CRUSE (Chronic Urticaria
Self Evaluation APP)
United States Privacy
Policy
Effective Date: 12/1/2023
GA²LEN eV (“GA²LEN eV” or “we,” “us” or “our”) values your privacy. This Privacy Policy (“Policy”) describes how we collect, use, protect, and disclose the Personal Data we collect from or about you when you access, use, or interact with the cruse-control.com (“Site”) or the Cruse App (“App,” together with the Website, the “Services”) or otherwise communicate with us.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. WE MAY MODIFY THIS POLICY AT ANY TIME. ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING TO THE services. MATERIAL CHANGES WILL BE CONSPICUOUSLY POSTED in the services OR OTHERWISE COMMUNICATED TO YOU.
1. WHAT IS PERSONAL DATA?
When we refer to “Personal Data” in this Policy, we mean any information relating to an identified or identifiable natural person. A natural person is considered to be identifiable if, directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more special features, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified.
Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
2. WHAT PERSONAL DATA DO WE COLLECT?
Depending on how you use our Services, we may collect the following categories of Personal Data about you:
- Identifiers: Identifying and contact information such as name, email address, password, IP Address, gender, the month, day, and year of your birth, CURE ID and STUDY ID.
- Health Data: Health Data is Personal Data relating to the physical or mental health of a natural person, including the provision of health services, and which reveals information about their state of health (e.g. complaints, diagnoses, medication plans). Health Data we collect includes information on your symptoms, your medication, your gender, information on conditions that trigger an outbreak, and photos of your symptoms you choose to upload.
- Internet Activity: Date and time of the request, time zone difference to Greenwich Mean Time, content of the request (specific page), access status/http status code, amount of data transferred in each case, website from which the request comes, operating system, mobile phone model, App installation-specific device ID, camera interface, language and the version of the browser software.
- Commercial Information: Viewed and completed content, your consent to our terms and conditions and other important policies, content of messages or emails you send to us, context of feedback or survey responses you send to us, comments you post in the Services, and comments or messages you post on our social media pages.
- Other information you provide to us.
3. WHAT ARE THE SOURCES OF PERSONAL DATA WE COLLECT?
We may collect Personal Data that you provide to us, that is collected automatically using technology, and from third parties in the ways described in this Policy.
Information We Collect Directly From You
You may provide your Personal Data to us when you access, use or otherwise interact with the Services. Below are some of the ways you provide us with your Personal Data.
- When you create an account.
- When you contact us.
- When you upload photos.
- When you input information.
- When you complete surveys or quizzes.
- Other times you share your Personal Data with us as is evident from your interaction with us or the CRUSE APP, or is as disclosed at the time of collection.
Information We Collect Automatically
Types of Information Collected Through Technology. We use technology to automatically collect certain Personal Information when you visit our Services. For example, we may collect information such as the pages you visit in the Services, your IP address, cookie information, browser type, operating system, date and time you access the Services, the amount of time spent on the Services, and the device you use to access the Services.
Account Activity. We may collect data about how you use (i) your account, and (ii) the Services when you are logged into your account. For example, if you use the Services while signed into your account, we will collect information on how you use your account and the Services.
Cookies & Other Tracking Technologies. We use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) when you use our Services. To learn more about how we use Cookies and your options to limit the data collected from our Services, see What Cookies and Other Analytics Tools Do We Use? in Section 7 below.
Information We Collect About You From Service Providers And Third Parties
We may also receive information (which may include Personal Data) about you from our service providers and third-party business partners, such as online and offline sources, social media platforms, or other public or commercial sources, which may include the following categories:
- Social Media Platforms: This category includes social media platforms owned or operated by third parties, such as Facebook, Instagram, and Twitter (now X), where we maintain a social media account or where you otherwise interact with us or share our content.
- Service Providers: This category includes third parties that provide services to us related to the functionality and operability of our Services, such as hosting the Services, managing communications we send and receive, and processing orders and payments.
- Analytics Providers: This category includes third parties that operate tracking technologies, such as web beacons, cookies, clear gifs and pixel tags in the Services to collect information used to analyze the use and performance of the Services, including, among other things, measuring the effectiveness of the Services, content and communications.
4. HOW DO WE USE PERSONAL DATA?
We use Personal Data for various purposes to operate and improve and conduct the Services. The primary purposes for which we use Personal Data are:
- Customer Service and Customer Communications: (1) sending you emails to provide you with alerts and updates to the Terms or this Policy; (2) to respond to your questions and provide customer service; and (3) those purposes in which you authorize or instruct us to use your Personal Data.
- Operation of the Services. (1) Troubleshooting any errors in the Services; (2) to operate the Services, (3) to improve functionality of the Services; (4) to improve your experience using the Services; (5) to develop and improve the content, materials, features, and interfaces on the Services; (6) to evaluate your needs, and (7) to notify you of any changes to our Terms, this Policy, or the Services.
- Account Creation and Maintenance: (1) to create your account; (2) to maintain your password; (3) maintain your account settings and security.
- Marketing and Advertising Purposes: We may use your Personal Data to advertise and market to you including notifying you of offers and events via e-mail and other means.
- Perform Analytics: To improve the content of the Services; to enhance your experience when accessing the Services; and to customize the Services.
- Research and Publication: We share deidentified and aggregated data with research institutions and with publications in accordance with our research mission. We do not share Personal Data for such purposes.
- Business Purposes: We may use Personal Data for business purposes including but not limited to: (1) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, the Terms or any other contracts between you and us; (2) operating and improving our products and services; (3) conducting statistical analysis; (4) customizing your experience with our Services; (5) preventing fraud; and (6) other business purposes permitted under applicable law.
- Legal Purposes: We may use Personal Data to cooperate with law enforcement or other legal purposes including: (1) complying with legal and regulatory requirements; (2) satisfying contractual obligations; (3) cooperating with law enforcement or other governmental agencies for purposes of investigations, public safety or matters of public importance when we are legally required to do so or believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; and (4) protecting and defending against legal actions or claims.
5. WHO DO WE SHARE PERSONAL DATA WITH?
To operate our business, we may share Personal Data with third parties, including:
- Service Providers: We may share Personal Data in connection with the services our service providers provide to us, including data hosting and processing, and fraud protection and prevention. We require these Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which we provided it to them.
- Third Party Platforms: We may disclose Personal Data to Third Party Platforms to perform data and statistical analysis about the Services and for marketing purposes.
- Parties to Business Transactions: In the event of an anticipated or actual merger or acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us, including Personal Data. We reserve the right, in connection with these types of transactions, to transfer, share, assign, or sell your Personal Data and other information we have collected to third parties or to authorize such third parties to use any such information including for due diligence as part of any of the transactions described in this paragraph. Any Personal Data you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
- Research and Publication. We share deidentified and aggregated data with research institutions and with publications in accordance with our research mission. We DO NOT share Personal Data for such purposes.
- Government and Law Enforcement: We may share your Personal Data with individuals or private parties where necessary to enforce and comply with the law, to protect our property or legal rights, for the safety of the public or any person, to prevent harm, to protect the security and integrity of the Services and any equipment used to make the Services available.
- Professional Advisors: We may disclose your Personal Data to our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.
- Others: We may disclose your Personal Data to any other third party upon your request or with your express consent to do so.
6. ADDITIONAL INFORMATION ABOUT OUR PRIVACY PRACTICES
Aggregated Personal Data
We may use your Personal Data, including Personal Data you submit in the App, to create pseudonymous aggregated data to compile summary statistics on the geographic and drug-related distribution of certain types of symptoms and manifestations of urticaria for scientific research purposes. Pseudonymous data is data that has been deidentified but can be used to reidentify the individual if needed. These summary statistics are made available to cooperation partners, but only using irrevocably anonymous data, which is a form of aggregated data that cannot be used to reidentify an individual.
Security
GA²LEN eV uses commercially reasonable safeguards to protect your Personal Data. GA²LEN eV and its third-party service providers have implemented security measures to help protect against the risk of loss, misuse or alteration appropriate to the type of Personal Data under GA²LEN eV’s control.
WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.
Third-Party Websites And Services
For your convenience, the Services may link to, or be linked to, websites not maintained or controlled by GA²LEN eV. This does not imply any affiliation with, or an endorsement, authorization, sponsorship or promotion of a non-GA²LEN eV website or its owner. GA²LEN eV is not responsible for the privacy policies or practices of any third-parties or any third-party websites. If you choose to access third-party websites, you do so at your own risk, and you should read the terms and conditions and privacy policies for each website that you visit.
Social Media Websites
GA²LEN eV participates in social media platforms such as Facebook®, Twitter®, and Instagram® (“Social Media”) that enable online sharing and collaboration among customers. The Services may allow you to connect to and share information with these various social media platforms. These features may require us to implement Cookies, plug-ins, and application protocol interfaces (APIs) provided by those Social Media platforms to facilitate those communications and features.
By choosing to use any third-party Social Media platform or choosing to share content or communications with any Social Media platform, you allow us to share information with the designated Social Media platform. We cannot control any policies or terms of any third-party platforms. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy. We encourage you to review those policies and terms. As a result, we cannot be responsible for any use of your Personal Data or content by a third-party platform, which you use at your own risk.
Access By Children
The Services are not directed at children under the age of 18 . We do not knowingly collect, use, or share Personal Data from children under the age of 18. If a parent or legal guardian learns that their child provided us with Personal Data without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Data.
7. WHAT COOKIES AND OTHER ANALYTICS TOOLS DO WE USE?
We may use, or permit the use of, cookies and other analytics tools in the Services that, subject to your choices and any exercise of rights available to you, may collect information about you in connection with your access to, use of, or interaction with the Services, which may include cookies and other tracking technologies. A cookie is a small text file that our Site saves onto your computer or other device when you use the Services, that allow the Services to remember your actions and preferences and recognize you or your browser.
Analytical/Performance Cookies.
We use analytical/performance cookies with the Services. These cookies show us if a user of our Site has used our Site before. The analytic cookies allow us to recognize and count the number of users of our Site and see how such users navigate through our Site. We also use cookies to understand, improve, and research products, features, and services. For instance, analytical cookies may show us, which websites are visited more frequently, and help us to record dysfunctionalities of the Site.
Google Analytics. We use Google Analytics and other analytics cookies to improve our Site. Google Analytics is a third-party data analytics service used to collect and process information about how you use the Site. Google Analytics will set cookies on your browser or device and then your web browser will automatically send information to Google Analytics. Google Analytics uses this information to provide us with reports that we use to better understand and measure how users interact with the Site For more information, see the section entitled “How Google uses information from sites or apps that use our services" located at www.google.com/policies/privacy/partners/
To opt-out of this data being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent us from using other analytics tools and will not prevent Personal Data from being sent to the Site or to Google.
8. How Can You Manage Your Personal Data?
We recognize that you may want to limit how your Personal Data is collected, used, and shared. We offer several choices with respect to how we collect, use or share your Personal Data, including:
- Opting Out of Email Marketing: We do not currently send e-mails for marketing or other promotional purposes. If we do send e-mails for marketing or other promotional purposes in the future, you will be able to opt-out of receiving marketing and other promotional email communications we send you by following the unsubscribe instructions contained in the email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your access to or use of the Services.
- Updating Your Contact Information: You may update your contact information and communication preferences by contacting us as described below or logging into your online account.
- Closing Your Account: You may close your account with us by contacting us as described below or logging into your online account.
- Consumer Resources: You can also visit the National Advertising Initiative Consumer Opt-Out page and the Digital Advertising Alliance’s Consumer Choice Tool.
- Configuring Your Device: The electronic device you use to access the Services may offer additional privacy settings; please see the device settings for details. Please note that even if you opt-out of receiving interest-based advertising, you will still receive advertisements, but they will be more general in nature.
- Configuring Your Browser Settings: Most browsers automatically accept cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Services. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Services. You can manually delete persistent Cookies, or Cookies that track your activity across websites, through your browser settings.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.
We do not recognize “Do Not Track” or other signals broadcasted from a user’s browser to opt them out of online tracking or analytics or advertising tools.
California Shine the Light
Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Data, as defined by this statute, within the past year for direct marketing purposes, and (b) a description of the categories of Personal Data disclosed, by contacting us at cruse@ga2len.berlin.
Contact Us
We welcome your questions, comments, and concerns about privacy.
-
Mail:
- GA²LEN e.V
- c/o DGAKI
- Robert-Koch-Platz 7
- 10115 Berlin
- E-Mail: cruse@ga2len.berlin
- Webform: https://cruse-control.com/
https://www.cruseapp.org/data-protection-declaration / en-us