This is the privacy policy of Tripomatic s.r.o., with its registered seat at Za Parkem 14, 621 08 Brno, Czech Republic (“Tripomatic”, “we”, “us”, “our”). This privacy policy provides an overview about how we process personal data about users of our mobile applications, software, websites or generally our products and services we provide to you including anciallary services that we provide together with our business partners and which may be available through our mobile applications (the “Services”).
We take privacy very seriously. Being an EU-based company, we must comply with the EU general data protection regulation (the “GDPR“) when processing the personal data. We provide our Services either directly to natural person end-users or to our business clients in which case we process personal data about their employees or users. We regard all natural person users of our Services data subjects according to the GDPR.
If you have any questions concerning how we process your personal data, you can contact us at privacy@tripomatic.com or by post using our registered seat address above. All privacy enquiries sent to us are received and reviewed by our data protection officer ('DPO') appointed to serve as a contact point for you and supervisory authorities.
Generally, we need to process your personal data in order to:
In particular, we process your personal data for the following purposes:
| Purpose | Legal basis |
| Provision of the Services | Performance of contract pursuant to the Art. 6(1)(b) of the GDPR and legitimate interest pursuant to the Art. 6(1)(f) of the GDPR |
| Development, improvement & testing | Legitimate interest pursuant to the Art. 6(1)(f) of the GDPR |
| Direct marketing communications (newsletter & push notifications) | Consent pursuant to the Art. 6(1)(a) of the GDPR, legitimate interest pursuant Art. 6(1)(f) GDPR |
| Marketing analytics | Legitimate interest pursuant to the Art. 6(1)(f) of the GDPR |
| Statistics | Article 89 of the GDPR |
| Maintaining social media profiles | Legitimate interest pursuant to the Art. 6(1)(f) of the GDPR |
| Consumer contests | Performance of contract pursuant to the Art. 6(1)(b) of the GDPR |
| Billing, Tax & Accounting | Compliance with legal obligations pursuant to the Art. 6(1)(c) of the GDPR |
| Security of personal data | Compliance with legal obligation the Art. 6(1)(c) of the GDPR |
| Handling user requests | Compliance with legal obligation the Art. 6(1)(c) of the GDPR |
| Legal enforcement (establishment, exercise or defense of legal claims) | Legitimate interest pursuant to the Art. 6(1)(f) of the GDPR |
| Archiving purposes and administration of the registries | Compliance with legal obligation the Art. 6(1)(c) of the GDPR and the regime of privileged purposes according to Art. 89 GDPR |
Every time you download any application from Tripomatic whether through Google Play, App Store or other stores,
you agree to and conclude with us the End-User-Licence-Agreement which represents a contract concluded
between us (the"EULA"). According to EULA, we are obliged to provide you with the Services which
correspond to the specific functionality of the particular application and your in-product purchases. Any processing
which is necessary to perform our obligations from the EULA as
explained above is regarded a separate purpose of processing and is not subject to a separate data subject consent.
For example, this includes:
• Ensuring the basic functionality and additional functionality of the application (add-ons, features);
• User registration and administration of the user accounts (user login);
• Customer pre-contractual relationship management;
• Handling orders and purchases via app or e-shop;
• Recommendations for better user experience;
• Customer support; or
• Communication of service information to user.
Provision of the Services covers all the below listed applications EULA.
Provision of the Services may also include the so-called Anciallary Services that we provide in cooperation with our business partners and which you can order through our applications (see more info in point 8 of the EULA).
As a software developer we need to be able to continuously develop, improve, maintain and test our software products
which we regard our own legitimate interest. This typically includes:
• Removal of bugs and other software faults or errors;
• Development of new application updates, versions or functionalities (features);
• General analysis of application;
• Analysis of user trends within the application including general user profiling based on that;
• Accuracy analysis (location, speed, direction or other values);
• Customer polls focused on improvement of the Services;
• Customer feedback on design and user experience;
• Testing on the production copies of partially anonymized data.
We do not send-out direct marketing communication to everyone. If you receive a direct marketing message from us it’s either because you have previously granted us a specific direct marketing consent or because we have obtained your email within the process of providing you with our Services and the message relates to a similar product or service. Irrespective of that, you can always opt-out from receiving any further direct marketing communication and/or object to processing of your personal data for direct marketing purposes as explained below.
We regard our marketing analytics a distinct purpose of processing personal data from sending out direct marketing
communications. Some of the below activities might not necessarily involve processing of personal data. However, we
would like to be transparent about the processing activities we undertake (with data generally) and would like to
give our users full control over marketing related processing of personal data, as explained here. All of the below activities do correspond with our legitimate interest of
better understanding our customers, customer trends and expectations when providing or offering our Services. For
example, marketing analytics may include:
• General analysis of user behavior for better marketing strategies, decision or more personalized targeted
advertising;
• Targeted advertising of Tripomatic products or services for example via Facebook App Install ads, Google AdWords,
PayPerClick and similar tools;
• Performance analysis of different marketing campaigns (e.g. Exponea, Google Analytics);
• Cross-device linking (pairing of data about different devices of the same user);
• User segmentation for more personalized direct marketing communication (if conditions for direct marketing
communications are met).
We keep various anonymous or aggregated statistics based on which one cannot identify an individual. For example, we might keep statistics about how many users are using our applications or what is the average usage time of our applications. Although these statistics are made by conversion or analysis of real personal data, the statistic findings or results are not personal data.
We maintain several business profiles on social media platforms where you can interact or communicate with us. By doing so, we are pursuing our legitimate interest: increasing company/brand awareness in online environment. We might process your personal data via our social media profiles when you write to us, comment, like or share our posts. Your provision of personal data via social media to us is voluntary. Please read relevant privacy policies to better understand processing of your personal data by providers of social media. We only have a typical admin control over the personal data processed by us via our own company profiles. We assume that by using these social media platforms, you understand that your personal data might be processed for other purposes and that your personal data might by transferred to other third countries and third parties by providers of social media platforms. You can currently find us on Facebook, Linkedin, Twitter, Instagram, Pinterest, Youtube, Stack Overflow, Github, Tumblr, Dribble, Behance and Vimeo.
We might organize customer contests, price giveaways or similar promotional activities for example via our social media profiles. When we do so, we typically put forwards terms & conditions or statute which you need to accept before joining the contest. By doing so, you conclude a contract with us meaning we do not need your consent for participation and related processing of your personal data. However, we would always ask your consent should the circumstances require so.
When you purchase any paid add-on, feature or application from us, we must process your personal data in line with the applicable billing, tax and accounting legislation. Invoices and invoicing documentation might include your personal data. However, we are obliged to process, keep and store such data for statutory periods in order to be compliant with local law. Specific provisions of billing, tax and accounting legislation might vary across different jurisdictions.
We are obliged to adopt measures to ensure appropriate level of personal data security. Although these measures are not primarily directed for processing of personal data (which is rather a by-product of their purpose), processing of your personal data to some necessary extent might be needed in order for these measures to be implemented (for example encryption, pseudonymization, logging, backups, crash reporting, breach/incident reporting, security investigations and documentations, access control, harmful content detection, etc.).
Every time we are legally required to handle your requests, we must necessarily process your personal data. For example, when you approach us with request based on your data subject rights stemming from GDPR, we must process your personal data in order to comply with GDPR requirements.
From time to time, we might need to pursue a legal claim, ask for compensation or off-court settlement, keep evidence for potential dispute, manage legal contracts, request legal advice from external advisors, report illegal activity to law enforcement authorities or otherwise protect our legitimate legal interests (i.e. enforcing our legal rights). Although these activities do not automatically involve processing of personal data about our users (which happens very rarely), we would like to be transparent about such purpose of processing in case it does.
By virtue of this privacy policy, all of the above purposes are determined by us generally against all users of our Services , or any other persons concerned, from the moment of their collection despite the fact that the actual processing operation or purpose might not be relevant to every individual in every case. From this reason, we do not regard these as “other” purposes pursuant to Art. 6(4) of the GDPR which would require us to inform you about such purposes once they become relevant in future.
Regulations on archives and registries apply to the storage of personal data that we process about you. According to the registry plan, we are obliged to keep registry records during the storage periods specified therein.
Generally, we collect your personal data directly from you (source), for example when you decide to download our app, make a purchase, register your account, use an additional service, which may also include to get a service provided jointly with a business partner fill-out marketing consent form, contact us or otherwise use our Services. Provision of personal data to us by you might happen directly, for example by filling-out registration, order or consent form but might also happen indirectly for example by using our apps which need to collect data in order to operate and in order to provide you with the Services requested. For example, when using our navigation or localization apps, we must collect your precise location, speed and bearings. Provision of personal data by you is voluntary or presents either a requirement to enter into a contract or a contractual requirement (EULA). Certain processing of personal data might be required by law or required by us in order to pursue our own legitimate interests, as explained above. However, if you decide not to provide us your personal data in the first place, these additional statutory or legitimate interest provisions of data should not happen.
In certain cases, we may receive your personal data from another person - for example, from a user which, decided to include you as an insured person in the insurance when joining the insurance, or which reported to us an insurance event that happened to you. However, if you, as a user, do not provide Tripomatic as with the necessary personal data, you will not be able to access to insurance and thus obtain the appropriate insurance protection (i.e. the provision of personal data is necessary to access to insurance through us). If you do not provide Tripomatic with the necessary personal data in connection with the reporting of an insurance event and / or the filing of a complaint after accessing to insurance, we will not be able to manage report the insurance event behalf you and / or file a complaint to the insurance company and arrange its resolution.
We take the confidentiality of your personal data very seriously and have policies in place to ensure that your data
is only shared with authorized personnel of Tripomatic or a verified third party. Our employees might have access to your
personal data on a strictly need-to-know basis typically governed and limited by function, role and department of
the particular employee. We also use sub-contractors to support us in providing the Services who might process
personal data for us. We ensure that selection of our sub-contractors and any processing of personal data by them is
compliant with the GDPR. Categories of recipients of your personal data are:
• Hosting or cloud services providers or related services to support the operation or operation of our applications
and Services (e.g., Google, LLC, Apple, Inc., Amazon Web Services, Inc., Stormware, s.r.o.);
• Marketing and analytics software service providers (e.g. Google LLC, Facebook Ireland, Ltd., Facebook Inc.,
Exponea s.r.o.);
• Social media platform operators (Facebook Inc., Facebook Ireland, Ltd., Youtube LLC, Twitter, Inc., Microsoft
(LinkedIn), Pinterest, Stack Overflow, Github, Tumblr, Dribble, Behance, Vimeo);
• Authorized personnel of the above, internal subcontractors as well as employees of the above recipients and
suppliers
By default, we seek not to transfer your personal data outside the EU and/or European Economic Area where not necessary. However, some of our sub-contractors or the above-mentioned recipients of personal data might be based or their servers might be located in the United States of America (U.S.) or in other country regarded as third party not ensuring adequate level of protection. Any transfer of personal data outside the European Economic Area is done by us only under strict compliance with the GDPR. We ensure the third-party recipients concluded EU model Standard Contractual Clauses (SCC) with us or follow equivalent safeguards in place.
We must not and we do not want to store your personal data for longer than necessary for the given purpose of
processing. Due to this legal requirement but also due to technical and financial aspects of data storage we
actively delete data where no longer necessary. In general, storage periods of the following purposes are linked to
active usage of our apps and the actual data on our product servers at the given time:
• Provision of the Services
• Development, improvement & testing
• Marketing analytics
• Statistics
• Security of personal data
This means (in general) that if you stop using our app, we stop processing your personal data for the above purposes
of processing. If you uninstall our app, we delete personal data collected by the app. However, depending on the
circumstances we delete some data sooner or later than that, for example:
• Data used for application improvement after 3 months
• Security and system logs are deleted after 1 year
• Back-ups for security purposes are deleted after 3 years
Some of our users might have a life-time license for our apps. In that case, we must store credentials of the license holder for a period equivalent to “life-time” period which is 90 years from license purchase. If you request us to erase your personal data including your license credentials we can do so, but you will loose the life-time license as well (i.e. you will no longer be in the list of license holders). Please note that if you then decide to use our apps again in the future, you might not be able to rely on your license unless you prove to us that you had the license before. We therefore suggest you keep evidence of our communication about the license credentials erasure.
For deleted accounts, we may retain certain personal data for compliance with legal obligations or for legitimate purposes, such as legal claims or fraud prevention, as outlined in this policy. Refer to specific retention periods mentioned above for further details.
As regards the purpose of direct marketing communications (newsletter & push notifications), the storage period generally lasts until you revoke your consent (opt-out) or object against direct marketing.
As regards Billing, Tax & Accounting purposes the retention period are governed by local law and depending on the type of information or document in which billing personal data might be included the storage period is 10 years.
It stems from the nature of social media profiles that we do not actively delete the history of our profiles, but you are free do so or request us to do so at any time. We delete old private messages via social media once every 3 years.
In general, storage periods for consumer contests is the duration of the contest.
As regards handling user requests and legal enforcement, we might keep your personal data if we believe it might be necessary for us in court, criminal or administrative proceedings in the future. General limitation period under Czech law is 3 years.
The storage periods are set out in the company's registration plan represent retention periods in relation to the archival purposes and administration of the registry. By default, these storage periods are 2-10 years from the creation of the registry record, for some HR documents 50 years or 70 years from birth.
You have right to object to any processing that is based on legitimate interest including to profiling based on such legitimate interest pursuant to the Article 21 GDPR. We rely on legitimate interest for purposes of Development, improvement & testing, Marketing analytics, Maintaining social media profiles and Legal enforcement.
Nevertheless, you have the right to object effectively at any time to the processing of personal data for direct marketing purposes, including profiling.
You also have a right to object to any direct marketing processing of your personal data including profiling.
If we process your personal data, you have so-called data subject rights under the Article 15 to 22 of the
GDPR:
• Right to request access to your personal data according to Article 15 of the GDPR;
• Right to rectification according to Article 16 of the GDPR;
• Right to erasure of personal data according to Article of the 17 GDPR;
• Right to restriction of processing according to Article 18 GDPR;
• Right to be notified in connection with a rectification, erasure or restriction pursuant to Article 19 GDPR
• Right to data portability according to Article 20 GDPR;
• Right to object against the processing including profiling based on legitimate or public interest according to
Article 21 of the GDPR;
• Right to object against processing for direct marketing purposes including profiling according to Article 21 of
the GDPR;
• Right to not be subject to the automated individual decision making according to the Article 22 of the GDPR.
However, these are not absolute rights and they only exist if the relevant conditions are met. For example, right for erasure does not apply in case when such personal data is required for compliance with legal obligation (Billing, Tax & Accounting) or for the establishment, exercise or defence of legal claims (Legal enforcement). Please contact us at privacy@tripomatic.com if you have a general query about your data subject rights.
You have a right to lodge a complaint related to personal data to the relevant data protection supervisory authority. Please note that our lead data protection authority is the Personal Data Protection Office of the Czech Republic and the "complaint" must be submitted in accordance with the current legislation.
If you are not sure about whether we process your personal data, you can request our confirmation by reference to the
right of access under the Art. 15(1) of the GDPR. If we do process your personal data you can request the following
information:
• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular
recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria
used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data or restriction
of processing of personal data concerning the data subject or to object to such processing;
• the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their
source;
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at
least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject.
Please note, that if you use our apps, most of the above information is already included in this privacy policy. You have also right to request copy of your personal data pursuant to the Art. 15(3) of the GDPR. You have right to request some of your personal data in a structured, commonly used and machine-readable format provided that the conditions for data portability under Art. 20 of the GDPR are met. These conditions might be met where the legal basis for processing is your consent or performance of contract (provision of the Services, newsletters and consumer contest) or arranging the opportunity of ordering the products of our business partners through our applications where you provide the personal data to us.
When we process your personal data based on your consent, you can always revoke your consent at any time. You can always use our general contact details for revoking consent or objecting to processing. In case of email newsletters, you will find opt-out button at the bottom of every direct marketing email.
If you feel that we are processing incorrect personal data about you given the purpose and circumstances and you cannot change such personal data via functionality of the app, account or website, you can request rectification of incorrect or incomplete personal data using the below supplementary statement (all information is voluntary) and/or our general contact details:
| Supplementary statement for rectification of personal data | |
| Your name and surname: | |
| Account email: | |
| Type of service used: | Please indicate what application, website or service your request relates to |
| Nature of your rectification: | Please explain whether you would like to request correction of incorrect or completion of incomplete personal data |
| Context of your rectification request: | Please explain us why you believe we are processing incorrect or incomplete data |
| Rectification: | Please express the correction or completion of the particular personal data you are requesting |
This supplementary statement for rectification can be send to Tripomatic at privacy@tripomatic.com
When enforcing your data subject rights, please be as explicit and detailed as possible. Otherwise, we might respond with request to clarify a generic, vague or too general requests which in turn delays getting the information you request.
When processing your personal data, operating our websites or generally providing or supporting our Services we may use cookies and similar technologies. Specifically, we use these technologies for Direct marketing communications (newsletter & push notifications) and Marketing analytics. You have a control about the use of cookies via setting of your internet browser, where you can disable cookies at any time.
We may change this privacy policy from time to time by posting the most current privacy policy and its effective date on our website. In case we change this privacy policy substantially, we may bring such changes to your attention by explicit notice in our apps, on our websites or by email.
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