General

The protection of your data is top priority for WebToGo GmbH. It is important we inform you what personal information is collected and used by us.

Where can I find the details?

This Privacy Policy gives an overview of what applies to processing of your data in the Wenewa app. Further information, including that on data protection in other WebToGo products, may be found here

Whom should I contact if I have questions about data protection?

If you have any questions, do contact our Data Protection Officer

What rights do I have?

You have the right to:
  1. Request information on types of data, processing reasons, potential recipients of the data and planned storage periods (Art. 15 GDPR);
  2. Request amendments or alterations, in case of incorrect or incomplete data (Art. 16 GDPR);
  3. Revoke consent previously given, at any time, with immediate effect (Art. 7 (3) GDPR);
  4. On the grounds of a legitimate interest, require for your data to be processed under conditions specific to your particular situation (Art. 21 (1) GDPR);
  5. In specific cases, request for your data to be deleted (Art. 17 GDPR). Such requests are valid when the data is no longer needed for its primary intended purpose or is proven to be processed unlawfully; or when you revoke your consent to process data (c) or submit a processing request (d);
  6. In specific cases, restrict the use of your data, when deletion is not possible or is disputed (Art. 18 GDPR);
  7. Data portability. You may request the data you provided us with to be made available to you in a machine-readable format (CSV) and ask us to transfer it to others (Art. 20 GDPR);
  8. To complain to a competent German supervisory authority on data processing (in this case, Landesamt für Datenschutzaufsicht, 91522, Ansbach, Federal Republic of Germany).

Are there any other data processors working in collaboration with WebToGo GmbH?

Yes, these are data companies we commission (Art. 28 GDPR; service providers, agents). WebToGo GmbH is still responsible for protection of your data when with the third party. We engage data processing companies in IT, sales, marketing, finance, consulting, customer service, human resources, logistics and printing.

Any data processors providing services directly to you, used to support the WebToGo service you have contracted, remain your own responsibility. This includes cases where you request for us to rely on your data processors or when you wish to involve a partner or when we license parts of the service to your partner(s).

Where does data processing take place?

Your data is processed in Germany and other European countries. In exceptional cases, your data may also be processed outside the European Union; this is only done with your consent or when this is required for us to provide you services or when there is a legal requirement in Germany for us to do so (Art. 49 GDPR). In addition, your data will only be processed outside the EU when the processing party can demonstrate adequate levels of data protection (see European Commission decisions on data protection guarantees; Art. 44 GDPR).

What data is collected, how is it used and how long is it stored for?

When you use our apps, our servers keep a temporary record of your device IP address, along with other technical data (Art. 6 (1b) GDPR). Also, in order to improve the quality of service provided to you, the app collects, stores and processes the following information:

Technical information about the smartphone:

  • Operating system type
  • Device make and model
  • Device location
  • System date/time
  • Test ID
  • Connection technology (2G, 3G, 4G, WLAN)
  • SSID of the Wi-Fi access point
  • BSSID of the Wi-Fi access point
  • Frequency of the Wi-Fi access point
  • Uplink speed of the Wi-Fi access point
  • RSSI of the Wi-Fi access point
  • Encryption method on the Wi-Fi access point
  • Spatial sector assignment, Cell-ID and Cell-LAC
  • Mobile Country Code (MCC) and Mobile Network Code (MNC)
  • RSSI and Signal-to-Noise ratio (SNR) of the mobile network
  • Number of hops between the test client and test server(s)
  • Upload and download data rates
  • Package runtimes
  • Measured jitter
  • Number of lost packets
  • Device permissions

For the app to work on your device, it must access device functions and data. This requires that you grant permissions to the app (Art. 6 (1a) GDPR). Permissions are set up differently by manufacturers; for example, on Android devices, permissions are grouped into categories and you can only grant access within a single category. Please note, you may not be able to use all features of our app if one or more permissions are declined. The app requires permissions exclusively for testing and optimizing your device or to transfer your device data to your new device.

When permissions are granted by you, we use these to the extent described below:

Location data

The app needs information on the current location of the device to establish connection between two devices to transfer your mobile phone data to your new device using the data transfer function. The data is used only for this purpose and is not stored permanently.

Manage contacts / contacts, calendars, photos, media and files, phone calls, retrieve SMS

The app requires access to device contacts / the address book to transfer your mobile phone data to your new device using the data transfer function. The data is used only for this purpose and is not stored permanently.

Internet access

The app requires access to the Internet via Wi-Fi or mobile connection in order to test connection quality and to contact other integrated services. No permanent data storage occurs as a result of this process.

Phone status and identity (TAC)

The app requires access to device type / TAC for voluntary device benchmarking programs. The data is used only for this purpose and is not stored permanently.

Microphone, USB, photos, videos, news content

The app requires access to the microphone to test audio components as part of the hardware check on the device.

Device and apps history

The app needs this permission to identify energy-consuming apps on the device and to run device software and battery tests.

Mobile data settings

The app needs this permission to verify accuracy of the mobile cell settings on the device. This permission is also used for battery and connection testing.

Storage

The app needs this permission to check for available memory and apps using it, when optimizing device memory usage.

Device Administrator

The app needs this permission to allow technical support personnel to remotely configure the device.

Additional permissions

To ensure better device performance, the app requires access to Bluetooth settings, audio settings, system settings, hardware components and other apps. No data is stored permanently.

Google

On individual app screens, Google Maps is used to show locations, route planning and maps. Google Maps is operated by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Google Maps sends its IP address to Google and keeps its cookies on the device. Google data processing policies and corresponding documentation may be accessed here