Status December 2021
Summary
As far as possible, the CargoTour app tries to avoid collecting and processing personal data. However, it is not possible to do completely without:
As a navigation app, we process location information to provide the navigation service. For this, we use maps and SDKs from Here, which also evaluate usage in anonymized form (but without location data).
To enable user accounts, we require an email address. The account management is done via Google Firebase. In the process, the account is also assigned a randomly generated ID, which itself does not allow any conclusions to be drawn about the person behind it. In all other areas of the app, only this ID is used to identify the account.
This also applies to the payment processing of subscriptions. This is handled via google’s own payment system for Android apps. We do not receive access to payment data or similar.
To analyze the use of the app, we use Google Analytics for Firebase. When transferring the usage data, the IP is anonymized before it is sent to google.
In terms of third-party services, we otherwise only use Firebase for the cloud databases and RevenueCat to facilitate payment integration. These services only receive the randomly generated account ID to assign the data to the respective accounts.
And importantly, we do not collect any other personal data or share any data with ad networks or similar service providers.
Complete privacy policy
In the following, we provide information about the collection of personal data when using our website and apps. Personal data is all data that can be related to you personally, e.g. name, address, email addresses, user behavior. We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to technological progress.
1. Person responsible for data processing
Person responsible according to Art. 4 para. 7 EU General Data Protection Regulation (DSGVO):
Stefan Tiess
Wesertrasse 44D, 10247 Berlin
Phone: +49 151 172 36 755
E-mail: info@cargotourapp.com
2. Contact possibility of the data protection officer
You can reach our data protection officer at info@stefantiess.de or by mail at
Stefan Tiess
Weserstrasse 44D
10247 Berlin
3. Your rights
You have the following rights with respect to personal data concerning you:
3.1 General rights
We would like to inform you that you have the right at any time to request information about which of your personal data is processed by us. The right to information also includes the right to receive a copy of the data, provided that this does not affect the rights and freedoms of other persons (Art 15 GDPR). You have the right to request that inaccurate or incomplete data concerning you be corrected or completed (Art 16 GDPR). In principle, you have the right to have your data deleted (Art 17 GDPR). However, the right to erasure does not exist, for example, insofar as the processing is necessary for the fulfillment of a legal or contractual obligation. You have the right to request the restriction of the processing of your data if certain conditions are met (Art 18 DSGVO). In principle, you also have the right to receive the transfer of the data you have provided in a structured, common and machine-readable format. However, the right to data portability only exists if the processing is based on your consent or on a contract (Art 20 DSGVO).
3.2 Objection or revocation
If you have given us consent for the processing of your data (see the specific cases of consent in each case in the description below), you may revoke such consent at any time. Such revocation will affect the permissibility of the processing of your personal data after you have expressed it to us.
Insofar as we base the processing of your personal data on a balancing of interests, i.e. in particular on Art. 6 (1) lit. f DSGVO, you may object to the processing. This is the case if the processing is not necessary, in particular, for the performance of a contract, which is shown by us in each case in the following description of the functions. When exercising such an objection, which you can send to the contact details mentioned in section 2, we ask you to explain the reasons why we should not process your personal data as carried out by us. We will review the facts and either stop or adjust the data processing or show you our compelling legitimate grounds on the basis of which we continue the processing.
You can, of course, object to the processing of your personal data for the purposes of advertising and data analysis at any time. Please address your objection to advertising to the contact data mentioned in section 2.
3.3 Right to complain to a supervisory authority
You also have the right to complain to a competent data protection supervisory authority about the processing of your personal data by us.
In Austria, the competent supervisory authority is the Austrian Data Protection Authority.
4. Collection of personal data when visiting our website
In the case of purely informational use of the website, i.e. if you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security. The legal basis for this is Art. 6 (1) lit. f DSGVO:
IP address, date and time of the request, time zone difference to Greenwich Mean Time (GMT), content of the request (specific page), access status/HTTP status code, amount of data transferred in each case, website from which the request comes, browser, operating system, and its interface, language and version of the browser software.
5. Collection of personal data when using our mobile app
5.1 Data processing operations of the app store operator.
When downloading the mobile app, the required information is transmitted to the App Store, i.e. in particular user name, e-mail address and customer number of your account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to your mobile device.
5.2 Data processing operations when using the apps.
When you use our apps, we collect the following personal data that are technically necessary for us to offer you the functions of our mobile app (legal basis is Art. 6 (1) lit. b DSGVO) and to ensure stability and security (legal basis is Art. 6 (1) lit. f DSGVO):
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software.
6. Contacting us by e-mail or contact form
When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions. Insofar as we request input via our contact form that is not required for contacting us, we have always marked this as optional. This information is used to specify your request and to improve the processing of your request. A communication of this information is expressly on a voluntary basis and with your consent, Art. 6 para. 1 lit a DSGVO. Insofar as this involves information on communication channels (for example, e-mail address, telephone number), you also consent to us contacting you via this communication channel, if necessary, in order to respond to your request. You can, of course, revoke this consent at any time for the future.
We delete the data accruing in this context after the storage of the data.
7. Registration and service use
7.1 Registration
You have the option to register with us and create a customer account. For the registration we collect and store the following data from you:
- E-mail (user name)
- Password
After successful registration you will receive a personal, password-protected access. Registration is voluntary, but is a prerequisite for using our services.
If you use our service, we store your data required for the fulfillment of the contract Furthermore, we store the voluntary data provided by you for the time of your use of the portal, unless you delete them beforehand. The legal basis is Art. 6 para. 1 lit. b and f DSGVO.
8. Online orders – store
If you place an online order on our website or in the app, we collect various data required for the conclusion of the contract. The legal basis is the conclusion and execution of a contract according to Art. 6 para. 1 lit. b DSGVO. The data is stored for the duration of the contract and in accordance with legal obligations. The legal basis for storing the data due to legal storage obligations is Art. 6 para. 1 lit. c DSGVO. For payment processing, we use various payment service providers, which are always identified and directly accept your input and are therefore recipients of your personal data collected in connection with the payment process. The legal basis for the involvement of payment service providers is the execution of the contract according to Art. 6 para. 1 lit. b DSGVO. The storage for the purpose of payment takes place for the duration of the payment processing.
9 Google
You can also register and log in via your Google account. If you register via Google, Google will request your consent to release certain data from your Google account to us. This may include your first name, last name, gender and email address to verify your identity, as well as a link to your Google profile and your profile picture. This data is collected by Google and transmitted to us in compliance with the terms of Google’s privacy policy.
This data is used to set up, provide and personalize your account. The legal basis is Art. 6 para. 1 lit. b and f DSGVO; the storage of technically unnecessary cookies in this context is based on your consent (Art. 6 para. 1 lit. a DSGVO).
10. Use of cookies
If you give us your consent to set cookies, cookies will be stored on your computer when you use our website and our apps. The storage of technically necessary cookies also takes place without consent. Cookies are small text files that are stored on your device memory assigned to the browser or app you are using and through which certain information flows to the body that sets the cookie. Cookies cannot execute programs or transmit viruses to your terminal device. They serve to make the Internet offer more user-friendly and effective overall, tracking for analysis purposes and are partly technically necessary for the provision of our services. We also use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.
11. Analysis services
For the purpose of analyzing and optimizing our websites or our apps, we use various services, which are outlined below. For example, we can analyze how many users visit our site, what information is most in demand, or how users find the offer. Among other things, we collect data on which website a data subject came to a website from (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. This helps us to design and improve our offers in a user-friendly way. The data collected is not used to identify individual users personally. Anonymous or at most pseudonymous data is collected. The legal basis for the processing is Art. 6 para. 1 lit. f DSGVO; the setting of cookies in this context is based on your consent (Art. 6 para. 1 lit. a DSGVO).
11.1 Google Analytics
Our website and apps use Google Analytics, a web analytics service provided by Google Inc, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) The use includes the Universal Analytics mode of operation. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID and thus analyze a user’s activities across devices.
Google Analytics uses cookies that enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, by activating IP anonymization on this website, your IP address will be truncated beforehand by Google within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. Our legitimate interest in data processing also lies in these purposes. The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs are automatically deleted after 26 months. Data whose retention period has been reached is automatically deleted once a month. For more information on terms of use and data protection, please visit https://www.google.com/analytics/terms/de.html or https://policies.google.com/?hl=de.
The storage of technically unnecessary cookies in this context is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the https://tools.google.com/dlpage/gaoptout?hl=de. Opt-out cookies prevent the future collection of your data when visiting this website. To prevent collection by Universal Analytics across different devices, you can opt-out on all systems used. If you click here, the opt-out cookie will be set: Disable Google Analytics. The setting of this cookie is based on your consent (Art. 6 para. 1 lit. a DSGVO), the legal basis for other processing in this context is Art. 6 para. 1 lit. f) DSGVO.
12. Data transmission
As a matter of principle, your data will not be transferred to third parties unless we are legally obliged to do so, or the transfer of data is necessary for the performance of the contractual relationship, or you have previously expressly consented to the transfer of your data.
External service providers and partner companies such as online payment providers will only receive your data to the extent necessary to process your order. In these cases, however, the scope of the transmitted data is limited to the necessary minimum. Insofar as our service providers come into contact with your personal data, we ensure within the framework of order processing pursuant to Art. 28 DSGVO that they comply with the provisions of data protection laws in the same manner. Please also note the respective data protection notices of the providers. The respective service provider is responsible for the content of third-party services, whereby we check within the scope of reasonableness that the services comply with the legal requirements.
We attach importance to processing your data within the EU / EEA. However, it may happen that we use service providers who process data outside the EU / EEA. In these cases, we ensure that an adequate level of data protection is established at the recipient before transferring your personal data. This means that via EU standard contracts or an adequacy decision, a level of data protection is achieved that is comparable to the standards within the EU.
For the provision of the service, personal data is transferred to the following external service providers:
12.1 HERE Global B.V.
This app licenses map material and services from the company HERE Global B.V. and its partners. In the process, certain information is also transmitted from the App. This includes license data and data on the use of individual features by end users. However, this data does not identify individual end users.
13. Data security
We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to technological progress.