June 14, 2018
Threema GmbH (hereafter “Threema”) was founded on the premise of bulletproof data protection. It is our primary goal to store only the absolute minimum of information for the shortest possible time (“Privacy by Design”). In addition to using state-of-the-art encryption methods, we take all necessary technical and organizational measures to prevent unauthorized data access and misuse. The processing and protection of data is carried out in accordance with applicable legal regulations and EU Regulation 2016/679 (GDPR).
By using the “Threema Broadcast” website, you consent to the collection, processing and use of data as described below.
1. General Information
2. Purpose of Data Processing
Threema processes personal data to enable the Customer to access the web administration interface of the service and to process orders. The data processed within the scope of order fulfillment will be processed exclusively by Threema on its own server infrastructure in Switzerland and will not be passed on to third parties.
Threema does not process special categories of personal data as defined by Art. 9 (1) or Art. 10 GDPR. Based on Art. 5 (1) GDPR, personal data is processed solely as a result of self-declaration and only to the extent required for the Use of the Service.
3. Scope and Duration of Data Processing
A. Inventory data
When creating an account as well as during order and payment processing, the following inventory data is collected and stored:
- Mandatory information
- Session cookie (identifies the current browser session so that the customer remains logged in during his or her visit to the website)
- Email address
- Optional information
- A Threema ID if it is provided for two-factor authentication (“2FA”) as additional proof of identity for logging into the Threema Broadcast account. Alternatively, the 2FA can also be done via an OTP app.
- Invoice address: Name and address of the Customer (required for payment by credit card only)
Except for the legally required data storage for business transactions, inventory data is only stored until it is deleted by the Customer or the Customer deletes all accounts.
B. Usage data
In the context of the use of the service the following potentially personal data is processed and/or stored:
- Threema IDs of recipients added by the Customer and all subscribers of Customer's feeds
- Optional, if entered by the Customer: Recipient's first name, last name and language
- Only for groups administered on the Service: If the “Save message history” option is activated, the entire chat history since the option was activated is stored encrypted in the group on Threema's servers, including incoming messages from other group members added to the group by the Customer. Should this option be used, the Customer is obliged to comply with the relevant legal provisions and to inform it users of this fact.
Personal data arising from the use of the Service will only be stored until deleted by the Customer or until the Customer deletes all of his accounts. Deleted data will not be archived and cannot be restored.
4. Data Processed by Third Parties
As a matter of principle, Threema does not pass on any data to third parties. The service is completely ad-free and does not employ analytics software to track user behavior.
5. Right to Information, Correction, Blocking, Deletion and Appeal
The Customer has the right to receive information about his personal data stored by Threema at any time. Likewise, he has the right to correct, block, or delete his personal data, apart from the legally required data storage for business purposes.
The Customer has access to this information and the appropriate tools for its management. Threema will take necessary measures according to Customer's instructions if the Customer cannot implement them with the tools provided. The Customer can change or revoke his consent with effect for the future with a message to Threema and exercise his right of appeal at the competent authority.
6. Responsible Body
If you have any questions about data protection at Threema or would like to exercise your rights, you can contact us directly. Send us an email to firstname.lastname@example.org.
Responsible body and direct contact for questions on data protection at Threema in terms of data privacy law:
Data Protection Officer
8808 Pfäffikon SZ
Representative in the EU according to Art. 27 (1) GDPR: GeKaCe GmbH, Dept. T, Weilerweg 13, 72411 Bodelshausen, Germany.
This is a mere translation of the German version of this document. In case of any discrepancies between the English and the German text, the German version shall prevail.