Privacy Policy

We collect and process personal data for the following specific purposes:

1. To verify your identity and assign the correct shift context, so the App presents you with the task list relevant to your current shift
2. To register and manage device bindings, ensuring that only authorised devices can access the App on behalf of an employee. A device must be activated using a time-limited activation code issued by a manager or authorised system before it can access the App.
3. To register who is working on a given task, and to track start and end times for time registration purposes
4. To record task completions, photos, and barcode/QR scan results as operational and compliance documentation
5. To determine your location on demand where you initiate a location-related feature within the App
6. To support fault diagnosis, technical maintenance, and improvement of the App through application logs and telemetry data
7. To generate anonymised statistics and reports for the ongoing quality assurance and optimisation of operational processes
8. To comply with any law, rule, regulation, legally binding provision, decision or directive from a supervisory authority, including but not limited to:
   1. Documentation requirements
   2. Compliance with basic principles for the processing of personal data and legal basis for processing
   3. Implementation and maintenance of technical and organisational security measures, including prevention of unauthorised access to systems and data, prevention of malicious code distribution, and mitigation of denial-of-service attacks
   4. Investigation of suspected or known security breaches and reporting of such breaches to individuals and authorities
   5. Processing and responding to requests and complaints from data subjects
   6. Handling of inspections and requests from supervisory authorities
   7. Management of disputes with data subjects and third parties

Your personal data will not be sold to third parties or used for advertising or marketing purposes.

When we collect personal data from you, it is necessary in order for Falck to provide you with access to the App and to support your operational activities. You are not obligated to provide personal data to us. If you do not provide personal data necessary for authentication and core use of the App, you will not be able to use the App. If you do not grant optional permissions such as location, camera, or gallery access, the App can still be used, but the related features will not function.

Device permissions used by the App

The App requests the following device permissions, each used solely for the purposes stated:

On newer Android versions (API 33+), photo and media access is handled through READ_MEDIA_IMAGES instead of READ_EXTERNAL_STORAGE / WRITE_EXTERNAL_STORAGE. The App requests only the permissions necessary for your device's Android version.

You can manage camera and location permissions at any time through your device's settings. Denying these permissions will limit certain App features but will not prevent you from using the App.

Location data and location permissions

The App can determine your location (precise GPS and approximate) when you initiate a location-related feature (e.g., viewing your position on a map). Location is collected on demand only — the App does not continuously track your location in the background. The App can be used without location permission, but location-dependent features will not function. Location data is not used for employee tracking, advertising, or marketing.

Device information

Basic device information (device model, operating system version, app version, platform) is captured at the time of device binding (activation). This data is stored as part of your device registration record. Additional device telemetry (OS version, app version, device type) may also be captured by Microsoft Application Insights as part of automatic telemetry during app usage for the purposes of technical support and performance monitoring.

Authentication and security audit logs

To protect your account and ensure system security, the App records authentication events including: successful and failed login attempts, device activation and revocation events, lockout events, and the IP address used during device activation. These logs are used for security monitoring and are not used for employee tracking or performance evaluation.

Local data storage on your device

The App stores a local encrypted database (SQLite) on your device to support offline functionality. This cache contains shift and task data relevant to your current session. Images stored locally are encrypted using AES-GCM encryption, with encryption keys managed through the Android Keystore. The local cache is cleared upon session expiry, logout, or uninstallation of the App.

Categories of ordinary personal data:

• Name and employee ID
• Email address and username
• Device binding data (device name, platform, activation codes, binding/revocation history, IP address)
• Authentication security logs (events, timestamps, lockout data)
• Shift assignment and task records
• Time registration entries
• Photos and scan results
• Location data (on-demand precise and approximate GPS)
• Device information and application log data

Categories of special types of personal data ("sensitive personal data"):

The App does not intentionally collect sensitive personal data. However, photos taken during task execution may in specific circumstances incidentally capture information relating to health and safety conditions or other sensitive matters on site. Such photos are processed exclusively for operational documentation purposes.

1. Compliance with legal obligations in specific cases — such as transfer of personal data to public authorities (including police) or other third parties in cases involving substantial public interest. Should such cases arise, you will be informed unless this is prohibited by law.
   • Retention and deletion criteria: Defined on the basis of the specific legislation applicable in the relevant case.
   • Legal basis: Varies depending on the specific case and circumstances.
2. Legal documentation — such as documentation of the handling of a request from you, storage of data in connection with ongoing or anticipated legal proceedings, or investigation of a data breach.
   • Retention and deletion criteria: Retained only for as long as necessary to comply with the relevant obligation or to establish or defend a legal claim. As a general rule, 3 years.
   • Legal basis:
     • Ordinary personal data: Legal obligation, GDPR art. 6(1)(c).
     • Potential sensitive personal data: Legal claims, GDPR art. 9(2)(f).
3. Authentication, shift and task management — account data, device binding records, shift context, task records, time registration entries, photos, and scan results.
   • Retention and deletion criteria: Task and operational data, including account data, device binding records (device name, activation code references, binding/revocation timestamps), shift context, task records, time registration entries, photos, and scan results are retained for the duration of employment and up to 5 full calendar years thereafter. Device binding history (including revoked bindings) is retained for the same period for security audit purposes. Photos stored in Azure Storage are property of the employer and retained for operational purposes. Local device data (SQLite cache and locally stored images) is retained until session expiry, logout, or uninstallation of the App.
   • Legal basis:
     • Ordinary personal data: Performance of the employment contract, GDPR art. 6(1)(b), and legitimate interest, GDPR art. 6(1)(f).
     • Falck's legitimate interest is based on its need to maintain accurate operational records, support compliance, and enable audit and quality assurance.
4. Application logs and telemetry — log files on the application server, Azure Log Analytics, and Application Insights data.
   • Retention and deletion criteria: Retained for 180 days for troubleshooting and operational monitoring purposes, after which they are deleted or anonymised.
   • Legal basis: Legitimate interest, GDPR art. 6(1)(f). Falck's legitimate interest is based on its need to ensure the technical reliability and security of the App.
5. Device information and authentication security logs — device model, OS version, app version, activation event logs, IP addresses at activation, authentication events.
   • Retention and deletion criteria: Retained for the duration of employment and up to 5 full calendar years thereafter.
   • Legal basis: Legitimate interest, GDPR art. 6(1)(f).
6. Compliance with legal obligations relating to employment, health and safety, or operational record-keeping.
   • Retention and deletion criteria: For as long as required by applicable legislation.
   • Legal basis: Legal obligation, GDPR art. 6(1)(c).

Deletion requests

You may request deletion of your personal data by contacting krystian.gadomski@falck.com or dpo@falck.com. Deletion requests are processed within 30 days. Some data may be retained where required by law, employment obligations, or where the data constitutes employer-owned operational documentation (e.g., task photos).

Independent data controllers in specific cases

(e.g. public authorities including police, other individuals in exceptional circumstances)

• Country: Varies depending on the specific case and circumstances
• Purpose: Compliance with legal obligations where Falck is required by law to transfer data to public authorities or other controllers
• Reference to relevant processing in section 4: items 1 and 2

Data processors — IT suppliers and cloud service providers

A full list of Microsoft's sub-processors and their locations is available at:
https://servicetrust.microsoft.com/ViewPage/TrustDocumentsV3

Legal basis for transfers to third countries:

• (a) EU Standard Contractual Clauses: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_de

Right of access

You have the right to receive a copy of all personal data Falck processes about you, free of charge and in a commonly used format.

Right to rectification

You have the right to have incorrect or incomplete personal data about you corrected or completed.

Right to erasure

You may request deletion by emailing krystian.gadomski@falck.com or dpo@falck.com. Deletion requests will be processed within 30 days. This right may be limited where Falck has a legal basis justifying continued processing, including employment obligations, legal claims, audit requirements, or where data constitutes employer-owned operational documentation. Deletion of your active App account is managed through Falck's employment and IT systems.

Right to restriction of processing

In certain circumstances you have the right to restrict Falck's processing of your personal data, meaning that Falck may only store — but not otherwise process — your data. This right may apply if the accuracy of the data is disputed, if you object to deletion, or if you object to processing.

Right to data portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format.

Right to object

You have the right to object to Falck's processing of your personal data. Falck may only continue processing if it can demonstrate a compelling legitimate basis, for example where processing is necessary to establish or defend a legal claim.