With this Privacy Notice we would like to inform you about the processing of your personal data in the course of using ANGEL, more precisely the ANGEL application as well as the ANGEL web services, and the rights you are entitled to under data protection law. In addition, we will give you insight into how anonymized usage data can help make your work environment a little safer.

Your personal data will be processed in accordance with the applicable data protection laws of the European Data Protection Regulation (GDPR) and any other applicable local data protection regulations.

At ADRESYS, we do our best to handle customer and user data transparently and carefully — we therefore only store the data that are necessary to provide targeted assistance in an emergency. Herewith, we give you a comprehensive overview of how ANGEL processes your data.

Your rights

Based on the applicable data protection regulations, you have the right to information, correction, deletion, restriction of data processing, data portability and objection at any time. You can revoke any consent provided for the future.

If you wish to exercise any of these rights, please contact ADRESYS as indicated in this document. In addition, you have the right to file a complaint with the competent supervisory authority — for ADRESYS in Austria, the responsible authority is the “Oesterreichische Datenschutzbehoerde” (Barichgasse 40-42, 1030 Vienna).

Data Controller is:
ADRESYS – Adaptive Regelsysteme Gesellschaft m.b.H.
Oberndorfer Straße 35, Eingang C, 5020 Salzburg, Austria

If you have any questions about data protection, please do not hesitate to contact us — we can be reached on the hotline +43 59495 6969 and by e-mail at angelreact@adresys.com.

In general, ANGEL customers buy ANGEL for their employees (ANGEL users). ANGEL users wear a smart-textile shirt, on which the central control unit — the Genius — is mounted. This unit senses electrical voltages and changes in motion.

The Genius connects to the ANGEL application installed on the smartphone (the ANGEL App) using Bluetooth® technology. After a successful connection, the ANGEL App communicates with the ANGEL server, the central data hub. The ANGEL server is connected to the ANGEL database, an anonymized long-term memory of all event-related ANGEL activities, as well as a technically necessary short-term memory for processing important emergency information.

Via the ANGEL Server, the personal data of the users are transferred to the ADRESYS customer database, which is kept strictly separate from the rest of the databases. Only in an individual emergency scenario is the emergency call center (if this additional option has been selected) provided with all the user’s information required to provide assistance, which enables help to be provided on the spot.

Processed Data

• Data from customers
  (employer or purchasing company — name, contact information, bank details)
• User data (first and last name, telephone number, e-mail address, password)
• ANGEL ID
• Contract data (start, duration)
• Selected additional options (emergency call center)
• Emergency contact information (first and last name, phone number)
• Genius serial number

Processing Purpose

All collected data are necessary for the correct processing of the service provided. All processed data of users are necessary for assistance in case of emergency — otherwise assistance at the scene of an accident will be delayed, if, for example, names of accident victims are not known. Contract data and data on customers are mandatory for the correct processing and billing of the service. The legal basis for the processing is Section 6 para. 1 lit. b GDPR.

Data Origin

All personal data are provided directly by the customer at the time of purchase or by the user at the time of registration. As a rule, customers buy ANGEL for their employees. During the purchase process, the Genius serial number is assigned to the customer (usually the employer) by ADRESYS. Users then register independently via the ANGEL App and establish a connection between the Genius and the ANGEL App. If the emergency call center is selected as an additional option, users receive an activation code from their employer that can be activated directly in the ANGEL App.

Data Recipients

All personal data are stored in the ADRESYS customer database. ADRESYS uses the IT services of OMICRON electronics GmbH (Oberes Ried 1, 6833 Klaus, Austria) for this purpose. In the event of an alarm, the data required for the specific assistance and the individual case are transmitted to the emergency contact or the emergency call center. Transfer to third parties — except for assistance in an emergency — does not take place.

Retention Periods

After users have informed ADRESYS that ANGEL is no longer in use, all registration data will be deleted after one year at the latest, provided that statutory periods for storage or defense of legal claims do not require or justify longer retention periods.

Special Security Measures

User data (e-mail address, password) are already protected during registration in the ANGEL web portal, so that ADRESYS can only validate these data, but not read it in plain text. In the ANGEL database, users are assigned unique but randomly selected ANGEL IDs. These are defined during registration. The assignment between ANGEL ID and the user is only possible locally in the ANGEL App and in the ADRESYS customer database.

Processed Data

ANGEL Status

• Time of activation of ANGEL
• Measured value of the electrode resistance
• Time of termination of ANGEL
• Activation/deactivation of the task timer

Emergency Relevant Information

• User data (first and last name, telephone number)
• Employer or customer of ANGEL (if different from user)
• Emergency contact (first and last name, phone number)
• Location data (e.g., GPS position)
• Electrical Accident Detection (voltage in the body)
• Fall and No-Motion Detection (data from acceleration and position sensors)
• Task Timer function status

Processing Purpose

All data processing in active operation is required for specific assistance in the event of an emergency. The legal basis for the processing is Section 6 para. 1 lit. b GDPR and, with regard to the processing of incident data (electrical accidents, falls, no-motion, etc.), the express consent of the users pursuant to Section 6 para. 1 lit. a GDPR, Section 9 para. 2 lit. a GDPR.

Data Origin

All processed data come directly from the users or their smartphones and are processed by the ANGEL App. The ANGEL App constantly forwards location data in the background (even when the app is closed or not in use) — this is necessary to send help to the current location of the user.

Data Recipients

The ANGEL status is transferred to the ANGEL database at regular intervals (see also data recipients on page 06). Emergency-related events are also stored in the ANGEL database. In a specific emergency scenario, all emergency relevant information (and other data entered by the user in the ANGEL App) as well as additional helpful information from the ANGEL server is transmitted to the emergency call center (if the additional option is selected).

Retention Periods

The data are stored in the ANGEL database during the contract and usage period. Subsequently, the personal data of users are deleted as already described and the ANGEL ID is anonymized. Technically necessary short-term memories are continuously overwritten with current data or deleted, unless there are legally permissible reasons that justify or require storage. The respective emergency call center stores all emergency call-related information (including the telephone calls made) and processes it on its responsibility in accordance with the statutory provisions for emergency call centers. After expiration of the legal retention periods, these data are deleted.

Special Security Measures

When transferring the ANGEL status to the ANGEL database, assignments to users are only possible via the ANGEL ID — as soon as the ANGEL ID is deleted from the ANGEL database, assignment to individual users is no longer possible. If possible, emergency relevant Information is transmitted to the emergency call center by text message as well as via data connections. After receiving the emergency call message, the emergency call center verifies the authenticity of the emergency call message with the ANGEL server.

Processed Data

• ANGEL status
• Event-related information
  • Voltage characteristic and/or acceleration data
  • Anonymized communication history between ANGEL server and emergency call center (without names, phone numbers are shortened to the area code, no communication content, such as the wording, is processed).
  • Anonymized location data (rounded to whole degrees, therefore deviations of up to 100 km are possible)
  • Technical usage data

• Feedback information after incidents (electrical accidents, falls, no-motion, etc.)

Processing Purpose

Data on electrical accidents collected by ANGEL are not only intended to help the users themselves, but also to contribute to greater safety in the company for all other ANGEL customers by making statistics on electrical accidents available in anonymized form as part of the ANGEL service provision. In addition, these anonymized data will contribute to further scientific knowledge in the field of electrical accidents. The processing of event-related information for evaluation and statistical purposes is carried out to fulfill contractual obligations. With regard to the processing of specific incident data, this is based on the consent of the user and with regard to the technical usage data, it is based on the legitimate interest of ADRESYS to further technically optimize ANGEL and to make the knowledge gained available to scientific research in anonymized form. The legal basis for the processing is Section 6 para. 1 lit. b GDPR and, with regard to the processing of incident data, the express consent of the users pursuant to Section 6 para. 1 lit. a GDPR, Section 9 para. 2 lit. a GDPR.

Data Origin

All data used are provided directly by the users when using ANGEL. If appropriate, users are asked on a voluntary basis after an incident (electrical accident, fall, no-motion, etc.) to provide feedback to ADRESYS on the facts and consequences.

Data Recipients

All event-related information, which forms the basis for evaluations and statistics, is stored in the ANGEL database. Employers receive anonymous evaluations of ANGEL use in the company. ADRESYS reserves the right to pass on collected event-related information to research institutes in anonymized form.

Retention Periods

The data are stored in the ANGEL database during the contract and usage period. Subsequently, the personal data of users are deleted as described above, and the ANGEL ID is anonymized.

Special Security Measures

Contact data and location data are anonymized with special care as part of the statistical evaluation. In the case of telephone numbers, for example, only the first four digits of the area code (for geographic assignment) are processed, and geographic location data are displayed artificially enlarged (only accurate to whole degrees, without decimal places, so that only an approximate region is recorded) — this makes it almost impossible to draw conclusions about individual persons.