iCober Key app — privacy policy

Dit privacybeleid is voorlopig alleen in het Engels beschikbaar.

Who is responsible for your data

The app is provided by ICOBER Spółka z ograniczoną odpowiedzialnością, ul. Stradzewo 27, 73-200 Choszczno, KRS 0000967675, NIP 5941611508 ("iCober"). Privacy contact: office@icober.pl.

Different parties are responsible for different parts of the processing:

• iCober is the data controller for the functions the app performs on your phone: disposal history, statistics, settings and calculating your card number.
• The container system operator — the municipality or company that granted your access — is the data controller for the records in the readers and in the container system, for linking a card number to a specific person, and for the data processed in service mode. The operator is responsible for providing information about this processing — contact the organisation that granted your access.
• If the operator uses the iCober cloud, iCober processes the operator's data on its behalf as a processor, under an agreement with the operator.

In short

• The app needs no account. You do not enter your name, e-mail or phone number — in the app and in the reader you are a card number.
• The app does not make its own internet connections. Links (e.g. to this policy) open in your browser.
• Data leaves your phone over NFC to a container reader — your card number and, in service mode, also a list of card numbers — and when a technician personally shares an exported file. This is described below.
• App data is not included in backups and is not copied to a new phone when you transfer your data.

Your phone as a card

The app turns your phone into an access card for waste containers equipped with an iCober reader. Your number is the card identifier, calculated with a hash function from the Android system identifier. That identifier depends on the phone, the user profile on the phone and the app's signature. Uninstalling and reinstalling the same app does not change the number; a factory reset does, and a version of the app signed with a different key may change it too.

When you hold your phone to a reader, the app passes the card number to it over NFC. The phone and the reader verify each other cryptographically to reduce the risk of impersonation. The card number itself is sent without encryption. The reader checks your access and records the event: card number, time and decision (access granted or refused). In the ONLINE version, the reader sends events to the operator's cloud through its own modem — not through your phone.

The card number and the events may be personal data if they can be linked to a person — for example when the operator knows to whom it issued a given number. The app does not know such links. For the records in the readers and in the container system, contact the operator.

What the app stores on your phone

• Disposal history: date and time, waste type, the reader's decision and the access method (NFC). The app uses it to show your sorting statistics.
• Settings: your language and whether the tutorial has been shown.
• A cryptographic key for communication with the reader — in the protected Android key store.

This data does not leave your phone. Uninstalling the app deletes it.

Service mode (operator technicians only)

An operator's technician can use the app to:

• collect events from a lock — card numbers (no names), time, lid state, battery voltage and the lock identifier. In a lock without a network connection (OFFLINE), events are removed from the lock after collection;
• manage the lock's card list: enter a card number, send the list of numbers to the lock over NFC, import or export the list as a CSV file;
• read the lock's diagnostics.

Technicians and administrators are also just card numbers in the system. Collected events are stored on the technician's phone until they are deleted. Card lists are sent to the lock over NFC and are not stored on the phone permanently. The technician can export events or the card list to a file and share it through an app of their choice (e.g. e-mail). After exporting events, the app asks whether to delete them from the phone; a file passed on stays with its recipient. The operator is responsible for this data.

Purposes and legal bases

• Calculating the card number — why: the phone working as an access card; responsible: iCober; legal basis: Art. 6(1)(f) GDPR — legitimate interest: providing the service you ask for by installing the app.
• Disposal history and statistics — why: showing you your sorting history; responsible: iCober; legal basis: Art. 6(1)(f) GDPR — legitimate interest: giving you information about your disposals.
• Settings — why: remembering your language and the tutorial; responsible: iCober; legal basis: Art. 6(1)(f) GDPR — legitimate interest: ease of use.
• Card number passed to the reader, events — why: access control to containers; responsible: operator; legal basis: stated by the operator.
• Service-mode data — why: operating and servicing locks; responsible: operator; legal basis: stated by the operator.

Recipients

• The reader and the operator — the card number when you hold your phone to a reader.
• The lock — the card number list sent by a technician in service mode.
• A recipient chosen by the technician — files passed on in service mode.

iCober receives no data from the app. If you install the app from Google Play, the store follows Google's own privacy policy.

How long data is kept

• Disposal history and settings — on the phone until the app is uninstalled.
• Events collected in service mode — on the technician's phone until they are deleted after an export or until the app is uninstalled.
• The copy of an exported file in the app's cache — until the system clears it or the app is uninstalled.
• Files passed on by a technician — with the recipient, under the operator's rules.
• Records in the readers and in the container system — as stated by the operator.

Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability and to object to processing based on legitimate interest — to the extent provided by law and the legal basis of processing.

• Data on your phone is stored only on your phone — iCober has no access to it, so it cannot read or delete it remotely. You can see your history in the app (Statistics). You can delete all app data in Android settings (Apps → iCober Key → Storage → Clear data) or by uninstalling the app. Requests concerning your rights, including objection to processing for which iCober is responsible, can be sent to office@icober.pl — we will explain how to exercise them for data stored only on your phone.
• Records in the readers and in the container system — direct requests to the operator, who is responsible for that data.

Complaints

You have the right to lodge a complaint with a supervisory authority in an EU member state, in particular in the state of your habitual residence, place of work or place of the alleged infringement:

• in Poland — Prezes Urzędu Ochrony Danych Osobowych (uodo.gov.pl),
• in Croatia — Agencija za zaštitu osobnih podataka (azop.hr).

In Bosnia and Herzegovina, personal data protection is overseen by Agencija za zaštitu ličnih podataka u Bosni i Hercegovini (azlp.ba), under national law.

Providing data and automated decisions

You do not enter your name or contact details. Your card number is generated automatically on the phone and is needed for the app to work as an access card. In service mode, a technician can enter other users' card numbers. The app does not profile you. Access is granted or refused by the reader according to the permissions set by the operator; the operator is responsible for assessing such decisions.

Children

The app is not directed at children.

Changes

We will announce changes to this policy by updating it on this page together with the date of the update.