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I just noticed but even the German language footer doesn't included a link clearly labelled "Impressum". That information seems to be in the privacy policy (whi

by hnbad 6y ago

I just noticed but even the German language footer doesn't included a link clearly labelled "Impressum". That information seems to be in the privacy policy (which I can only get in English even when switching to German?) but that is not sufficient to meet German legal requirements. The privacy policy also doesn't provide all the information the GDPR generally requires you to provide, e.g. spelling out users' rights under the GDPR and what legal basis is given for collecting each specific piece of information. I'm mostly pointing this out because it could get them sued, but I'd also expect a company based on a service like this to take privacy a bit more seriously, or at least present themselves as if they do so.

rauf_f 6y ago
Thanks for the review. The privacy policy lists all collected information, how (if any) they're shared with other parties, also right for the users to delete the information any time. What else should be listed here? I didn't get the "legal basis for collecting each information" -- is it required? This is just basic information that software needs to operate.
- hnbad 6y ago
  Well, first of all, you need a link clearly indicating it's the "Impressum" (usually translated as "imprint", "legal" or similar in English versions) as per §5 TMG: https://de.wikipedia.org/wiki/Impressumspflicht#Telemediengesetz https://de.wikipedia.org/wiki/Impressumspflicht#Telemedienge... You can get sued for omitting such a page (by any bored lawyer really) because it's considered anti-competitive and a misdemeanor: https://de.wikipedia.org/wiki/Impressumspflicht#Ordnungswidrigkeiten_und_Zust%C3%A4ndigkeiten https://de.wikipedia.org/wiki/Impressumspflicht#Ordnungswidr... Here's a lengthy explainer of what should go in a privacy policy to be fully compliant (in German), note that "clear and precise" language is generally understood to mean being explicit about the legal basis (i.e. parts of the GDPR) under which the data is collected and processed: https://www.datenschutz.org/datenschutzerklaerung/ https://www.datenschutz.org/datenschutzerklaerung/ In any case, your privacy policy link on the German language version of your website gives me the policy in English, which violates the GDPR's requirements for "clear language" regardless of the actual content by not being in German: https://voicedocs.com/de/legal/privacy-policy https://voicedocs.com/de/legal/privacy-policy But to be honest, you shouldn't be asking a random person on HN, you should talk to a lawyer.

by hnbad 6y ago

rauf_f 6y ago

Thanks for the review. The privacy policy lists all collected information, how (if any) they're shared with other parties, also right for the users to delete the information any time. What else should be listed here? I didn't get the "legal basis for collecting each information" -- is it required? This is just basic information that software needs to operate.

hnbad 6y ago
Well, first of all, you need a link clearly indicating it's the "Impressum" (usually translated as "imprint", "legal" or similar in English versions) as per §5 TMG: https://de.wikipedia.org/wiki/Impressumspflicht#Telemediengesetz https://de.wikipedia.org/wiki/Impressumspflicht#Telemedienge... You can get sued for omitting such a page (by any bored lawyer really) because it's considered anti-competitive and a misdemeanor: https://de.wikipedia.org/wiki/Impressumspflicht#Ordnungswidrigkeiten_und_Zust%C3%A4ndigkeiten https://de.wikipedia.org/wiki/Impressumspflicht#Ordnungswidr... Here's a lengthy explainer of what should go in a privacy policy to be fully compliant (in German), note that "clear and precise" language is generally understood to mean being explicit about the legal basis (i.e. parts of the GDPR) under which the data is collected and processed: https://www.datenschutz.org/datenschutzerklaerung/ https://www.datenschutz.org/datenschutzerklaerung/ In any case, your privacy policy link on the German language version of your website gives me the policy in English, which violates the GDPR's requirements for "clear language" regardless of the actual content by not being in German: https://voicedocs.com/de/legal/privacy-policy https://voicedocs.com/de/legal/privacy-policy But to be honest, you shouldn't be asking a random person on HN, you should talk to a lawyer.