Privacy Policy

FootWall GmbH Privacy Policy

Effective Date: July 09, 2024

FootWall GmbH ("FootWall", "we", "our", "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our app (“App").

1. Information We Collect

We process your personal data for various purposes and based on several different legal bases that allow this processing. For example, we process your personal data to provide and improve our Services, to provide you with a personalised user experience on our Services, to contact you about your account and our Services, to provide customer service, to provide you with personalised advertising and marketing communications, and to detect, prevent, mitigate and investigate fraudulent or illegal activity. We also share your information with third parties, including service providers acting on our behalf, for these purposes. In addition, we may share your personal data in order to fulfil our contract with you under our Terms of Service. 

We may collect information about you when you visit our Sites or use our Services, including the following: Registration and use information – When you register for or use our Services, or otherwise provide information to us, we will collect Personal Data as necessary to offer and fulfil the Services you request.  

2. How We Use Your Information

Currently, we do not collect additional data beyond the personal data provided during account creation. Google AdMob may have access to certain user data for advertising purposes. We retain Personal Data for our business purposes, to provide the Services and to fulfil our legal or regulatory obligations.  We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.  If your Account is closed, or you ask us to delete your information, we may take steps to mask Personal Data and other information in accordance with law. We reserve at all times our ability to retain and access Personal Data for so long as required to comply with applicable laws, and in such cases, we will continue to use and disclose such Personal Data in accordance with this Privacy Policy and law.

We may also us it to manage our business needs, such as monitoring, analysing, and improving the Services and the Sites’ performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services. To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. We may use Personal Data, Device Information and Technical Usage Data from our Sites and websites to help detect and prevent fraud and abuse of the Services. We may also use it to respond to your requests, for example to contact you about a question you submitted to our customer service team.

The data retention in case for our European Union users, we will retain your personal information for as long as we need it to deliver the services to you and a reasonable period thereafter to respond to requests or questions from you, to protect our legal rights, to analyse and improve our services, as necessary to comply with legal requests and as otherwise disclosed in our Privacy Policy.

3. Data Sharing

We MAY share your Data or other information about you with others as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons:

With our business partners for our legitimate business persons: We may share Personal Data with our business partners to offer additional features or services to you.  For example, we may share your Personal Data with certain club partners in connection with relevant transactions. In certain jurisdictions, we are required to obtain your consent to do so, but not all jurisdictions impose these requirements.

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf.  These third-party service providers may, for example, provide you with Services, assist in processing transactions, allow us to send you advertisements for our products and Services, provide customer support, send email marketing on our behalf, etc. We do not sell your information to these third-party service providers.

In aggregated, anonymous form to provide data to third parties for our benefit: We may provide aggregated statistical data to third-parties for our own analytics and business purposes.  This data will not personally identify you or provide information about your specific use of the Sites or Services.  We do not share your Personal Data with third parties for their marketing purposes without your consent.

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including:

  • if we need to do so to comply with a law, legal process or regulations;

  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Us;

  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

  • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;

  • to protect our property, Services and legal rights;

  • in connection with shipping, payment and related services for purchases made using a Service;

  • to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;

  • to banking partners/payment processors as required by card association rules;

  • to credit reporting and collection agencies;

  • to companies that we plan to merge with or be acquired by; and

  • to support our audit, compliance, and corporate governance functions.

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorise an account communication with a third-party account or platform.  

4. Data Storage and Security

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this Privacy Policy. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged or permitted to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes, or to detect and prevent fraudulent or illegal activity). In Europe, the retention periods are generally between 6 and 10 years. As far as legally permissible or required, we restrict the processing of your data instead of deleting it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the execution of the contract or for the assertion of or defence against legal claims, or where such retention is otherwise required or permitted by law. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be deleted after the relevant limitation or retention periods have expired.

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration.  The security measures include firewalls, data encryption, access controls to our data centres, and information access authorisation controls.  While we are dedicated to securing our systems and Services, you are not responsible for securing and maintaining the privacy of your password(s) and Account/profile information and verifying that the Personal Data we maintain about you is accurate and current.  We are not responsible for protecting any Personal Data that we share with a third-party based on an account communication that you have authorised.

5. User Rights

In certain jurisdictions in which we operate, as a data subject, you have the right to access, rectification, erasure, restriction of processing and data portability with regard to your personal data. In addition, you can withdraw your consent and object to our processing of your personal data on the basis of our legitimate interests. Contact us to exercise these rights. 

In case of users that access our Services from the European Union, you may wish to view, delete, restrict, correct or receive a copy of the personal information collected about you in a structured, machine-readable format. Where we process your information with your consent, you may withdraw it at any time. You also have a right to (i) object to processing based on legitimate interests or (ii) ask from which source the personal data originates and if applicable, whether it came from publicly accessible sources. Should you wish to exercise these rights, you may send an e-mail to info@footwallapp.com. Please indicate your country of residence in your correspondence. If you have unresolved concerns, where applicable, you may also have the right to complain to data protection authorities.

6. Cookies and Tracking Technologies

We do not currently use cookies or other tracking technologies.

7. International Data Transfers

Some recipients of your personal data are located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. When transferring personal data to such recipients, we provide appropriate safeguards.

We may transfer your personal data to recipients who may be located anywhere in the world for the purposes set forth in this Privacy Policy. We will only transfer your personal data from the European Economic Area (EEA), United Kingdom or Switzerland to third countries, i.e. countries outside the EEA, on the basis of appropriate safeguards or if otherwise authorised by applicable law. We provide the necessary safeguards, e.g. through the conclusion of data protection contracts adopted with the recipients, or through other measures provided for by law. 

8. Children’s Privacy

The App is intended for users over the age of 13. We do not knowingly collect data from children under 13. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us immediately if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

9. Contact Information

For any questions or concerns about this Privacy Policy, please contact us at info@footwallapp.com.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Users will be notified of any changes through app updates. Continued use of the App constitutes acceptance of the new terms