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Data Privacy Statement

Ministry of Internally Displaced Persons from Occupied Territories, Labor, Health and Social Affairs of Georgia

March 24th, 2020


Ministry of Internally Displaced Persons from Occupied Territories, Labor, Health and Social Affairs of Georgia (“Ministry” or "we")  as the responsible (“controller”) for data protection is committed to the sensitive handling and active protection of user data as well as transparent information for users, especially in the areas of data collection and use.

This data protection declaration explains which data we collect within the scope of using the Stop Covid App and for what purpose we process and store it.

In order to technically cover data protection as good as possible, we encrypt the data collected by the App on your smartphone and also rely on encrypted transmission to our server infrastructure.

In any case, it has to be considered that the Stop Covid App cannot work without collecting and processing of the data mentioned below.

Should you wish to delete your account at a later date, you can do so at any time by deleting the app. This does not apply to historical information, this information is still available to us on the basis of our legitimate interests, in pseudonymized form, and will be deleted after a maximum of 3 years. For further information on the storage periods, please refer to the respective processing purpose.

You can request information about the data stored about your person at any time. In addition, under certain circumstances you may request the correction or deletion of your data. You may also have the right to limit the processing of your data, to object to it and to have the data provided by you given back in a structured, common and machine-readable format.

If you have any questions, please contact our data protection officer at:

Ministry of Internally Displaced Persons from Occupied Territories, Labor, Health and Social Affairs of Georgia

Mikheil Janiashvili
144 Tsereteli av., 0159 Tbilisi, Georgia
info@moh.gov.ge

In addition, you have the option of using your right to appeal to a supervisory authority (e.g.: State Inspector Service).


Processing purposes

Registration, contract management

No registration is needed to use the App. We will generate an anonymous User-ID to identify you within our system.

Warning in case of infection risk

The use case of the App is to recognize and evaluate your encounters with other app users. It is meant to warn users if they have been in contact with a COVID-19 infected person. For this purpose, we collect, process and store locally on your device the following data to fulfill the contract

which is generated or provided by your smartphone. Should you report to being infected yourself, your encounters with other users will be uploaded to our servers. You can voluntarily submit your location information which will help to better fight contagious diseases. The data will be stored for the duration of the contract and for a maximum of 3 years beyond, for supporting our research.

Communication, customer journeys

We will contact you via push messages without separate consent within the framework of contract fulfillment.
For this purpose, we collect, process and store the following data:

We will share the data with our technology provider NOVID20 - Technologieplattform zum Krisenmanagement (NGO), Austria. They will act as our external service provider and will will process the data in raw or processed form as required for:

In the future, we will implement a feature that enables international interoperability with applications of the same purpose for cross-border analysis and data modeling. This will help fight COVID-19 on a global scale. For these purposes, NOVID20 will operate under their own responsibility. However, this will only happen once you explicitly consented to it in the app. You can find NOVID20’s privacy policy here.

In order to send messages and analyse data we make use of external service providers:

Dolphin Technologies GmbH - "Dolphin", Austria
all data collected by us, in raw or processed form as required for analysis and data modeling, creation of customized communication and the subsequent dispatch of these messages

Peaberry Software Inc. - "Customer.io", USA
all data collected by us, in raw or processed form as required for the creation of customized communication and the subsequent dispatch of these messages

The data will be stored for the duration of the contract and for a maximum of 3 years beyond. 

The respective service provider lists the data that we have to transfer in order to achieve the purpose. Service providers located in the USA are subject to the rules of the EU-US Privacy Shield Agreement for the protection of personal data.

Service expansion and improvement

The purpose of the feature is to increase public safety. Achieving this goal is not limited to collecting the IDs of other users you have been in contact with, but can also include other information, like past geolocations. For this reason, we may use all collected data (location data, Bluetooth data, etc.) in our legitimate interest to create and store models for service enhancement and improvement. The data is stored for the duration of the contract and for a maximum of 3 years beyond, so that we can continuously improve our service. 

Usage optimization, customer service

We try to ensure that our services function optimally at all times, but unfortunately, we do not always succeed in doing so in every constellation. In order to continuously improve the user experience of the App and to be able to optimally respond to possible requests from you, we collect, process and store data regarding the use of the App in our legitimate interest:

Data is stored for the duration of the contract and for a maximum of 3 years in order to improve our service on an ongoing basis.

Optimization of our services

Firebase Services

We use Google Firebase to improve the performance and usability of our services and measure the effectiveness of our communication efforts. We do not share any personal information with service providers (i.e., we transmit the information pseudonymously), but we do share information such as your advertising ID, which is linked to your personal information by the service provider to enable our evaluations. We do this in our legitimate interest to determine whether our communication efforts are successful and to obtain information about the use of our app to improve performance and usability. The data is stored for the duration of the contract and for a maximum of 18 months beyond that, in order to be able to create our evaluations.

For this purpose we process:

In order to fulfil these tasks, we make use of the following external service providers:

Google LLC, USA
Google Ireland Limited, Ireland
for Firebase Services 

U.S.-based service providers are subject to the rules of the EU-US Privacy Shield Agreement for the protection of personal data.

Further information can be found at:

Google Firebase:
https://support.google.com/firebase/answer/6318039?hl=de&ref_topic=6317497
https://firebase.google.com/terms/analytics/
https://docs.fabric.io/apple/fabric/data-privacy.html 

You have the right to object at any time, for reasons related to your particular situation, to the processing of personal data concerning you carried out pursuant to Law of Georgia on Personal Data Protection. In the event of your objection, we will no longer process your personal data unless we can prove compelling and justified reasons for the processing which outweigh your interests, rights and freedoms. If you wish to file such an objection, please contact our data protection officer!

Statistical evaluations

We use the collected positioning and sensor data for evaluations and will publish or share these evaluations with partners in the context of publications, research work, reports etc. in such cases however exclusively in processed and anonymized form.

We protect your data, process it exclusively for the purposes stated and do not share it in any other way than stated here, unless we are forced to do so by legal requirements.