1 Implementation of and Compliance with this Data Privacy Statement
We, Via Verde Serviços, S.A., a company registered with the Commercial Registry of Cascais under VAT number 509039863, with registered address at Quinta da Torre da Aguilha, 2785-599 São Domingos de Rana, (hereinafter referred to as "we" or "VVS), are providing you with a smartphone application (hereinafter referred to as the "app"), with which you (hereinafter also referred to as the "user") can track your movements and your mobility free of charge during your everyday activities within the framework of the General Terms and Conditions, for a period of up to 12 (twelve) weeks (hereinafter referred to in general as the "service"). Since the protection of your personal data – especially with regard to protecting your personal rights in collecting, processing, and using data – is important to us, we are providing you this information on aspects of use relevant to data privacy.
Before agreeing to the use of the service, please carefully read all of the information we provide on data privacy. VVS hereby undertakes to adhere to the following points related to data privacy as described.
2 Purpose of Collection
The transport industry is becoming ever more dynamic, and is trending towards diversification. New types of services like car and bike sharing are becoming more and more popular. Against this background, classic tracking instruments like travel diaries are no longer sufficient means of collecting data on mobility.
In order to understand and shape these changes in the mobility world and aiming at the study and analysis of a potential offer of services, up-to-date and detailed information on mobility behaviour must be available.
3 Description of the Service
The service has been developed to provide new insights into mobility behavior and to collect relevant key data, such as modal splits or transport volumes, as well as to identify centers of use for individual means of transport (hot spots), aiming at the study and analysis of a potential offer of new services. The data recorded (see 4) and corrections of stages help us to improve the quality of the methods by which we determine this key data, and thereby improve the service itself.
4 Collection Methods
4.1 Movement Data
We use the app to collect your movement data (hereinafter referred to as "movement data"). We complete traffic analyses based on this movement data. These allow us to derive key data related to mobility (e.g. modal split). Furthermore, we determine trip purposes using activity patterns recorded over multiple days and spatial analyses.
Traditional approaches are no longer sufficient to precisely record trips which use various methods of transportation (intermodal trips). The app records mobility behavior pseudonymously. Over a long period of time, this allows us to quantify indications of a change in mobility behavior, and to improve the MotionTag service using your feedback.
As soon as you start recording in the app, we collect data points that contain spatial coordinates, times, and states of movement. We have developed algorithms that interpret groups of these data points as stages using various methods of transportation, and determine other associated attributes like duration and distance. If you record over multiple days, the app can create multi-day movement profiles.
Although movement profiles are recorded pseudonymously, revisiting the same location multiple times can allow conclusions to be drawn regarding residences, places of employment, and individual persons. Even if no attempt is made to identify users, recorded mobility profiles are personal data. Accordingly, we treat these with the same sensitivity as we do your personal registration data (user name, e-mail address).
Both the apps for iOS and Android operating systems transmit information on:
- your smartphone model,
- operating system version,
- app version,
- location data, and
- movement activities pre-analyzed by the mobile phone (e.g. “motorized” or “walking”), as well as the data listed under 4.2.
All further attributes, such as the means of transportation used or the trip purpose, are calculated using algorithms based on these input data, as well as through a comparison with geodata (geomatching). Geodata includes data from the OpenStreetMap project.
4.2 Type and Scope of Data Collected
The following list provides an overview of the data collected:
Primary identification data
- User name and e-mail address for establishing contact, recruiting, and potential incentives.
- Registration information for registering through the app
- Time of localization
- GPS coordinates and precision (determined by GPS chip)
- Acceleration values (determined by sensors in smartphone)
- Gyro sensor values (determined by sensors in smartphone)
- Barometer / air pressure data (determined by sensors in smartphone)
- Magnetometer (determined by sensors in smartphone)
- Movement activities from operating system
- Detection reliability (confidence) for movement activities
- User agent device type, operating system version, app version)
4.3 Processing Movement Data
After being recorded by the app, data is transmitted via Wifi connection or, if activated, through mobile data to a server managed by MotionTag GmbH, a German company with head office at Rudolf-Breitscheid-Str. 162, 14482 Potsdam, which acts as Data Processor on behalf of VVS, in an ISO certified computing center, where it is saved in a databank. Transmission of data recorded by the app occurs exclusively through encrypted procedures. Raw data is processed on our server using the analyses described above.
4.4 Saving Data in the App
Besides the data points collected, the app itself saves only the e-mail address for the login of the last user. This makes it easier to log in again, since users do not need to re-enter their e-mail addresses. Passwords and other user information are not saved. After data points are transmitted to the server, they are deleted in the app.
4.5 Establishing Contact
We would like to keep you informed of important information such as new features, changes to the Data Privacy Statement, or new matching projects. We would like to use the e-mail address you provided during registration to do so.
5 Transfer to Third Parties
The data is processed by MotionTag GmbH, Rudolf-Breitscheid-Str. 162, 14482 Potsdam, which acts as Data Processor on behalf of VVS, in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation). External service providers who process data for us under contract are subject to strict contractual obligations in accordance with the General Data Protection Regulation.
We transmit data to service providers through an encrypted and secured connection. We use computing centers (Amazon Web Services) certified in accordance with ISO 27001.
6 Saving and Deleting Movement Data
You can block or delete all of your movement data at any time. To do so, you can simply send us an email to firstname.lastname@example.org with the subject “Please delete movement data” from the e-mail address with which you registered for our service. We will then remove your data from the live system, so that it will not be included in further assessments.
Deletion of data is irreversible, and data will be deleted from all data media, including back-up memories. For technical reasons, however, deletion from back-up memories will be subject to a time delay.
All data saved in the app will be deleted when you uninstall the app.
Your stages are displayed on a map in the app. You can also use the app to correct your analyzed stages.
7 Individual Rights
7.1 Right of revocation and objection
Independently of the above mentioned provisions it is your right at all times (in accordance with Art. 7(3) and Art. 21 GDPR) to contradict the use of your data and revoke any previous given consent for your data being processed.
In case of revocation of consent to process your data or use of any data obtained, legality of data processing up to the date of revocal cannot be disputed.
7.2 Right of adjustment, blocking and limitation
Moreover, you can ask us to adjust, block or delete data collected by us (Art.16, 17, 180 GDPR). We would like to explicitly point out that there may be legal obligations to continue storing data - in this case this data can only be blocked.
7.3 Right for data portability and complaint to a regulatory body
Since May 25, 2018 you furthermore have the right to data portability (Art. 20 GDPR) and the right to complain to the responsible regulatory body in accordance with Art. 77 GDPR.
National Data Protection Commission, address - Av. Dom Carlos I 134 - 1 º, 1200-651 Lisbon, Portugal
7.4 Contact person for exercising individual rights
According to Art. 15 GDPR you are entitled to receive information on what data of you is stored (right to information). The responsible party of the processing of data is VVS and MotionTag GmbH acts as its Data Processor. To exercise the above mentioned rights please contact EPD_VVS@viaverde.pt .
Via Verde Serviços, S.A.
Quinta da Torre da Aguilha, Edifício Brisa
2785-599 São Domingos de Rana, Portugal