Privacy notice
Corona-Warn-App
This privacy notice explains what data is collected when you use the Corona-Warn-App, how that data is used, and your rights under data protection law.
To ensure that this privacy notice can be understood by all users, we have made every effort to make it simple and as non-technical as possible.
The Corona-Warn-App (the “App”) is provided by the Robert Koch Institute, Nordufer 20, 13353 Berlin (the “RKI”).
The RKI is also what is called the controller under data protection law, meaning it is responsible for the processing of App users’ data.
You can contact the RKI’s data protection officer at the above address (“FAO the data protection officer”) and by emailing: datenschutz@rki.de.
Using the App is voluntary. It is therefore your decision alone whether you install the App and which features you use. Your data (such as information about your exposures and your risk of infection) will only be generated and stored on your own smartphone. Your data will only be shared with the RKI, your smartphone’s operating system or other users if you use one of the following App features and have consented to the necessary data transfer in the individual case:
You are not obliged to use these features. If you decide not to grant the consent requested by one of these features, or if you subsequently withdraw your consent, you will not suffer any disadvantages. This will only mean that you cannot or can no longer use that consent-based feature of the App.
The data processing performed in connection with these features is described in more detail in the following sections.
In principle, the RKI will process your data only on the basis of your consent granted pursuant to Article 6(1) Sentence 1(a) and Article 9(2)(a) of the General Data Protection Regulation (GDPR). If you have granted your consent, you can withdraw it at any time. Further information on your right of withdrawal and instructions on how to exercise this right can be found under 11.
The App is aimed at people who are resident in Germany and at least 16 years old.
The App is designed to process as little personal data as possible. This means, for example, that the App does not collect any data that would allow the RKI or other users to infer your identity, health status or location. In addition, the App deliberately refrains from using tracking tools to record or analyse how you use the App.
The data processed by the App can be grouped into the following categories:
Every time data is exchanged over the internet between the App and the App’s server system, the server system processes so-called access data. This is necessary for the App to retrieve current data from the server system or to transmit certain data stored on the smartphone to the server system. The following App features require this type of data exchange with the App’s server system:
This access data comprises the following information:
This access data is only processed to secure and maintain the technical infrastructure. You are not identified personally as a user of the App and it is not possible to create a user profile. The IP address will not be saved beyond the end of the period of use.
In order to prevent unauthorised identification of your data by means of your IP address when you use the App, the App 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, so that your IP address is no longer processed within the server system.
If you enable exposure logging in your smartphone’s operating system, then your smartphone will continuously send out randomly generated identification numbers (“random IDs”) via Bluetooth Low Energy, which other smartphones in your vicinity can receive if exposure logging is also enabled on them. Your smartphone, in turn, also receives the random IDs of the other smartphones. In addition to the random IDs received from other smartphones, your smartphone’s exposure logging functionality records the following exposure data:
Your own random IDs and those received from other smartphones as well as the other exposure data (date and time of the contact, duration of the contact, signal strength of the contact and encrypted metadata) are recorded by your smartphone’s exposure logging functionality and currently stored there for 14 days.
The exposure logging functionality is called “COVID-19 Exposure Notifications” on Android smartphones and “Exposure Notification” on iPhones. Please note that this functionality is not part of the App, but an integral part of your operating system. The exposure logging functionality is therefore provided to you by Apple (iPhones) or Google (Android smartphones). Accordingly, any data processing performed by the operating system using this exposure logging functionality is subject to these companies’ respective privacy policies. The RKI is not responsible for this and has no influence on it.
More information about the exposure logging functionality is available from the providers:
Please note that the actual named us, operating steps, and settings options for the exposure logging functionality on your smartphone may differ from those described in this privacy notice depending on the version and configuration of your operating system.
The App will only process the exposure data generated and stored by your operating system’s exposure logging functionality if the App’s risk identification feature is enabled.
Health data is any data containing information about the health of a particular individual. This includes not only information about past and current illnesses, but also about a person’s risk of illness (such as the risk that the person has been infected with the coronavirus).
The App will process your health data if you use the following features:
The App’s core functionality is risk identification. This serves to track possible contacts with other users of the App who are infected with the coronavirus (possible exposures), to evaluate the risk that you yourself have been infected, and to provide you with health advice and recommendations for what to do next.
If you enable the risk identification feature, then several times a day while the App runs in the background (or when you tap on “Update”), the App will retrieve a list from the App’s server system of random IDs, each with a transmission risk value (a numerical value from 1–8) from users who have tested positive and provided their own random IDs via the App using the feature for warning others. The transmission risk value is an estimate of the likelihood of infection on the day of the possible exposure in question. Since infectiousness (i.e. the risk of infection for those who come into contact with a person who has tested positive) is currently believed to depend 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 infection on the day of a possible exposure.
The App shares these random IDs with your smartphone’s exposure logging functionality, which then compares them with the random IDs logged by the exposure logging functionality. If your smartphone’s exposure logging functionality detects a match, it transfers the exposure data (date, duration, signal strength) to the App, but not the random ID of the contact in question.
In the event of a potential exposure, the App analyses the exposure data provided by the exposure logging functionality as well as the transmission risk value in order to determine your individual risk of infection.
The evaluation algorithm which determines how the exposure data and the transmission risk value are interpreted (for example, how the duration of a contact influences the risk of infection) is based on current scientific findings. To account for new findings as and when they arise, the RKI can update the evaluation algorithm by adjusting its settings. The settings for the evaluation algorithm are sent to the App together with the list of random IDs of infected users.
The identification of your risk of infection is only carried out locally on your smartphone, meaning that the data is processed offline without accessing the App’s server system. Once identified, the risk of infection is also only calculated in the App and is not passed on to any other recipients (including the RKI, Apple, Google and other third parties).
The legal basis for the processing of your access data, exposure data and, if applicable, health data (if the App determines a possible exposure) described above is your consent which you gave when enabling the risk identification feature.
If you have been tested for the coronavirus, you can register the test in the App by scanning the QR code which you received from your doctor or the testing facility. The app will then inform you as soon as the test result is available from the laboratory.
For this to work, the testing laboratory needs to be connected to the App’s server system and, as part of the testing procedure, you must have agreed separately to the laboratory transmitting your test result to the App’s server system (test result database). Test results from laboratories that are not connected to the App’s server system cannot be displayed in the App. If you have not received a QR code, the testing laboratory is not connected. In this case you will not be able to use this feature.
Registering a test
To receive the test result in the App, you must first register the test you have taken in the App. For this purpose, your doctor or the testing facility will provide you with a QR code when taking the sample. This QR code contains a code number which can be read with a QR code scanner. To register your test, you will need to scan the QR code in the App using your smartphone’s camera.
The code number read from the QR code is then hashed by the App, which 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 recognised. As soon as your smartphone is connected to the internet, the App will transmit the hashed code number to the App’s server system. In return, the App receives a token from the server system, i.e. a digital access key that is stored in the App. The token is linked to the hashed code number on the server system. The App then deletes the hashed code number on your smartphone. The server system will only issue a token once for each hashed code number. This ensures that your QR code cannot be used by other users of the App to retrieve test results.
This completes the registration of your test.
Filing of the test result
As soon as the testing laboratory receives the test result, it stores the result in the RKI’s test result database, indicating the hashed code number. The test result database is operated by the RKI on a special server within the App’s server system. Based on the code number contained in the QR code issued to you, the testing laboratory also generates the hashed code number using the same mathematical procedure as the App.
Retrieval of the test result
Using the token, the App regularly requests the status of the registered test from the App’s server system. The server system then assigns the token to the hashed code number and transfers it to the test result database. If the test result has now been stored there, the test result database sends the test result back to the server system, which forwards it to the App without gaining any knowledge of the content.
If the test result is positive, the App uses the token again to request a TAN (transaction number) from the server system. The server system reassigns the token to the hashed code number and requests confirmation from the test result database that a positive test result exists for the hashed code number. If the test result database confirms this, the server system generates the TAN and transmits it to the App. A copy of the TAN remains on the server system.
The TAN is required to ensure that no false information is distributed to other users in the event of a positive test result being transmitted.
The legal basis for the processing described above of the data mentioned above is your consent to using the test registration feature.
If you use the feature for warning others, the App will transfer the random IDs (including the respective transmission risk values) generated and stored by your smartphone from the last 14 days and the TAN to the App’s server system. The server system first checks whether the TAN is valid and then adds your random IDs to the list of random IDs of users who have provided a positive test result. Your random IDs can now be downloaded by other users as part of the risk identification process.
The information about symptoms and symptom onset requested by the feature for warning others is optional and not required to warn other users. However, this information can help to calculate more accurately the risk of infection to other users you have encountered. If you can’t or don’t want to answer some or all of the questions, just select “no answer”. In this case, the transmission risk values determined by the App and assigned to your random IDs will be based on the time that has passed since your test result was retrieved, assuming an average infection – meaning that the more time has passed since using a random ID, the lower its transmission risk value will be.
If you have not retrieved your test result in the App:
Even if you have not retrieved a positive test result in the App, you can share the test result via the App to warn other users. In this case, the App prompts you to enter a so-called TeleTAN, which acts as a TAN.
To obtain a TeleTAN, please call the Corona-Warn-App hotline on +49 (0)800 7540002. The operator will first ask you some questions over the phone to check the plausibility of your call. These questions serve to prevent fraudulent reports of infections and any resulting incorrect warnings and risk levels. Once you have answered these questions sufficiently, you will be asked for your mobile/telephone number. This is so that you can be called back later and given a TeleTAN to enter in the App. Your mobile/telephone number will only be temporarily stored for this purpose and deleted within one hour at the latest.
After your call, the hotline employee will generate a TeleTAN via a special access to the App’s server system and then call you to tell you the TeleTAN. If you enter the TeleTAN in the App, the TeleTAN will be sent back from the App to the App’s server system for comparison and verification. In return, the App receives a token from the server system, i.e. a digital access key that is stored in the App. Using this token, the App then requests a TAN from the server system.
The legal basis for this processing of your access data and health data (random IDs, test result, TAN and, if applicable, TeleTAN) is your consent to using the feature for warning others.
As long as you use the App for information purposes only, i.e. do not use any of the App features mentioned above and do not enter any data, then processing only takes place locally on your smartphone and no personal data is generated. Depending on your operating system, websites linked in the App, such as www.bundesregierung.de, will open in your smartphone’s standard browser (Android smartphones) or within the App (iPhone). The data processed here depends on the data processing practices of the website you are visiting.
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. Permissions are programmed differently by different manufacturers. For example, individual permissions may be combined into permission categories, where you can only agree to the permission category as a whole. Please note that if the App is denied access, you will not be able to use any or all of the App’s features.
The App requires an internet connection for the risk identification feature, and so that it can receive and transmit test results, so that it can communicate with the App’s server system.
Your smartphone’s Bluetooth interface must be enabled for your smartphone to record random IDs from other smartphones and store them in the device’s exposure log.
Your smartphone requires a camera to be able to scan a QR code when registering a test.
The App runs in the background (i.e. when you are not actively using the App) in order to be able to automatically identify your risk and query the status of a registered test. If you deny the App permission to run in the background in your smartphone’s operating system, then you must start all actions in the App itself.
If you are using an Android device, the following system features must also be enabled:
The App’s risk identification feature requires this functionality. Otherwise, no exposure log with the random IDs of your contacts will be available. The functionality must be enabled within the App to allow the App to access the exposure log.
Your smartphone’s location service must be enabled for your device to search for Bluetooth signals from other smartphones. Please note that no location data is collected in this process.
The user is notified locally of the identified risk and available test results. The necessary notification function is already enabled in the operating system.
The App also requires the following permissions:
The App requires access to the camera to read the QR code when registering a test.
If you are using an iPhone, the following system features must be enabled:
The App’s risk identification feature requires this functionality, otherwise no exposure log with the random IDs of your contacts will be available. The functionality must be enabled within the App to allow the App to access the exposure log.
The user is notified locally of the identified risk and available test results. Notifications must be enabled for this.
The App also requires the following permissions:
The App requires access to the camera to read the QR code when registering a test.
All data stored in the App is deleted as soon as it is no longer needed for the App features:
If you provide a test result by using the feature for warning other users, your random IDs and their transmission risk values from the last 14 days will be passed on to the App on other users’ smartphones.
The RKI has commissioned Deutsche Telekom AG 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 (Article 28 GDPR).
Otherwise, the RKI will only pass on personal 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.
The data generated when the App is used is processed exclusively on servers in Germany or in another EU or EEA member state.
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 that this will not affect the lawfulness of the processing before the withdrawal.
To withdraw your consent to the risk identification feature, you can disable the feature using the toggle switch in the App or delete the App. If you decide to use the risk identification feature again, you can toggle the feature back on or reinstall the App.
To withdraw your consent to the test registration feature, you can delete the test registration in the App. The token for retrieving the test result will then be deleted from your device. Neither the RKI nor the testing laboratory can then assign the transmitted data to your App or smartphone. If you wish to register another test, you will be asked to grant your consent again.
To withdraw your consent to the feature for warning others, you must delete the App. All of your random IDs stored in the App will then be removed and can no longer be assigned to your smartphone. If you wish to report another test result, you can reinstall the App and grant your consent again. Alternatively, you may be able to delete your own random IDs in the exposure logging functionality in your smartphone’s system settings. Please note that, once transmitted, the RKI has no way of deleting your random IDs and transmission risk values from the lists provided and from other users’ smartphones.
If the RKI processes your personal data, you also have the following data protection rights:
Please note that the RKI can only fulfil the rights mentioned above if the data on which your claim is based can be clearly assigned to you. This would only be possible if the RKI were to collect further personal data that would allow the data mentioned above to be clearly assigned to you or your smartphone. Since this is not necessary – and not intended – for the purposes of the App, the RKI is not obliged to collect such additional data (Article 11(2) GDPR). Moreover, this would run counter to the stated objective of keeping the amount of data processed for the App as low as possible. Against this backdrop, it will not normally be possible to directly fulfil the above data protection rights under Articles 15, 16, 17, 18, 20 and 21 GDPR, as doing so would require additional information about you which is not available to the RKI.
Last amended: 05 October 2020