Privacy Policy App

Privacy Policy for the 21energy Smartphone Application

Effective Date: April 15th, 2025

This Privacy Policy outlines how 21energy GmbH ("we", "us", "our") collects, processes, and protects personal data when users interact with the 21energy smartphone application ("App") to control and monitor 21energy hardware products, including "Ofen" and "Ofen Pro".

By using the App, you acknowledge and agree to the processing of your personal data in accordance with this policy.

1. Data We Collect and Process

1.1. Application-Level Data

We store device-related data in our database, including:

  • Device Type: (e.g., "MOBILE", "CONTROL")
  • Bonding Token: Unique identifier for authentication
  • Connection Status: Whether the device is connected
  • Timestamps: Creation and update timestamps
  • Device-Specific Information: API version, hardware ID (hWId), order number, and announcements (where applicable)

1.2. Cluster-Level Data (Volatile Connection Data)

We temporarily store connection data for system functionality and debugging:

  • IP Address
  • Timestamp of Connection
  • Service Logs: Requests made to the App backend

1.3. Cloudflare-Level Data

To ensure security and mitigate risks (e.g., DoS attacks), we utilize Cloudflare as a proxy. Cloudflare processes and logs:

  • IP Address
  • User-Agent String
  • Metadata required for Cloudflare services

Cloudflare’s data processing is subject to their own Privacy Policy, which you can review at: https://21energy.com/pages/privacy-policy-app

1.4. Support-Level Data

When the Support Mode is activated, we may collect:

  • Customer IP Address
  • Remote Access Logs (SSH): Includes diagnostic information stored on connected "21control" and "bosminer" devices

1.5. Website Data Collection

Data collected through our website, including APIs (e.g., calculator-api), is handled separately. For further details, please refer to our general privacy policy at: https://21energy.com/pages/privacy-policy-app

2. Legal Basis for Processing

We process personal data based on:

  • Performance of Contract (Art. 6(1)(b) GDPR): Required for App functionality
  • Legitimate Interests (Art. 6(1)(f) GDPR): System security, fraud prevention, and debugging
  • Consent (Art. 6(1)(a) GDPR): Where applicable, such as for support mode activation

3. Data Sharing and Storage

  • We do not sell or share personal data with third parties for advertising.
  • Connection data is stored temporarily and is deleted after system-relevant use.
  • Cloudflare processes data as an independent data controller under its own GDPR-compliant policies.

4. User Rights

As per GDPR, you have the right to:

  • Access: Request a copy of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Request deletion of data (subject to legal obligations)
  • Objection: Object to certain data processing activities
  • Data Portability: Receive data in a structured format

For exercising these rights, contact: privacy@21energy.com

5. Contact Information

For any privacy-related inquiries, you can reach us at:

21energy GmbH
Wilhelm-Greil-Straße 21
6020 Innsbruck
Austria

Email: support@21energy.com

6. Changes to This Policy

We may update this policy as needed. The latest version will always be available within the App and at: https://21energy.com/pages/privacy-policy-app

By using the App, you confirm your acceptance of this Privacy Policy.