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Privacy Policy for INTENT-01 Mobile App

Effective Date: 2025-08-15
Last Updated: 2025-08-15

1. Data Controller Information

This privacy policy applies to the INTENT-01 application (mobile and web versions) distributed by:

Open Telos GmbH (Data Controller and Distributor)
Grotfeldsweg 55
47506 Neukirchen-Vluyn
Germany
VAT ID: DE325263947
Email: severin.deutschmann@opentelos.net

Open Telos GmbH serves as the distributor and data controller for this App. The intellectual property is owned independently by the developer(s).

2. Introduction

Open Telos GmbH ("we," "us," or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our INTENT-01 application ("the App") on mobile devices and web platforms.

This policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable data protection laws.

3. Data We Collect

3.1 Information You Provide Directly

  • Account Information: Name, email address, username, password
  • Profile Information: Optional profile details you choose to provide
  • User Content: Any content, data, or information you create, upload, or share within the App
  • Communications: Information from your correspondence with us

3.2 Information Collected Automatically

  • Device Information: Device type, operating system, unique device identifiers
  • Usage Data: Features used, actions taken, time and date of activities
  • Log Data: IP address, browser type, access times, pages viewed
  • Location Data: Only if you grant permission (can be disabled in device settings)
  • Cookies and Similar Technologies: Session cookies, preference cookies, analytics cookies

3.3 Information from Third Parties

  • Social Media: If you connect social media accounts
  • Payment Providers: Transaction verification information (we do not store full payment details)

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Contract Performance: To provide the App services you requested
  • Legitimate Interests: To improve our services, ensure security, and conduct business operations
  • Consent: Where you have explicitly agreed to specific processing
  • Legal Obligations: To comply with applicable laws and regulations

5. How We Use Your Data

We use collected information to:

  • Provide, maintain, and improve the App
  • Create and manage your account
  • Communicate with you about services, updates, and support
  • Personalize your experience
  • Ensure platform security and prevent fraud
  • Analyze usage patterns to improve functionality
  • Comply with legal obligations
  • Process transactions (if applicable)

6. Data Sharing and Disclosure

We may share your information with:

6.1 Service Providers

Carefully selected third parties who assist in operating our App and conducting business, subject to confidentiality agreements.

6.2 Legal Requirements

When required by law, court order, or governmental authority, or to protect our rights and safety.

6.3 Business Transfers

In connection with any merger, acquisition, or sale of company assets.

6.4 With Your Consent

When you explicitly agree to sharing for specific purposes.

We do NOT sell, rent, or trade your personal information to third parties for marketing purposes.

7. International Data Transfers

As we operate from Germany, data is primarily processed within the European Economic Area (EEA). Any transfers outside the EEA will be conducted using appropriate safeguards such as:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions
  • Your explicit consent

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy, typically:

  • Account data: Duration of account activity plus statutory retention period
  • Usage data: 24 months
  • Marketing communications: Until you opt-out
  • Legal compliance data: As required by applicable laws

9. Your Rights Under GDPR

You have the right to:

  • Access: Request copies of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Request deletion of your data ("right to be forgotten")
  • Restriction: Request limited processing of your data
  • Portability: Receive your data in a machine-readable format
  • Object: Object to certain processing activities
  • Withdraw Consent: Where processing is based on consent

To exercise these rights, contact us at severin.deutschmann@opentelos.net.

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

  • Encryption of data in transit and at rest
  • Regular security assessments
  • Access controls and authentication
  • Employee training on data protection
  • Incident response procedures

However, no method of transmission over the Internet is 100% secure.

11. Children's Privacy

INTENT-01 is not intended for users under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware of such collection, we will promptly delete the information.

12. Cookies Policy

We use cookies and similar tracking technologies to:

  • Maintain your session
  • Remember your preferences
  • Analyze usage patterns
  • Improve user experience

You can control cookies through your browser settings. Disabling certain cookies may limit App functionality.

13. Third-Party Links

The App may contain links to third-party websites. We are not responsible for the privacy practices of these external sites.

14. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via:

  • Email notification
  • In-app notification
  • Updated "Last Updated" date

15. Data Protection Officer

For privacy-related inquiries, you may contact our Data Protection Officer at: [Insert DPO Contact Information]

16. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority, particularly in the EU member state of your residence, place of work, or place of alleged infringement.

The relevant authority for Germany is:

Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Husarenstraße 30
53117 Bonn
Germany

17. Contact Us

For questions about this Privacy Policy or our privacy practices, please contact us at:

Open Telos GmbH
Grotfeldsweg 55
47506 Neukirchen-Vluyn
Germany
Email: severin.deutschmann@opentelos.net

By using INTENT-01, you acknowledge that you have read and understood this Privacy Policy.