Dolphin Technologies GmbH
July 12th, 2019
Dolphin Technologies GmbH, Stella-Klein-Löw-Weg 11, 1020 Vienna, Austria FN: 210359b, info@dolph.in / info@mobilio.cc (“Dolphin” or “we”) as the responsible (“controller”) for data protection is committed to the sensitive handling and active protection of user data as well as transparent information for users, especially in the areas of data collection and use.
This data protection declaration explains which data we collect within the scope of using the App Mobilio and for what purpose we process and store it.
In order to technically cover data protection as good as possible, we encrypt the data collected by the App on your smartphone and also rely on encrypted transmission to our server infrastructure.
In any case, it has to be considered that the Mobilio cannot work without collecting and processing of the data mentioned below.
Should you wish to delete your account at a later date, you can do so at any time in the menu item “Profile”, please note that in this case all collected Points and Mobilio will expire and related information will be deleted from our systems. This does not apply to historical information, this information is still available to us on the basis of our legitimate interests, in pseudonymized form, and will be deleted after a maximum of 3 years. For further information on the storage periods, please refer to the respective processing purpose.
You can request information about the data stored about your person at any time. In addition, under certain circumstances you may request the correction or deletion of your data. You may also have the right to limit the processing of your data, to object to it and to have the data provided by you given back in a structured, common and machine-readable format.
If you have any questions, please contact our data protection officer at:
Dolphin Technologies GmbH
Irene Pöschl
Stella-Klein-Löw-Weg 11
1020 Vienna / Austria
FN: 210359b
E-mail: privacy@mobilio.cc
In addition, you have the option of using your right to appeal to a supervisory authority (e.g.: Austrian Data Protection Authority, www.dsb.gv.at).
Processing purposes
Registration, contract management
In order to be able to clearly assign your contract and trip data as well as information concerning your Mobilio wallet, to prevent abuse of our services and to be able to communicate with you outside the App we need
- email address
This information is queried during registration for contract fulfillment, processed in our systems and stored. The data is stored for the duration of the contract and for a maximum of 3 years beyond, in order to facilitate any re-registration.
If you prefer to use the App without registration, you can do so without significant restrictions. Please keep in mind that in such a case neither points nor Mobilio can be restored after deletion or any other problem with the App.
Reward for safe driving / mobile phone waiver / calculation of reward points / Mobilio
In order to recognize and evaluate your journeys, we need positioning and usage data. For this purpose, we collect, process and store the following data to fulfill the contract
- location data
- sensor data (gyroscope, acceleration sensor, magnetometer)
- Activity data provided by smartphone operating system
- Wallet address
which we receive from your smartphone. The reward points calculated from this will also be stored and processed to fulfill the contract. The data will be stored for the duration of the contract and for a maximum of 3 years beyond, in order to enable a possible re-registration.
Data concerning converted Mobilio is also handled under this processing purpose.
Communication, customer journeys
We will contact you via e-mail and push messages without separate consent within the framework of contract fulfillment.
For this purpose, we collect, process and store the following data:
- Location data
- Smartphone sensor data
- Activity data provided by smartphone operating system
- E-mail address
- App-ID
- Function calls in the app
In order to send messages we make use of external service providers:
- SendGrid, Inc., USA
e-mail address
to send e-mails - Elastic Email, Canada
e-mail address
to send e-mails - Peaberry Software Inc. – “Customer.io”, USA
all data collected by us, in raw or processed form as required for the creation of customized communication and the subsequent dispatch of these messages
The data will be stored for the duration of the contract and for a maximum of 3 years beyond.
The respective service provider lists the data that we have to transfer in order to achieve the purpose. Service providers located in the USA are subject to the rules of the EU-US Privacy Shield Agreement for the protection of personal data.
Service expansion and improvement
The purpose of the feature is to increase road safety. Achieving this goal is not limited to rewarding safe driving, but can also be based on elements such as weather information, forecasts, and more. For this reason, we use all collected data (location data, sensor data, reward data, etc.) in our legitimate interest to create and store models for service enhancement and improvement. The data is stored for the duration of the contract and for a maximum of 3 years beyond, so that we can continuously improve our service.
Usage optimization, customer service
We try to ensure that our services function optimally at all times, but unfortunately, we do not always succeed in doing so in every constellation. In order to continuously improve the user experience of the App and to be able to optimally respond to possible requests from you, we collect, process and store data regarding the use of the App in our legitimate interest:
- smartphone brand
- smartphone model
- smartphone operating system
- App ID
- function calls in the App
Data is stored for the duration of the contract and for a maximum of 3 years in order to improve our service on an ongoing basis.
Optimization of our services – Firebase Services / Facebook Business Tools
We use Google Firebase and Facebook Business services to improve the performance and usability of our services and measure the effectiveness of our advertising efforts. We do not share any personal information with service providers (i.e., we transmit the information pseudonymously), but we do share information such as your advertising ID, which is linked to your personal information by the service provider to enable our evaluations. We do this in our legitimate interest to determine whether our advertising efforts are successful and to obtain information about the use of our app to improve performance and usability. The data is stored for the duration of the contract and for a maximum of 18 months beyond that, in order to be able to create our evaluations.
For this purpose we process:
- Installation UUID
- Firebase Instance ID
- Mobile Advertising ID
- Android ID / IDFV
- Pseudo ID / Contract ID
- Crash Trace (tracking of app crashes)
- Smartphone Info (brand, model, operating system, smartphone settings, etc.)
- IP address (to display the region)
- Function calls in the app
- App Events
In order to fulfil these tasks, we make use of the following external service providers:
Google LLC, USA
Google Ireland Limited, Ireland
for Firebase Services
Facebook Inc, USA
for Facebook Business Tools
U.S.-based service providers are subject to the rules of the EU-US Privacy Shield Agreement for the protection of personal data.
Further information can be found at:
Facebook Business Tools:
https://www.facebook.com/
https://www.facebook.com/
Google Firebase:
https://support.google.com/firebase/
https://firebase.google.com/
https://docs.fabric.io/
You have the right to object at any time, for reasons related to your particular situation, to the processing of personal data concerning you carried out pursuant to Article 6 (1) f GDPR (Data processing for the protection of a legitimate interest). In the event of your objection, we will no longer process your personal data unless we can prove compelling and justified reasons for the processing which outweigh your interests, rights and freedoms. If you wish to file such an objection, please contact our data protection officer!
Statistical evaluations
We use the collected positioning and sensor data for evaluations and will publish or share these evaluations with partners in the context of publications, research work, reports etc. in such cases however exclusively in processed and anonymized form.
We protect your data, process it exclusively for the purposes stated and do not share it in any other way than stated here, unless we are forced to do so by legal requirements.