Privacy Policy of tonies US INC

Below we will show you how tonies US INC (also “We”, “Us”) processes the personal data of test subjects. You will be given an overview of which specific data is processed, how We use it and what rights you derive from such processing.


The controller with responsibility for the processing of personal data within the meaning of the data protection legislation is

Tonies US, Inc.
3000 El Camino Real

Building 4, Suite 200
Palo Alto, CA 94306


How is personal data collected and processed?

1. Registration as a test subject

If you have agreed with Tonies US, Inc. that you will participate in studies regarding the use of our products, you will receive an email invitation from Tonies US, Inc. to register with TestingTime AG. As a sub-processor on behalf of tonies GmbH and acting as our processor, TestingTime coordinates the registration of test subjects and the sending of invitations to participate in our studies.

For this purpose, TestingTime will invite you to register in the tonies GmbH private pool on the TestingTime platform. The following data is collected as part of the process: name, email address, phone number, gender, age, postcode, country. In addition, your IP address and the date and time of registration are stored to prevent misuse of the service.

tonies GmbH only processes your data as instructed to do so by Tonies US, Inc. and in particular does not use it for advertising messaging or its own purposes. TestingTime also has no access to the studies.

The personal data that tonies GmbH collects on behalf of Tonies US, Inc. to prepare and enter into this agreement will be stored in accordance with the statutory retention and documentation obligations and then deleted.

You can request to have your data deleted from the database at any time.

2. Invitation to a study

If we select you to participate in a study, TestingTime will send you a short reminder with details on how to complete the study.

In this reminder, you will also be asked to provide TestingTime with your IBAN or PayPal details so that your remuneration can be processed and transferred, if applicable. The subject of the data processing agreement with TestingTime is the coordination of invitations and payment of remuneration (if applicable) after completion of a study.

3. Participation in a study

Natural persons who are at least 18 years old and have registered to participate are eligible to participate.
The studies are carried out by tonies GmbH on our behalf (pursuant to Art. 28 GDPR). There are three types of studies:

  • In-house study: the test subject will be invited to a location selected by Us or to rented premises for the purpose of the study.
  • Online questionnaires: the test subject fills out a questionnaire online.
  • Remote testing: the test is carried out via a video conferencing tool.

The aim of a study is to establish which presentation methods, product changes or services are preferred by users and customers in order to further develop and/or optimise our services and products. Example questions could be:

– What kind of stories do you want to hear on Tonies?
– What new features would you like to see in the mytonies App?

The information requested during your registration is used to assess your eligibility for participation in certain studies, tests and/or surveys.

From time to time, We will invite you to participate in studies, tests and/or surveys via (video) interviews (e.g. Google Meet) to better understand user experiences and thoughts, emotions and wishes. These invitations are voluntary and whether you want to participate is up to you.

With in-house studies and remote testing, test subjects can be recorded in a video file while testing and evaluating the products and packaging materials. These recordings are used exclusively to document and evaluate the tests for the purpose of developing tonies GmbH products. Tonies US, Inc. shall ensure that the recordings are deleted after the evaluations have been completed. Any further use of the test data will only take place in anonymised form.

tonies GmbH uses solutions for online surveys provided by subcontractors (e.g. Survey Monkey) for responses to the online questionnaires.

If Tonies US, Inc. engages processors to conduct and evaluate the study, tonies US INC shall oblige them to process the data exclusively for the stated purpose and to comply with the requirements of the applicable data protection laws.

4. Recipients of the data

Tonies US, Inc. only shares data if so required by legal provisions or contractual services or if you have consented to its being shared. We require all such recipients to comply with applicable data protection laws and standards.

Recipients may receive personal data under the following conditions:

  • During the study, only those employees who need your personal data to fulfill the purposes stated in this Privacy Policy will be granted access to it. These include, for example, employees who are involved in the development of our products or in research.
  • Processors employed by Tonies US, Inc. or tonies GmbH may receive personal data for the following purposes:
    • Processors for hosting, SAAS solutions or platform providers;
    • Advice and consulting.

The processors We use are contractually obliged to comply with data protection standards.

If required by law or by a public authority, Tonies US, Inc. may process and disclose your personal data without prior notice or consent. This may be due to a court order or other regulatory obligation.

5. Where is your personal data processed?

Your personal data (registration and study content) is generally processed in Germany, the USA, Switzerland or the EU.

However, some processors that provide video conferencing tools or online questionnaires are headquartered in a third country (i.e. countries outside the European Economic Area, EEA or the jurisdictions noted above). In order to provide the services, certain technical data that does not directly refer to individuals may be transmitted to these third countries.

Tonies US, Inc. contractually obliges the data processors deployed in a third country to comply with the EU data protection level and the instructions it issues. Such contracts generally include the standard contractual clauses of the EU Commission or certification in accordance with the Data Privacy Framework. If a processor is located in the USA, it will only be used if it is certified under the Data Privacy Framework for EU–US transfers.

Consent to processing

To successfully register for the tonies GmbH private pool and participate in our studies, you must approve the general Conditions of Participation and consent to the processing of your personal data.

You further agree to treat all information, documents, tests and test results made available orally, in writing or in any other form as part of the study, including all records and copies made thereof, as confidential at all times and not to use, exploit or disclose them to third parties for commercial or personal purposes.

You can revoke your consent at any time without giving reasons or request to have your data deleted from the database.

Your rights

As long as the legal requirements are met, you have the right:

  • to receive information about and a copy of your data;
  • of correction and erasure of your data;
  • of restriction of the processing of your data;
  • to the transfer of your data in a structured, common and machine-readable format;
  • to make a complaint to the competent supervisory authority in your place of residence, place of work or place of the alleged infringement;
  • to revoke consent to data processing without giving reasons;
  • to lodge an objection if the data is processed by tonies US INC based on a legitimate interest.