We use the information that we collect (described in “Personal Data we collect and for what Purpose,” below) for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

Vouchers. Merchant shall be solely responsible for ensuring that all terms and conditions applicable to the Merchant’s services (the “Merchant Services”) to users of the App are complete, correct and in compliance with all applicable laws, and that the issuance of the Vouchers and all terms and conditions applicable to the issuance, use and redemption of the Vouchers and the goods, services, and/or experiences offered or provided in connection with the Vouchers are in compliance with all applicable laws. Merchant is the provider of the goods, services, and/or experiences described in the Voucher and the obligations and duties deriving from the Voucher are the sole responsibility of the Merchant. Moreover, Merchant is solely responsible for the choice of, the terms of and the effectiveness of the Vouchers that are offered in the Contextual Campaigns. 

• Provide you with our content and the Services
• Respond to your questions or requests concerning the Services;
• Fulfill your requests for our Services or otherwise complete a transaction that you initiate;
• Send you information about our Services and other topics that are likely to be of interest to you;
• Improve our artificial intelligence and machine learning capabilities;
• Train our statistical models;
• Deliver confirmations, account information, notifications, and similar operational communications;
• Analyze your movement patterns and repetitive habits;
• Improve your user experience and the quality of our products and Services;
• Provide you with personalized information and suggestions relevant to time and place and support your travel and commuting behavior in general;
• Comply with legal and/or regulatory requirements;
• Aggregate and deidentify information;
• Benchmark results for our customers;
• Serve advertisements and offers from third parties in connection with your travels;
• Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
• Create new products and services; and
• Manage our business.

We may link information gathered through the Services with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.

We collect personal and other information from you directly when you provide it to us through the App or Site. We also automatically collect certain information about you and your smartphone, or other device when you use, access, or interact with our Services. We may also collect information from third parties in relation to providing you our Services.

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

If you make an account with us in relation to our Services, we will collect information from you related to your account. This may include, for example, 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 and for the purposes of identification, support, and communication (such as collection of your feedback). We may also ask you to enter your preferences (e.g. your favorite places, stations or preferred mode of travel), which we will use to personalize the Services provided to you.

You can visit the Site without submitting any information that we can use to identify you personally. However, to use certain features on the Site, such as the “Contact Us” feature, you may be required to provide personal information. Such information could include, for example, your name, email address, and phone number.

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 Services. The IP address used by the device to access the Services is also recorded for fault analysis. A coarse location (city/district level) is determined by the IP address and stored under user metrics. To obtain this information, we may use cookies, web logs, app logs, and server logs.

We collect metrics relating to the usage of the App and the Site (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 Google LLC. We also collect survey feedback data you enter in the App.

To provide you an optimal service that is tailored to your daily needs and interests, we collect data from your interaction with our Services, such as data from journey planning or data from favorites you set. This data is processed to provide you with an optimal app experience, assistance for your travels and to personalize offers. To obtain this information, we may use cookies, web logs, app logs, and server logs.

If you allow the App to access your location, the Services will use it for the purpose of centering the map at or planning a journey from your current location. With your explicit consent, the Services will collect location data (such as geographical coordinates and visits) and motion data (such as motion activity and pedometer data). We use this data to understand your mobility behavior (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., a voucher for a restaurant based on your travel history or weather conditions). These advanced features require that collecting your location and motion data also happens when the App is closed.

The Site or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.

We may partner with certain third parties to collect, analyze, and use the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons in email communications from us. This information may be used for a variety of purposes, as discussed below (see “Sharing your Personal Information with Third Parties”).

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, and road traffic data, as well as data relating to public transport stations or other places.

In order to provide the Services, the App and the Site 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.

• You can view the Google Terms of Service here: https://policies.google.com/terms
• The Google Maps/Google Earth Additional Terms of Service can be found at: https://www.google.com/help/terms_maps
• The Google Privacy Policy is available at: https://policies.google.com/privacy

The App uses the login services of Google and Apple. When you sign in using these services, we receive certain basic profile information (such as your name, email address, and profile picture) as provided by your Google or Apple account. We do not access or store any additional data from your Google or Apple account beyond what is necessary for authentication and account creation.

We do not sell your personal information. We may share your personal information with select third parties as described in this section.

We may enlist subcontractors to render the Services. We shall ensure that this Policy is binding on such subcontractors. Our subcontractors include

• Amazon Web Services (AWS)
• Google LLC

We partner with certain third parties (such as Google LLC) to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting.

We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Sometimes we anonymize data so that it can no longer identify you. 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 analyze 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 Services. We will maintain and use such information in anonymized form and not attempt to reidentify the information, except where reidentification is allowed by law for particular purposes. In those situations, we will use the re-identified data in a manner consistent with this policy and applicable law.

We may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

• To comply with applicable law or a court order, subpoena, or other legal process;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
• To establish, protect, or exercise our legal rights or defend against legal claims; or
• To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

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

Sometimes we anonymize data so that it can no longer identify you. 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 analyze 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 Services. We will maintain and use such information in anonymized form and not attempt to reidentify the information, except where reidentification is allowed by law for particular purposes. In those situations, we will use the re-identified data in a manner consistent with this policy and applicable law.

Sometimes we anonymize data so that it can no longer identify you. 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 analyze 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 Services. We will maintain and use such information in anonymized form and not attempt to reidentify the information, except where reidentification is allowed by law for particular purposes. In those situations, we will use the re-identified data in a manner consistent with this policy and applicable law.

Sometimes we anonymize data so that it can no longer identify you. 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 analyze 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 Services. We will maintain and use such information in anonymized form and not attempt to reidentify the information, except where reidentification is allowed by law for particular purposes. In those situations, we will use the re-identified data in a manner consistent with this policy and applicable law.