Sojo - Privacy Policy

The Sojo 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 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, deleted and shared when using the app Sojo (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 are 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 behavior in general. Furthermore, we may provide you with personalized offers from third parties in connection with your travels. We may also use the collected data to improve our statistical models. 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:

Profile Information

Information you entered into the app, such as phone number, name, e-mail. We use this information for the purpose of identification, communication and customizing your profile. We may also ask you to enter your preferences (e.g. your favorite places 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, browser type or the name of the current mobile phone operator are recorded to analyze 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. 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 enable the location and motion services of your operating system (iOS, Android), 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. Advanced app features such as automatic commuter alerts require that recording of your location and motion data also happens when the app is closed. This 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 use 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 public transport 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 provide the Service. We shall assure that this privacy statement is binding on such subcontractors.

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 fulfillment of the third-party service.

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

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. The Service allows you to view and export location and motion data or 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. www.axonvibe.com.

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

©Axon Vibe AG, Version 1.0.0, Last Updated 22.03.2021