Data Privacy “LINDERA Mobility Analysis” app

Information about the processing of your personal data when using our application

The following data protection information provides an overview of the collection and processing of your data and how you can use the rights you are entitled to under the General Data Protection Regulation.

The EU General Data Protection Regulation (GDPR), which entered into force on May 25, 2018, obliges us to inform you comprehensively about the processing of your personal data. Among other things, we inform you in detail about your rights as a “data subject” whose personal data we process.

WHAT is the “LINDERA Mobility Analysis” app?

LINDERA Mobility Analysis is a software application for smartphones and tablets. 

The app identifies the fall risk of seniors and supports caregivers in the implementation of fall prevention. 

The application can be used by caregivers and by seniors* as well as their relatives. The effectiveness of our software is regularly examined in scientific studies.

WHO is responsible for data processing?

The responsible person within the meaning of the General Data Protection Regulation (GDPR) is:

Lindera GmbH
Kottbusser Damm 79
10967 Berlin
Phone: +49 30 12085471
E-Mail: hello@lindera.de 

Data Protection Officer: 

Nicole Motiee Tehrani
ap datenschutz GmbH
Hohenstaufenring 8
50674 Köln
Phone: +49 221 99989 030
Telefax: +49 221 423 2785 -9
E-Mail: info@ap-datenschutz.de 

Competent supervisory authority: 

Berliner Beauftragte für Datenschutz und Informations-sicherheit
Friedrichstraße 219
10969 Berlin
Deutschland
Phone: +49 (0) 303 13889-0
Telefax: +49 (0) 30 2155050
E-Mail: mailbox@datenschutz-berlin.de

WHAT personal data are used?

We process your personal data to the extent that it is necessary to perform the fall analysis.

The personal data of our users is regularly processed only with the consent of the user. The data collected by LINDERA Mobility Analysis App is in principle not passed on to third parties. The following data are necessary for the implementation of the mobility and fall analysis.

The following categories of data are collected and stored:

Personal data

This data is not used for marketing or advertising purposes. This is solely for quality improvement and to improve our service quality.

Health-related information (patient data)

• As part of the questionnaire on fall risk factors – only collected for seniors
  • Type of residence
  • Cognitive or physical impairment
  • Level of Care. The gradations are: 0 = no level of care; 1 – 5 (5 is the highest).
  • Analysis interval
  • Gait-related illnesses
  • Medication
  • Fall history
  • Fear of falling
  • Use of walking aids
  • Elimination behavior
• Analysis/walking videos (more info under “HOW does the mobility analysis work?”)

Meta/communication data (device IDs, IP addresses, location data)

• Installation IDs (unique, device-independent ID)
• Device manufacturer and model
• Operating system version
• App version 

Furthermore, no app usage data is collected.

HOW does the mobility analysis work?

By entering your data, your fall risk is determined digitally. This means that you or your caregiver enters the data in the app. Then a video of you must be recorded with the cell phone camera. To do this, you have to walk 6 meters (3 meters each way). You can use your everyday walking aids to do this. The program then analyzes your gait. By answering the questionnaire, you will receive an evaluation of your risk of falling at the end. You will also receive suggestions on how to reduce your risk of falling. This should help you stay mobile.

WHERE does the data come from?

We process personal and health-related data that you provide to us about yourself or third parties as part of your registration and fall analysis. The data collected in relation to mobility and fall analysis have been determined and processed by means of the completed questionnaires and personal data. In principle, this data is not passed on to third parties. As our application is used by professional caregivers, they have access to the collected data and the analysis results.

WHY and on what legal basis do we process your data?

We process your personal data in particular in compliance with the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) as well as all other relevant laws. Our mobile application is used to perform our fall analysis to promote effective prevention and health. In addition, the data is used pseudonymously for clinical studies. Data processing based on consent given by you (Art. 6 para. 1 lit. a DS-GVO). For the use of our app, you have given us, during registration, voluntary consent to the collection, processing or transmission of certain personal data. This consent forms the legal basis for the processing of this data.
Upon initial registration, you also have the option to consent to participation in our effectiveness study. Participation is voluntary and can be revoked at any time. You will find further information on this study in the further course of this privacy policy.

Data processing for the fulfillment of a contract (Art. 6 para. 1 lit. b DS-GVO).

We may base our data processing on Art. 6 (1) lit. b GDPR if it is necessary for the performance of the contractual relationship. Data processing is not only necessary for the performance of the contract if the contract could not be performed at all without the data processing; rather, it is sufficient if the data processing is objectively reasonable with regard to the purpose of the contract (VG Mainz, judgment of 20.2.2020 – 1 K 467/19.MZ, para. 30). Without personal data, we would not be able to assign your completed questionnaires to individuals, perform a gait analysis, and consequently provide our service (fall analysis). Therefore, the processing appears to be reasonable with regard to the purpose.

WHERE is your data processed and stored?

Your data is mainly processed automatically by our software. This requires that our internal IT department is granted access to the data.

The companies (e.g. nursing homes) that use our app only have access to patient data in their own organisation.

To provide our service, we use the Open Telekom Cloud and Hetzner Cloud Hosting, where your data is stored. Our app communicates exclusively with the instances that serve as a prerequisite for processing and performing mobility analyses.

A transfer of data to third parties is hereby excluded in principle.

Deutsche Telekom Cloud
Telekom Deutschland GmbH
Landgrabenweg 151
53227 Bonn
Phone: 0228 – 181 0 

Hetzner Online GmbH
Industriestr. 25
91710 Gunzenhausen
Deutschland 
Phone: +49 9831 505-0
Telefax: +49 9831 505-3
E-Mail: info@hetzner.com 

The service providers mentioned above only provide servers and IT infrastructure and do not have access to the data themselves.

WHERE is your data transferred to?

The transmission and processing of your data takes place in Germany.

Therefore, we do not use service providers located in third countries outside the European Union to process your data.

HOW LONG will your data be stored?

We store your personal data for as long as it is necessary for the service provision of the fall analysis. You can proactively request us to delete the data.

If you delete your account with us via the app, the data will remain stored on our IT system for a further 30 days before being completely deleted. Access to the data is no longer possible in the app from the time of the deletion request.

In this case, we will comply with your request as soon as possible. Otherwise, the data will remain archived for up to 10 years in accordance with statutory retention obligations (e.g. tax and commercial law retention and documentation obligations). After that, the data will be deleted.

What RIGHTS do you have in connection with the processing of your data?

Every data subject has the right to information under Article 15 of the GDPR, the right to rectification under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to object under Article 21 of the GDPR and the right to data portability under Article 20 of the GDPR. With regard to the right to information and the right to erasure, the restrictions according to §§ 34 and 35 BDSG apply.

Right of objection

Pursuant to Article 21 (1) of the GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 (1) (e) of the GDPR (data processing in the public interest) or on the basis of Article 6 (1) (f) of the GDPR (data processing for the purposes of safeguarding a legitimate interest); this also applies to profiling based on this provision.
In the event of your objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

Revocation of consent

You can revoke your consent to the processing of personal data at any time via all communication channels (e-mail, telephone, mail). Please note that the revocation is only effective for the future.

LINDERA GmbH, Kottbusser Damm 79, 10967 Berlin, hello@lindera.de.

Right to information

You can request information about whether we have stored personal data about you. If you wish, we will tell you what data is involved, for what purposes the data is processed, to whom this data is disclosed, how long the data is stored and what other rights you have in relation to this data.

Other rights

In addition, you have the right to correct incorrect data or to have your data deleted. If there is no reason for further storage, we will delete your data, otherwise we will restrict the processing. You may also request that we provide any personal data you have provided to us in a structured, common and machine-readable format either to you or to a person or company of your choice. In addition, you have the right to lodge a complaint with the competent data protection supervisory authority (Art. 77 GDPR in conjunction with Section 19 BDSG).

Exercise your rights

To exercise your rights, you can contact the person responsible or the data protection officer using the contact details provided. We will process your requests promptly and in accordance with the legal requirements and inform you of the measures we have taken.

Information for study participants

The study data is stored in electronic form on storable data carriers for 10 years. After that, they are also deleted. This complies with the guidelines of the German Research Foundation (DFG). Furthermore, safeguards for data protection and data security are in place and regularly reviewed.

If you consent to participate in a study, your data may be aggregated pseudonymously and shared with the following scientific partners in this context: 

Charité – Universitätsmedizin Berlin
Charitéplatz 1
10117 Berlin
Deutschland
Phone: +49 30 450 – 50 

Wilhelm Löhe Hochschule
Merkurstr. 41
90763 Nürnberg
Deutschland
Phone: +49 991 7660690
E-Mail: datenschutzbeauftragter@wlh-fuerth.de

HOW will your data be used in the study?

At three-month intervals, a member of your care team will conduct the LINDERA Mobility Analysis with you. Afterwards, you discuss the results together with your caregiver. In addition, at the beginning of the study, you fill out a questionnaire about your degree of care and other factors that may have an influence. The data is summarized pseudonymously in the study to check how effective the mobility analysis is.
After the study, the results are anonymously forwarded in a report to funding agencies/clients. In this way, the results can be used for the future.
Currently, various scientific studies on the effectiveness of the app in the setting of inpatient and outpatient geriatric care are underway. Participation in all scientific studies is voluntary. A separate consent and privacy policy applies to study participation, which provides information on how the data collected is analyzed. Our scientific studies run separately from the regular use of the app. Accordingly, with the regular use of the app, explicit consent is given not to share data for study purposes.

We are currently implementing the following studies:

• Usability Study
  • In cooperation with the Charité. The data is analyzed anonymously.

• Randomized control study
  • In cooperation with Charité, sponsored by the health insurance company Audi BKK.
  • On the usability, acceptance and effectiveness of the LINDERA Mobility Analysis. The data sets are evaluated pseudonymously. 

• Randomized control study
  • In cooperation with the Wilhelm Löhe University of Applied Sciences, sponsored by the health insurance company Barmer Bayern. Study on usability, acceptance, effectiveness and care processes. Data are evaluated pseudonymously.

Changes to this information

If there is a significant change in the purpose or manner of processing your personal data, we will update this information in a timely manner and inform you of the changes in a timely manner.