Tokyo Nudge - Privacy Policy

Last updated 29.04.2022 (version 1.2.0); effective 29.04.2022

The Tokyo Nudge app offers you intelligent travel assistance – a navigation system for your daily mobility. Various data is collected and analyzed to provide you with the best possible support for your travel. This Service is rendered 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, deleted, and shared when using the app Tokyo Nudge (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 immediately discontinue 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 analyze your movement patterns and repetitive habits. The collected data and the analysis results are used by us to provide you with personalized information and suggestions relevant to time and place and support your travel and commuting behavior in general. Furthermore we may provide you with offers from third parties in connection with your travels. The processing of your personal 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:

Device Information

General device data such as technical specifications of the end device, its battery level, operating system, browser type or the name of the current mobile phone operator are recorded to analyze possible error sources and improve the user experience of the app. The IP address used by the device to access the Service is also recorded for fault analysis. A coarse 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 user needs and optimize the user experience on an ongoing basis. For this purpose, we use analytics services from Countly Ltd.

Location and Motion Information

If you enable the location and motion services of your operating system (iOS, Android) to assist with map navigation and travel planning, we collect location data (such as geographical coordinates) and motion data (such as pedometer data). By doing so, we can provide you with optimal support (e.g., personalized travel assistance) and contextual offers (e.g. free usage of Station Work offices for an amount of time during your business day). Recording of your location and motion data happens also when the app is closed and only takes place after you have given your explicit consent in the app.

Chat Information

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

3. Integration of external Data Sources

We refine the forecasts of your travel behavior 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 railway stations or other places.

4. Integration of Third-party Map Services

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

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

The app uses the log-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 render the Service. We shall assure that this privacy statement is binding on such subcontractors.

Third-party Service Providers and Partners

With your explicit consent, we may pass your personal data to third-party service providers and partners to the extent necessary for the fulfillment of the third-party service or the partner’s task.

Anonymized Data

We are authorized to pass on anonymized data and analysis results to third parties. We may supplement it with additional data not specific to any individual (e.g. to analyze aggregated commuter flows) to improve the Service.

Disclosure required by Law

We may share your Personal Information to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful requests for Information we receive, or otherwise protect our rights.


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.
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 an high level of data protection (e.g. EU Member States or adequate). If this is not the case, we conclude agreements to ensure adequate protection.

8. Your Data - your Rights

The Service contains the possibility that you, if necessary, pause the recording of your location and motion data at any time by withdrawing the corresponding consents or by logging out of the app. You can use the app to view and export location and motion data, or use the app to completely and irretrievably delete all data linked to your profile, including the predictions generated using your location and motion data. Erasure of all your data occurs automatically in the event of more than 6 months of inactivity of the user.
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

Your data is stored and processed in the European Union, Switzerland and United Kingdom.
Data from the feedback chat may also be stored and processed in the United States.
Your raw location and motion data are processed and stored for a maximum duration of 12 months.

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 Christoph Hofer, and privacy@axonvibe.com.