DE: Data protection Switzerland

CH: Data protection Switzerland

FR: Confidentialité Suisse

IT: Protezione dei dati Svizzera

Data Protection Policy

Last update: October 2025

DATA PROTECTION INFORMATION ON USING THE “Dräger Companion med” APP

With this data protection notice, we would like to inform you on what basis and for what purposes

purposes for which we process personal data that we collect from you or that you provide to us,

if you use the “Dräger Companion med” app (the “App”). We would also like to inform you about the

and other general conditions of data processing.

The app is a classified medical device for the European Economic Area and fulfills the

Requirements of Regulation (EU) 2017/745 (Medical Devices Regulation – MPV).

Further information can be found in the app’s terms of use.

The app will process your personal data in strict confidence and for a specific purpose in accordance with the

following notes.

1. who is responsible for data processing and who can I contact?

Controller within the meaning of the General Data Protection Regulation (GDPR) and the Federal Act on Data Protection

Data Protection Act (DSG):

Dräger Safety AG & Co. KGaA (“Dräger”)

Revalstrasse 1

23558 Lübeck

jointly responsible with

BAYOOCARE GmbH (“BAYOOCARE”)

Europaplatz 5

64293 Darmstadt

You can reach the company data protection officers of the responsible parties at the aforementioned

Contact details and by e-mail: dataprivacy(at)draeger.com and dataprivacy(at)bayoocare.com.

The essence of the division of responsibilities between the responsible parties results from the

following tabular overview. For the avoidance of doubt, this in no way affects your legal rights.

legal positions under data protection law against both or one of the controllers.

Processing activity/obligation Responsibility/contact point
Back-end operation for data storage Dräger
Operative app operation (incl. vigilance) BAYOOCARE
Technical 1st & 2nd level support Dräger
Technical 3rd level support BAYOOCARE
Operation of the ticket system for 1st/2nd/3rd level
support
Dräger
Exercising the rights of data subjects in accordance with Art. 15 ff.
GDPR and Art. 19 DSG
Dräger, BAYOOCARE
Information for data subjects pursuant to Art. 12 et seq. GDPR
and Art. 19 et seq. DSG
BAYOOCARE

2 What data do we process?

When you use the app, the following personal data concerning you will be processed:

– Name

– (Delivery) address

– E-mail and password

– Breath alcohol measurement results and times

– Image recordings during the measurements

– Usage data that is collected in anonymized form to ensure proper operation of the website.

of the app and to improve it (e.g. “crashes” that have occurred or other

bugs)

– Master data of your therapist and/or doctor

3 Where do we store your personal data?

Your personal data is initially stored exclusively on your smartphone. When you log in

decide to share your data with your therapist and/or doctor, it will be processed for this purpose.

additionally – on servers maintained by Dräger (“back-end”). This is ensured in any case,

that the servers used to store your data are located exclusively within the European Union

are located.

4. for what purpose do we process your data and on what legal basis?

We process personal data in accordance with the provisions of the GDPR and the

Federal Act on Data Protection (FADP):

4.1. For the fulfillment of contractual obligations (Art. 6 para. 1 lit. b GDPR, Art. 6 DSG)

We process the contractual data in order to provide you with the contractually agreed services.

and to be able to allocate and provide the data to the correct recipients.

4.2. For the processing of personal health data based on your consent (Art. 6 para. 1 lit.

a GDPR, Art. 9 para. 2 lit. a GDPR, Art. 6 DSG)

When you start the app for the first time, you consent to the processing of your health data by activating

of a switch. Based on your consent, we process your health data in order to provide you with

to be able to provide relevant app services.

4.3. For the exercise or defense of legal claims (Art. 9 para. 2 lit. f GDPR, Art. 6 FADP)

If necessary, we may process your data for the establishment, exercise or defense of legal claims.

legal claims.

4.4. To fulfill legal obligations (Art. 9 para. 2 lit. i GDPR, Art. 83 para. 3 lit. e, f MPV, Art. 9 FADP)

Finally, we process data insofar as this is necessary to fulfill our legal obligations to

is required in the field of vigilance of medical devices.

5. to whom will my personal data be transmitted?

In order to provide the services contained in the app, we transmit your data to your therapist and/or

Doctor, if you use this functionality.

In addition, access to data is generally only granted to those persons who need it to fulfill our

contractual and, if applicable, legal obligations. Service providers used by us and

Agents may be given access to data for these purposes, for example with regard to externally commissioned

IT services (e.g. hosting). In this case, we provide the following services through corresponding agreements with these

service providers to ensure that the data protection requirements for their integration are met.

are fully safeguarded.

In addition, we do not transfer any personal data or data that can be related to you to third parties without your consent.

express prior consent.

You are free to extract your results generated via the app in the form of the PDF report and

then transfer it to third parties themselves.

6. is the provision of personal data required by law or contract?

You are not obliged to provide us with the aforementioned personal data.

Please note, however, that the incorrect or incomplete provision of data may jeopardize the

proper provision of services within the scope of the app.

7 How long will my data be stored?

You can make deletions yourself at any time within the app. Dräger deletes data stored in the back end

otherwise immediately after termination of the respective user relationship (at the latest within 60

days).

Please note that we may have to retain individual categories of data for longer, for example due to

Mandatory tax or social law requirements regarding financially relevant accounting data.

The same applies in the case of other circumstances that justify longer storage – for example until the expiry of the

regular limitation period if claims for damages are imminent or until the expiry of regulatory periods.

Deadlines if a retention period under medical device law applies.

8. your rights as a data subject

As a data subject, you have the right to information in accordance with Article 15 GDPR and Article 25 FADP, the right to

Rectification pursuant to Article 16 GDPR and Article 32 (1) FADP, the right to erasure pursuant to Article 17 GDPR

and Article 32, para. 2, lit. C. FADP and the right to restriction of processing pursuant to Article 18 GDPR

and Article 32, para. 2, lit. B. DSG.

Details of who you can assert these rights against and how you can do so can be found in section 1 above.