Privacy policy for using the Swiss Climate Challenge app

Data protection is a matter of trust, and your trust is important to us. Responsible and legally compliant handling of personal data is of great concern to us, MotionTag GmbH and Swisscom (Switzerland) Ltd (hereinafter "we"). This privacy policy ("policy") describes the way we process your personal data in connection with the Swiss Climate Challenge app (hereinafter "app"). It also contains information about your rights under the applicable data protection laws.

1. Applicability

This policy applies to the processing of personal data in connection with your use of the app. Utilisation of the app is also regulated by specific terms and conditions of use. Furthermore, the terms and conditions of use and the privacy policy of the application via which you load the app may also be applicable.

2. Swiss Climate Challenge app

The app is a component of the Swiss Climate Challenge. The Swiss Climate Challenge aims to raise public awareness of the consequences that mobility presents for our climate and to promote more climate-friendly mobility. The app offered by Swisscom (Switzerland) Ltd analyses users' mobility with regard to the chosen method of transport, the distances covered and the associated CO2 emissions. This enables users to gain an overview of the environmental footprint created by their personal mobility. For this purpose, the app uses the tracking technology of MotionTag GmbH. The app is programmed by the Swisscom subsidiary NGTI, which also provides evaluation services.

3. Contact details of the responsible parties

The following companies are jointly responsible with regard to using the app:

  • Swisscom Ltd, Corporate Responsibility, 3050 Bern, Switzerland;
  • Motion Tag GmbH, Rudolf-Breitscheid-Str. 162, 14482 Potsdam, Germany.

4. Contact details of the data protection officers

  • Swisscom Switzerland (Ltd), Data Protection Officer, P.O. Box, 3050 Bern, datenschutz@swisscom.ch
  • Motion Tag GmbH, Data Protection Officer, Rudolf-Breitscheid-Str. 162, 14482 Potsdam, datenschutz@motion-tag.com – external data protection officer: Roman Maczkowsky, m-privacy GmbH, Werner-Voss-Damm 62, 12101 Berlin

5. Registration data

User registration is regulated in section 3.1 of the terms and conditions of use. Registration is carried out exclusively with your mobile phone number. During the registration process, you grant your consent to this privacy policy. We use your registered mobile phone number to ensure you can be identified again when using the app.

6. Processing of personal data

We process different categories of personal data in connection with your use of the app. Personal data is any information relating to an identified or identifiable natural person (“person concerned”). Personal data is processed as follows:

6.1 Location and motion data

We collect your location data based on GPS data via the app. This allows us to determine the time at which you were located at particular spatial coordinates. To do this, the GPS data is compared with geodata ("geomatching"). In exceptional cases, your mobile phone determines your location data by finding the nearest mobile communication antennas.

In addition, we collect your motion data based on acceleration patterns.

Since every method of transport has a specific acceleration pattern, we can analyse these patterns and determine the method of transport you are using as well as the duration and distance of use. We can also detect whether and for how long you walk on foot. If you use several methods of transport for a certain distance (e.g. on the way to work), we can create a movement profile and determine which means of transport you used during which stage (modal split). If you use the app over several days, we will collect movement profiles over several days.

If a WiFi connection is available or mobile data is switched on, your location and motion data will be transmitted to MotionTag GmbH's German data centre and stored in a database there. Your location and motion data is transmitted exclusively using secure encryption procedures. Once your location and motion data has been transferred to the MotionTag GmbH data centre, it is automatically deleted in the app on the mobile phone.

Only the mobile phone number for the login for the most recent usage is stored in the app. This makes it easier to log in again, as the mobile phone number does not have to be entered again. Passwords and other user-related data are not stored.  

MotionTag pseudonymises the location and motion data by applying a randomised user ID (uuid). Individual stages can be assigned to a user via this uuid. This allocation is necessary for the calculation of individual CO2 statistics.

MotionTag never has knowledge of any personal data, such as e-mail, telephone number or the user's name. Nevertheless, recurring positions could be used to draw conclusions about where people live and work and thus about individuals. Even if the participants are not identified, the collected movement profiles are still regarded as personal data. Accordingly, this data is treated with the same amount of care as your personal registration data (mobile phone number).  

An agreement regarding permissible evaluations was reached between Swisscom and MotionTag. MotionTag employees are prohibited from performing evaluations that are not covered by this agreement.

6.2 Climate-relevant data and contact details

MotionTag calculates the CO2 emissions, distance travelled per means of transport and the influence on the temperature of the planet based on the pseudonymised mobility data and stores this in the app on the respective user's mobile phone. In addition, NGTI temporarily stores and evaluates this climate-relevant data.

The climate-relevant data can also be released by the user for comparison with the data of other participants, which, in turn, can provide an additional incentive for climate protection. For this purpose, the mobile phone number and an identification number for each contact in the contact list are uploaded to Swisscom's App Cloud and stored there in pseudonymised form. This is necessary to make a comparison with other participants possible. Users can decide for themselves whether or not to share their climate-relevant data with other users in their contact lists.

6.3 Personal data at a glance

We process the following personal data:

  • Model of the mobile phone;
  • Version of the installed operating system;
  • Version of the app;
  • Location data (GPS coordinates);
  • The motion activity that is pre-evaluated by the mobile phone (e.g. "motorised" or "on foot")
  • Mobile phone number;
  • User identification via SMS (two-factor authentication);
  • Mobile phone number and identification number of the contacts;
  • Location time of the localisation;
  • Geo-coordinates and accuracy (determined by the GPS chip);
  • Acceleration values (determined via sensors in the mobile phone);
  • Gyroscopic sensor/gyroscope values (determined via sensors in the mobile phone);
  • Barometer/air pressure data (determined via sensors in the mobile phone);
  • Magnetometer (determined via sensors in the mobile phone);
  • Motion activity;
  • Detection reliability (confidence) of the motion activity.

7. Purposes of personal data processing

We process your personal data for the following purposes:

  • To offer, manage and improve the app's services, such as tracking mobility, calculating the impact on the climate or comparison with others;
  • To perform aggregated, anonymised analyses of movement data for cities and municipalities;
  • To survey the means of transport used;
  • To determine the duration and distance of motion stages;
  • To collect and analyse one-day and multi-day motion profiles;
  • To calculate CO2 emissions;
  • To determine the ecological footprint and compare it with those of other users;
  • To manage the contractual relationship between you and Swisscom;
  • To validate your data;
  • To open and update the user account;
  • To identify users;
  • To communicate with the user;
  • To provide user support;
  • To answer your questions and concerns;
  • To send newsletters and other news concerning the Swiss Climate Challenge and the app;  
  • To ensure Swisscom and MotionTag's app and infrastructure security;
  • To carry out troubleshooting, data analysis, testing and research;
  • To develop new features and functions, improve the user experience and increase usability;
  • To verify compliance with applicable laws and regulations and the terms and conditions of use;
  • To prevent abuse of the app; and
  • To comply with applicable laws and regulations or answer requests from the competent courts and authorities.

8. Recipients of personal data

Employees of our companies have access to your personal data to the extent necessary to achieve the above-mentioned purposes.

Insofar as it is necessary to achieve the purposes set out here, we utilise service providers who support us with data processing in the scope of order processing (service providers for the following services: data analyses, IT and data centre operation, destruction of documents and data carriers, operation of websites). These service providers are subject to strict contractual agreements, including those on confidentiality.

9. Data processing in third countries

We process your personal data only in Switzerland and Germany. 

10. Your rights

You have the right to receive information about your personal data processed by us in writing and free of charge at any time. You can send us your information requests in writing, enclosing a copy of your identity card or passport, to the following e-mail address: Swisscom (Switzerland) Ltd, Legal & Regulatory, Data Protection, PO Box, CH-3050 Bern or Auskunft.Datenschutz@swisscom.com.

You also have the right to request the rectification of incorrect personal data.

As a matter of principle, we delete personal data if it is no longer required for the above-mentioned purposes. At the end of the recording period (end of the Swiss Climate Challenge), we will delete all personal data.

If you would like to have your personal data deleted before the end of the Swiss Climate Challenge, you can request this at any time by sending an e-mail to Auskunft.Datenschutz@swisscom.com. Your data will be definitively deleted within one month.

Finally, you have the right to revoke any consent provided regarding the processing of your personal data and/or to object to the processing of your personal data at any time.

11. Amendments to this privacy policy

As changes in the law or changes to our internal company processes may make it necessary to adapt this privacy policy, which we reserve the right to do accordingly, we ask you to check this privacy policy at https://www.swissclimatechallenge.ch/en/privacy-policy at regular intervals.

January 2020