Privacy Policy

Last Updated: January 2025

1. Data Controller

2. Data Protection Officer

Currently, no external data protection officer is appointed. For questions regarding data protection, please contact the Board of Directors using the contact information above.

3. Purpose and Legal Basis for Data Processing

a) Registration and Account Management

When you register for the HONSEN Club app, we collect and store the following personal data:

• First and last name
• Email address
• Username (generated from first and last name)
• Password (encrypted)
• Verification code (temporary)
• Profile picture (optional)
• Device token for push notifications (iOS Device Token)

This data is necessary for membership management, internal communication, and club-related purposes such as invitations, voting, and using app features.

Legal Basis: Art. 6 para. 1 lit. b GDPR (contract performance)
Retention Period: Data is deleted upon termination of membership or app account deletion, unless legal retention obligations apply.

b) Chat and Communication Data

For the chat functionality of the app, we process:

• Chat messages (text content)
• Message timestamps
• Group chat information (group name, participants)
• Read receipts
• User blocks between users

Legal Basis: Art. 6 para. 1 lit. b GDPR (contract performance)
Retention Period: Messages are stored for the duration of membership. Users can delete their own messages at any time.

c) Feedback and Support Data

When you submit feedback or support requests, we collect:

• Feedback text
• Images (if uploaded)
• Category (flight feedback, lounge feedback, general feedback)
• Timestamp

Legal Basis: Art. 6 para. 1 lit. f GDPR (legitimate interest)
Retention Period: Feedback is retained for improvement purposes and deleted after 3 years.

d) Event Data

For club events and activities, we process:

• Event participation status
• Event preferences
• Location data (if provided)

Legal Basis: Art. 6 para. 1 lit. b GDPR (contract performance)
Retention Period: Event data is deleted 1 year after the event date.

4. Data Recipients

Your personal data is only shared with:

• Other club members (name, profile picture, messages in group chats)
• Board members (for administrative purposes)
• Technical service providers (hosting, email services) - under strict data processing agreements
• Apple Inc. (for push notification services)

5. International Data Transfers

Push notifications are processed by Apple Inc. in the United States. This transfer is based on Apple's compliance with privacy frameworks and our legitimate interest in providing app notifications.

6. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security audits
• Secure hosting infrastructure
• Password encryption using bcrypt

7. Your Rights

Under GDPR, you have the following rights:

• Access: Request information about your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data
• Restriction: Limit processing of your data
• Portability: Receive your data in a structured format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent

To exercise these rights, contact us at kontakt@honsenclub.com.

8. Data Retention

We retain your data only as long as necessary for the purposes outlined in this policy:

• Account data: Until membership termination
• Chat messages: Until user deletion or account termination
• Feedback: 3 years after submission
• Event data: 1 year after event date
• Logs: 6 months

9. Cookies and Tracking

Our app uses minimal tracking technologies. We do not use advertising cookies or third-party tracking. Only essential cookies for app functionality are used.

10. Children's Privacy

The HONSEN Club app is not intended for users under 16 years of age. We do not knowingly collect personal data from children under 16.

11. Changes to this Privacy Policy

We may update this privacy policy from time to time. Users will be notified of material changes through the app or by email.

12. Contact and Complaints

For privacy-related questions or complaints, contact us at kontakt@honsenclub.com.

You also have the right to lodge a complaint with the competent data protection authority in your jurisdiction.

Last updated: January 2024