parties.
The processing is carried out in accordance with Art. 6 Para. 1 lit. b) GDPR (fulfillment of a contract) and on the basis of our legitimate interest according to Art. 6 Para. 1 lit. f) GDPR, to optimize the user experience.
Cookies
Cookies are small files that make it possible to store specific device-related information on the user's access device (PC, smartphone, etc.). They serve, on the one hand, the user-friendliness of websites and, on the other hand, they serve to collect statistical data on website usage and to analyze it for the purpose of improving the service. (e.g., for storing login data). Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system.
Instingo points out that only internal cookies are used for the storage and processing of data.
The use of cookies for website analysis, such as Google Analytics, is not used by instingo as part of the challenge.