Types of Data collected
Among the types of Personal Data that the publisher of this mobile app or web app ("the app") collects, by itself or through third parties, there are:
geographic position, Storage permission, Calendar permission, Camera permission, Precise location permission (continuous), Approximate location permission (non-continuous), Phone permission, Social media accounts permission, Cookies, Usage Data, first name, last name, email address, phone number and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the app.
Unless specified otherwise, all Data requested is mandatory and failure to provide this Data may make it impossible to provide its services. In cases where the app specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through mTrip and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of mTrip (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data may be processed in the USA or in Germany. Feel free to contact us to know more about the precise location of the data storage.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, please contact the data processor.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the processor using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:
Location-based interactions, Device permissions for Personal Data access, Analytics, Hosting and backend infrastructure, Interaction with online survey platforms, Registration and authentication, Heat mapping and session recording, Infrastructure monitoring, Interaction with external social networks and platforms, SPAM protection and Managing contacts and sending messages.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Device permissions for Personal Data access
Depending on the User's specific device, the app may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of the app.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed).
Mobile phone and SMS
mTrip offers the option to our customers to engage in conversations with travelers to provide trip informations. Message frequency varies. Message and data rates may apply. Text HELP to [Number] for help. Reply STOP to cancel. Carriers are not liable for any delays or undelivered messages.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. The app may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for the app to derive the approximate position of the User on a continuous basis.
Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Precise location permission (continuous)
Used for accessing the User's precise device location. The app may collect, use, and share User location Data in order to provide location-based services.
Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of the app, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected:
Cookies and Usage Data.
Place of processing:
United States
–
Privacy Policy
–
Opt Out
.
Google Analytics for Firebase (Google Inc.)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc.
In order to understand Google's use of Data, consult
Google's partner policy
.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
The app uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data collected:
Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing:
United States
–
Privacy Policy
.
-
Device permissions for Personal Data access
The app requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access
The app requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data collected:
Approximate location permission (non-continuous), Calendar permission, Camera permission, Phone permission, Precise location permission (continuous), Social media accounts permission and Storage permission.
-
Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Inspectlet (Inspectlet Inc.)
Inspectlet is a session recording and heat mapping service provided by Inspectlet Inc.
Personal Data collected:
Cookies and Usage Data.
Place of processing:
United States
–
Privacy Policy
.
-
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable the app to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of the app.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon)
Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
See the Amazon privacy policy
–
Privacy Policy
.
Engine Yard (Engine Yard, Inc.)
Engine Yard is a hosting service provided by Engine Yard, Inc.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
Firebase Cloud Functions (Google Inc.)
Firebase Cloud Functions is a hosting and backend service provided by Google Inc.
Personal Data collected:
Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
Firebase Cloud Storage (Google Inc.)
Firebase Cloud Storage is a hosting service provided by Google Inc.
Personal Data collected:
Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
Firebase Realtime Database (Google Inc.)
Firebase Realtime Database is a hosting and backend service provided by Google Inc.
Personal Data collected:
Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
-
Infrastructure monitoring
This type of service allows the app to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of the app.
Crashlytics (Google Inc.)
Crashlytics is a monitoring service provided by Google Inc.
Personal Data collected:
geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
New Relic (New Relic)
New Relic is a monitoring service provided by New Relic Inc.
The way New Relic is integrated means that it filters all traffic of the app, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on the app to be collected.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
-
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of the app.
The interaction and information obtained through the app are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected:
Cookies and Usage Data.
Place of processing:
United States
–
Privacy Policy
.
-
Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of the app.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
SurveyMonkey Widget (SurveyMonkey Inc.)
The SurveyMonkey Widget is a service for interacting with the SurveyMonkey online survey platform provided by SurveyMonkey Inc.
Personal Data collected:
Cookies and Usage Data.
Place of processing:
United States
–
Privacy Policy
.
-
Location-based interactions
Geolocation
The app may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by the app.
Personal Data collected:
geographic position.
Non-continuous geolocation
The app may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by the app.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data collected:
geographic position.
-
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mandrill (The Rocket Science Group, LLC.)
Mandrill is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected:
email address and Usage Data.
Place of processing:
United States
–
Privacy Policy
.
Firebase Cloud Messaging (Google Inc.)
Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
United States
–
Privacy Policy
.
-
Registration and authentication
By registering or authenticating, Users allow the app to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, the app will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration
The User registers by filling out the registration form and providing the Personal Data directly to the app.
Personal Data collected:
email address, first name and last name.
-
SPAM protection
This type of service analyzes the traffic of the app, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.
The use of reCAPTCHA is subject to the Google
privacy policy
and
terms of use
.
Personal Data collected:
Cookies and Usage Data.
Place of processing:
United States
–
Privacy Policy
.
Further information about Personal Data
-
Push notifications
The app may send push notifications to the User.
-
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by the app depends on the payment system used.
-
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use the app only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use the app.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
-
Withdraw their consent at any time.
Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
-
Object to processing of their Data.
Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
-
Access their Data.
Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
-
Verify and seek rectification.
Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
-
Restrict the processing of their Data.
Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
-
Have their Personal Data deleted or otherwise removed.
Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
-
Receive their Data and have it transferred to another controller.
Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
-
Lodge a complaint.
Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
The app uses Cookies. To learn more and for a detailed cookie notice, the User may consult the
Cookie Policy
.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the app or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, the app may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, the app and any third-party services may collect files that record interaction with the app (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
The app does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within the app and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through the app (or third-party services employed in the app), which can include: the IP addresses or domain names of the computers utilized by the Users who use the app, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using the app who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the app. The Data Controller, unless otherwise specified, is the Owner of the app.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies
Small sets of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to the app, if not stated otherwise within this document.