Privacy Policy

The party responsible for data processing is:
flinc GmbH
Heinrich-Hertz-Strasse 6
64295 Darmstadt
hilfe@flinc.org

Thank you for your interest in using flinc’s services. We want to work with you to make mobility more flexible, green and affordable.

The flinc portal was developed with the aim of recording as little data as possible while also developing a service that makes arranging car shares easier than ever. This was frankly a huge challenge because we can only offer special features (such as partial route arrangement or arrangement directly in the navigation system) by recording certain data.

We have kept the amount of data initially recorded when registering with the flinc portal as small as possible (please refer to the section on Registration). You can voluntarily complete your user profile in the internal section of the flinc portal under “My flinc”. Under “Menu” → “Settings” → “Privacy” you can also specify what data of yours is visible to other users.

The more information you voluntarily reveal (real name, photo), the more trust you engender with other users, making it more likely that others will share rides with you.

We comply with the data protection laws of the Federal Republic of Germany and the European Union’s General Data Protection Regulation (GDPR) with respect to all of the data that we record.

We generally follow the basic principles set out below:

  • We do not sell any personal data
  • We follow the principle of using data sparingly
  • We never pass on your details to third parties for marketing purposes without your consent
  • We do not record, process or use any personal data unless permitted to do so by law or you have given us your consent
  • You will not receive any spam e-mails from us

We store your personal data on servers situated in Germany and the EU. There are just a few exceptions to this:

  • In order to allow us to focus on the technical development of flinc and other services, for our support system we use the established software of Zendesk, which stores your e-mail address in the US. You can find out more about this in the section on Support and Feedback.
  • For users who request our newsletter and e-mail notifications we use the US-based provider SendGrid, who only receive the e-mail addresses for the recipients of each mailing. Please refer to the section on the “Newsletter and Regular Status E-mails” in this regard.
  • We send SMS notifications using the US-based provider Twilio, who also only receive the cell phone numbers for each individual messaging batch. Please refer to the section on “Master Data” in this regard.

All three of the aforementioned companies are certified in accordance with the EU-US Privacy Shield Framework and are therefore committed to compliance with data protection provisions that provide an adequate level of protection along the lines of the EU provisions.

Master Data for the Use of flinc (Registration)

You must provide us the following personal data in order to use flinc. The legal basis is therefore the execution of a contract with you (Art. 6 (1) b GDPR).

  • First name
  • Last name
  • E-mail address
  • Password
  • Cell phone number (for verification)

Please make sure that you choose a secure password. This means one that is at least 10 characters long, and with 3 of the following 4 features: upper/lower-case letters, numbers, special characters. Your e-mail address and password are never visible to other flinc users.

We use your e-mail address and/or cell phone number to send you messages, for example if we have found a driver for you or we receive a request from a potential passenger. You can specify the notifications you would like to receive in your account settings. If you opt out of receiving newsletters and notifications, we will also not provide your e-mail address and/or cell phone number to the service providers we use for those purposes. Your cell phone number is only visible during the arrangement process between a driver and passenger, and only to the other person in each case.

We need your first and last names in order to personalize the use of flinc. Please provide accurate information in order to establish trust with other drivers and passengers.

We also save the date of your registration and display it on your profile as “Member since May 2011”.

User Profile

After registering you can add the following personal data to your profile. You grant us your consent to the use of this data (Art. 6 (1) a GDPR). The data is provided on a voluntary basis, and you can use flinc without providing it.

  • Date of birth
  • City/town of residence
  • Gender
  • Photo

Entering your date of birth allows other users to see your age. We use your place of residence to display other flinc users in your area.

You can also personalize your profile by uploading a photo that can be viewed by other flinc users. A photo also engenders trust, and makes a connection more likely.

Following a completed journey the driver and passengers can leave a positive (thumbs up) or negative (thumbs down) review of the other person. The total number of positive and negative reviews is displayed in your profile. This allows people to judge the reliability of drivers and passengers.

You may delete your flinc account at any time. This deletes your profile data without delay. Any identifying data is removed from your ride shares and routes.

Creating Journeys

When you create a journey we store the following data that you provide:

  • Your route
  • Pricing
  • Comment
  • Vehicle (if provided)

This data is required to arrange journeys, which means that it is also required for the execution of the contract (Art. 6 (1) b GDPR). Your route is used to find passengers who would like to travel a similar route. You can find out more about the data stored for a route in the “Routes” section. The pricing is used to calculate the price of the journey for passengers.

Real-Time Positioning

If you use flinc as part of a navigation system (such as the Navigon app) or activate real-time positioning in the app as a driver, in addition to using the flinc website and app, the following additional data is recorded and stored:

  • Your current location in the form of geopositioning coordinates
  • Your covered route

The navigation system or app sends your current position to the flinc server every 30-90 seconds in the form of geopositioning coordinates. We require your location in order to avoid suggesting passengers that you have already driven past. We continue to store the route you have covered on the basis of the position reports in order to allow the correct determination of detours and prices, and to display statistics once the journey has been completed.

If you actively confirm a passenger, that person sees your most recent position report which allows them to estimate how far you are from the collection point. You can deactivate this function at any time in the settings.

Voluntarily sharing your real-time position allows you to also receive inquiries from passengers while you are driving. You can also find rides automatically via the web site or app. If you do not want the flinc server to store your current location, we would therefore ask you not to use flinc as part of your navigation system or activate the disclosure of your real-time position as a driver in the app. If you share your real-time position, the processing of data described above is necessary in order to offer this feature (Art. 6 (1) b GDPR).

Rides and Routes

When you create a ride we store the following data that you provide:

  • Your route
  • Comment
  • Number of people

We use your route to suggest drivers who are covering a similar route to yours.

There is a route for every journey or ride that you create. A route always comprises the following data:

  • Starting location, destination, stops
  • Departure time
  • Arrival time
  • Distance
  • Duration
  • Waypoints

Routes form the basis for the flinc algorithm, and are used to find suitable combinations of drivers and passengers. It is necessary to process rides and routes in order to identify suitable opportunities for ride sharing and therefore the execution of the contract (Art. 6 (1) b GDPR).

Similarly to existing ride sharing portals, we also show your routes to users who have not registered. Your address is obscured, however, and your name cannot be viewed in full. After registering the passenger only sees the obscured departure location of the driver as this is not necessary for matching. The starting location and therefore the collection point of the passenger is shown because it is the meeting point for the driver.

You can use the privacy settings to specify what information of yours should be visible to non-registered users.

We will statistically analyze created routes with identifying data removed, for example in order to show you how widespread flinc is in your region.

Personal Statistics

We record the following statistics while you are using flinc, which we also display in your profile:

  • Your reviews
  • The number of journeys and rides you have created
  • The total mileage of your journeys and rides
  • The number of kilometers covered with flinc integrated a navigation system
  • How often you have picked up passengers
  • How often you have been a passenger
  • The volume of CO² emissions you have produced and reduced
  • The number of your friends and friends of friends

You can specify which statistics you can view in your account settings.

Vehicles

You can also create vehicle profiles (manufacturer, model, color, license plate number) in order to make it easier for passengers to find you. Your license plate number is only visible to passengers you have accepted so that they can spot you more readily at the meeting point. This information is provided on a voluntary basis (Art. 6 (1) a GDPR).

Newsletter and Regular Status E-mails

We will send out e-mails at irregular intervals to inform you about important changes to products or new functions. We will also send you regular status e-mails in which we will present you with your personal statistics in order to allow you to use flinc more effectively.

We send these e-mails on the basis of a justified interest (Art. 6 (1) f GDPR), and believe that they serve your interests as well. If you do not wish to receive these e-mails, however, you may of course cancel them at any time in your account settings.

Zendesk Forum and Support Software

We use the Zendesk program to provide you with the best possible support. Zendesk stores your e-mail address and your issue on servers in the US. This happens when you write in our forum, give us feedback (for example in the flinc apps) or if you send us an e-mail at mailto:hilfe@support.flinc.org.

Duration of Data Storage

We store your personal data for as long as you use our service. If we do not receive active notice of termination from you we will assume that you are no longer using the service if you do not use the flinc portal for more than three years. Please note that certain data must be kept for longer even after you have finished using the service due to legal obligations (e.g. invoices for 10 years).

Web Analysis

This web site uses Google Analytics, a web analysis service provided by Google Inc. (“Google”), with the anonymizeIP() feature. This means that IP addresses are only processed in an abbreviated form in order to exclude the possibility of establishing a link with a particular person.

Google Analytics uses “cookies”, i.e. text files that are stored on your computer and allow your use of the web site to be analyzed. The information generated by the cookie regarding your use of this web site is generally transmitted to and stored on a Google server in the US. If IP anonymization is activated on this web site, however, Google abbreviates your IP address within the member states of the European Union or other EEA countries. The full IP address is only transmitted to a Google server in the US and abbreviated there in exceptional cases.

Google will use this information to analyze your use of the web site, compile reports on your web site activities for the web site operators and provide additional services associated with your web site and Internet usage. The IP address supplied by your browser in connection with Google Analytics is not linked with other data by Google. You can prevent the installation of cookies by choosing the appropriate setting in your browser software. However, we wish to point out that if you choose not to accept cookies, you may not be able to use all the features of our website, or individual features may be available with limited functionality only.

You can also prevent the data created by the cookie relating to your use of the web site (including your IP address) from being recorded and processed by Google by downloading and installing the browser plugin provided at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

By using this website, you agree to allow the data collected about you to be processed by Google in the manner described and for the purpose stated above.

You may object to the collection and storage of data at any time with future effect by installing the aforementioned browser plugin.

Analysis of Usage Data and Information Relating to Interests

This web site uses the analytics functions for reports on views in the Google Display network, the integration of the DoubleClick Campaign Manager and Google Analytics reports on performance by demographic characteristics and interests for the purposes of statistical evaluation. You can deactivate Google Analytics for display advertising and adjust adverts in the Google Display network by accessing the advertising settings at https://www.google.de/settings/ads.

We use “retargeting” technologies to be able to incorporate information on flinc into third-party web sites. This involves registering your interest in flinc using cookies. These cookies are read when you visit certain web sites or search engines. The process is anonymized, which means you cannot be identified through retargeting.

We also analyze how advert views, other usage of advertising services and interactions with these advert views and advertising services relate to visits to our web site.

If you do not want flinc to record information about your visit or receive advertising based on your interests, you can deactivate the use of cookies by Google by accessing the page for deactivating Google advertising. Alternatively, you can deactivate third-party cookies by accessing the deactivation page of the network advertising initiative or deactivating the use of cookies in your browser’s settings. This may impact the functionality of our page.

We also use data obtained from Google via interest-based marketing and visitor data from third-party providers (for example on age, gender and interests) in Google Analytics for statistical analyses.

Your Data Protection Rights

You have the following general rights in connection with the processing of your personal data:

  • 15 GDPR grants you the right to receive information about the personal data stored by us. This means that you can obtain confirmation of whether personal data relating to you is being processed. If this is the case, you have the right to information about said data. This is not an unrestricted right, however, and the interests of others may limit your right to information. The right also includes a right to a copy of the personal data being processed. We may demand appropriate compensation for all other copies that you request.
  • 16 GDPR grants you the right to the rectification of any inaccurate data we have stored relating to you.
  • 17 GDPR grants you the right to the erasure of your personal data in certain circumstances.
  • 18 GDPR grants you the right to impose restrictions on the processing of your personal data, subject to the criteria it describes.
  • 20 GDPR grants you the right to receive the personal data provided by you in a structured, commonly used and machine-readable format (data portability).
  • You also have the right to submit a complaint to the relevant data protection regulatory authority, particularly in the EU member state of your habitual abode or the site of the suspected breach of the GDPR.

Art. 21 also grants you a right of objection with respect to your personal data.

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data which is based on Art. 6 (1) f) GDPR (processing of data on the basis of a balance of interests). This also applies to profiling based on these provisions.

If personal data is processed for the purposes of direct marketing, you have the right to object to the processing of your personal data for the purposes of such marketing at any time. The same applies to profiling in connection with such direct marketing.

Please contact us as follows in order to exercise the aforementioned rights:

flinc GmbH
Heinrich-Hertz-Strasse 6
64295 Darmstadt
Germany
hilfe@flinc.org

Changes to this Privacy Policy

From time to time it may be necessary to update this privacy policy, for example due to the introduction of new technologies or new services. We reserve the right to amend or supplement this privacy policy at any time. We will publish such changes here and/or notify you accordingly (for example by e-mail).

Last revised: 2018, version no. 11