Privacy Policy

 

Privacy Policy

As of: 16.11.2017

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 includes all particulars that refer to an identified or identifiable natural person. This includes details such as your name, your telephone number and your postal or emailaddress.

Categories of data collected

To use the CleverShuttle car service, you need to use our app to enter personal data, which is required to identify and process the transport service in question (such as your name,
location, destination, etc.). We use this data to the extent required in order to provide you
with the transport service. You can also enter additional optional details in the app (these are
marked as such), such as are needed to create your own personal account or contact our
Customer Support, for example. These items of data include your name, your email address
and your enquiry. This data is stored and processed only with your consent (you may also
request erasure of the stored data).

We also collect other items of data as part of your usage of the app. This data can be grouped into the following categories:

  • Location data: When you make use of our transport services, we collect location data
    (GPS data) about the route booked and driven from the app used by the driver, as well as the location identified and transmitted by your mobile device, if the app is running.

  • Transactions data: Transaction details associated with the usage of our transport services, such as the date and time of day that the service was provided, the trip charge, the route driven and other associated details are also collected by our company (also to ensure we comply with requirements from tax and commercial legislation).

  • Usage data: To ensure we can make continuous improvements to our system and our services, we collect data on and analyse the ways in which you use our app and our car service. For details, please see “Analysis services”.

  • Linked contacts: If a customer uses your personal Tell-a- Friend code for their (optional) registration, so as to receive a starting bonus, we can associate this customer with your code and therefore also with you. If you link your app account to a payment service (e.g. PayPal) or social media service (e.g. Facebook), we can receive information about you or your links from the associated website or app.

  • Ratings: After the journey, our drivers can use the app to enter user ratings about you. We can see and analyse these ratings.

  • Device data: Once you have installed the app on your mobile device, we can uniquely identify this device at any time when the app is running. This also applies if you delete the app and then reinstall the app on the same device. Information about your mobile device is also collected and stored. This includes the hardware model and operating system, and the language setting selected on the device. Your personal Apple ID or Google ID is not collected.

  • Log data: When you use our transport services, we collect server logs, information such as the IP addresses of devices, login details and login times, app outages and other system activities that may occur while our system is being used. Log data is always collected in relation to a device and not an actual person.

Mobile operating systems such as iOS and Android (“OS”) define categories of device data that apps are not allowed to access without your consent. The first time an app or function is used that requires a specific type of permission, the OS will inform you about this permission request and gives you the option of granting or denying the app this permission. Please note that denying the app the location services permission may result in the app becoming unusable or usable only with restricted functionality.

Use and sharing of your data

We collect and process this data to the extent required, for the following reasons:

  • To provide our transport services and run our business processes. This includes using the data to identify optimised routes and car sharing groups, for example, or to receive and handle payments, and send receipts.

  • To manage and monitor our transport services and business processes. This includes utilising the data for business processes that cannot be automated – such as handling accidents, road blockages and system outages, for example.

  • To analyse and optimise our transport services and business processes. This includes using the data to track down system errors or to develop new features (such as safety/security functions) or to send out product updates.

  • To run internal business processes, which are used to prevent fraud and the abuse of our transport services, to fix software bugs and problems in business operations, and to perform data analyses, tests and research activities.

  • To send you optional messages that we think would be of interest to you, such as information about products, advertising campaigns, events organised by CleverShuttle and its partners, and prize competitions (see also under Advertising).

In the cities of Berlin and Munich, the legal contract of carriage is made between you and GHT Mobility GmbH. In all other cities, the contract of carriage is made between you and a third party who also operates under the CleverShuttle brand. To ensure the proper and correct handling, management, monitoring and optimisation of the transport services and business processes, we share your data with these third parties to the extent required.

In addition, we also share your data to the extent required with the following groups of people and third parties in the following situations:

  • With your contacts, after you have expressly requested that we do so by using certain features (e.g. Tell-a- Friend or sharing your estimated arrival time).

  • With the general public, if you publish content onto public forums, post app ratings, write social media articles or use any other features of our system that can be viewed by anyone and everyone.

  • With subsidiaries of GHT Mobility GmbH that perform transport services or complete administrative tasks on our behalf and with external service providers that require access to this data to fulfil the work we have commissioned (collectively hereinafter “service providers”). These service providers are carefully selected by us and commissioned in writing. They are obliged to follow our instructions, agree to uphold data protection safeguards and are audited by us at regular intervals. The service providers do not share the data with third parties.

  • With other third parties, if you expressly agree to this sharing. This affects information sent to and from other apps or websites, for example, which can be integrated with our API, our system or our transport service, or other APIs, systems or transport services with which we can be integrated.

  • In an anonymised, summarised or aggregated format.

Analysis services

To ensure we can continuously improve our system and our service provision, and optimise our business processes whilst also catering to user requests, we utilise a range of programs that enable us to analyse your usage of our website and our app.

To do so, we use the following web and app analysis services:

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

  • Flurry Analytics (https://flurry/legal-privacy)

  • Facebook Analytics ( https://www.facebook.com/policy)

  • Adjust (https://www.adjust.com/privacy-policy)

  • These services collect technical data that includes the following: user device model, operating system incl. version number, time stamp, app version, provider name, usage time and language setting, country code, time zone, network status, battery status, error reports and user activities. These items of data may be used to create pseudonym-based usage profiles. Cookies and similar kinds of technologies may also be used. These enable the identification of your mobile device on subsequent occasions. Under no circumstances is this technical data aggregated with your personal data.

    We use this technical data to analyse the use of the app by its users and to compile reports on usage activities, and to use these analyses and reports to improve the service that we provide.

    The technical data about your use of our service generated with the help of the analysis services is typically transferred to a server run by the analysis services in the USA, and stored there.

    Advertising and product information

    When using our app, you have the option of providing certain kinds of data on a voluntary basis that is not required for us to provide our services to you. Regarding this data, when you enter your data for subsequent transfer to our servers, you simultaneously give your consent for us to collect, process and utilise this data for the purposes that are identifiable when entering your data and are associated with this data entry. You can withdraw this consent with future effect at any time.

    To provide you with information about similar products or services via an electronic channel (i.e. by email or text message), we may use your name, your form of address (title/salutation) and your email address. You can withdraw your consent to this use of your personal data for marketing purposes with effect for the future at any time.

    Social sharing

    Some features of our app actively integrate social sharing services (e.g. Facebook), which enable you to share information with other people about the services we provide (e.g. to post your arrival time on your Facebook profile). The use of these services includes the sharing of your data with your friends and/or the general public. The degree to which data is shared is directly dependent on your personal configuration of the sharing service used.

    Protecting your data

    We utilise a range of technical and organisational measures to secure our app and IT systems against loss, destruction and unauthorised access, and the modification or sharing of your data by unauthorised persons. In particular, we utilise the following measures to protect your personal data in accordance with this privacy policy:

    • All transmission of payment and login data uses the secure socket layer (SSL) encryption technique with a key length of at least 128 bits at all times.

    • If the device sending the data is using a Wi-Fi network, all data transmitted is encrypted using the secure socket layer (SSL) encryption technique with a key size of at least 128 bits.

    • All of the data we collect is stored behind a series of firewalls at all times.

    • All payment and login data stored on our servers is additionally encrypted using the SHA-256 or SHA-512 encryption technique.

    • Optional payments via the app are handled exclusively with PayPal. PayPal for its part deploys security certificates and licenses (e.g. PCI-DSS Certified PCI Level 1). Our servers are ever involved in the handling of your personal payment data (e.g. credit card number) and we therefore neither collect nor store such payment data.

    Right to information, correction, blocking and erasure of your data

    You have the right to obtain information about the personal data we store about you at no charge, and you also have the right to correct, block or erase this data as required.

    If you want to delete your account, including all of the data related to this account, please email us at delete_account@clevershuttle.de.

    You can withdraw the consent you have given to data collection, processing and usage with future effect at any time. To do so, please email us at legal@clevershuttle.de.

    We are happy to answer any other questions you may have about data protection and the processing of your personal data. Please send us your enquiry by email to legal@clevershuttle.de. You can of course also contact us by using the contact details given in our legal notice.

    Updates to this policy

    We reserve the right to update this privacy policy from time to time. Updates to this privacy policy will be published on our website at clevershuttle.org. Changes enter into force once published on our website. We therefore recommend that you visit our website regularly to inform yourself about any changes we have made to this policy.

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