1. Summary information on data processing
Below you will find the essential information on the processing of your personal data by SPINSIGHT ESN Digital GmbH, Hans-Elbe-Str. 11, 97461 Hofheim i. Ufr., ("Spinsight", "We", "Us") in connection with the use of the APP of SPINSIGHT ESN Digital ("Spinsight APP").
This Privacy Policy consists of this summary information (hereinafter "Summary Information") and the following in-depth data protection information (hereinafter "Full Information") on data processing to provide you with an overview of Our procedures regarding the collection, storage, use, disclosure or deletion (hereinafter collectively "Processing" or "Processing") of information of any kind about you (such as your email address, name) (hereinafter collectively "Personal Data") in connection with your use of the Spinsight App.
The Spinsight App allows the user to use his compatible mobile device (e.g. smartphone) to measure and record movements of table tennis balls. Especially for measuring the quality of ball trajectories in table tennis training and table tennis play.
1.1 Processing of your Personal Data (Categories of Personal Data)
We process the following categories of Personal Data: Email address, IP address, product data (e.g. device ID generated in the APP), state data (e.g. speed, direction and rotation frequency of the table tennis ball). For more information, please refer to Section I. of the Complete Information.
1.2. Processing purposes
Your Personal Data is processed for the following purposes: Providing the functionalities of the Spinsight APP, product improvement, error analysis and quality assurance, compliance with legal obligations. For more information, please refer to Section II. of the Complete Information.
1.3 Legal basis of the processing of your personal data
We process your Personal Data on the basis of the following legal grounds: (i) your consent (Art. 6 para. 1 lit. a DS-GVO) (ii) for the performance of a contract to which you are a party or as far as necessary for the implementation of pre-contractual measures (Art. 6 para. 1 lit. b DS-GVO); (iii) for the fulfillment of a legal obligation to which Spinsight is subject as data controller (Art. 6 para. 1 lit. c DS-GVO; as well as (iv) if necessary for the protection of the Legitimate Interests of Spinsight or a third party, unless your interests or fundamental rights requiring the protection of Personal Data override (Art. 6 para. 1 lit. f DS-GVO). For more information, please refer to Section III. of the Complete Information.
1.4. Data transfers and recipients and legal justification for such transfers
We transfer your Personal Data to other ESN Technology Group companies and third parties (e.g., social media platform providers), Our service providers and, in accordance with applicable law, government authorities, courts, external advisors and similar third parties, some of the aforementioned recipients being located in countries outside the EU. For more information, please see Section IV. of the Full Disclosure.
1.5 Retention periods for and deletion of your personal data
Your Personal Data will be deleted as soon as it is no longer needed for the purposes for which it was originally collected or as required by applicable law. For more information, please refer to Section V. of the Complete Information.
1.6 Your legal rights
Under applicable law, you have certain rights in relation to the processing of your Personal Data, in each case in accordance with the applicable legal provisions, such as the right to access, rectify, erase or surrender your data. Please direct your questions to the contact details above. For more information, please refer to Section VI. of the Complete Information.
1.7. Amendments to this summary and the complete data protection information
This summary as well as the complete data protection information may require updating from time to time - e.g. due to the implementation of new technologies or the introduction of new services or functions. We reserve the right to change or amend this privacy policy at any time. We will inform you about changes accordingly (e.g. popUP in the new version of the APP).
2. Complete information on data processing
2.1 Categories of Personal Data
We process the following Personal Data in connection with your use of the Spinsight APP:
- email address and password ("Account Data");
- photo, club, location, score, racket material ("Player Professional Data");
- name, contact details (email address or phone number), content of user requests ("User Service Data");
- use of APP functionalities ("Telemetry Data"); -
Spin, direction, speed of the table tennis ball hit ("State Data");
- Recordings of the camera of your mobile device ("Image Data");
- Heart rate, height, weight, Calculated calories burned ("Fitness Data");
- Data related to the mobile device used: Operating system, Spinsight APP version, battery level, brightness setting, internet connection used (mobile network or WLAN), memory usage, camera, processor data, device ID generated in the APP ("Device Data");
- IP address ("App Usage Data").
2.2. processing purposes
Your Personal Data will be processed by Us to the extent permitted by law for the following purposes:
- Providing the functionalities of the Spinsight App ("App Functionalities");
- Improving the functionalities of the Spinsight App as well as the table tennis bat coverings produced by the ESN Group ("Product Improvement"); -
For compliance with legal obligations to which Spinsight is subject as operator of the Spinsight App ("Compliance");
- Answering and processing user inquiries via e-mail or telephone ("User Service").
- Feedback with APP users, comment function ("User Feedback").
2.3 Legal basis for the processing of your personal data
Spinsight processes your personal data on the basis of the following legal grounds: We process your personal data insofar as
- you have consented to the processing of your data, Art. 6 para. 1 lit. a DS-GVO ("Consent");
- this is necessary for the performance of a contract with Us to which you are a party or for the performance of pre-contractual measures, Art. 6 para. 1 lit. b DS-GVO ("Performance of Contract");
- this is necessary for the performance of
a legal obligation to which Spinsight is subject, Art. 6 (1) lit. c DS-GVO ("Legal Obligation");
- this is necessary for the safeguarding of Our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms which require the protection of personal data override, Art. 6 (1) lit. f DS-GVO ("Legitimate Interest").
The following table shows which categories of Personal Data are processed for which purposes and on which legal basis We base this processing:
| Processing Purpose: App functionalities Relevant categories of personal data: Account data Legal basis: Contract fulfillment, Art. 6 para. 1 lit. b DS-GVO |
| Processing Purpose: Product improvement Relevant categories of personal data: Telemetry data Legal basis: Legitimate interest, Art. 6 para. 1 lit. f DS-GVO in the improvement of the functionalities of the Spinsight App and the elimination of any existing errors. Only pseudonymous or anonymized data is processed for this purpose. |
| Processing Purpose: Error analysis and quality assurance Relevant categories of personal data: Telemetry data Legal basis: Legitimate interest, Art. 6 para. 1 lit. f DS-GVO in ensuring the functionalities of the Spinsight App and its permanent provision. |
| Processing Purpose: Compliance Relevant categories of personal data: Account data Legal basis: Legal obligation, Art. 6 (1) lit. c DS-GVO |
| Processing Purpose: User service Relevant categories of personal data: Account Data Legal basis: Fulfillment of contract, Art. 6 para. 1 lit. b DS-GVO |
You are not obliged to provide us with your personal data. If you do not provide us with your personal data, certain functionalities of the Spinsight APP cannot be used, for example, you cannot register or start your own measurement.
3. Data transfers and recipients and legal bases for such transfers
3.1. Receiver
Special features for image data: Image data is recorded by the camera of your mobile end device for the analysis of the game and evaluated directly on the end device. A transmission of the image data to Spinsight or third parties does not take place.
To other companies of the ESN Technology Group: Your personal data will be transmitted by Us to other companies of the ESN Holding within the scope permitted by Art. 6 para. 1 lit. f DS-GVO.
Third Parties: Certain Personal Information will also be disclosed by Us to third parties. In accordance with applicable law, We also disclose Your Personal Information to government agencies, courts, outside counsel and similar third parties.
Service providers: For the provision of the Spinsight APP functionalities, Spinsight uses external service providers, to whom personal data may also be transmitted for the provision of the services. These are cloud service providers, as the app functionalities are provided via a cloud environment, as well as service providers used for the provision of user accounts.
3.2 Cross-border data transfers
We sometimes transfer your data to recipients outside of the country in which you reside. Some of the recipients of your Personal Data named above are not located in a member state of the European Union ("EU") or within the European Economic Area ("third countries"). The level of data protection in a Third Country may differ from that guaranteed within the EU.
Insofar as the recipients are located in countries for which the EU Commission has made an adequacy decision, the transfer is thus subject to an adequate level of protection from the perspective of EU data protection (Article 45 GDPR).
We secure any other data transfer to third countries in accordance with data protection law requirements by concluding appropriate data transfer agreements based on the standard contractual clauses (2010/87/EU and/or 2004/915/EC) or by other appropriate means to ensure an adequate level of data protection for the Personal Data transferred. A copy of the appropriate means can be obtained by contacting us using the contact details below.
4. Retention periods for and deletion of your personal data
Your personal data will only be stored by us for as long as is necessary to achieve the respective purpose on which the data collection was based and as long as is necessary and permissible under the applicable data protection regulations.
Thereafter, We will remove Your Personal Data from Our systems and records and/or take steps to properly anonymize it so that You can no longer be identified from it, unless We are subject to a legal obligation to retain it. As a rule, Spinsight will retain your data for 30 days after termination of the user relationship.
5. Your legal rights
Under the conditions established by applicable law (i.e. the GDPR), you have the following rights:
5.1 Right to information
You have the right to request information as to whether personal data concerning you are being processed; if this is the case, you have the right to request information about the personal data. The information about which information may be requested includes, but is not limited to, the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
You have the right to obtain a copy of the Personal Data that is the subject of the processing. For any additional copies you request, we may charge a reasonable fee based on administrative costs, if applicable.
5.2 Right to rectification
You have the right to request us to correct inaccurate personal data concerning you. Depending on the purpose of the processing, you have the right to request the completion of incomplete personal data - also by means of a supplementary declaration.
5.3 Right to erasure (right to be forgotten)
You have the right to request that we delete your personal data.
5.4 Right to restriction of processing
You have the right to request a restriction of the processing of your personal data. In this case, the relevant data will be marked and may only be processed by us for specific purposes.
5.5 Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transfer this personal data to another entity without hindrance from us.
5.6 Right of objection
You have the right to object to the processing of your Personal Data by Us at any time on grounds relating to your particular situation, and We may be obliged to stop processing your Personal Data. If you exercise a right to object, We will no longer Process Your Personal Data for these purposes. No costs will be incurred as a result of exercising this right.
Such a right of objection may not exist, in particular if the processing of your Personal Data is necessary to take measures prior to the conclusion of a contract or to fulfill a contract already concluded.
6. Right of revocation for consents
Insofar as the data processing is based on your consent, you have the right to revoke your consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. Please address your revocation to the following contact details.
7. Right of appeal to the supervisory authority
In case of complaints, you also have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence or of the alleged breach of the GDPR.
8. Contact
If you have any questions or wish to exercise your rights as a data subject, please contact us preferably at the address SPINSIGHT ESN Digital GmbH, Hans-Elbe-Str. 11, 97461 Hofheim i. Ufr. or by e-mail to privacy@spinsight.com.
In addition, you are also welcome to contact our data protection officer at datenschutz@esn-tt.de with questions, suggestions and complaints regarding data protection.
(Version status 25.08.2022)