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Privacy Policy for the WizGo App
Date: September 2023
Version: 2.0
This Policy was translated with the support of semi-automized tools from the valid original German version. We checked carefully for mistakes and tried to provide a complete translation. Nevertheless, we cannot guarantee absolute correctness. You can find the original German version here.
Our privacy policy is regularly reviewed to ensure it aligns with evolving data protection laws, technology changes, and organizational developments. We will keep you informed of any updates.
Introduction to Data Privacy
Transparency and trust are the foundations of our approach. Accordingly, we will inform you, in compliance with relevant legal requirements, particularly the EU General Data Protection Regulation (EU GDPR) and the Federal Data Protection Act (BDSG), about:
- The processing of your personal data in connection with the use of the WizGo app
- Your rights and how to contact us
- Additional information and tips on data privacy and data security
1. Legal Basis for Processing Your Data
The processing of your personal data is based on legal grounds and, where necessary, your consent. The most important legal basis is the General Data Protection Regulation (EU GDPR) since May 25, 2018. We also comply with all other relevant legal requirements, especially those of the German Federal Data Protection Act (BDSG).
2. Data Controller
The data controller for processing personal data under the EU GDPR is WizGo UG (limited liability).
Hardenbergstraße 38,
10623 Berlin,
GERMANY
Tel.: +49 162 836 0195
Email: contact@wizgo.org
You can contact our data protection officers using the above contact details or at datenschutz@wizgo.org / +49 162 836 0195 (WizGo).
3. How Your Data Is Processed in Connection With the App
In our app, we follow the principle of data minimization, aiming to collect as little personal data from you as possible. Simultaneously, we strive to prevent misuse and enable a trustworthy interaction.
For personal data, this is limited to profile data visible to other users (see Profile) plus your email-address.
We process this information to provide you with our services, especially for:
- Connecting you with other nearby users, both individually and in group chats
- Conducting communications with public transport operators for the purpose of transmitting feedback/reports to them
- Transmitting feedback to the software developers
Unless otherwise stated in the following sections, we store this information for the duration of your use of the app and delete your personal data once it is no longer needed for the purposes for which it was collected or used, unless legal requirements (e.g., § 257 HGB or § 147 AO) require longer retention.
Legal Basis for Processing
The processing of data mentioned in Section 3 is carried out to perform the user agreement according to Art. 6 Para. 1 lit. b EU GDPR and to safeguard our legitimate interests according to lit. f EU GDPR.
3.1 Download & Installation
When downloading the mobile app, the data required for this purpose (especially username, email address, and customer number of your account, download time, payment information, and the unique device identifier) are processed by the app store provider as the data controller. We have no influence on this data processing and are not responsible for it.
3.2 Profile
In general, registration is required for most app functionalities. During onboarding or in the settings, we ask you to truthfully update the profile data visible to other users. This includes:
- Age
- Gender
- Languages spoken by you to assist other users
Additionally, you can customize your profile picture. This is important to help other users identify you personally.
You can update this data in your app settings at any time.
3.3 Filtering Settings and Trust Score
In your settings, you can decide which groups of other users you would generally trust based on their profile settings and trust score, and whose assistance you would accept. You can also choose whether users who do not match your settings should be completely hidden.
You will also be assigned a score based on ratings from other users.
These setting data are stored on the server along with your profile settings.
3.4 Obligation to Provide Data / Consequences of Non-Provision
The provision of the above mentioned data, unless otherwise indicated as ‚optional‘, is required for the conclusion of the user agreement and the use of the app. Without this data, the contract cannot be concluded, and the app cannot be used. The activation of access to the above-mentioned technical features is essential for the functionality of the app. If you choose not to provide this data, you can only use the app with limited functionality.
3.5 Using the App
To connect you with other users in your vicinity, provide you with location-specific information, and enable the functions of the Dashboard, your data is synchronized with the WizGo Server every time you start the app and during its operation. This notably includes:
- Your profile settings
- Whether you are in the immediate vicinity of a station or in public transport
- The current time
Outside of the station, your location data is not uploaded, and your phone must actively log into a station or public transport vehicle.
The transmission of this data occurs automatically through technology and is mandatory for using the app. Without it, the user agreement cannot be executed, and the app cannot be used.
We temporarily store your location based on your logins at stations/vehicles, as long as you do not perform other activities within the app. If you use the features to send reports or interact via chat messages, your messages will be associated with a location. These data will be deleted as described in the Data Deletion section.
3.6 Interacting with Other Users
When you use the support request feature, you may be connected with other users in your vicinity. In chats, you can exchange messages and requests for help and offers of assistance. For other users, aside from the message contents, your profile data and received ratings are visible.
These data, including message contents, are additionally transmitted to the WizGo Dashboard and are only accessible there to authorized users for the purposes of community management, emergency situation detection, and improving WizGo. These data are also semi-automatically analyzed and retained for a maximum of 2 years. By accepting this privacy policy, you explicitly agree to this.
Statistical data for which there is an additional legitimate interest and which are essential components of the service will not be deleted. During their storage and processing, they undergo a process of anonymization or pseudonymization, which ensures that personal identification is excluded.
3.7 Emergency Call
If you feel unwell and trigger an emergency call using the SOS button, you will be redirected to your phone app. There, you can dial the emergency number in the usual way. We have no influence on the correct functioning of this app and the data processing associated with it, and we are not responsible for it.
3.8 Push Notifications
If you have allowed this in your device settings, we use push services provided by the operating system manufacturers, Google and Apple. This allows us to send short messages directly to the notification center of your mobile phone. This functionality is used to inform you, for example, about support requests from a user or an emergency call, or to contact you on behalf of Wizgo or the Dashboard to provide you with important updates or relevant information.
3.9 WizGo Dashboard
In addition to the WizGo app, the WizGo Dashboard is also part of the IT system. This provides authorized Dashboard users with the opportunity to interact with app users (community management) and receive support requests and feedback. The collected data and metadata are also analyzed to provide Dashboard users with current and historical information about the quality and (perceived) safety of the infrastructure used by app users. Unless it involves direct communication with app users (reports or help requests), all data undergo a process of anonymization or pseudonymization, which ensures that individual users are no longer identifiable based on their personal data.
4. How Do We Use Your Data to Improve WizGo?
With your consent during the onboarding process (app introduction after creating your profile), we collect usage data. We use your usage data to, for example, identify which features of the app are used most frequently or rarely, or in which areas of the app users tend to abandon their usage. We use these insights to specifically enhance the user experience of the WizGo app. Usage data may include:
- Which menu items are accessed.
- Which app screens are displayed.
- Which elements (e.g., buttons) users interact with.
- On which app screens users terminate their interactions, and so on.
The legal basis for processing is Art. 6 para. 1 lit. f EU-GDPR. Our legitimate interest is to improve the user experience of the app and to correct errors.
Disabling and Objection
You have the option to object to the use of your data described in this chapter (collection and transmission of your usage data) by instructing us as described in the Tips on Data Protection and Data Security chapter.
5. How Do We Use Your Data for Advertising & Marketing?
5.1 Direct Advertising
We do not use any of the data stored in the WizGo app for direct or indirect advertising. If you wish to be informed about WizGo news, please subscribe to our newsletter on our website https://wizgo.org.
5.2 Pilot Operations
During executed pilot operations of the app, we may contact you regarding the mentioned app features (e.g., chats) to test functions or receive feedback. If we organize such tests, we will inform you about it during the app installation, and you have the option to opt out.
As part of these pilot operations, we may also conduct studies and surveys in the form of questionnaires. For this purpose, we have a cooperation with the Technical University of Berlin. The questionnaires aim to gain insights into the mood of public transport passengers, passenger experiences, and the testing of digital features. For more information, please use the contact options as listed in the section Who else will your data be shared with?.
If we conduct a prize draw among participants in this context, you must register separately for this, and your contact details will be stored for the duration of the pilot and until the draw. These contact details will be compared with the app’s usage data to verify your participation but will not be merged with them and will be deleted after the draw.
6. How Do We Use Your Data for Error Analysis?
We automatically collect data from you for error analysis. This helps us to reconstruct the cause in case of an error. This data is not merged with other information.
Processing
The processing of your data described in the previous section is based on our legitimate interest pursuant to Article 6(1)(f) of the EU General Data Protection Regulation (EU GDPR). Our legitimate interest is to offer the comfortable use of the app’s functions; ensure stability and security, and rectify malfunctions.
6.1 Connection Data
In the context of using the app or as long as the app is active, the app also transmits the following additional information („connection data“) to our server:
- Date, time, and IP address of access.
- Information about content that you retrieve with the WizGo app.
- Identification data of the used browser and operating system type.
These connection data are stored as log files by our servers by default for the purpose of system security and error analysis.
Connection data are deleted 42 days after storage.
7. Where Do We Transmit Your Data?
7.1 WizGo Server
We provide all central functions of WizGo through the WizGo server. We operate this server in Google’s data center with the data location in Western Europe. Data storage for WizGo also takes place here. If Google needs to access the data hosted in Europe from the USA due to technical issues or for system maintenance purposes, this is done based on approved EU standard contract clauses. Access from third countries is unlikely but cannot be completely ruled out.
7.2 Authorized Users
WizGo prepares your data as described under Wizgo Dashboard and displays it on a dashboard. Two categories of authorized users have access to this dashboard:
I. Administrators of WizGo UG to receive user feedback about the app and interact with users.
II. Employees of public transport companies to provide feedback on user interactions and user experience.
7.3 Who else will your data be shared with?
The Technical University of Berlin, Straße des 17. Juni, 12623 Berlin, receives access exclusively to anonymized data from the questionnaires and anonymized feedback as part of the joint pilot, and optionally, metadata about the application’s usage for statistical analysis. There is no possibility of identifying individuals at TU Berlin.
For questions, you can contact them at (Tel.: +4930314-73432 Fax: +4930314-21120, Email: martin.t.schlecht@tu-berlin.de) or info@datenschutz.tu-berlin.de / +49 30 314-21784.
8. Your Rights and Contact Information for Data Protection
8.1 Your Rights as a Data Subject
If our company processes data about you, you have the following rights to the extent provided by law:
- Information, in particular, about the data stored about you by the data controller and the purposes of processing (Article 15 EU GDPR).
- Correction of incorrect or completion of incomplete data (Article 16 EU GDPR).
- Deletion, for example, of unlawfully processed or no longer required data (Article 17 EU GDPR).
- Restriction of processing of your personal data (Article 18 EU GDPR).
- Data portability if the processing is based on consent or for the performance of a contract or is carried out using automated procedures (Article 20 EU GDPR).
- Object at any time to the processing of personal data concerning you (Article 21 EU GDPR).
To the extent that processing is based on your consent given (Article 6(1)(a) or Article 9(2)(a) EU GDPR), you have the right to revoke your consent at any time. Such revocation does not affect the legality of the processing carried out based on the consent until your revocation.
Furthermore, you have the option to complain about the collection and processing of your personal data:
- to our data protection officers (contact details see above under 2.), or
- to the competent supervisory authority Landesbeauftragte/r Berlin für Datenschutz und Informationsfreiheit Friedrichstr. 219, Puttkamerstraße. 16 – 18 (5. Etage), 10969 Berlin (mailbox@datenschutz-berlin.de).
8.2 Contact
To exercise your legal rights, you can contact us in the most convenient way for you using the contact information provided above under 2.
In the event of contacting us, your provided contact data (e.g., name, address, email address, phone number, and the contents of your message) will be stored and processed by us to answer your question. The processing is based on our legitimate interest pursuant to Article 6(1)(f) EU GDPR. Our legitimate interest is to provide you with satisfactory customer service and clarify the questions raised. We delete the data collected in this context after it is no longer required or – in the case of legal retention periods – restrict the processing. If you want to provide us with feedback and suggestions for improvement, you can reach us in the app settings under the menu item ‚Contact / Help.‘
9. Additional Information and Tips on Data Privacy and Security
9.1 Security of Your Data
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties, taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, as well as the existing risks of a data breach (including its likelihood and impact) for the data subject. Our security measures are continually improved in line with technological developments. We will be happy to provide you with more information on this upon request. Please contact our data protection officers for this (see 2).
To protect the security of your data during transmission, we encrypt your data with Secure Sockets Layer (SSL).
9.2 Data Misuse
Please note that we cannot rule out third-party misuse, such as in the case of smartphone theft. Therefore, we recommend:
- Securing your smartphone, for example, with a code lock.
- As a user, you are responsible for safeguarding your end device against misuse, malware, etc. This includes, in particular, securing access data in accordance with the state of the art, possibly by using the PIN locks of the end device and/or by securing the entered data beyond that. We recommend that you adequately protect against malware („viruses“), for example, by purchasing antivirus software, and keep your device’s operating system constantly up to date (updates and patches).
- If you notice any misuse of your data, please notify us immediately.
9.3 Deletion of Your Data
You can delete your personal data at any time by deleting your profile in the settings. Excluded from this are chat messages and all information about triggered emergency calls. Chat messages are stored for 30 days after being sent and are then automatically deleted, while information about triggered emergency calls is deleted immediately after evaluation for statistical purposes. After uninstallation, only your publicly visible profile data (3.2) and filter settings and Trustscore) (including all parameters) are saved. However, this information cannot be used to identify individuals.