Sojo SEQ - Privacy Policy

Last updated 23.06.2022 (version 1.0.1); effective 23.06.2022

The Sojo app offers you intelligent travel assistance – a navigation system for your daily mobility. Various data is collected and analysed to provide you with the best possible support for your travel. This service is provided by Axon Vibe AG (hereinafter: "we"). We are committed to ensuring your privacy and confidentiality of your personal data.

This Privacy Policy describes how your personal data is collected, used, stored, erased, and shared when using the Sojo app (hereinafter: "the Service").

By using the Service, you consent to this Privacy Policy. If you do not agree to any part of it, you must immediatelydiscontinue using the Service.

1. Scope of the Processing of Personal Data

The processing of personal data is limited to data required for the provision of content and services. We use the data collected by the Service to analyse your movement patterns and repetitive habits. The collected data and the analysisare used by us to provide you with personalized information and suggestions related to your current context (such as your current location and journey intent) and support your travel and commuting behaviour in general. Furthermore,we may provide you with personalized offers from third parties in connection with your travels.  The processing of yourpersonal data is based on the purposes agreed through consent or on a legal basis. We only collect personal data necessary to implement and process our tasks and services, or if you provide personal data voluntarily.

2. Personal Data we collect and for what Purpose

When you are using the Service, the following personal data may be collected and processed:

Profile Information

Information you entered in the app, and basic profile information obtained from your Google or Apple account used for sign-in, such as name, address, phone number, email, or profile picture. We use this information to customize your profile, for the purpose of identification, support, and communication (such as collection of your feedback). We may also ask you to enter your preferences (e.g. your favourite places, stations or preferred mode of travel), which we will use to personalize the Service provided to you.

Device Information

General device data such as technical specifications of the end device, its battery level, operating system, browsertype or the name of the current mobile phone operator are recorded to analyse possible error sources and improve the user app experience. The IP address used by the device to access the Service is also recorded for fault analysis.A rough location (city/district level) is determined by the IP address and stored under user metrics.

Usage Information

We collect metrics relating to the usage of the app and the related websites (e.g. session duration, use of features, crash logs, etc.) to tailor it to your needs and optimize your experience on an ongoing basis. We also collect survey feedback data you entered in the app. For this purpose, we use analytics services from Countly Ltd.

Interaction Data

To provide you an optimal service that is tailored to your needs, we collect data from your interaction with our service, such as data related to your journey planning activity or feedback you provide on information rendered in the app. We use this data to personalize your experience and to improve our Service.

Location and Motion Information

If you allow the app to access your location, the Service will use it for the purpose of centring the map at or plan a journey from your current location. With your explicit consent, the Service will collect location data (such asgeographical coordinates and visits) and motion data (such as motion activity and pedometer data). We use this data to understand your mobility behaviour (including the carbon emissions related to your travels) and predict future journeys. This enables us to provide you with automatic commuter or traffic alerts and personalized travel assistance. We may also provide you with contextual offers (e.g. retail vouchers or discounts). These advance features require that collecting your location and motion data also happens when the app is closed.

Chat Information

The information you voluntarily provide us via the in-app support and feedback chat is collected and stored for the purpose of supporting you, processing your feedback and following up on questions that may arise at a later stage.We use services of  Zendesk Inc. and Slack Technologies Inc. to support you.

3. Integration of external Data Sources

We refine the forecasts of your travel behaviour with real-time data that is not specific to any individual, such as weather data, timetable data, rail, and road traffic data, as well as data relating to public transport stations or other places.

4. Integration of Map Services

To provide the Service, the app and the related websites include services of Google Maps Platform. These are used toe.g. display interactive maps and routes on our app for you, which requires the transmission of certain location datasuch as your current position.

5. Integration of Log-in Services of Google and Apple

The app uses the sign-in services of Google and Apple. We do not access or store any data of your Google or Apple profile.

6. Sharing your Personal Information with third parties

We will not sell or otherwise pass your data to third parties other than stated below.

Subcontractors

We may enlist subcontractors to provide or administer the Service. We shall assure that this privacy statement is binding on such subcontractors. Our subcontractors include:

  • Amazon Web Services (AWS)

  • Countly Ltd

  • Zendesk Inc.

  • Slack Technologies Inc.

Third-party Service Providers

With your explicit consent, we may pass your personal data to third-party service providers to the extent necessary for the fulfilment of the third-party service. These third-party services act as independent data controllers with their own privacy policies. You should read the respective privacy policy before consenting.

These third-party services include:

  • Google Maps Platform

Anonymized Data

Anonymized data and analysis can be passed on to third parties. We may supplement it with additional data not specific to any individual (e.g. to analyse commuter flows). We may also use anonymized data to improve the services rendered to you, e.g. by optimizing the routes we provide to you based on data collected through the Service.

Disclosure required by Law

We may disclose your personal data to government authorities if we are required to do so by law.

7. Data Security and Data Protection

We protect your personal data stored with us against manipulation, loss, or unauthorized third-party access. To ensure continuous protection, we are continually developing our security measures. We are certified according to the ISO 27001 standard for information security.

The transmission of data over the Internet and via other electronic means always entails risks. Despite taking appropriate precautions, we cannot, therefore, guarantee the security of any information transmitted over the Internet.

We ensure that the countries to which we transfer data have a high level of data protection (e.g. EU Member States or adequate).  

8. Your Data - your Rights

The Service contains the option that you, if necessary, can pause the recording of your location and motion data at any time by withdrawing the corresponding consents or by logging out of the app. Your raw location and motion data are processed and stored for a maximum duration of 60 days after the completion of the Proof of Concept. Data captured from non-personal test devices during the designated field test period is exempted from deletion and Axon Vibe is allowed to keep the data for future analysis and quality assurance of its algorithms.

The Service allows you to view and export location and motion data or to completely and irretrievably erase all datalinked to your profile, including the predictions generated using your location and motion data. Data that has arisen from interactions with our support is exempted from deletion and will be stored for a maximum duration of one year.

We are allowed to keep data in an anonymized form.

You may also contact us in confidence using the contact details provided to erase your profile or exercise any other rights available to you concerning your personal data.

9. Data Editing by the User

You are responsible for using all content, data, and information offered by the Service exclusively in compliance with the contractual provisions and with the applicable legislation in your jurisdiction.

10. Data Storage Location

Your data is stored and processed in the European Union, Switzerland, and the United Kingdom. Data from the feedback chat may also be stored and processed in the United States.

11. Changes

We may update this privacy policy from time to time to reflect, for example, changes to our practices or other operational, legal, or regulatory reasons.

12. Contact us

Axon Vibe AG, Schlössli Schönegg, Wilhelmshöhe 1, 6003 Luzern, Switzerland.

The operational Data Protection Officer of Axon Vibe AG is available at said address c/o Data Protection Officer and privacy@axonvibe.com.