Who we are
The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:
Instagrid GmbH Solitudeallee 27 71636 Ludwigsburg Germany +49 7141 696240 hello@instagrid.co https://instagrid.co/
How to contact the data protection officer
The designated data protection officer is:
DataCo GmbH Sandstr. 33 80335 Munich Germany privacy@dataguard.com www.dataguard.de
General information on data processing
On this page, we provide you with information regarding the processing of your personal data on the Instagrid App.
How we collect and use your personal data will depend on how you interact with us or the services you use. We only collect, use or share your personal data where we have a legitimate purpose and a legal basis for doing so.
What do we mean by ‘legal basis’?
Consent (Art. 6(1) (a) GDPR)– You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time. To do so please contact the Data Protection Officer via the details supplied above.
Contract (Art 6(1) (b) GDPR) – We need to use your data to fulfil a contract you have with us. Alternatively, it’s necessary to use your data because we have asked you to, or you have taken yourself, specific steps before entering that contract.
Legal Obligation (Art 6(1) (c) GDPR) – We need to use you’re your data to comply with the law.
Vital Interests (Art 6(1) (d) GDPR) – Processing your data is necessary to protect your vital interests or of another person. For example, to prevent you from serious physical harm.
Public Task (Art 6(1) (e) GDPR) – Using your data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law, for example, for a statutory function.
Legitimate Interests (Art 6(1) (f) GDPR) – Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests.
Please note where your data is processed under the performance of a contract or for a legal obligation, if you do not provide the data requested, we may be unable to provide you with our app.
Your rights
When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:
Purposes of processing
Categories of personal data being processed.
Recipients or categories of recipients to whom the personal data have been or will be disclosed. Planned storage period or the criteria for determining this period
The existence of the rights of rectification, erasure or restriction or opposition. The existence of the right to lodge a complaint with a supervisory authority.
If applicable, origin of the data (if collected from a third party).
If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
If applicable, transfer of personal data to a third country or international organization.
2. Right to rectification (Art. 16 GDPR)
You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.
3. Right to the restriction of processing (Art. 18 GDPR)
You may request the restriction of the processing of your personal data under the following conditions:
If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant and it is not yet certain whether the legitimate interests of the data controller override your interests.
4. Right to erasure ("Right to be forgotten") (Art. 17 GDPR)
If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:
Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data.
You object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
Your personal data has been processed unlawfully.
The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
The right to deletion does not exist if the processing is necessary:
to exercise the right to freedom of speech and information;
to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative;
for reasons of public interest in the field of public health;
for archival purposes of public interest, scientific or historical research purposes or for statistical purposes; or
to enforce, exercise or defend legal claims.
5. Right to data portability
You have the right to receive your personal data given to the data controller in a structured and machine- readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data.
6. Right to object
For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) GDPR; this also applies to profiling based on these provisions.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.
7. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR. A list, of the locally competent supervisory authorities in Germany can be found on the website of the Federal Commissioner for Data Protection at the following link: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html
Data sharing and international transfers
As explained throughout this Privacy Policy, we use various service providers to help us deliver our services and keep your data secure. When we use these service providers, it is necessary for us to share your personal data with them.
We have agreements in place with all our service providers that we share your data with that oblige them to protect your data.
Where your personal data is shared outside the EU, we ensure that your personal data is given an equivalent level of protection, either because the jurisdiction to which your data is transferred has an ‘adequate’ data protection standard according to the European Commission, or by using another safeguard such as an enhanced contractual agreement, i.e. Standard Contractual Clauses adopted by the European Commission (SCCs).
For example, where we use US service providers, we either rely on SCCs or the EU-US Data Protection Framework, depending on the specific provider. You can request a copy of SCCs we have concluded with our service providers by sending an email to the email address provided in this Privacy Policy.
Provision of app and creation of log files
1. Description and scope of data processing
Each time our app is accessed, our system automatically collects data and relevant information from the computer system of the calling device.
The following data is collected:
Information about the browser type and the version used
The user's operating system
Date and time of access
This data is stored in the log files of our system
2. Purpose of data processing
The storage in logfiles is done to ensure the functionality of the app. The data is also used to optimize the app and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.
3. Legal basis for data processing
The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (f) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the app is accomplished.
If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses are deleted or alienated so that an assignment of the calling client is not possible.
5. Exercising your rights
The collection of data for the provision of the app and the storage of the data in log files is absolutely necessary for the operation of the app. You can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.
App registration
1. Description and scope of data processing
We offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:
Email address
Last name
First name
As part of the registration process, your consent to the processing of this data is obtained.
2. Purpose of data processing
User registration is necessary for the fulfilment of a contract with or for the execution of pre-contractual measures.
3. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 (1) (a) GDPR where you have provided consent.
The legal basis for the processing of registration data necessary to conclude or fulfil a contract with you is Art. 6 (1) (b) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.
This is the case for the data collected during the registration process for the fulfilment of a contract or for the execution of pre-contractual measures if the data is no longer required for the implementation of the contract. Even after the conclusion of the contract, it may be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.
5. Objection and removal
As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time, through the following method:
To delete your account, please navigate to the ‘Settings’ section within your account. Once there, select the ‘Account’ tab where you will find the option to ‘Delete Account.’ By clicking on the ‘Delete Account’ button, your account will be permanently deleted. Please be aware that this action is irreversible and will result in the permanent removal of all your data associated with the account.
If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible insofar as contractual or legal obligations do not stand in the way of a deletion.
Data processing when using the Instagrid App
1. Description and scope of data processing
When using the Instagrid App and the associated digital services Instagrid CONNECT, Instagrid CONNECT PLUS and Instagrid PULSE, various categories of personal data are processed. During account creation, we collect the user’s first name, last name and email address. When a user connects Instagrid ONE or Instagrid GO devices to the App, we also process device-related data such as the serial number or unit ID, status information, energy metrics including charging and discharging cycles, connectivity information, time stamps, historical usage data, sustainability-related performance metrics and, where applicable, data retrieved via interfaces such as the ISO 15143 API or the advanced analytics API available in Instagrid PULSE. If the user enables the corresponding function within the App, the location of the Instagrid device is also processed.
Account data is entered directly by the user during registration. Telemetry and IoT data is generated automatically during the operation of the devices and transmitted to Instagrid when connected to the App or associated digital services. Instagrid collects and processes the full set of device-related, telemetry and usage data described above irrespective of the specific service configuration selected by the user. This data is processed partly to provide the IoT service and its functionalities and partly for internal purposes such as product development, diagnostics, servicing, maintenance, technical support, security monitoring and continuous improvement of our devices and digital services.
2. Purpose of data processing
The data described above is processed to enable the creation and administration of user accounts, to provide access to the purchased Service tier and its functionalities, and to support asset and fleet management for the user’s Instagrid devices. If location tracking is enabled, the location of a device is processed to support theft protection and to improve fleet visibility. Energy data and usage metrics are collected to display device performance, generate sustainability reports and support the user in monitoring the condition and utilisation of their devices. Telemetry, event and diagnostic data are also processed to ensure the security, stability and continuous improvement of the App and the associated digital services.
3. Legal basis for processing
Personal data is processed on the basis of Article 6(1)(b) GDPR where this is necessary for the performance of the contract between the user and Instagrid, in particular for providing access to the App, managing user accounts and supplying the functionalities of the IoT Service. Processing operations relating to diagnostics, analytics, IT security and service optimisation are carried out on the basis of Instagrid’s legitimate interests under Article 6(1)(f) GDPR. Where data processing requires the user’s prior consent, such as device location tracking, the legal basis is Article 6(1)(a) GDPR. Users may withdraw their consent at any time by adjusting the relevant settings in the App.
4. Duration of storage
Personal data is stored only for as long as necessary to fulfil the purposes for which it was collected. Account data remains stored for the duration of the user relationship and is deleted if the user deletes their account, unless legal obligations require a longer retention period. Telemetry and IoT data is generally stored for up to one year unless a longer retention period is required by law or expressly agreed with the user. Log files created during technical access to the App are stored for up to seven days, unless a longer storage period is required for security or troubleshooting purposes.
5. Exercising your rights
Users may object to the processing of their personal data where processing is based on legitimate interests. They may also request the correction or deletion of their account data at any time. Objections to optional processing can be exercised directly within the App by disabling the relevant functionality. For example, users who do not wish their device’s location to be processed may deactivate the location feature at any time through the settings menu. All further rights under the GDPR, including the right of access, rectification, erasure, restriction, data portability and the right to lodge a complaint with a supervisory authority, apply without restriction.
App performance monitoring
1. Description and scope of data processing
We collect various types of telemetry data in our app in order to monitor, analyse, and optimise system performance and resource utilisation.
We use the following service provider in order to monitor and analyse app performance:
Firebase Analytics
2. Purpose of data processing
The collection, analysis and sharing of telemetry data serves in particular the following purposes:
Infrastructure monitoring
Application monitoring
Resource optimization
Bug fixing
3. Legal basis for data processing
The collection of this data is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the collecting the data necessary for app performance monitoring, analysis and optimisation.
4. Duration of storage
Your personal information will be stored as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.
5. Exercising your rights
You can object to the processing of your data by sending an email to the email address provided in this Privacy Policy.
Use of Software Development Kits
1. Scope of processing of personal data
Our App incorporates third-party Software Development Kits (SDKs) to enable essential technical functions and to support the stability, security and performance of the App. SDKs are sets of tools and libraries provided by external service providers. Depending on their purpose, SDKs may process certain technical information from your device and share it with the respective provider. Instagrid has identified the following SDKs as currently implemented in the App.
AWS Cognito Auth SDK
We use the AWS Cognito Auth SDK provided by Amazon Web Services EMEA SARL (Frankfurt Region) to authenticate users and to manage secure login sessions within the App.
When you use our App, AWS Cognito processes the following data:
• Email address • Authentication credentials (hashes) • Device identifiers • Security tokens and technical metadata required for login and session handling
Further information on AWS data processing can be found at: https://aws.amazon.com/privacy/
Google Analytics for Firebase SDK
We use the Google Analytics for Firebase SDK provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to analyse app performance and general usage patterns necessary to maintain service quality.
When you use our App, Google Analytics for Firebase processes the following information:
• Aggregated interaction events (e.g. feature usage, screens viewed) • Device information (model, operating system version, language settings) • Installation identifiers • General performance and stability metrics
This SDK does not process names, email addresses or precise location data.
Further information: https://policies.google.com/technologies/partner-sites Opt-out settings: https://adssettings.google.de
Firebase Crashlytics SDK
We use the Firebase Crashlytics SDK provided by Google Ireland Limited to identify errors and crashes, to ensure app stability and to support troubleshooting.
When you use our App, Crashlytics processes the following data:
• Crashlytics installation UUIDs • Firebase installation IDs • Crash traces and diagnostics • Technical device information relevant to the crash event
Further information: https://policies.google.com/technologies/partner-sites Opt-out settings: https://adssettings.google.de
Firebase Cloud Messaging
We use Firebase Cloud Messaging provided by Google Ireland Limited to deliver push notifications.
When you use our App, Firebase Cloud Messaging processes the following data:
• Firebase installation IDs
Further information: https://policies.google.com/technologies/partner-sites Opt-out settings: https://adssettings.google.de
Google Maps SDK
We use the Google Maps SDK provided by Google Ireland Limited to enable map-based visualisation within the App.
When you use the map feature, Google processes the following data:
• Device metadata • IP address • Technical identifiers required to display map content
Further information: https://policies.google.com/technologies/partner-sites Opt-out settings: https://adssettings.google.de
2. Purpose of processing
The use of SDKs enables essential technical functions such as authentication, app stability, error monitoring, performance analytics and (where activated by the user) map-based visualisation. These SDKs help ensure that the App functions securely, reliably and in accordance with the features offered.
3. Legal basis for processing
Where an SDK is strictly necessary to provide the core functions of the App (e.g. authentication, crash diagnostics or performance monitoring), processing is based on Art. 6(1)(f) GDPR (legitimate interest in ensuring the provision, stability and security of the App) or Art. 6(1)(b) GDPR (contract performance).
Where SDKs support optional features (e.g. map visualisation), data is processed only with your consent under Art. 6(1)(a) GDPR.
4. Exercising your rights
You have the right to withdraw consent for optional SDKs at any time. Withdrawal does not affect the lawfulness of prior processing. For SDKs required for core functionality, you may exercise your rights under the GDPR, including the right to object, in accordance with the ‘Your rights’ section of this Privacy Policy.
This privacy policy has been created with the assistance of DataGuard.