Privacy policy for apps in accordance with the General Data Protection Regulation (GDPR)

§ 1 General

We take the protection of your personal data very seriously and treat it confidentially and in accordance with the statutory data protection regulations and this Privacy Policy. This Privacy Policy applies to our mobile iPhone and Android apps (hereinafter referred to as the “APP”). It explains the nature, purpose and scope of data collection in connection with the use of the APP. Please note that data transmission over the Internet may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

(1) Controller

The controller responsible for data processing in connection with this APP is:

TRIXIE Heimtierbedarf GmbH & Co. KG
Industriestr. 32
24963 Tarp

Telephone: +49 4638 2109-100
Email: info@trixie.de

The “controller” is the entity that collects, processes or uses personal data (e.g. names, email addresses, etc.).

(2) Data Protection Officer

You can contact our Data Protection Officer at:

TRIXIE Heimtierbedarf GmbH & Co. KG – Data Protection Officer
Industriestraße 32
24963 Tarp

Telephone: +49 4638 2109-100
Email: dst@trixie.de

General retention period for personal data

Unless otherwise specified or stated in greater detail in this Privacy Policy, personal data collected by this APP will be stored only for as long as is necessary for the respective processing purposes or for as long as statutory retention obligations apply.
You may object to the processing or withdraw consent that you have given at any time. In such cases, your personal data will be deleted unless statutory retention obligations or other legal grounds prevent this.
The retention period is determined in particular according to the following criteria:

  • Support and contact enquiries: storage for up to 6 months after final processing
  • Contract-related data: storage for 6 to 10 years in accordance with commercial and tax-law requirements
  • Data in the user account: until you delete the account or request its deletion

After the relevant periods have expired or the purpose of processing no longer applies, the data will be routinely deleted.

(3) Legal basis for storing personal data

The processing of personal data is permitted only if there is a valid legal basis for processing such data. Where we process your data, this is generally done on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG, for the performance of a contract pursuant to Art. 6(1)(b) GDPR (e.g. when using in-app purchases or other paid APP functions), or on the basis of legitimate interests pursuant to Art. 6(1)(f) GDPR, which are always balanced against your interests (e.g. in connection with advertising measures). Where applicable, the relevant legal bases are specified separately in this Privacy Policy.

(4) Encryption

For security reasons and to protect the transmission of confidential content, such as enquiries that you send to us as the APP operator or communications between APP users, this APP uses transport encryption. This encryption prevents unauthorised third parties from reading the data that you transmit.

(5) Recipients

Recipients of your personal data may include IT service providers, analytics providers, hosting and cloud services, newsletter distribution providers and support service providers. A detailed list is provided in each case in connection with the processing activities described in this Privacy Policy.

(6) Changes to this Privacy Policy

We reserve the right to amend these data protection provisions at any time in compliance with the statutory requirements.

§ 2 Your Rights

The GDPR grants certain rights to data subjects whose personal data are processed by us. We would like to inform you about these rights here:

(1) Withdrawal of your consent to data processing

Many data processing operations are possible only with your consent. We will expressly obtain this consent from you before processing begins. You may withdraw this consent at any time with effect for the future. An informal notification by email to info@trixie.de is sufficient. The lawfulness of the data processing carried out up to the time of withdrawal remains unaffected by the withdrawal.

(2) Right to object (Art. 21 GDPR)

Objection on grounds relating to your particular situation (Art. 21(1) GDPR):
Where we process your personal data on the basis of Art. 6(1)(e) GDPR (task carried out in the public interest) or Art. 6(1)(f) GDPR (legitimate interests), you have the right to object at any time on grounds relating to your particular situation. This also applies to profiling based on those provisions.

Objection to direct marketing (Art. 21(2) GDPR):
If your personal data are processed for direct marketing purposes, you may object to such processing at any time. Once we receive your objection, your data will no longer be used for advertising purposes.

(3) Right to lodge a complaint with a supervisory authority

In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority. This right is without prejudice to any other administrative or judicial remedies. The supervisory authority responsible for us is:

Independent State Centre for Data Protection Schleswig-Holstein (ULD)

Address:
Independent State Centre for Data Protection Schleswig-Holstein (ULD)
Holstenstraße 98
24103 Kiel
Germany

Telephone: +49 431 988-1200
Email: mail@datenschutzzentrum.de
Website: https://www.datenschutzzentrum.de

(4) Access, erasure and rectification

You have the right at any time to obtain, free of charge, information about your stored personal data, their origin and recipients, and the purpose of the data processing, as well as the right to have such data rectified or erased. You can contact us at any time at the address provided in the legal notice regarding this or any other questions concerning personal data.

(5) Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time at the address provided in the legal notice. The right to restriction of processing applies in the following cases:

  • If you dispute the accuracy of the personal data stored by us, we generally require time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of erasure.
  • If we no longer need your personal data, but you require them for the establishment, exercise or defence of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, your interests and ours must be weighed against each other. Until it has been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data may – apart from being stored – be processed only with your consent for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest of the European Union or a Member State.

(6) Right to data portability

You have the right to receive data that we process automatically on the basis of your consent or in performance of a contract, or to have such data provided to a third party, in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will be carried out only where technically feasible.

(7) Profiling

No automated decision-making, including profiling, takes place.

§ 3 App Access Rights

To provide our services via the APP, we require certain access permissions to functions and data on your device. These are used exclusively to provide the respective APP functions.

Calendar

  • Read calendar events and confidential information
  • Add or change calendar events and send emails to guests without the owners’ knowledge

Location

  • Approximate location (network-based)
  • Precise location (GPS- and network-based)

Photos / media / files

  • Read USB storage contents
  • Modify or delete USB storage contents

Storage

  • Read USB storage contents
  • Modify or delete USB storage contents

Camera

  • Take pictures and record videos

Microphone

  • Record audio

Wi-Fi connection information

  • View Wi-Fi connections

Other

  • Retrieve data from the Internet
  • View network connections
  • Pair with Bluetooth devices
  • Access Bluetooth settings
  • Change network connectivity
  • Allow Wi-Fi multicast reception
  • Connect to and disconnect from Wi-Fi networks
  • Access all networks
  • Change audio settings
  • Run at startup
  • Control vibration
  • Prevent device from sleeping
  • Read Google service configuration

Bluetooth interaction

  • Access Bluetooth settings
  • Scan for and connect to devices

Access to device functions is required to ensure the functionality of the APP.

The processing of personal data in connection with these access permissions is based on:

  • your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG,
  • performance of a contract pursuant to Art. 6(1)(b) GDPR (where necessary),
  • or our legitimate interest pursuant to Art. 6(1)(f) GDPR (e.g., to optimise the user experience).

Consent is given via your device’s operating system when the respective function is accessed for the first time. You may withdraw or adjust the permissions at any time via your device’s system settings. Without these access permissions, certain APP functions may be available only to a limited extent.

§ 4 Collection of Personal Data in the Context of APP Usage

(1) General information

When you use our APP, we collect the following personal data from you:

  • First and last name
  • Email address
  • Date of birth (if provided voluntarily, for sending a birthday voucher by email)
  • Usage data
  • IP address
  • Metadata
  • Profile pictures
  • Device identifier

The processing of these personal data is necessary to ensure the functionality of the APP. The legal basis for this data processing is our legitimate interest within the meaning of Art. 6(1)(f) GDPR, your consent within the meaning of Art. 6(1)(a) GDPR and Section 25(1) TDDDG and – if a contract has been concluded – the performance of our contractual obligations (Art. 6(1)(b) GDPR).

Providing your date of birth is voluntary and is neither legally nor contractually required. Failure to provide it merely means that we cannot send you a birthday voucher.

(2) Enquiries within the APP, by email, telephone or fax

If you contact us (e.g. via the contact form within the APP, by email, telephone or fax), your enquiry, including all personal data arising from it (e.g. name, enquiry), will be stored and processed by us for the purpose of handling your request. These data are processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary in order to take steps prior to entering into a contract. In all other cases, processing is based on your consent (Art. 6(1)(a) GDPR) and/or our legitimate interests (Art. 6(1)(f) GDPR), as we have a legitimate interest in effectively processing enquiries addressed to us. Your data will be disclosed only within the scope of the statutory requirements, in particular in connection with processing on behalf of a controller pursuant to Art. 28 GDPR. The data you send us in a contact enquiry will remain with us until you request their erasure, withdraw your consent to their storage, or the purpose for storing the data no longer applies (e.g., after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected. We do not disclose your data without your consent.

The retention period for the data collected in this way is governed as follows:

Personal data are stored only for the required period and are deleted no later than when erasure is requested, provided that no statutory retention obligations prevent this. Enquiries within the APP, by email, telephone or fax, are generally deleted after no more than 6 months. Contract-related data may be retained for up to 10 years in accordance with commercial and tax-law regulations (Section 257 HGB, Section 147 AO).

§ 5 Data Analysis

When you access our APP, your behaviour may be statistically evaluated using certain analytics tools and analysed for advertising and market research purposes or to improve our services. When using such tools, we ensure compliance with statutory data protection provisions. Where external service providers (processors) are used, we ensure through appropriate contracts that the data processing complies with German and European data protection standards.

(1) Google Analytics Firebase

We use Google Analytics Firebase (hereinafter referred to as Google Firebase) to analyse user behaviour. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Firebase includes various functions that enable us to analyse your in-APP behaviour. For example, we can analyse your screen views, button presses, in-app purchases or the effectiveness of advertising measures. We can also determine which functions within our APP are used frequently or rarely. For these purposes, Google Firebase stores, among other things, the number and duration of sessions, operating systems, device models, region and a range of other data. A detailed overview of the data collected by Google Firebase is available at:

https://support.google.com/firebase/answer/6318039?hl=en

The use of Google Firebase may require your personal data to be transferred to the USA. The data transfer is based on the EU Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. Further information is available at:
https://firebase.google.com/support/privacy

Google Firebase is used to optimise this APP and improve our services. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. Where consent has been requested, Google Firebase is used on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent may be withdrawn at any time.

Further information about Google Firebase is available at:

https://firebase.google.com/

https://www.firebase.com/terms/privacy-policy.html

§ 6 Use of IoT Services

Our APP uses the IoT services of Tuya Inc., a provider of smart devices and platforms, to provide and control the functionality of connected devices. Personal data are processed in order to enable and optimise the use of the devices. The provider is Tuya Inc., 11F Building A, Huace Center, Hi-tech Zone, Binjiang District, Hangzhou, Zhejiang, China.

(1) General information

Data processed

The following data may be processed during use:

  • Device information (e.g. model, status, serial number),
  • User data (e.g., user ID, APP usage behaviour),
  • Connection data (e.g. IP address, network status),
  • Location data (if you enable this function).
  • Image information (live video streaming)
  • Audio information (e.g. voice recordings for feeding)

Audio and video data are processed exclusively with your express consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG. Consent may be withdrawn at any time.

(2) Purpose of data processing

Processing takes place to provide the functions of our APP and the connected devices. In addition, data may be used for analytics purposes and to improve the services.

(3) Legal basis

Data processing is carried out on the basis of:

  • Art. 6(1)(b) GDPR (necessary for the performance of a contract),
  • Art. 6(1)(f) GDPR (legitimate interest, e.g. to improve the services),
  • and your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG where image or audio data are concerned.

(4) Data transfers to third countries

Data are processed by Tuya via data centres distributed around the world. Depending on your region and device settings, processing may take place within the European Union (e.g., via servers in Germany or Ireland) or in third countries (e.g., China or the USA).

Where processing takes place in a third country outside the EU that does not provide an adequate level of data protection within the meaning of the GDPR, the transfer is based on the EU Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. These are intended to ensure an adequate level of protection. A copy of these safeguards can be provided on request.

§ 7 Supplementary Information under the EU Data Act

(1) Scope

In addition to the requirements of the GDPR, we inform you, pursuant to Regulation (EU) 2023/2854 (“Data Act”), about the data generated through the use of our smart products in conjunction with the APP.

(2) Types of data generated

Device operating and status data:

  • Feeding times and schedules (automatic & manual)
  • Fill level, status indicators for the food compartment, number of feedings
  • Motor and flap status, blockage detection, error messages
  • Motion alerts
  • Camera live stream, video and image recordings
  • Audio streams (from and to the device)

APP usage data:

  • Control commands via the APP
  • Login times
  • Interactions in the APP

Personal data associated with your user account:

  • User ID
  • Account information

(3) Access to the data

As a user, you have the right at any time to access the data generated by the device and the APP.

The data are available through your user account in the APP and, on request, in a commonly used, machine-readable format (e.g. JSON, CSV).

(4) Disclosure to third parties

You may request at any time that the data be transferred to a third party designated by you.

The transfer will take place without undue delay, free of charge or on fair, reasonable and non-discriminatory terms (FRAND).

(5) Retention period

  • Device data: until deleted by the user,
  • Cloud/APP data: until deleted by the user

unless statutory retention obligations prevent this.

(6) Restrictions

The disclosure of data may be refused if the transfer would jeopardise trade secrets, security interests or the protection of personal data. In this case, we will document the decision and inform you.

(7) Product-specific information about our smart products is available at www.trixie.shop.

§ 8 Newsletter

If you subscribe to our newsletter, we will use your email address to send you regular information about our products, offers and services.

The newsletter is sent exclusively on the basis of your express consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG.

We use the double opt-in procedure for newsletter subscriptions. This means that after subscribing, you will receive an email asking you to confirm your subscription. The subscription becomes effective only after this confirmation.

You may withdraw your consent to the processing of your data for newsletter distribution at any time. Each newsletter email contains an appropriate unsubscribe link for this purpose. Alternatively, you may also send your withdrawal to us by email. The lawfulness of the processing carried out up to the time of withdrawal remains unaffected.

Last updated: December 2025