As part of the app, we offer users reliable navigation with individual navigation profiles, detailed route planning and many other extras on their own smartphone or tablet. The app simplifies the connection to other devices (especially the e-bike), enables the user to plan routes and evaluate his data easily.
When using the app, we process personal data of the user. By personal data we mean all information relating to an identified or identifiable natural person.
Because the protection of your privacy is important to us, we would like to use the following information to inform you which personal data we process when you use the app and how we handle this data. In addition, we will inform you about the legal basis for the processing of your data.
1. Information on the processing of your data
Certain information is already processed automatically when you use the app. We have listed the specific personal data that will be processed for you below:
1.1. Information collected during download
When you download the app, certain necessary information will be transmitted to the App Store you select (e.g. Google Play or Apple App Store), including but not limited to your username, email address, customer number of your account, time of download, payment information, and unique device identification number. The processing of this data is carried out exclusively by the respective App Store and is beyond our control.
1.2. Information collected at the time of first use
During your first use of the app the following information of the user will be requested:
- Bicycle Type
- Bicycle Weight
This information is stored in the end device and is anonymized and transferred to us; (1) to provide you with the service and related features; (2) to improve the features and performance of the app.
This data processing is legitimated because (1) you consent to the processing by providing the data in accordance with Art. 6 para. 1 lit. a) GDPR or (2) we have a legitimate interest in being able to offer a service that is in line with the market and interest-oriented and outweighs your rights and interests in the protection of the data to be processed within the meaning of Art. 6 para. 1 lit. f) GDPR.
1.3. Information that is collected automatically
As part of your use of the app, we automatically collect certain data required for the use of the app. This includes
IP address and time of access
Requesting server (so-called user agent)
ID of the end device (so-called UUID)
Type, version of the operating system, and language of the end device.
Distance to next intersection
This data is automatically transmitted to us and stored by us in accordance with Section 4 (1) in order to provide you with the service and the associated features; (2) to improve the services and features of the App; and (3) to prevent and eliminate misuse and malfunctions.
This data processing is legitimate because (1) the processing is necessary for the fulfilment of the contract between you as the data subject and us pursuant to Art. 6 para. 1 lit. b) GDPR for the use of the app, or (2) we have a legitimate interest in ensuring the operability and error-free operation of the App and can offer a service that is in line with the market and interest-oriented and outweighs your rights and interests in the protection of the data to be processed pursuant to Art. 6 Para. 1 lit. f) GDPR.
1.4. Use of the app
When using the app, we collect the following data in anonymous form, which is required for the use of the app or the features offered. These are, as far as e.g. over connected devices made available:
- Location, start and end point (only at 500m distance)
- Type of bicycle, Weight of bicycle
- Motor SW version
- Engine type
- Error codes
- Support level
- Total time
- Total distance
- Active Time
- Battery software version
- Cell temperature
- Maximum cell temperature
- Minimum cell temperature
- Battery temperature
- Battery Management System Power Supply
- Battery Management System Voltage
- State of charge
- Battery condition
- Remaining capacity
- Full capacity
- Maximum voltage
- Minimum voltage
- Charge current / discharge current (maximum, minimum and average respectively)
- Engine temperature
- Power reduction
- Motion profile
- Downloaded maps
- Bike UUID
This data is automatically transmitted to us and stored by us in anonymous form in accordance with Section 4 (1) in order to provide you with the service and the associated features; (2) to improve the services and features of the app; and (3) to prevent and eliminate misuse and malfunctions. An assignment to a specific user is not possible for us.
The App also requires the following authorizations:
- Internet access: This is required in order to save your entries on our servers.
- Location access: This is required in order to be able to offer the corresponding location-related functions.
- Access to external memory card: This is needed to ensure the possibility of data storage on the external memory card.
The processing and use of this usage data is done to provide the service. This data processing is legitimated by the fact that the processing is necessary for the fulfilment of the contract between you or the respective customer and us pursuant to Art. 6 Para. 1 lit. b) GDPR.
In accordance with Art. 13 GDPR, you must inform the respective customer about this data processing and the transfer to us at the time of collection.
2. Transmission and transfer of data
The data to be processed will only be transmitted without your express prior consent in addition to the cases explicitly mentioned in this data protection declaration if it is legally permissible or necessary.
2.1. The information that you provide during the registration will be shared within our group of undertakings for internal administrative purposes, including joint customer support as necessary.
Any transmission of personal data is legitimate by the fact that we have a legitimate interest in disclosing the data for administrative purposes within our group of undertakings and that your rights and interests in the protection of the data to be processed within the meaning of Art. 6 para. 1 lit. f) GDPR do not predominate.
2.2. For the provision of our service we are dependent on the following external companies and service providers:
GPS Tuner Systems Kft, Vérmezö út 4, 1012 Budapest. Hungary
Any transmission of personal data is legitimate because we have carefully selected our third-party companies and external service providers as contract processors in accordance with Art. 28 (1) GDPR, regularly checked them and contractually obliged them to process all personal data exclusively in accordance with our agreement with said companies.
3. Data transfers to third countries
A transfer to states outside the European Economic Area does not take place.
4. Period of data storage
We erase or anonymize the data to be processed as soon as they are no longer required for the purposes for which we have collected or used them in accordance with the above paragraphs. As a rule, we store the data to be processed for the duration of the usage or contractual relationship via the app plus a period of 30 days during which we store backup copies after erasure, provided that this data is no longer needed for criminal prosecution or to secure, pursue or enforce legal claims.
Specific details in this data protection declaration or legal requirements for the storage and erasure of personal data, in particular those which we have to store for tax reasons, remain unaffected.
5. Rights of the data subject
5.1. Right of access
You have the right to obtain from us at any time upon request information on the personal data processed by us concerning you in the scope of Art. 15 GDPR. For this purpose, you may submit an application by post or by e-mail to the address given above.
5.2. Right to rectification
You have the right to ask us to correct your personal data immediately if it is inaccurate. If you wish to do so, please contact us at the above address.
5.3. Right to erasure
You have the right, under the conditions described in Art. 17 GDPR, to request us to erase your personal data. In particular, these conditions provide for a right of erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, or in cases of unlawful processing, the existence of an objection or the existence of a duty to erase under Union law or the law of the Member State to which we are subject. For the period of data storage, please see Section 5 of this data protection declaration. In order to assert your right to erasure, please contact us at the above address.
5.4. Right to restriction processing
You have the right to demand from us the restriction of processing in accordance with Art. 18 GDPR. This right exists in particular if the correctness of the personal data is disputed between the user and us, for the duration which the verification of the correctness requires, as well as in the event that the user demands limited processing instead of erasure in the case of an existing right to erasure; furthermore in the event that the data is no longer necessary for the purposes pursued by us, but the user requires it for the assertion, exercise or defense of legal claims, and if the successful exercise of an objection between us and the user is still disputed. To exercise your right to restrict processing, please contact us at the above address.
5.5. Right to data portability
You have the right to receive from us the personal data concerning you which you have provided to us in a structured, common, machine-readable format in accordance with Art. 20 GDPR. To exercise your right to data portability, please contact us at the above address.
6. Right to object
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is carried out, among other things, on the basis of Art. 6 para. 1 lit. e) or f) GDPR, pursuant to Art. 21 GDPR. We will terminate the processing of the data to be processed unless we can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms, or if the processing serves the assertion, exercise or defense of legal claims.
7. Right to complain
You also have the right to address complaints to the competent supervisory authority.
8. Changes to this Data Protection Declaration
We always keep this data protection declaration up to date. Therefore, we reserve the right to change it from time to time and to update changes in the collection, processing or use of your data.
Last update: 30.07.2020