Privacy Policy

⚠️ DRAFT FOR LEGAL REVIEW not final

This policy is a draft (Version 2.0-draft) describing the currently implemented data flows: granular consent per TDDDG §25, a 16+ self-declaration gate for sponsors/ads, and contextual sponsor slots that process zero personal data. Legal counsel must review this text before publication. Points requiring review: sponsor-contract wording, the legal basis for contextual (non-personalised) ads, and the offline sponsor-card placement.

1. Controller Art. 4(7) GDPR

This application is operated by Sofiane (the "controller"), contactable at advice@onpremise.cloud. It is a non-commercial hobby project operated privately; there is no business, no company and no revenue. The app is permanently free for end users. Because the app stores no account or identity data server-side, no dedicated Data Protection Officer is required (Art. 37 GDPR does not apply to this processing). You can exercise any of the rights below by using the in-app ☰ → Delete my data function or by contacting the operator directly via email.

2. What we process Art. 13 GDPR

The navigation core sets no cookies, no advertising identifiers, no fingerprinting, and never reads your contacts, photos or messages. Because the app is used over HTTPS, we also cannot re-read your location once you leave. We run a privacy-by-design setup: the only directly identifying personal data we ever store is your email — and only if you voluntarily subscribe to the newsletter. Like almost any website, this server keeps short technical access logs (IP, time, requested file) to protect against abuse; these are not linked to your identity in the app and are not used to profile you. Anonymous analytics, sponsors and ads are collected/shown only after the corresponding granular consent is granted (see §5); without it none of that processing happens at all.

3. Legal basis Art. 6 GDPR

• Art. 6(1)(b) — performance of a contract / pre-contractual steps: processing your location is strictly necessary to provide the navigation service you requested by pressing "Start navigation".
• Art. 6(1)(a) — consent: sharing your live position and name with other riders, and storing preferences in your browser, happen only after you explicitly accept the consent prompt.
• Art. 6(1)(f) — legitimate interest: transient in-memory routing of your request to OSM services (map tiles, routing, geocoding). This is minimal, ephemeral, and does not override your rights.

4. Third-party processors Art. 13(1)(e) GDPR

To function, the app makes client-side requests to free OpenStreetMap-based services. No personal data beyond the immediate query (coordinates / address) is transferred, and none is stored by us:

• OpenStreetMap map tiles (tile.openstreetmap.org) — map rendering. Server logs standard HTTP request data per their policy.
• OSM routing (routing.openstreetmap.de) — route geometry for your current origin→destination pair.
• Nominatim (nominatim.openstreetmap.org) — geocoding the address you type. Subject to their usage policy.
• Overpass API (overpass.openstreetmap.fr, via our /api/overpass proxy) — loading public charging-station points; sends only map coordinates.
• Elevation API (api.opentopodata.org, via our /api/elevation proxy) — elevation profile for a route; sends only the route's coordinates.
• This server (/api/destinations, /api/route) — the built-in list of Amazon fulfillment-center addresses (public location data) and the cached routing proxy. No personal data is involved.
• Amazon Europe (amazon.de) — only when you click a product in the Marketplace. You are then on Amazon's own site under Amazon's privacy policy. We receive no personal data back from Amazon.
• Google AdSense (googleads.g.doubleclick.net, pagead2.googlesyndication.com) — consent-based advertising, loaded only if you accept the sponsors/ads purpose and confirm you are 16+. Never contacted in privacy mode.

These are privacy-respecting, non-tracking services. For affiliate transactions (Amazon Associates), we act purely as an advertising intermediary and never see, store, or receive your payment or account data.

We do not sell data. ScootNav does not sell, rent, or trade personal data to anyone, and does not sell personal data for money or any other consideration to any third party. Any revenue would come only from consent-based advertising and affiliate commissions paid by click-through/qualifying purchase on Amazon.de — neither of which involves selling your data.

5. Consent & granular choices Art. 7 GDPR, §25 TDDDG

• On first launch you are shown a granular consent dialog with three separate purposes: (1) Essential navigation — always on, no choice needed; (2) Anonymous analytics — optional (aggregate counts, no identity, no GPS path); (3) Sponsors & offers — optional and additionally gated on your self-declaration "I am 16 or older" (e-scooter riders may legally be 14+ in Germany, so non-essential processing requires the adult self-declaration).
• If you reject the optional purposes, the app runs in privacy mode: no analytics are collected or uploaded, no sponsors/ads are shown, and no ad network or analytics server is ever contacted. Essential navigation remains 100% functional (FREE-CORE guarantee).
• Consent can be revoked at any time via ☰ → Delete my data with the same ease as it was given (Art. 7(3)).
• Live position sharing with the optional multi-rider feature is a separate, explicit toggle — it is OFF by default (privacy-preserving). Nothing leaves your device for this feature until you switch it on in the menu, and it stops as soon as you switch it off or end the ride.
• In plain terms: what stays on your device vs. what leaves it — your ride history, XP/coins, settings and preferences are stored only in your browser's localStorage. The only data that ever leaves your device is: (a) your live position + chosen name, but only while you have opt-in live sharing switched ON; (b) anonymous analytics events, but only if you granted the analytics purpose; (c) your email, but only if you subscribe to the newsletter; (d) the address you type, sent to the OSM geocoding service to find it.

6. Storage & retention Art. 5(1)(e) GDPR

• Server side: live rider positions exist only in RAM, expire automatically after 25 seconds with no new report, and are purged on process restart. There is no database, no log of locations, and no backup of this data.
• Client side: preferences (name, cruise speed, rider ID, consent choice) live in your browser's localStorage on your own device and never leave it except when you actively ride (the current name + position for 25s).
• Trip history: your past rides (date, distance, duration, destination, XP) are stored in your browser's localStorage only, on your own device, and are kept until you clear site data or use ☰ → Delete my data. They are never sent to our server.
• Newsletter: the consent checkbox is unchecked by default — you must tick it to subscribe. Your email is stored on our server only if you subscribe, and is deleted on unsubscribe or on request.
• Deleting the app / clearing site data removes all client-side storage immediately.

6b. Newsletter Art. 6(1)(a) GDPR

If you subscribe, we store your email address and the date/time of your explicit consent to send occasional update and tip emails. Subscribing is entirely optional. You can unsubscribe at any time — every message includes an unsubscribe link, or email advice@onpremise.cloud. On request we delete your email immediately (see rights below).

7. Your rights Arts. 15–22 GDPR

• Access (Art. 15) — a copy of any personal data we hold about you.
• Rectification (Art. 16) — fix your rider name/identity.
• Erasure (Art. 17) — use ☰ → Delete my data; server-side live data self-deletes within 25s.
• Restriction (Art. 18) & Objection (Art. 21) — stop sharing or processing.
• Data portability (Art. 20) — your data is already fully under your control in your browser.
• Right to withdraw consent (Art. 7(3)) — at any time, with the same ease as giving it.
• Complaint (Art. 77) — you may lodge a complaint with your local supervisory authority (in Germany, e.g. the LDI NRW).

Because of the in-browser, ephemeral architecture, most rights are already exercised by design — there is no server-side account to lock or export.

8. Sponsors, advertising & affiliate program Art. 6(1)(a), §25 TDDDG

ScootNav is permanently free for end users. The only monetization is the operator's personal Amazon Associates affiliate program: a commission if you make a qualifying purchase through a product link in the Marketplace tab. There are no third-party sponsors, no user payments, and no sale of data:

• Consent + 16+ gate required: no sponsor card, ad, or ad network is involved before you accept the consent prompt and confirm you are 16 or older. In privacy mode, no sponsors/ads are shown and no ad network is contacted (TDDDG §25).
• Contextual only — zero personal data: sponsor cards are matched purely on the destination you select (e.g., "Destination: DTM1 Werne → local bike shop"). No cookies, no advertising identifiers, no user profiles, no cross-session or cross-device tracking. Every placement carries a clear "Sponsored" label.
• Never gates the core: sponsor and ad placements never block, delay, or degrade navigation, offline maps, voice guidance, or charging-station data (FREE-CORE guarantee).
• Removed during navigation: ad/sponsor slots exist only on the pre-ride setup screen and post-ride summary. During active navigation all placements are removed.
• Offline-safe: when offline, a static local sponsorship card replaces network ads — no request is sent when there is no connection.
• No rider data: sponsor/ad delivery never receives your GPS position, rider name, or destination; only the selected destination string is used client-side for matching.
• Affiliate links: Marketplace product links go to amazon.de and carry our Amazon Associates tag. These links are marked rel="sponsored", and we record the click only as an anonymous aggregate count. Amazon processes everything on their site per their own privacy policy.

8b. Your rights shield Arts. 15–22, 77 GDPR

German and EU law give you a protective shield over your personal data. You can invoke all of these rights at any time, free of charge:

• Access (Art. 15) — a copy of any personal data we hold about you.
• Rectification (Art. 16) — correct your rider name/identity or email.
• Erasure (Art. 17) — “right to be forgotten”. Use ☰ → Delete my data or email the operator; server-side live data self-deletes within 25s, your newsletter email is deleted on request.
• Restriction (Art. 18) & Objection (Art. 21) — stop processing or sharing.
• Data portability (Art. 20) — your data is already fully in your browser.
• Withdraw consent (Art. 7(3)) — any time, as easily as given.
• Complaint (Art. 77) — lodge a complaint with the supervisory authority of your EU member state; in Germany that is the State Commissioner for Data Protection (Landesbeauftragte), e.g. LDI NRW.

We will honour any request within 30 days (Art. 12 GDPR). Because the app is designed with data minimization “by default and by design” (Art. 25 GDPR), most of your rights are already satisfied: there is no account system, and no data beyond what is described in §2 exists to be exported or locked.

9. California Consumer Privacy Act (CCPA)

California residents have the right to opt out of the "sale" or "sharing" of personal data.

• ScootNav does not sell personal identity information.
• Anonymized ad telemetry served through third-party networks can be managed through the Network Advertising Initiative Opt-Out Portal.

10. Security Art. 32 GDPR

• Transport is fully encrypted (HTTPS / TLS 1.2+ via Let's Encrypt) and the app is a secure context, which is also required for GPS access.
• Server-side input is strictly validated (coordinates, speed, payload size capped at 4 KB) and the static-file server is path-traversal protected.
• The peer relay holds only minimal, ephemeral, pseudo-anonymous data with a hard memory cap.
• The service worker caches app assets locally for offline use; no personal data is written to the cache. Ad-network responses are never cached.

11. Changes to this policy Art. 13(3) GDPR

If processing changes materially, this page is updated with a new version date, and the app banner reflects it. Continued use after a change implies acceptance of the updated policy.

12. Contact

Questions, erasure requests, or audits: contact the operator Sofiane at advice@onpremise.cloud. Please allow 30 days for a response, as required by GDPR.