Privacy Policy

 

Privacy Policy

As of: 15.03.2016

This Privacy Policy of GHT Mobility GmbH, Torgauer Str. 12-15, 10829 Berlin, Germany, operating under the name CleverShuttle (hereinafter "CleverShuttle" or "we"), applies to our mobile app for booking transportation services of the CleverShuttle driving service (the app and the CleverShuttle driving service together are referred to as "transportation services").

The protection of your personal information is very important to us. For this reason, we would like to provide you with a clear explanation of all occurring data processing methods when you use our app. We collect, process, and use your personal data exclusively in accordance with the principles described below and in compliance with the applicable data protection laws.

Your personal data

Personal data refers to all information relating to an identified or identifiable individual. This includes, for example, your name, your telephone number, as well as your mailing and e-mail address.

Categories of collected data

In order to use the CleverShuttle service, you are required to enter the personal data necessary for determining and processing the actual transportation service (e.g., name, location, destination, etc.) via our app. We use these data to the extent necessary to provide the transport service. In addition, you can optionally add voluntary information in the app (labeled as such), e.g., in order to create your own user account or to contact customer support. This includes your name, your e-mail address, and your concern. These data will be revocably stored and processed only with your consent.

We also collect additional data related to the app's use. These are divided into the following categories:

  • Location data: When you use our transportation services, we record location data (GPS data) about the booked and driven route via the app used by the driver, as well as the location determined by your mobile device if the app is open on your device.

  • Transactions data: Transaction details relating to your use of our transportation services, such as the date and time of the service rendered, the fare, the distance covered, and other related details, will be recorded by us (for tax and commercial reasons, among other things).

  • Usage data: To continually improve our system and service, we record and analyze your behavior regarding the use of our app, our service, and our system. For more information, please refer to Analytics,

  • Linked contacts: If a customer uses your personal Tell-a-Friend code during registration (optional) in order to receive a start-up bonus, we can associate this customer with your code and thus also your person. If you link your app account to a payment service (e.g., PayPal) or social media service (e.g., Facebook), we may obtain information about you or your connections from the associated website or app.

  • Ratings: Our drivers may subsequently provide user ratings via the app. We can examine and analyze these data.

  • Device information: Once you have installed the app on your mobile device, we can uniquely identify this device at any time when the app is open. This also applies if you reinstall the app on the same device after deletion. In addition, information about your mobile device is recorded and stored. This includes the hardware model and operating system as well as the language settings selected on the device. Your personal Apple or Google ID is not recorded.

  • Log files: When you use our transportation services, we record server logs, information such as IP addresses of devices, access data and times, app failures, and other system activities that occur during the use of our system. Log data are always recorded in relation to the device and not persons.

Mobile operating systems such as iOS and Android ("OS") define types of device data that apps can not access without your permission. When you first use the app or a function that requires access permission, the OS informs you of the access request and enables you to allow or deny access. Please note that denying access to the location services may render the app useless or result in limited functionality.

Use and sharing of your data

We collect and process these data to the extent required to

  • transact our transportation services and business procedures. This includes, for example, use of the data for finding optimized routes and carpooling groups, handling payments, and sending receipts,

  • control and monitor our transportation services and business processes. This includes, for example, use of the data for business processes that can not be automated, such as dealing with accidents, road closures, and system failures,

  • analyze and optimize our transportation services and business processes. This includes, for example, use of the data for identifying system errors and the development of new features (e.g., security functions) as well as for sending product updates.

  • process internal business transactions, e.g., to prevent fraud and misuse of our transportation services, correct software bugs and problems in the course of operations, perform data analyzes, tests, and research.

  • send you optional notices we believe could be of interest to you, for example, information about products, promotions, events of CleverShuttle and its partners, promotional drawings (please also refer to Ads).

In the cities of Berlin and Munich, the contract of transportation is concluded between you and GHT Mobility GmbH. In all other cities, the contract of transportation is concluded between you and a third party, also known as CleverShuttle. For the proper handling, control, monitoring, and optimization of the transportation services and business processes, we therefore pass on your data to these third parties as needed.

In addition, we will forward your data to third parties as needed, to the following parties or in the following situations:

  • to your contacts after you have explicitly requested us to do so by using certain features (e.g., Tell-a-Friend or notification of the expected time of arrival);

  • to the public when you post content to public forums, provide app ratings, write social media posts, or use other features of our system that can be viewed by anyone;

  • to subsidiaries of GHT Mobility GmbH who provide transportation services or administrative tasks on our behalf, as well as to external service providers who need access to these data in order to operate on our behalf (together hereinafter referred to as "Service Provider"). These Service Providers are carefully selected and assigned by us in writing. They are bound by our instructions, guarantee compliance with data protection regulations, and are regularly checked by us. The Service Providers will not pass on the data to third parties;

  • to other third parties if you expressly agree to the transfer to a specific third party. This applies, for example, to information from and to other apps or websites that can be integrated into our API, our system, or transportation services, or APIs, systems or transportation services into which we can be integrated;

  • in an anonymized, summarized, or aggregated form.

Analysis services

In order to continuously improve our system and service, including the incorporation of user requests and to optimize business processes, we use programs that allow us to analyze how you use the app.

We use the following web analytics:

  • Flurry Analytics (http://www.flurry.com/legal-privacy)

  • Google Analytics (https://www.google.de/analytics/terms/de.html)

These analytical services collect, among other things, the following technical data: Device model, operating system including version number, time stamp, app version, provider name, usage time and language setting, country code, time zone, network status, battery status, error reports. From this data, usage profiles can be created under a pseudonym. Cookies and similar technologies can be used for this purpose. These make it possible to identify your mobile device. At no time will this information be combined with your personal data.

Google and Flurry use this information on our behalf in order to evaluate how users use the app, to compile reports on the usage activities, and to provide additional services related to the use of the app and the Internet.

The information about your use of our app generated by Google Analytics and Flurry Analytics through the use of cookies is generally transferred to a Google or Flurry server in the USA and stored there.

You can disable the use of the analysis services at any time in the settings of the app and deactivate all tracking and evaluations. If cookies are also used for analysis, their use is stopped as soon as the analysis function is deactivated.

Advertising and product information

Within the context of using the app, you may voluntarily provide data which are not required for the provision of our services. By entering and subsequently transmitting these data, you consent to our collection, processing, and use of these data for the purposes indicated and associated upon entering the data. You may revoke this consent at any time with effect for the future.

In order to provide you with information about similar products or services provided by us by e-mail or text message, we may use your name, form of address, and your e-mail address. You may object to this use of your personal data for advertising purposes at any time for the future.

Social sharing

Some features of our app actively involve social sharing services (e.g., Facebook), which allow you to share information with other users about our service (e.g., sharing your arrival time in your Facebook profile). The use of these services involves the exchange of your data with your friends and/or the public. The scope of the exchange depends mainly on your own configuration of the used sharing service.

Protection of your data

We secure our app and IT systems by appropriate technical and organizational means against loss, destruction, unauthorized access, alteration, or dissemination of your data by unauthorized persons. In particular, we will take the following measures to protect your personal data in accordance with this privacy policy:

  • The transmissions of payment and log-in data are made exclusively using the Secure Socket Layer (SSL) encryption method with at least 128 bits.

  • When the sender of the data is connected to Wi-Fi, all transmitted data is encrypted with at least 128 bits using the Secure Socket Layer (SSL) encryption method.

  • We store all collected data behind a series of firewalls.

  • All payment and log-in data are additionally encrypted on our servers using the encryption method SHA-256 and SHA 512, respectively.

  • Optional payments via the app are handled exclusively by PayPal. PayPal uses its own security certificates and licenses (e.g., PCI-DSS Certified PCI Level 1). Your personal payment information (e.g., credit card number) is never processed via our servers and is therefore neither collected nor stored by us.

Right to information, rectification, blocking, and deletion of your data

You are entitled to information about data stored about you free of charge as well as a right to rectification, refusal of access or deletion of your data where appropriate.

If you want to delete your account including all the data stored for this purpose, please send an e-mail to delete_account@clevershuttle.de.

You may revoke your consent for data collection, processing and use at any time with effect for the future. Please contact us by e-mail at legal@clevershuttle.de.

We would be glad to answer any questions you may have about data protection and the processing of your personal data. Please contact us at the following e-mail address: legal@clevershuttle.de. Of course, you can also contact us under the contact details provided in the legal notice.

Changes

We reserve the right to update this Privacy Policy from time to time. Updates to this privacy statement are posted on our website http://clevershuttle.org. Changes are valid as of their publication on our website. We therefore recommend that you visit this site regularly to check for updates.

* * *