App Data Privacy - Private User | EU
The "Pave Commute" app ("App") is operated by Carployee GmbH, FN 487221b, Peter-Behrens-Platz 10 ("we" or "us"). Since the protection of your personal data ("data") is of particular concern to us, we process your data exclusively on the basis of the applicable legal provisions. In this statement, we inform you in accordance with Art 13 and 14 of the General Data Protection Regulation ("DSGVO") about how we, as the data controller, process your data in connection with the App.This privacy statement is intended for private individuals who use the app without being linked to an organizational account ("users"; collectively "you", "your"). Corporate customers, in particular employers / universities / recreational institutions including their representatives ("Organization") as well as their employees / students / participants who use the App and whose account is linked to the respective Organization account, we refer to the existing privacy policy for this customer and user group (Privacy Policy Pave Commute App - Corporate Customers).
The app can be downloaded to a mobile device via Google Play Store or Apple App Store ("App Store"). In the course of registering a user in the app, the user can either create a user account via email or use an existing user account from Google or Apple (Single Sign On, "SSO").
If a user decides to register using SSO and clicks on the respective registration button, he or she is automatically redirected to the pages of Google or Apple. There, the user can log in to his or her user account. This links the respective Google or Apple user account with our app. This link gives us access to a user's data stored at Google or Apple. These are in particular name and email address. This data is used exclusively to set up, provide and personalize the app user account. We do not use the registration to access personal data such as friend lists or contacts or to store them for our own purposes.
This processing of data in the context of the registration of a user is carried out on the basis of our to fulfill our (pre-) contractual obligations arising from the contractual relationship with you (Art 6 para 1 lit b DSGVO), to fulfill legal obligations (Art 6 para 1 lit c DSGVO) and/or to protect legitimate interests to operate the app and grant users access to the app, unless the interests of the user in the confidentiality of the data prevail (Art 6 para 1 lit f DSGVO).
Processing in the context of any linking with SSO services is based on the consent of the user pursuant to Art 6 para 1 lit a DSGVO. Users can undo the link at any time via their Google or Apple user account.
Users receive suggestions regarding optimal travel routes and means of transport within the scope of using the app. In addition, users can also search for carpooling opportunities or exchange information with like-minded users about their travel route or choice of means of transport within the framework of chat groups. Users can either create chat groups themselves or search for groups based on days, times, transportation mode and their respective location ("matching"). Chat groups are created for users who have a similar or identical travel route, but a maximum of 5 people per chat group are connected ("matches"). In the course of matching, only the first name, the user name, and the respective distance of different users to each other as well as information about the same/similar working hours and days are visible to other users. Users are free to further exchange information via the chat and to share their exact route or address or location with other users.
This processing of data in the context of matching or the creation and search of chat groups is carried out for the fulfillment of our (pre-) contractual obligations arising from the contractual relationship with you (pursuant to Art 6 para 1 lit b DSGVO), for the fulfillment of legal obligations (Art 6 para 1 lit c DSGVO) and/or on the basis of our legitimate interest in being able to offer the best possible service within the framework of the app for users, unless the interests of the user in the confidentiality of the data prevail (Art 6 para 1 lit f DSGVO).
The disclosure of data other than the user name, the respective distance to other users as well as information on the same/similar working hours and days (e.g. exact route, address or location) to other users via the app occurs at most on the basis of the user's consent pursuant to Art 6 para 1 lit a DSGVO.
In the course of using our app, we collect the following data from users, in particular for the purposes of quality assurance and further development of the app: date, time and duration of use of the app, IP address, system data on the device and operating system used. We collect this data automatically with cookies and analysis tools provided by third-party providers based on the consent of the user pursuant to Art 6 para 1 lit a DSGVO (or iVm § 165 para 3 TKG in the case of so-called "persistent" cookies, which are stored on the end device of the user).
Users can refuse the storage of individual cookies or the use of analysis tools (by means of configuration in the cookie banner) or revoke the storage or use of analysis tools in the app settings at a later time. When cookies are set or analysis tools are used on the basis of voluntary consent, user data is sometimes transmitted to recipients in third countries outside the EEA, in particular to the USA. The USA has not been certified by the European Court of Justice as having an adequate level of data protection; in particular, there is a risk that data may be viewed by US authorities for control and monitoring purposes. By giving their consent, users agree that cookies and analysis tools from third-party providers in the USA or from other insecure third countries may be used and accept a possible lower level of data protection (Art 49 para 1 lit a DSGVO).
Cookies that are absolutely necessary for the structure or functioning of the app (technically necessary cookies) cannot be deactivated. In these cases, the data processing is based on our legitimate interest pursuant to Art 6 para 1 lit f DSGVO to be able to provide the app in a correspondingly functional manner.
In order to fully exploit the functionalities of the app, in particular to receive optimal suggestions regarding the choice of means of transport and routes or carpooling to the desired destination or to check whether users also implement these suggestions correctly, the app accesses the user's location and activity sensors of the user's terminal device. This is done exclusively on the basis of explicit consent pursuant to Art 6 para 1 lit a DSGVO, which users can edit or revoke at any time in the app settings. The user can give consent either generally or manually by means of "start and stop".
In order to keep users up to date with regard to new features of the app, they receive regular emails about any technical innovations within the scope of app use.
We base this data processing on our legitimate interest pursuant to Art 6 para 1 lit f DSGVO to improve the use of the app and to inform users about innovations. Users have the option to unsubscribe from notifications at any time via the link provided in the respective email.
If users contact us via email or via the contact options otherwise offered, the data provided by the user will be processed in order to process and respond to the respective request, in particular: Name, email or phone number, any data provided in the text or conversation.
We process data for the purpose of contacting us in the context of (pre)contractual relationships pursuant to Art 6 para 1 lit b DSGVO and/or for the fulfillment of legal obligations (Art 6 para 1 lit c DSGVO).
We generally store user data for the duration of their contractual relationship with us as well as beyond that in accordance with the statutory retention and documentation obligations. If the processing of user data is based on consent, we store the data until revoked by the respective user.
Your data will be transferred to the following recipients in the course of processing for the above-mentioned purposes:
* IT service providers used by us
* Banks, tax consultants, auditors
* In case of need to legal representatives, notaries, courts and administrative authorities
If the above-mentioned recipients are order processors within the meaning of Art 4 No. 8 DSGVO, they will be obligated to comply with data protection provisions in accordance with Art 28 DSGVO.
If the above-mentioned recipients of your data are located outside the EEA and it has not been determined by decision of the EU Commission that the country in question has an adequate level of data protection, we will ensure that the transfer takes place on the basis of standard contractual clauses or otherwise in accordance with Art 46, 47 or 49 DSGVO.
If we process data from you, you have the right to information about the processing purposes, the categories of data processed, the recipients of this data, storage period, the rights you are entitled to, the origin of the data and the existence of automated decision-making.
You are entitled to request the rectification of incorrect or incomplete data concerning you. You are entitled to request the erasure of data concerning you, provided that the processing of the data is not lawful and there are no legal obligations on our part against the erasure.
You are entitled to request the restriction of the processing of your data in certain cases.
You have the right to request the transfer of your data that you have provided to us in a structured, common and machine-readable format. You have the right to have the data transferred by us directly to a responsible party, insofar as this is technically feasible.
You are entitled to object to the processing of data concerning you at any time on grounds relating to your particular situation. If you object, we will not further process data concerning you unless we can demonstrate that our reasons for processing outweigh your interests.
You have the right to revoke any processing of your data which is based on your consent at any time. This will not affect the lawfulness of the data processing carried out up to that point.
If you believe that the processing of your data violates data protection law or that your data protection rights have otherwise been violated in some way, you can complain to the supervisory authority. In Austria, this is the Data Protection Authority, Barichgasse 40, 1030 Vienna (www.dsb.gv.at).
For questions or personal concerns, please contact:
Carployee GmbH
A-4020 Linz, Peter-Behrens-Platz 10
Tel.: +436802381701
Email: support@pavecommute.app
1. How do we process your data?
a.) Registration
The app can be downloaded to a mobile device via Google Play Store or Apple App Store ("App Store"). In the course of registering a user in the app, the user can either create a user account via email or use an existing user account from Google or Apple (Single Sign On, "SSO").
If a user decides to register using SSO and clicks on the respective registration button, he or she is automatically redirected to the pages of Google or Apple. There, the user can log in to his or her user account. This links the respective Google or Apple user account with our app. This link gives us access to a user's data stored at Google or Apple. These are in particular name and email address. This data is used exclusively to set up, provide and personalize the app user account. We do not use the registration to access personal data such as friend lists or contacts or to store them for our own purposes.
This processing of data in the context of the registration of a user is carried out on the basis of our to fulfill our (pre-) contractual obligations arising from the contractual relationship with you (Art 6 para 1 lit b DSGVO), to fulfill legal obligations (Art 6 para 1 lit c DSGVO) and/or to protect legitimate interests to operate the app and grant users access to the app, unless the interests of the user in the confidentiality of the data prevail (Art 6 para 1 lit f DSGVO).
Processing in the context of any linking with SSO services is based on the consent of the user pursuant to Art 6 para 1 lit a DSGVO. Users can undo the link at any time via their Google or Apple user account.
b.) Matching, creation and search of chat groups within the scope of app use
Users receive suggestions regarding optimal travel routes and means of transport within the scope of using the app. In addition, users can also search for carpooling opportunities or exchange information with like-minded users about their travel route or choice of means of transport within the framework of chat groups. Users can either create chat groups themselves or search for groups based on days, times, transportation mode and their respective location ("matching"). Chat groups are created for users who have a similar or identical travel route, but a maximum of 5 people per chat group are connected ("matches"). In the course of matching, only the first name, the user name, and the respective distance of different users to each other as well as information about the same/similar working hours and days are visible to other users. Users are free to further exchange information via the chat and to share their exact route or address or location with other users.
This processing of data in the context of matching or the creation and search of chat groups is carried out for the fulfillment of our (pre-) contractual obligations arising from the contractual relationship with you (pursuant to Art 6 para 1 lit b DSGVO), for the fulfillment of legal obligations (Art 6 para 1 lit c DSGVO) and/or on the basis of our legitimate interest in being able to offer the best possible service within the framework of the app for users, unless the interests of the user in the confidentiality of the data prevail (Art 6 para 1 lit f DSGVO).
The disclosure of data other than the user name, the respective distance to other users as well as information on the same/similar working hours and days (e.g. exact route, address or location) to other users via the app occurs at most on the basis of the user's consent pursuant to Art 6 para 1 lit a DSGVO.
c.) Cookies and tracking in the context of app use
In the course of using our app, we collect the following data from users, in particular for the purposes of quality assurance and further development of the app: date, time and duration of use of the app, IP address, system data on the device and operating system used. We collect this data automatically with cookies and analysis tools provided by third-party providers based on the consent of the user pursuant to Art 6 para 1 lit a DSGVO (or iVm § 165 para 3 TKG in the case of so-called "persistent" cookies, which are stored on the end device of the user).
Users can refuse the storage of individual cookies or the use of analysis tools (by means of configuration in the cookie banner) or revoke the storage or use of analysis tools in the app settings at a later time. When cookies are set or analysis tools are used on the basis of voluntary consent, user data is sometimes transmitted to recipients in third countries outside the EEA, in particular to the USA. The USA has not been certified by the European Court of Justice as having an adequate level of data protection; in particular, there is a risk that data may be viewed by US authorities for control and monitoring purposes. By giving their consent, users agree that cookies and analysis tools from third-party providers in the USA or from other insecure third countries may be used and accept a possible lower level of data protection (Art 49 para 1 lit a DSGVO).
Cookies that are absolutely necessary for the structure or functioning of the app (technically necessary cookies) cannot be deactivated. In these cases, the data processing is based on our legitimate interest pursuant to Art 6 para 1 lit f DSGVO to be able to provide the app in a correspondingly functional manner.
d.) GPS tracking and activity sensors
In order to fully exploit the functionalities of the app, in particular to receive optimal suggestions regarding the choice of means of transport and routes or carpooling to the desired destination or to check whether users also implement these suggestions correctly, the app accesses the user's location and activity sensors of the user's terminal device. This is done exclusively on the basis of explicit consent pursuant to Art 6 para 1 lit a DSGVO, which users can edit or revoke at any time in the app settings. The user can give consent either generally or manually by means of "start and stop".
e.) Contacting users regarding new app features / changes
In order to keep users up to date with regard to new features of the app, they receive regular emails about any technical innovations within the scope of app use.
We base this data processing on our legitimate interest pursuant to Art 6 para 1 lit f DSGVO to improve the use of the app and to inform users about innovations. Users have the option to unsubscribe from notifications at any time via the link provided in the respective email.
f.) Contact by the user
If users contact us via email or via the contact options otherwise offered, the data provided by the user will be processed in order to process and respond to the respective request, in particular: Name, email or phone number, any data provided in the text or conversation.
We process data for the purpose of contacting us in the context of (pre)contractual relationships pursuant to Art 6 para 1 lit b DSGVO and/or for the fulfillment of legal obligations (Art 6 para 1 lit c DSGVO).
2. Storage period
We generally store user data for the duration of their contractual relationship with us as well as beyond that in accordance with the statutory retention and documentation obligations. If the processing of user data is based on consent, we store the data until revoked by the respective user.
3. To whom is your data passed on?
Your data will be transferred to the following recipients in the course of processing for the above-mentioned purposes:
* IT service providers used by us
* Banks, tax consultants, auditors
* In case of need to legal representatives, notaries, courts and administrative authorities
If the above-mentioned recipients are order processors within the meaning of Art 4 No. 8 DSGVO, they will be obligated to comply with data protection provisions in accordance with Art 28 DSGVO.
4. Transfer to third countries
If the above-mentioned recipients of your data are located outside the EEA and it has not been determined by decision of the EU Commission that the country in question has an adequate level of data protection, we will ensure that the transfer takes place on the basis of standard contractual clauses or otherwise in accordance with Art 46, 47 or 49 DSGVO.
5. What rights do you have?
Right of access
If we process data from you, you have the right to information about the processing purposes, the categories of data processed, the recipients of this data, storage period, the rights you are entitled to, the origin of the data and the existence of automated decision-making.
Correction and deletion
You are entitled to request the rectification of incorrect or incomplete data concerning you. You are entitled to request the erasure of data concerning you, provided that the processing of the data is not lawful and there are no legal obligations on our part against the erasure.
Restriction of processing
You are entitled to request the restriction of the processing of your data in certain cases.
Data portability
You have the right to request the transfer of your data that you have provided to us in a structured, common and machine-readable format. You have the right to have the data transferred by us directly to a responsible party, insofar as this is technically feasible.
Objection
You are entitled to object to the processing of data concerning you at any time on grounds relating to your particular situation. If you object, we will not further process data concerning you unless we can demonstrate that our reasons for processing outweigh your interests.
Revocation
You have the right to revoke any processing of your data which is based on your consent at any time. This will not affect the lawfulness of the data processing carried out up to that point.
Complaint
If you believe that the processing of your data violates data protection law or that your data protection rights have otherwise been violated in some way, you can complain to the supervisory authority. In Austria, this is the Data Protection Authority, Barichgasse 40, 1030 Vienna (www.dsb.gv.at).
Our contact details:
For questions or personal concerns, please contact:
Carployee GmbH
A-4020 Linz, Peter-Behrens-Platz 10
Tel.: +436802381701
Email: support@pavecommute.app
