Privacy Policy

TougeTech App · Last updated: March 7, 2026 · Effective: March 7, 2026

Summary: The TougeTech App does not transmit any data to external servers. No personal data is collected, stored on our side, or shared with third parties. All settings and configurations remain exclusively on your device. The app uses Bluetooth Low Energy (BLE) solely to control your own TougeTech hardware.

1. Data Controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) and other applicable data protection laws is:

TougeTech – Fölsch & Ernst GbR
Brandenburger Straße 32
21244 Buchholz in der Nordheide
Germany
Email: info@tougetech.de

2. Our Privacy Principles

The TougeTech App was developed following the principles of Privacy by Design and Privacy by Default in accordance with Art. 25 GDPR. Specifically:

No personal data is collected or processed beyond what is technically necessary for local app functionality.
No communication with external servers or third-party services takes place.
No user accounts, registration, or login are required.
No analytics, tracking, or advertising services are used.
No crash reporting tools (e.g., Firebase Crashlytics) are integrated.
All settings and configurations are stored exclusively on your device and are not accessible to us.

3. Locally Stored App Data

The app stores the following data in the protected local app storage on your device (Android SharedPreferences). This data never leaves your device and is inaccessible to us or any third party:

Data Category	Description	Retention Period
App Theme	Selected color scheme (Light / Dark mode)	Until app uninstall or manual data clearance
Brightness	App brightness overlay value (0.2 – 1.0)	Until app uninstall or manual data clearance
Language	Selected app language (German or English)	Until app uninstall or manual data clearance
Module Visibility	Settings for which navigation sections (PopUps, Gauges, Light, Sound) are shown	Until app uninstall or manual data clearance
Device Configurations	User-entered device names, categories (e.g. "Oil Temperature"), and measurement threshold values for gauge displays	Until app uninstall, manual data clearance, or removal within the app
Configuration Presets	Saved threshold value templates for gauge displays	Until app uninstall, manual data clearance, or removal within the app
Demo Mode Status	Boolean value indicating whether Demo Mode has been activated	Until app uninstall or manual data clearance

You can delete all locally stored data at any time by:

Navigating to Android Settings → Apps → TougeTech App → Storage → Clear Data, or
Uninstalling the app completely (all app data is automatically removed by the operating system).

4. System Permissions and Access

The app requires the following Android system permissions. We explain transparently the purpose of each permission below:

4.1 Bluetooth Low Energy (BLE)

The app requires Bluetooth permissions to establish a Bluetooth Low Energy (BLE) connection with TougeTech hardware modules (ESP32-based controllers) and to send control commands. This is the core function of the app.

BLUETOOTH_SCAN – Scanning for nearby BLE devices (Android 12 and above)
BLUETOOTH_CONNECT – Connecting to discovered BLE devices (Android 12 and above)
BLUETOOTH, BLUETOOTH_ADMIN – Equivalent permissions for Android 11 and below

During BLE scanning and connection, the device name and Bluetooth address of the hardware module are temporarily processed to establish the connection and identify the module. This data is not permanently stored, not transmitted to any server, and does not leave your device.

4.2 Location Permission (Android 11 and below only)

On Android 11 and earlier, the ACCESS_FINE_LOCATION permission is a mandatory technical requirement of the Android operating system for scanning for nearby Bluetooth devices. This requirement originates from Android, not from TougeTech.

The TougeTech App does not determine, process, or store your actual geographic location at any time. The permission is required solely for the technical operation of BLE scanning. As of Android 12, this requirement has been eliminated – the BLUETOOTH_SCAN permission is used with the neverForLocation flag, explicitly preventing location data from being collected.

4.3 Background Service (Foreground Service)

The app uses an Android Foreground Service of type connectedDevice to maintain the BLE connection to active hardware modules when the app runs in the background or the screen is turned off.

Permissions: FOREGROUND_SERVICE, FOREGROUND_SERVICE_CONNECTED_DEVICE
Visible as: System notification "TougeTech – BLE-Verbindung aktiv" (BLE connection active) while a device is connected
Purpose: Prevents the Android operating system from terminating the active hardware connection during background operation
Data processing: No additional data processing occurs within the background service – it exists solely to maintain connection stability

4.4 Internet Access

The app holds an Internet permission (INTERNET). This is currently used exclusively to open an external browser on your device when you tap the Privacy & Terms link in the app settings. The app itself does not transmit any data – the action is handled entirely by the Android system (url_launcher) and your default browser. The app makes no independent HTTP requests to external servers.

5. Legal Basis for Processing

The data stored locally on your device is processed on the following legal bases under GDPR:

Art. 6(1)(b) GDPR (Contract performance): Storing settings and configurations is necessary to provide the app's features to you in a persistent and convenient manner.
Art. 6(1)(f) GDPR (Legitimate interest): Our legitimate interest lies in the proper technical functioning of the app. Since all data remains on the device and serves exclusively local app functionality, this interest outweighs the rights of data subjects.

6. Disclosure of Data to Third Parties

We do not share any data with third parties. We do not use any third-party services for analytics, advertising, tracking, cloud storage, or any other purpose. All data stored within the app remains exclusively on your device.

7. International Data Transfers

No data is transferred to third countries (countries outside the EU/EEA), as the app does not transmit any data to external servers.

8. Data Retention

Locally stored app data is retained until you:

uninstall the app (all app data is automatically removed by the operating system),
manually clear app data via Android system settings, or
remove individual configurations within the app.

Since no data is stored on our servers, server-side retention does not apply.

9. Your Rights as a Data Subject

Under GDPR, you have the following rights. Since all data is stored exclusively on your device, you retain full control:

Right of access (Art. 15 GDPR): You may request information about the personal data being processed. Since no personal data is stored on our systems, we cannot access the app data on your device. Data stored locally can be viewed under Android Settings → Apps → TougeTech App → Storage.
Right to rectification (Art. 16 GDPR): Incorrect locally stored data can be corrected directly within the app or via Android system settings.
Right to erasure (Art. 17 GDPR): You can delete all locally stored data at any time by uninstalling the app or clearing app data in system settings.
Right to restriction of processing (Art. 18 GDPR): You may request restriction of processing where the conditions of Art. 18 GDPR are met.
Right to data portability (Art. 20 GDPR): You have the right to receive your data in a commonly used, machine-readable format. The locally stored app data is stored as key-value pairs (JSON) on your device.
Right to object (Art. 21 GDPR): You have the right to object to processing of your personal data where it is based on Art. 6(1)(f) GDPR (legitimate interests).

To exercise your rights, please contact us at: info@tougetech.de

10. Right to Lodge a Complaint with a Supervisory Authority

Under Art. 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority. The competent authority for our registered location in Lower Saxony, Germany, is:

Die Landesbeauftragte für den Datenschutz Niedersachsen (LfD Niedersachsen)
(State Commissioner for Data Protection of Lower Saxony)
Prinzenstraße 5
30159 Hannover, Germany
Phone: +49 511 120-4500
Email: poststelle@lfd.niedersachsen.de
Website: https://lfd.niedersachsen.de

Without prejudice to this, you may also lodge a complaint with the supervisory authority of your habitual residence or place of work.

11. Data Security

The app stores all data in the operating system's protected app sandbox. Other apps on your device cannot access this data. Bluetooth communication occurs exclusively with TougeTech hardware modules in immediate physical proximity and is secured by the BLE protocol specification.

12. Google Play Store Notice

The TougeTech App is distributed via the Google Play Store operated by Google LLC. When using the Play Store, Google's privacy policies apply. We are not responsible for data processing by Google in connection with the Play Store, app installation, or Google Play services. For details, please refer to Google's Privacy Policy.

13. Use by Minors

The TougeTech App is intended for persons who operate TougeTech hardware and is not directed at children under 16 years of age. Since the app does not collect personal data, there are no specific requirements under Art. 8 GDPR regarding parental consent. Nevertheless, we recommend that the use and, in particular, the hardware control functions be operated solely by adults or appropriately qualified persons.

14. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in law or new app features that are relevant under data protection law. The current version is always available at https://tougetech.com/privacy/app/privacy-policy.html and accessible directly via the Privacy link in the app settings. The date of the most recent update is indicated at the top of this document.

15. Contact for Privacy Matters

For questions, feedback, or to exercise your data protection rights, please contact:

TougeTech – Fölsch & Ernst GbR
Brandenburger Straße 32
21244 Buchholz in der Nordheide
Germany
Email: info@tougetech.de