Children’s Data and Legal Representative Processes
The legal capacity of the person who manages a business account is to be distinguished from the personal data of children that appears in event photos or customer content. You can find the rules on opening an account in the document “Age Limit and User Responsibility Policy”.
Children enjoy special protection when their personal data is processed (Recital 38 GDPR). If photos and other data of children are uploaded, the respective controller within the meaning of Art. 4(7) GDPR examines the required legal basis under Art. 6 GDPR, the information to be provided to data subjects under Art. 13 and 14 GDPR, the authority of the persons with parental responsibility to act, and access restrictions. As a rule, the controller is the business that publishes the content in its app. CXR App is offered and operated by Visual Memory Works GmbH (“VMW”). VMW processes this content as a processor under Art. 28 GDPR on behalf of the business.
Setting up a business account does not grant permission to process the data of all children. Separate processing operations, such as face matching, are assessed under their own requirements; for details, see the documents “Face Recognition, Selfie and Biometric Data Processing Notice” and “Separate Explicit Consent for Biometric Processing and Withdrawal of Consent”.
For requests from legal representatives, the authority to represent is verified only to the extent necessary. The ways to assert your concerns are described in the document “Personal Data Requests — Access, Correction, Export and Deletion”. Please send requests to erguen.kalayci@visualmemoryworks.de (contact person for data protection requests: Prof. Ergün Kalaycı).