CCSchwarz GmbH, Drosselweg 7, 76774 Leimersheim, Germany
With this privacy policy, we, CCSchwarz GmbH, inform you, in accordance with Articles 13 and 14 of the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), about the processing of personal data in connection with the provision and distribution of our software applications DeliveryApp, SalesApp, and WarehouseApp (each an “Application”, together the “Applications”) and the associated customer portal at apps.ccschwarz.de.
A. Controller and Contact
The controller within the meaning of Article 4(7) GDPR is:
CCSchwarz GmbH
Drosselweg 7, 76774 Leimersheim, Germany
Email: info@ccschwarz.de
CCSchwarz GmbH has not appointed a company data protection officer, as the statutory requirements for doing so are not met. For all questions and concerns regarding data protection, please use the contact address above.
B. Who is Responsible for What? Delimitation of Processing
(1) The contracting party of CCSchwarz GmbH is the respective customer business (the “Customer”). The Applications are used by natural persons authorized to do so by the Customer, in particular the Customer’s employees (the “Users”).
(2) The Applications are not operated as cloud-based services. All operational data processed in the course of the actual use of an Application is processed exclusively locally on the end devices of the Customer or the Users and exchanged directly between the Application and the Customer’s own Abas ERP system, without CCSchwarz obtaining access to it or storing or processing this data on its own systems. The specific operational data concerned is described per Application in Section C.5.
(3) Accordingly, with respect to the operational data referred to in paragraph 2 above, it is not CCSchwarz but solely the Customer that is to be regarded as the controller under data protection law, in particular in relation to its Users as its employees. This privacy policy does not cover such operational data; for information in this regard, please contact your employer (the Customer).
(4) As controller within the meaning of Article 4(7) GDPR, CCSchwarz processes only the data described in Sections C.1 to C.4, which arises in connection with the initiation and performance of the contract with the Customer, device registration and license administration including license verification, and support for the Applications.
C. Categories of Data Processed, Purposes, and Legal Bases
1. Data Relating to the Customer Relationship and License Administration
In the course of initiating and performing the contract with the Customer, we process contact and point-of-contact data (e.g., name, email address, telephone number of the Customer’s contacts), contract and order data, and data for administering the licenses acquired (e.g., number and activation status of device licenses, license keys, components added). The legal basis for this is Article 6(1)(b) GDPR (performance of the contract or pre-contractual measures) and, where necessary, Article 6(1)(f) GDPR (legitimate interest in administering the business relationship).
2. Technical Data in Connection with Device Registration and License Verification
Licensing is per end device. To register an end device and to technically verify the validity of a license, the Application communicates with the customer portal operated by CCSchwarz. In this context, technical data is processed, in particular the device name assigned by the User in the operating system (which may contain a personal name), the device model, the operating system version, the Application version, the language and time zone set, a device identifier (device UUID), the license key, and the IP address, to the extent required for registration, configuration, and license verification. The Applications are downloaded, and any updates to them are provided, exclusively via the respective app stores (see Section C.4); CCSchwarz does not operate its own infrastructure for this purpose. The legal basis is Article 6(1)(b) GDPR (performance of the usage agreement) and Article 6(1)(f) GDPR (legitimate interest in preventing unlicensed use).
3. Support and Contact Inquiries
If you contact us by email (e.g., at support@ccschwarz.de), we process the data you provide (in particular your name, email address, and the content of your inquiry) in order to process and respond to your inquiry. Where an Application offers a function for composing a support email, that email is sent solely at your initiative via the email program of your end device and contains technical details about the Application (in particular the Application version, operating system version, device model, and language); no automatic sending takes place. The legal basis is Article 6(1)(b) GDPR, insofar as the inquiry relates to an existing or prospective contractual relationship, and otherwise Article 6(1)(f) GDPR (legitimate interest in responding to inquiries).
4. Provision of the Applications for Download
The Applications are offered for download exclusively via third-party app stores (e.g., Apple App Store, Google Play Store); they are not made available for download via any infrastructure operated by CCSchwarz itself. The respective app store operator processes, under its own responsibility, the data required for the download and payment process (e.g., account and payment data, device identifier). CCSchwarz has no influence over this processing; it takes place outside our area of responsibility. Please refer to the privacy policy of the respective app store operator for further information.
5. Product-Specific Information on Operational Data (Responsibility of the Customer)
The following information is provided for transparency as to which operational data the respective Application processes on the end device. In accordance with Section B, the Customer alone is responsible for this processing.
DeliveryApp: The DeliveryApp processes the end device’s location data for route planning as well as data documenting completed deliveries. If requested by the Customer, this data is synchronized with the Customer’s Abas ERP system and the document management system contained therein. The location-processing function is designed exclusively for route planning and is not intended as a tool for the Customer to monitor the performance or conduct of Users.
SalesApp: The SalesApp accesses customer, quotation, and order data in the Customer’s Abas ERP installation; no data is held outside the Abas ERP installation. Documents created are sent to end customers via the User’s email program set up on the end device; CCSchwarz is not involved in this transmission.
WarehouseApp: The WarehouseApp processes item, storage location, batch, quantity, and posting data from the Customer’s Abas ERP installation. The User’s Abas ERP user name and password are stored in the end device’s keychain and transmitted exclusively to the Customer’s Abas ERP installation. A local log of the most recently executed postings (a maximum of 200 entries) is stored on the end device. For each posting, a posting identifier formed from the last four characters of the device identifier and a timestamp is stored in the posting record in Abas ERP; it can be attributed to a registered end device but not directly to a person. The end device’s camera is used exclusively to read barcodes and the registration QR code; decoding takes place on the end device, and images are neither stored nor transmitted. No location data is processed.
None of the Applications uses analytics, crash reporting, or advertising SDKs.
D. Cookies and Local Storage
The Applications are software installed on the end device and not websites; they therefore do not set cookies in the technical sense applicable to websites. For their technical functioning (e.g., temporary storage of login status, settings, or configuration data from the customer portal), the Applications may store information locally on the end device. This locally stored information is not transmitted to CCSchwarz unless it is expressly the subject of the processing described in Section C.
On the customer portal at apps.ccschwarz.de, we use a technically necessary session cookie to maintain your login status and your selected language during your visit. This cookie is required for the operation of the customer portal. The legal basis for this is Section 25(2) No. 2 of the German Telecommunications and Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz, “TDDDG”) in conjunction with Article 6(1)(f) GDPR (legitimate interest in the functional operation of the portal). No cookies for analytics or marketing purposes, and no third-party cookies, are used on the customer portal.
E. Recipients and Processors
(1) For the operation of the customer portal (device registration, license verification, administration of customer accounts, and handling of support inquiries), we engage the following processor within the meaning of Article 28 GDPR:
- HostEurope GmbH, Cologne, Germany (hosting services).
(2) A data processing agreement pursuant to Article 28 GDPR is in place with this service provider. Processing takes place exclusively on servers located in Germany. No further sub-processors that would be relevant to data protection for the purposes of this privacy policy are engaged.
(3) No personal data is transferred to recipients outside the European Union or the European Economic Area.
(4) Personal data is disclosed to authorities only to the extent CCSchwarz is legally obliged to do so (Article 6(1)(c) GDPR).
F. Retention Period
(1) We store customer, device, and license administration data (Sections C.1 and C.2) for the duration of the contract term and beyond, to the extent and for as long as statutory retention obligations apply (e.g., under Section 257 of the German Commercial Code (Handelsgesetzbuch) or Section 147 of the German Fiscal Code (Abgabenordnung)), or to the extent further storage is necessary to assert, exercise, or defend legal claims.
(2) We delete data from support and contact inquiries (Section C.3) once the inquiry has been conclusively handled and no statutory retention obligations preclude deletion.
(3) The Customer is responsible for the retention period of the operational data described in Section C.5. According to the information provided by the Customer, the operational data of the DeliveryApp is deleted from the Application after synchronization with the Abas ERP system has taken place; the local posting log of the WarehouseApp is deleted when the Abas ERP installation is changed or the device registration is reset. For details, please contact your employer (the Customer).
G. Automated Decision-Making
CCSchwarz does not use automated decision-making, including profiling, within the meaning of Article 22 GDPR in relation to Users. Support functions of the Applications (e.g., route planning in the DeliveryApp or warnings before stock postings in the WarehouseApp) serve operational organization and do not make decisions with legal effect concerning Users.
H. Your Rights as a Data Subject
Subject to the applicable statutory requirements being met, you have the following rights vis-à-vis CCSchwarz as controller:
- Access to the personal data concerning you (Article 15 GDPR);
- Rectification of inaccurate data (Article 16 GDPR);
- Erasure of your data (Article 17 GDPR);
- Restriction of processing (Article 18 GDPR);
- Data portability (Article 20 GDPR);
- Objection to processing based on Article 6(1)(f) GDPR (Article 21 GDPR).
To exercise these rights, please use the contact address given in Section A.
You also have the right to lodge a complaint with a data protection supervisory authority (Article 77 GDPR), in particular the authority competent for the registered seat of CCSchwarz GmbH:
Landesdatenschutzbehörde (RLP) – the supreme supervisory authority for the
state of Rhineland-Palatinate
Postfach 30 40, 55020 Mainz, Germany
Phone: +49 6131 / 208-2449
Email: poststelle@datenschutz.rlp.de
I. No Data Protection Officer
CCSchwarz GmbH is not legally required to appoint a company data protection officer and has not appointed one. Please direct any data protection inquiries to the contact address given in Section A.
J. Changes to this Privacy Policy
We review this privacy policy on a regular basis and adapt it as necessary to reflect changes in the legal framework or changes to the Applications. The version current at the time of your access shall apply.
As of: September 2026