Data protection PORTAL

Data protection in the ProForma PORTAL-App (English)

PRIVACY POLICY

ProForma PORTAL

1. Information on the collection of personal data

In addition to our online offer, we provide you with a mobile app that you can download and install on your mobile device (smartphone/tablet with iOS or Android). In the following, we inform you about the collection of personal data when using the ProForma PORTAL and/or using the mobile app "ProForma PORTAL". Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behaviour.

The responsible party pursuant to Art. 4 (7) EU General Data Protection Regulation (DSGVO) is CSW Peripheriesysteme GmbH, Peter Vroomen / Michael Schepers, Herrenpfad-Süd 18, 41334 Nettetal, info@cswgmbh.de, Tel. 02157 / 12913-0.

You can reach our data protection officer, Mr Stefan Kleinermann, at info@das-datenschutz-team.de, Tel. 02401 / 60540.

When you contact us by e-mail or via a contact form, your e-mail address and - if provided by you - your name and telephone number will be stored by us in order to answer your questions. The legal basis is Art. 6 para. 1 lit. f DSGVO. We delete the data accruing in this context after storage is no longer necessary or - in the case of statutory retention obligations - restrict processing.

If we use commissioned service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. In doing so, we will also state the defined criteria for the storage period.

2. Collection of personal data when using the ProForma PORTAL

When downloading the mobile app "ProForma PORTAL", the required information is transferred to the App Store (Apple App Store or Google Play Store), in particular user name, e-mail address and customer number of your account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We only process the data insofar as it is necessary for downloading the mobile app "ProForma PORTAL" to your mobile device.

When using the ProForma PORTAL or the "ProForma PORTAL" mobile app, we collect the personal data described below, which is stored on the server of the corresponding ProForma PORTAL. When you register for the first time, you must enter your individual access data. These are not stored in the ProForma PORTAL app. When the device is registered in the ProForma PORTAL, an individually unique access key is created, which is used to authorise future logins. This key is stored on the mobile device. (Legal basis is Art. 6 para. 1 lit. f DSGVO):

  • IP-Adress

  • Date and time of the request

  • Access status/HTTP status code

  • Browser typ

  • Operating system and its interface

  • Language and version of browser software.

  • Website

  • Session type​


We do not use cookies in our mobile app "ProForma PORTAL". However, so-called access tokens are stored for user authentication.

When using the ProForma PORTAL via browser, so-called "session cookies" and "PORTAL cookie status" are used. Session cookies are characterised by the fact that they are automatically deleted from your hard drive at the end of the browser session.

Push notifications are sent via google cloud messanging, if activated.


This data is automatically transmitted to us (i) to provide you with the Service and related features; (ii) to improve the features and functionality; and (iii) to prevent and remedy misuse and malfunction. This data processing is justified by the fact that (i) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) lit. b DSGVO for the use of the ProForma PORTAL, or (ii) we have a legitimate interest in ensuring the functionality and error-free operation of the systems and in being able to offer a service that is in line with the market and interests, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) lit. f DSGVO.

3. User accounts and registration

If you log in via the mobile app "ProForma PORTAL", we use your individual access key to grant you access to and manage your user account in the ProForma PORTAL ("mandatory data"). When you log in to the ProForma PORTAL via a browser, we use your personal access data to grant you access to and manage your user account in the ProForma PORTAL ("mandatory data"). Your name, address, e-mail address, personnel number and documents may be stored in the PORTAL. The data entered by you in the context of a registration will be processed and used by us (i) to verify your authorisation to manage the user account; (II) to enforce the terms of use of the "ProForma PORTAL" app and all related rights and obligations. This data processing is justified by the fact that (i) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) lit. b DSGVO for the use of the "ProForma PORTAL" app, or (ii) we have a legitimate interest in ensuring the functionality and fault-free operation of the "ProForma PORTAL" app, which here outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 (1) lit. f DSGVO.

4. Sharing and transferring data

In order to send so-called "push notifications" within the "ProForma PORTAL" app, we may transfer your personal data to an external service provider. Any transfer of personal data is justified by the fact that (i) we have a legitimate interest in transferring the data for administrative purposes and your rights and interests in the protection of your personal data within the meaning of Art. 6 para. 1 lit. f DSGVO are not overridden and (ii) we have carefully selected the external service provider as a processor within the framework of Art. 28 para. 1 DSGVO, regularly review it and contractually oblige it to process all personal data exclusively in accordance with our instructions. In addition to the case mentioned in 5.1, personal data will only be passed on without your express prior consent if it is legally permissible or required, or if it is necessary for the clarification of an illegal or improper use of the "ProForma PORTAL" app or for legal prosecution. In this case, personal data will be forwarded to law enforcement agencies or other authorities and, if necessary, to injured third parties or legal advisors. However, this only happens if there are indications of unlawful or abusive behaviour. A transfer may also take place if this serves the enforcement of terms of use or other legal claims. We are also legally obliged to provide information to certain public authorities upon request. These are law enforcement agencies, authorities that prosecute administrative offences subject to fines and the tax authorities. Any disclosure of personal data is justified by the fact that (i) the processing is necessary for compliance with a legal obligation to which we are subject pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with. national legal requirements to disclose data to law enforcement authorities, or (ii) we have a legitimate interest in disclosing the data to the aforementioned third parties if there are indications of abusive behaviour or to enforce our terms of use, other conditions or legal claims, and your rights and interests in the protection of your personal data within the meaning of Art. 6 para. 1 lit. f DSGVO are not overridden.

5. Use of the app "ProForma PORTAL
  • Within the framework of the "ProForma PORTAL" app, you can enter, manage and edit various information, tasks and activities. The "ProForma PORTAL" app also requires the following authorisations:

  • Internet access: This is required to save your entries on our servers.

  • Retrieve network connections: This is required to check whether your device has a connection to the server for the purpose of exchanging data with the server.

  • Camera access: This can be used to authenticate your mobile device during the initial setup (QR code scan) and to log in to the ProForma PORTAL APP with the set device security (facial recognition).

  • Usage data is processed and used to provide the service. This data processing is justified by the fact that the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 (1) lit. b DSGVO for the use of the "ProForma PORTAL" app.

6. Transfers of data to third countries

We do not process data outside the European Union ("EU") or the European Economic Area ("EEA").

Your Rights

  • You have the following rights with regard to the personal data concerning you:

  • Right of access (Art. 15 GDPR);

  • Right to rectification or erasure (Art. 16 and 17 GDPR);

  • Right to restriction of processing (Art. 18 DSGVO);

  • Right to data portability (Art. 20 GDPR);

  • Right to object to processing (Art. 21 DSGVO);

  • You also have the right to complain to a data protection supervisory authority about the processing of your personal data in our company.

The data protection authority responsible for us is: Landesbeauftragte für den Datenschutz Nordrhein-Westfalen, Kavalleriestraße 2-4, 40213 Düsseldorf, poststelle@ldi.nrw.de, Tel. 0211 / 384240.

7. Changes of purpose

Your personal data will only be processed for purposes other than those described if a legal provision permits this or if you have consented to the changed purpose of the data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you of these other purposes prior to further processing and provide you with all other relevant information.


8. Period of data storage
  • Personal data is not automatically stored on the ProForma PORTAL APP.

  • The duration of the storage of personal data on the ProForma PORTAL server is the responsibility of the respective PORTAL administrator.

  • Specific information in this data protection declaration or legal requirements for the storage and deletion of personal data, in particular data that we have to store for tax reasons, remain unaffected.


9. Contact
  • If you have any questions or comments about our handling of your personal data or if you would like to exercise the rights as a data subject mentioned in section 2, please contact CSW Peripheriesysteme GmbH, Herrenpfad-Süd 18, 41334 Nettetal, info@cswgmbh.de, Tel. 02157 / 12913-0.

  • For questions or comments on the practical handling and operation of the app or for support requests, please contact support@cswgmbh.de.


10. Changes to this privacy policy

We always keep this privacy policy up to date. Therefore, we reserve the right to change it from time to time and to update any changes in the collection, processing or use of your data. The current version of the privacy policy is available within the app.