This privacy notice explains how your data is processed and what data protection rights you have when using Corona Contact Tracing Germany.

It covers the following topics:

1. 1. Who is Corona Contact Tracing Germany published by?
2. 2. Is using the app voluntary?
3. 3. On what legal basis is your data processed?
4. 4. Who is the app aimed at?
5. 5. What data is processed?
6. 6. Why is your data processed?
7. 7. How does the transnational warning system work?
8. 8. What permissions does the app require?
9. 9. When will your data be deleted?
10. 10. Who will receive your data?
11. 11. Is your data transferred to countries outside the EU?
12. 12. How can you withdraw your consent?
13. 13. What other rights do you have under data protection law?
14. 14. Data protection officer and contact

To make sure that this text can be understood by all users, we have made every effort to make it simple and as non-technical as possible.

## 1. Who is Corona Contact Tracing Germany published by?

This app is published by a team of volunteers based on Corona-Warn-App (CWA) from Robert Koch Institute (RKI), which publishes CWA for the German Federal Government. As this app behaves mostly identical to CWA regarding data processing the RKI is also responsible for ensuring that your personal data is processed in accordance with data protection regulations. Differences have been noted in section 5.b) "COVID-19 Exposure Notification System". This app ships it's own implementation of this and doesn't rely on the implementation by Google shipping with Google Play Services.

If, after testing positive for coronavirus, you use the app’s transnational warning feature, it is also possible to warn users of official coronavirus apps of other countries whom you have encountered. In this case, the RKI and the competent health authorities of the countries participating in the respective transnational warning systems are so-called joint controllers, meaning they are jointly responsible for data processing. Please refer to Section 7 for more details.

## 2. Is using the app voluntary?

Using the app is voluntary. It is entirely up to you whether you install the app, which of the app’s features you use, and whether you share data with others. As a matter of principle, all of the app’s main features that require the transfer of your personal data to the RKI or to other users will obtain your express consent in advance. In the context of the official digital COVID certificates (COVID test certificate and COVID vaccination certificate), new legal requirements apply to the creation of the certificates. For this reason, no additional consent is required in this context. However, the certificates will only be created if you wish for this to happen. Requesting and using digital COVID certificates is voluntary.

If you do not give your consent, if you subsequently withdraw it, or if you do not request any digital COVID certificates, this will not result in any disadvantages for you.

## 3. On what legal basis is your data processed?

As a matter of principle, the RKI will only process your data for the purposes of exposure logging and warning others if you have given your express consent beforehand. The legal basis is Art. 6(1) Sentence 1(a) GDPR and, in the case of health data, Art. 9(2)(a) GDPR. After giving your consent, you can withdraw it at any time (so-called right of withdrawal). Please refer to Section 12 for further information about your right of withdrawal.

In the context of the official digital COVID certificates (COVID test certificate and COVID vaccination certificate), data processing is regulated by law. The creation and confirmation of vaccination certificates is based on Art. 9(2)(g) GDPR in conjunction with Sect. 22(5) of the Infection Protection Act (IfSG). The creation and confirmation of test certificates is based on Art. 9(2)(g) GDPR in conjunction with Sect. 22(7) IfSG.

On the basis of Art. 6(1) Sentence 1(e) GDPR in conjunction with Sect. 3 of the German Federal Data Protection Act (BDSG), the processing of access data for the provision of daily statistics (see Section 6 f.) is performed as part of the RKI’s duty to inform the public pursuant to Sect. 4(4) of the Act on Successor Agencies to the Federal Health Agency (BGA-NachfG).

## 4. Who is the app aimed at?

The app is aimed at people who are resident in Germany or another participating country and at least 16 years old.

## 5. What data is processed?

The app’s entire system has been programmed to process as little personal data as possible. This means that, when you use exposure logging, warn other users, or retrieve a test result, the system does not need to collect any data that would allow the RKI or other users to infer your identity, your name, your location or other personal details. The only exceptions to this are the feature for proving a rapid test result, which allows you to display a confirmation issued in your name for negative rapid test results (see Section 6 c.), and the feature for creating a rapid test profile, which allows you to provide a testing point with the data required to perform a rapid test (see Section 6 d.).

Exceptions apply to the feature for proving a rapid test result, which allows you to display a confirmation issued in your name for negative rapid test results (see Section 6 c.), the feature for creating a rapid test profile, which allows you to provide a testing point with the data required to perform a rapid test (see Section 6 d.) and if you add digital COVID certificates in the app.

The app refrains by default from using analysis tools to evaluate the way you use it. Only if you expressly record an error report and share it with the CCTG maintainers (see Sections 5 j.), will certain data about your use of the app be transmitted to the maintainers.

The data processed by the app can be grouped into the following categories:

### a. Access data

Every time the app exchanges data over the internet with the RKI’s server system (hereinafter referred to as the server system), the server system processes so-called access data. This is necessary so that the app can retrieve current data (e.g. for warnings) or transmit certain data stored on your smartphone to the server system. This access data includes the following:

- IP address
- Date and time of retrieval
- Transmitted data volume (or packet length)
- Notification of whether the data exchange was a success.

This access data is processed to maintain and secure the technical operation of the app and the server system. You will not be identified personally as a user of the app and no user profile will be created. Your IP address will not be stored beyond the end of the usage procedure.

In order to prevent unauthorised parties from using your IP address to associate your data with you when you use the app, the app only ever accesses the server system via a special access server. This access server then forwards the data requested or transmitted by the app to the appropriate server, but without your IP address, meaning that your IP address is no longer processed within the server system.

### b. Exposure data

As soon as you enable your the COVID-19 Exposure Notification system via the app, your smartphone transmits so-called exposure data via Bluetooth, which other smartphones in your vicinity can record. Your smartphone, in turn, also receives the exposure data of other smartphones. The exposure data transmitted by your smartphone comprises:

- Random identification numbers (hereinafter referred to as random IDs)
- Bluetooth protocol version
- Bluetooth transmit power in decibel-milliwatts (dBm).

If exposure to another smartphone is recorded, the exposure data also includes:

- Day, time and duration of the contact
- Bluetooth signal strength in dBm.

The random IDs are changed regularly. This helps prevent your smartphone from being identified using these random IDs. The exposure data transmitted by your smartphone and the exposure data recorded when you come into contact with other app users are stored on your smartphone and deleted after 14 days. The exposure data transmitted by your smartphone is processed in the same way when it is recorded by the smartphones of other app users.

Please note that the COVID-19 Exposure Notification System works in one of two modes: If microG is installed in your System, this installation will be used for Exposure Notifications. The random IDs will be stored by microG and can be deleted through the microG settings. If microG isn't installed, the Exposure Notifications implementation that ships within this app will be used instead. The random IDs will be collected and saved by this app and deleted when it's uninstalled.

- You can find out which of these two modes is used by checking the status in the App Information screen.
- Touching this status information will lead to more information about Exposure Notifications.

### c. Rapid test data

If you have taken rapid antigen tests at a testing point, you can retrieve the results of these through the app. If you choose to use this service, your testing point will generate an individual QR code for you to scan with the app. The QR code contains a unique code for your rapid test, and the time you were tested, in encoded form. If, in the event of a negative rapid test result, you wish to have the test result displayed along with your name in the app for verification purposes (see Section 6 c. for more information about this feature), the QR code will contain further data provided by you in encoded form.

### d. Rapid test profile

You can store information about yourself in your rapid test profile in the app. The rapid test profile includes the following fields: first name, last name, date of birth, street and house number, postcode, town, phone number, email address. The app then converts your data into your personal QR code, which contains all the data you have entered. Creating a rapid test profile in the app, and using it at a testing point, are voluntary. You decide yourself which data you enter in your rapid test profile. The QR code only contains this data. If the testing point requires more information that is not contained in the QR code, you can also provide this to the testing point in another way.

### e. Event data

If you visit an event (such as a party or concert) or a place (such as a shop or restaurant), you can record your stay there in the app. Event organisers and business owners can provide guests with a QR code for this purpose.

As a guest, you can “check in” when you arrive by simply scanning this QR code with the app. When leaving the event or place, you can “check out” again in the app. The app then remembers that you were at that event or place, and when you were there. If a guest later tests positive for coronavirus and activates the warning feature via their app, then all other guests who were checked in at the same time will receive a warning.

If you scan a QR code as a guest, the event details provided by the host (name of the event/place, address/location, typical length of stay and, if applicable, the time when the event started) as well as the check-in time will be stored on your smartphone. In addition, your app will derive an encrypted identifier (hereinafter referred to as the event ID) that can be uniquely assigned to the event based on the information contained in the QR code. No conclusions about the event or the place can be drawn from the event ID. When you check out in the app or are automatically checked out after the time preset by the host, the check-out time will be stored on your smartphone.

An entry will also be created in your contact journal by default. Sections 5 g. and 6 g. explain this in more detail. If you do not want to create an entry in your contact journal for an event or place, you can simply switch off this feature using the corresponding toggle switch.

If you as a host create a QR code for your guests, the event details you provide and a random code will be stored in the QR code. The random code ensures that different places and events for which the same event details have been entered will later have different event IDs. The QR codes you create are stored on your smartphone. Under “My QR codes”, you can delete the QR codes you have created at any time.

Using the event check-in feature is voluntary. You decide yourself whether you want to create a QR code for your event or place, and whether to check in at an event or place.

Under “My check-ins”, you can check and delete your previous check-ins and also adjust the check-out time.

### f. Health data

Health data is any data containing information about a person’s health. This includes not only information about past and current illnesses, but also about a person’s risk of illness (such as the risk that a person has been infected with coronavirus). The app processes health data in the following cases:

- When a possible exposure is identified
- If you use the app to retrieve a test result
- If you use the app to warn other users and guests from events or places you visited at the same time that they may be infected
- If you provide information about the onset of any coronavirus symptoms or
- If you add digital COVID certificates (vaccination certificates or test certificates) in the app.

Section 6 explains this in more detail.

### g. Entries in the contact journal

If you use the contact journal to note when and where you met certain people and record certain details of the encounter or contact details for people and places, this information is stored on your smartphone. The contact journal entries are only there to help you remember. The RKI and other agencies cannot gain access to entries in the contact journal. The contact journal can help you to keep track of your personal contacts over the last 14 days. If you test positive for coronavirus and the public health office (Gesundheitsamt) requests your assistance with contact tracing, then you can quickly provide the information it needs.

Using the contact journal is voluntary. You personally decide whether to store entries in the contact journal. In this respect, you are also responsible for what you record. For this reason, we kindly ask you to respect the privacy of the people you include in your contact journal. You should not share your entries with third parties or via insecure communication channels. The competent public health office will tell you what information it needs from you for contact tracing purposes, and how you can provide it.

### h. Data about your COVID vaccination (data in the COVID vaccination certificate)

In the app, it is possible to add your official vaccination certificates (digital COVID certificates) that you received when you were vaccinated. Requesting a digital vaccination certificate is voluntary. If you choose to use this service, you will receive a printout with a QR code at the time of your vaccination. This will contain the following data about your COVID vaccination in encoded form:

- Personal data (last name, first name, date of birth)
- Information about the vaccine (disease, vaccine, product, manufacturer)
- Vaccination information (dose number, total doses, date of vaccination, country, issuer)
- Unique certificate identifier.

The data will be stored in the app as soon as you scan the QR code for the digital vaccination certificate. This data will have been collected previously at the time of your vaccination.

### i. Data in the COVID test certificate

You request official test certificates (digital COVID test certificates) through the app. Requesting a digital test certificate is voluntary and only possible if a negative test result is available. You will then receive your test certificate with a QR code in the app. This contains the following data about your test result:

- Personal data (last name, first name, date of birth)
- Information about the test (disease, type of test, product, manufacturer)
- Information about the testing procedure (date and time of the test, location of the testing centre)
- Test result
- Unique test certificate identifier.

The data is stored in the app as soon as your test result is available.

### j. Contents of the error reports

To assist the app’s technical support team with error analysis, you can record an error report in the app. When you start recording the error report, a comprehensive record is made of

- the steps you take in the app,
- the technical steps and processes as well as status messages involving
  - exposure logging (e.g. involving the functioning of the processing of exposure data, the calculation of the risk of infection, the updating of the positive lists, the display of the calculated risk status),
  - the retrieval and display of test results, and
  - possible processes for warning others (e.g. the calculation of transmission risk values and the technical provision of your random IDs by your smartphone)

and stored on your smartphone. The error report may also contain health data, because the technical steps and processes related to the detection of a possible exposure are also recorded.

However, the error report does not contain information about QR codes for test registration, the token stored in your app (see “Retrieving a test result” in Section 6 b. below), rapid test results, digital COVID vaccination and test certificates and entries in your contact journal. Furthermore, the error report does not contain your name or other information with which the RKI can identify you.

You can stop recording the error report and delete the error report at any time. Creating and sharing an error report is voluntary. You decide yourself whether you want to record an error report and send it to the app’s mainrtainers.

## 6. Why is your data processed?

### a.

Exposure logging is part of the app’s main functionality. It serves to warn you of possible exposure to people who have tested positive for coronavirus (“possible exposures”) in a number of different countries, to assess the risk that you have been infected as a result of the exposure, and to provide you with health advice and recommendations for what to do next.

For this purpose, the app retrieves an up-to-date positive list from the server system several times a day. This list contains information from users who have used the warning feature in an official coronavirus app (see Section 7). This positive list contains the random IDs of users who have activated the warning feature and, if applicable, information about the onset of symptoms. If the users who have activated the warning feature were checked in at events, the positive list also contains the relevant event IDs and the duration of the check-ins (check-in and check-out times).

The random IDs and event IDs on the positive lists also contain a transmission risk value and an indication of the type of diagnosis (see Section 6 e.).

The app passes the random IDs from the positive list to the COVID-19 exposure notification system, which compares them with the random IDs it has recorded from your encounters with other users. If the COVID-19 exposure notification system detects a match, it transfers to the app the exposure data recorded for the possible exposure in question.

Similarly, the app matches event IDs from the positive list with the event IDs from your check-ins to determine whether you were at an event or place at the same time as users who have tested positive for coronavirus.

The app evaluates this exposure data, event IDs (including the associated check-in and check-out times) as well as the information on the positive lists (transmission risk value; information about the onset of symptoms) in order to determine your risk of infection. The rules for evaluating this information (for example, how the duration of a contact influences the risk of infection) are based on the RKI’s latest scientific findings. In the event of new findings, the RKI can update the evaluation rules by adjusting the evaluation settings in the app. In this case, the new evaluation settings are sent to the app together with the positive lists.

The risk of infection is calculated exclusively offline in the app and is not passed on to the COVID-19 exposure notification system or any other recipient (including the RKI, other health authorities in Germany or other countries, Apple, Google and other third parties).

If a risk of infection is identified for you, this will be displayed in the app. If an elevated risk is displayed, this means that you encountered one or more other users who later tested positive for coronavirus and used the warning feature in their app, or that such users were checked in at an event or place at the same time as you.

The risk calculated for each of the last 14 days is displayed in the calendar view of the contact journal. Please refrain from drawing false conclusions about the source of any risk: a risk calculated and displayed for a certain day may well be due to your having encountered users unknown to you without realising it, and will not necessarily have anything to do with the people, places or events you recorded in the contact journal.

### b. Retrieving a test result

If you have taken a coronavirus test (PCR test or rapid antigen test), you can retrieve your test result via the app. The app will notify you as soon as your test result is available. For this to work, the testing facility (e.g. testing laboratory or testing point) needs to be connected to the server system and, as part of the testing procedure, you must have given separate consent to your test result being sent. It is not possible to display test results from testing facilities that are not connected to the app’s server system. If you have not received a QR code, then you cannot use this feature either.

The test results are also stored in your contact journal. You can delete them there at any time

Scanning the QR code

In order to retrieve your test result via the app, you will need to scan the QR code using your smartphone’s camera. The QR code contains a code number that is read during scanning and is assigned to your test. If the test is a rapid antigen test, then the QR code will also contain the rapid test data described in Section 5 c. After reading the code number, the app ‘hashes’ it. This means that the app performs a certain mathematical procedure in order to convert the code number in such a way that it can no longer be identified. However, it is still possible to clearly assign the hashed code number to your test result. As soon as your smartphone is connected to the internet, the app will transmit the hashed code number to the server system. The server system then provides a digital access key (a so-called token), which is stored in the app. The token is linked to the hashed code number in the server system. The app now deletes the code number that has been hashed on your smartphone and keeps only the token. Once the QR code has been used in this way, it becomes invalid and can no longer be used by anyone. This ensures that no other users can use your QR code to retrieve your test result.

Filing of the test result

As soon as your test result is available, the testing facility stores it in the RKI’s test result database using only the hashed code number. The test result database is located on a special server within the server system. The testing facility generates the hashed code number based on the same QR code that you received.

Retrieval of the test result

Using the token stored in the app, the app regularly requests the status of your test from the server system. The server system then informs the app of the current status (result not yet available / result available). As soon as your test result is available, the outcome (i.e. whether you have tested positive or negative for coronavirus) is also transmitted to the app. If you have enabled the test status notification (under “Settings” > “Notifications”), you will be notified. The test result will not be displayed until you open the app.

If you have tested positive for coronavirus, the app uses the token again to request a TAN (transaction number) from the server system. The TAN is required to ensure that no false warnings are transmitted to other users. For this purpose, the server system reassigns the token to the hashed code number and requests confirmation from the test result database that a positive test result really does exist for the hashed code number. If this is confirmed, the server system generates the TAN and transmits it to the app. A copy of the TAN remains on the server system.

### c. Proof of a rapid test result

If you retrieve the result of a rapid antigen test and, when you were at the testing facility, you selected the option to have your name displayed in the event of a negative test result, then a negative result will be displayed along with your name, date of birth and the time you were tested. To do this, the app uses the corresponding rapid test data which it reads when scanning the QR code. The rapid test data will be deleted as soon as the negative rapid test result is no longer displayed in the app.

If necessary, you can show the test result displayed in the app to prove to third parties that you took a rapid test and the result of that test was negative. Please find out about applicable requirements for the recognition of digital test certificates where you are located. Please note:

- The RKI cannot guarantee that a rapid test result displayed in the app will be recognised by the competent authorities and other authorised bodies that may or must require you to provide proof of testing (e.g. shops, employers).
- You are not obliged to use the app’s certification feature. If you have to prove your test result to third parties, you can also present the proof in another form subject to the legal requirements (which may vary depending on the federal state).

Your name will not be displayed if you retrieve a positive rapid test result. In this case, your name and date of birth will be immediately deleted from the app memory. Your other rapid test data (code, time you were tested) will be deleted as soon as the positive rapid test result is no longer displayed in the app.

The rapid test results are also stored in your contact journal. You can delete them there at any time.

### d. Rapid test profile

The rapid test profile feature offers you the possibility to speed up data collection at participating testing points. To do this, you can store information about yourself in your rapid test profile in the app and convert it into your personal QR code, which contains all the data you have entered. At the testing point, you can present your rapid test profile’s QR code in your app so that it can be scanned by testing point staff, allowing the data you have provided to be read. This is a quick and secure way for you to provide the data required to perform a rapid test. You decide yourself which data you include in your rapid test profile and whether to present it at testing points. If the testing point requires information that is not contained in the QR code, you can provide the information to the testing point in another way.

### e. Warning others

If you have tested positive for coronavirus and share your random IDs with the app, then it is possible to warn other users whom you have encountered. In addition, users who were checked in at the same events or places at the same time as you will be warned. In this case, the app transmits the following data to the server system:

- Your own random IDs from the last 14 days
- The event IDs of events or places where you have checked in during the last 14 days, including the recorded check-in and check-out times
- Any information about the onset of symptoms
- Your TAN (see Section 6 b.).

Before passing on your test result (more precisely: before transmitting your random IDs and event IDs, including the recorded check-in and check-out times) to the server system, the app adds a transmission risk value to the data and also specifies the type of test performed. The transmission risk value is an estimate of how infectious you were on each day of the 14-day period. Since how infectious a person is or was depends on the duration and course of the infection, it can be taken into account, for example, that the more time has passed since the onset of symptoms, the lower the risk of a person spreading the virus on the day of a possible exposure. These additional transmission risk values allow a more precise determination of the likelihood that you have infected other users.

The information requested by the app about the onset of symptoms is optional. However, this information may help to calculate the transmission risk value even more accurately. If you do not provide information about your symptoms, then the transmission risk values will be calculated assuming a typical case of infection with coronavirus, i.e. the more time has passed since a random ID was used, the lower the associated transmission risk value.

If you have not retrieved your test result in the app:

In the event of a positive rapid antigen test result, you can only warn other people if you retrieved the test result in the app.

In the event of a positive PCR test result, on the other hand, you can warn others even if you received the test result outside the app. To do this, select the “Request TAN” procedure. The app will then prompt you to call the app hotline. A hotline worker will then ask you a few questions to make sure that you really have tested positive for coronavirus. This is to prevent false warnings being transmitted, either by accident or intentionally. Once you have answered these questions sufficiently, you will be asked for your mobile/telephone number and your name. This is so that you can be called back later and given a unique TAN to enter in the app. Your mobile/telephone number and your name will be temporarily stored for this purpose only and deleted after an hour at the latest. Immediately after your call, the hotline worker will generate a unique TAN via a special access to the server system and then call you back to tell you this TAN. A TAN is only valid for one hour and will therefore be deleted no later than one hour after it has been passed on to you. After a valid TAN is entered in the app, it is transmitted to the server system. The TAN thus makes it possible to check that a positive test result really does exist and thus prevent false alarms. The app then receives a token from the server system, as it does after a valid QR code is scanned (see “Retrieving a test result” in Section 6 b. above).

Please note that in rare cases, if you use the warning feature, people you know personally who also use the app and then receive a warning, may infer that the warning came from you. This may be the case if a person whom you know had no contact with anyone except with you on the day for which the possible exposure is displayed.

### f. Using the app for information purposes only

The app automatically receives the daily statistics that appear in the app via the server system. This generates access data. Websites linked in the app, such as www.bundesregierung.de, are opened and displayed in your standard browser (Android smartphones) or within the app (iPhones). Which data is processed in this context depends on the respective providers of the websites accessed.

### g. Contact journal

The contact journal is an additional feature of the app. What you enter in the contact journal serves as a reminder for you, and can only be accessed by you. If you later test positive for coronavirus and the public health office (Gesundheitsamt) requires your assistance with contact tracing, then you can provide the information that it needs more quickly. If the app calculates an elevated risk for you for a particular day, then seeing this information may help you to warn the people you have had contact with early on. This will give your contacts the chance to decide whether to change their plans if necessary, i.e. to meet up with fewer people and thus reduce the risk of causing undetected infections.

### h. Digital vaccination certificate (COVID vaccination certificate)

The app allows you to save your vaccination certificates and keep them with you in digital form. If necessary, you can then use the app to prove that you have been fully vaccinated against coronavirus if required by law.

To add a vaccination certificate in the app, scan the QR code you received when you were vaccinated. The app will read the information about your vaccination from the QR code and store it in a secure area on your smartphone.

Fourteen days after receiving the last vaccination dose required, the home screen in the app will show that you are fully vaccinated. To prove this, you can show the QR code from your digital vaccination certificate, which will be displayed in the app. The official verification app can be used to scan this QR code and read the information about your COVID vaccination. The verification app will then show whether you are fully vaccinated. In addition, your name and date of birth will also be displayed so that the person verifying your vaccination status can check this information against your official identification document.

Please note that using the feature for saving your vaccination certificates in the app is voluntary. If you are required by law to prove that you have been vaccinated, then you can also do this in other ways.

Please note that the QR code from your digital vaccination certificate contains your COVID vaccination details. You should only show it if you wish to prove your vaccination status. Do not provide vaccination certificates or QR codes to anyone if you do not want the data to be read.

### i. Digital test certificate (COVID test certificate)

The app allows you to save your test certificates and keep them with you in digital form. If necessary, you can then use the app to prove that you have tested negative if required by law

You can request a test certificate in the app when you register a test. To do this, scan the QR code you received during the test. The app will read the information about your test from the QR code and receive the test result from the server. If you have taken a PCR test, retrieving the result and the test certificate is additionally secured by means of your date of birth. A security code is generated from your date of birth (in the form of what’s known as a hash value) and compared with the RKI server. This ensures that no one else can retrieve your test result.

The app stores the test certificate data in a secure area on your smartphone. If you retrieved a positive test result, no test certificate will be generated.

Your current test certificate is displayed on the app’s home screen. To prove this, you can show the QR code from your digital test certificate, which will be displayed in the app. The official verification app can be used to scan this QR code and read the information in the test certificate (see Section 5 i.). The verification app will then show whether you tested negative and when the test was performed. In addition, your name and date of birth will also be displayed so that the person verifying your vaccination status can check this information against your official identification document.

Please note that using the feature for requesting and saving your COVID test certificates in the app is voluntary. In cases where you are required to do so by law, there are other ways to prove your test result.

Please note that the QR code from your digital test certificate contains your data. You should only show it if you wish to prove your negative test result. Do not provide test certificates or QR codes to anyone if you do not want the data to be read.

### k. Error reports

The CCTG maintainers strive to offer a bug-free app. However, due to the large number of different systems involved, this cannot always be guaranteed. To assist the app’s technical support with error analysis, you can share the error report that has been recorded in your app with the apps maintainers. The error report will be analyzed in order to be able to identify and eliminate the cause of the errors that occur in your app.

Please note that if you share your error report by e.g. by email) this may reveal information about your identity linked to the error report.

## 7. How does the transnational warning system work?

To ensure that users are also warned by the official coronavirus apps of other countries, the RKI, together with several official healthcare bodies and authorities in other countries (hereinafter referred to as health authorities) has set up central warning servers for sharing warnings between countries (hereinafter referred to as the exchange server).

- The exchange server of the participating countries among European Member States uses the digital infrastructure of the eHealth Network established between the Member States and the EU.
- In order to also enable warnings between users of the Swiss coronavirus app and the Corona-Warn-App, the RKI also operates another exchange server together with Switzerland (Federal Office of Public Health of the Swiss Confederation).

The national server systems of the coronavirus apps connected to the exchange servers regularly transmit their own positive lists to the exchange servers and receive the positive lists of the other countries. Transnational warnings can only be transmitted based on a positive PCR test and only based on encounters recorded in the COVID-19 exposure notification system. Event IDs and random IDs based on positive rapid antigen tests are therefore not transmitted to the exchange servers.

Each server system merges the positive lists received in this way with its own positive list, which allows the exposure logging feature to also take into account possible exposures involving users of another coronavirus app (see Section 6 e.) The other participating countries proceed in the same way with the positive lists provided by the RKI.

Only countries whose coronavirus apps are compatible with each other and which guarantee a comparably high level of data protection can participate in the exchange servers. In particular, this requires that the coronavirus apps of the participating countries also use the COVID-19 exposure notification system, are approved by the respective national health authorities, and respect the privacy of their users.

- The technical and organisational details of this cooperation concerning the exchange server operated within the EU are laid down in an EU Commission Decision (Commission Implementing Decision (EU) 2020/1023 of 15 July 2020, which is available at https://eur-lex.europa.eu/eli/dec_impl/2020/1023/oj). Under it, together with the respective competent health authorities of the participating countries, the RKI is a joint controller under data protection law, meaning it is responsible for processing the information contained on the positive lists (random IDs and, if applicable, information about the onset of symptoms) on the exchange servers in order to enable the transnational exposure logging and warning system.
- The operation and data exchange of the joint exchange server with Switzerland is regulated in an individual agreement between the RKI and Switzerland, available at https://www.rki.de/DE/Content/InfAZ/N/Neuartiges_Coronavirus/WarnApp/Warn_App.html. Under the agreement, the technical operation of the exchange server is carried out by the Federal Office of Public Health of the Swiss Confederation. Together with the Federal Office of Public Health of the Swiss Confederation, the RKI is a joint controller under data protection law, meaning it is responsible for the storage, provision and subsequent erasure of the positive lists.

Please note that the list of participating countries is subject to change. The current list, with details of the competent health authorities in each case, can be found in the FAQs available at https://www.coronawarn.app/en/faq/#interoperability_countries .

## 8. What permissions does the app require?

The app requires access to a number of your smartphone’s features and interfaces. For this purpose, you need to grant the app certain permissions. The permission system depends on your operating system’s specifications. For example, your smartphone may combine individual permissions into permission categories, where you can only agree to the permission category as a whole. Please note that without the permissions requested by the app, you will not be able to use some or all of the app features.

### a. Technical requirements (all smartphones)

- The app requires an internet connection in order to exchange data with the server system.
- The Bluetooth feature must be enabled so that your smartphone can transmit its own random IDs and record the random IDs of other smartphones.
- The app needs to be able to run in the background on your smartphone in order to automatically identify your risk of infection and check the status of your test. If you deny the app permission to run in the background, then you must start all actions in the app itself.

### b. Android smartphones

If you are using an Android smartphone, the following system features must also be enabled:

- If you have a smartphone running on Android version 10 or lower, location services need to be enabled for your smartphone to search for Bluetooth signals from other smartphones. Please note that no location data is collected in this process.
- The notification feature must be enabled so that you can be notified of changes to your risk of infection and the status of test results. The notification feature is enabled by default in the operating system.

The app also requires the following permissions:

- The features for retrieving a test result and checking in at an event require access to the camera in order to scan QR codes.

## 9. When will your data be deleted?

The storage period depends on the purposes or app features for which your data has been stored. When determining the storage period, the RKI takes into account the latest scientific findings on the incubation period (i.e. the period between exposure to infection and the appearance of the first symptoms, which is up to 14 days) as well as on how long there is a risk of an infected person infecting someone else after the end of the incubation period. Unless otherwise specified under Section 6, the following storage periods apply:

### a. Data on your smartphone

The positive lists are deleted from the app memory after 14 days. Event data under “My check-ins” is automatically deleted after 14 days. Alternatively, you can delete entries under “My check-ins” manually at any time. The infection risk determined for you (e.g. “low risk”) is deleted from the app memory after each update, but after 14 days at the latest. If you have retrieved a positive test result, the token in the app memory is deleted as soon as you activate the warning feature. Your entries in the contact journal will be stored on your smartphone for 16 days before being automatically deleted. You can also delete these entries yourself at any time. Please note that if entries are added to the contact journal when you check in at an event or place, these will still be stored there even after you delete the associated check-in. Once you have created your rapid test profile, it will be stored in the app until you delete it yourself. Once you have scanned your COVID vaccination or test certificates, these will also be stored in the app until you delete them yourself.

### b. Data on server systems

Positive lists are deleted from all server systems (including the exchange server) after 14 days. All other data, with the exception of data transmitted by the data sharing feature and to confirm the authenticity of your app, will be deleted after 21 days at the latest.

## 10. Who will receive your data?

If you warn other users of a positive PCR test via the app, your test result (in the form of your random IDs from the last 14 days) as well as optional information you provide about the onset of your symptoms will be forwarded to the competent health authorities of each of the countries participating in the exchange servers. From there, they will be passed on to the server systems of the coronavirus apps of those countries participating in the transnational warning system. The server systems of the national coronavirus apps then distribute this information to their own users as part of the positive lists. Event IDs are only distributed to users of the Corona-Warn-App via the RKI’s server system. In the event of a warning based on a positive rapid antigen test, your data will not be passed on to the exchange servers.

The competent national health authorities have commissioned the EU Commission, as data processor, to operate and maintain the joint exchange server of the participating EU countries. The exchange server for transnational warnings between the Corona-Warn-App and the Swiss coronavirus app is operated and maintained by the Federal Office of Public Health of the Swiss Confederation in consultation with the RKI.

The RKI has commissioned T-Systems International GmbH and SAP Deutschland SE & Co. KG to operate and maintain part of the technical infrastructure of the app (e.g. server system, hotline), meaning that these two companies are processors under data protection law and acting on the RKI’s behalf. The EU Commission has also commissioned these companies, as sub-processors, with the technical provision and management of the participating countries’ joint warning system.

Otherwise, the RKI will only pass on your data collected in connection with your use of the app to third parties if the RKI is legally obliged to do so or if this is necessary for legal action or criminal prosecution in the case of attacks on the app’s technical infrastructure. In other cases, personal data will not generally be passed on by the RKI.

## 11. Is your data transferred to countries outside the EU?

If you activate the warning feature based on a positive PCR test, your random IDs will also be transmitted to Switzerland to the exchange server that is operated by the RKI together with the Federal Office of Public Health of the Swiss Confederation. In the event of a warning based on a positive rapid antigen test, no such transmission of your data will take place.

Otherwise, the data transmitted by the app is processed exclusively on servers in Germany or in another country in the EU (or the European Economic Area), which are therefore subject to the strict requirements of the General Data Protection Regulation (GDPR).

## 12. How can you withdraw your consent?

You have the right to withdraw any consent you granted the RKI in the app at any time with effect for the future. Please note, however, that any processing of your data that has already been carried out cannot be reversed. In particular, once your random IDs have been transmitted, the RKI has no way of deleting these from other users’ smartphones.

### a. Consent to "exposure logging"

You can withdraw your consent to the app’s exposure logging feature at any time by disabling the feature in the app’s settings or by deleting the app. If you would like to use the exposure logging feature again, you can re-enable the feature or reinstall the app.

### b. Consent to “retrieving a test result”

You can withdraw your consent to the test result retrieval feature by displaying the test in the app and then deleting it. The token for retrieving the test result will consequently be deleted from the app memory, so that the token can no longer be assigned on the server system. It is not possible to assign the same test to your app again or to scan the same QR code again. If you have been tested again and wish to retrieve the test result, you will be asked for your consent again. If the test result is already available in the app, then you can no longer withdraw your consent.

### c. Consent to “warning others”

If you would like to withdraw your consent to the transmission of your test result (or, more precisely, your consent to the transmission of your random IDs and event IDs, including the recorded check-in and check-out times, from the last 14 days) for warning other people, you can display the test and then disable “Warn others”. You can also delete entries for events or places under “My check-ins” and thus prevent data for these events from being used for warnings. This option is available as long as you have not yet transmitted your random IDs and event IDs to warn other users.

After you have transmitted your random IDs, you can only withdraw your consent by deleting the app. Your random IDs already transmitted to the server system will consequently be deleted from the app memory and can no longer be assigned to you personally or your smartphone. If you wish to activate the warning feature again, you will need to reinstall the app and give your consent again. Once a test result has been assigned to your app and transmitted in order to warn others, it cannot be used again to warn others.

If event IDs have already been transmitted to the server system, you can also delete them from the app memory, by deleting the entries for the events or places under “My check-ins”. Event IDs can then no longer be assigned to you personally or your smartphone.

Once your random IDs, event IDs and transmission risk values have been transmitted, the RKI has no way of deleting them from the positive lists distributed by the server system or from users’ smartphones. If you also wish to delete your exposure data stored in your smartphone’s COVID-19 exposure notification system, you may be able to manually delete it in your smartphone’s system settings. Please also note the information in Section 5 b.

### d. Consent to “event check-in”

You can delete entries for events or places at any time under “My check-ins”. This will prevent data about these events from being used by the feature for warning others, and event IDs from being assigned to you personally or your smartphone.

## 13. What other rights do you have under data protection law?

If the RKI processes your personal data, you also have the following data protection rights:

- The rights under Art. 15, 16, 17, 18, 20 and 21 GDPR,
- the right to contact the official RKI data protection officer and raise your concerns (Art. 38(4) GDPR) and
- the right to lodge a complaint with a data protection supervisory authority. To do so, you can either contact your local supervisory authority or the authority responsible for the RKI. The supervisory authority responsible for the RKI is the Federal Commissioner for Data Protection and Freedom of Information, Graurheindorfer Straße 153, 53117 Bonn.

You also have these data protection rights vis-à-vis the health authorities responsible for data processing in the countries participating in the exchange servers, insofar as you have transmitted your random IDs from recent days to warn other people (see Section 7).

Please note that the rights mentioned above can only be fulfilled if the data on which your claim is based can be clearly assigned to you. This would only be possible if the app were used to collect further personal data that would allow the data transmitted to the server system to be clearly assigned to you or your smartphone. Since this is not necessary for the purposes of the app, the RKI is not obliged to collect such additional data (Art. 11(2) GDPR). Moreover, this would run counter to the stated objective of collecting as little data as possible. For this reason, it will generally not be possible to fulfil the above data protection rights even if you provide additional information about your identity.

## 14. Data protection officer and contact

If you have any questions or concerns regarding data protection, you are welcome to send them to the RKI’s official data protection officer by post to Robert Koch-Institut, FAO the data protection officer, Nordufer 20, 13353 Berlin, or by emailing datenschutz@rki.de.

Last amended: 17 June 2021