Data Privacy Policy

We, Iomob Technologies OU, registry code 14470136, address Katusepapi tn 6-502, 11412, Tallinn, Estonia, acting under the commercial name WheelCoin (hereinafter referred to as “we” or “Wheelcoin”) have created a useful and fun digital product – the smartphone tracking application named WheelCoin (hereinafter referred to as the “App”) so that you (under “you” we understand the individual user of the App) could be rewarded for your environmentally friendly mobility choices during your everyday activities.

Since the protection of your personal data – especially with regard to protecting your personal rights in collecting, processing, and using data – is important to us, we are providing to you this information on aspects of use relevant to data privacy.

Before agreeing to the use of our Service, please carefully read all of the information we provide on data privacy. Wheelcoin hereby undertakes to adhere to the following undertakings related to data privacy as described.


1 Purpose of Collection

As the world of mobility is facing the complicated issues of usability, sustainability (including in terms of finance and in terms of ecology), interoperability and security in the new changing world, new means of collecting data on mobility are required as well as incentivization for sustainable journeys.

Our goal is to be able to use our Service to track the trips and routes more precisely, as well as to develop new Service for users and business models for transportation companies.

We use the data recorded through our Service or services of our affiliates to improve our Service and to run assessments and incentive programs. We only make these assessments using psdeudonymous (quasi-anonymous) data which cannot be traced back to individual persons.


2 Description of the Service

The Wheelcoin service has been developed to incentivise green traveling and mindful behavior, to improve and simplify the way people travel and plan their journeys, to improve the user experience for transportation use, to create communities united by adherence to ESG, to help promote green mobility and improve business models in transportation, to provide new insights into mobility behavior, to gamify user cases for mobility, and to collect relevant key data, such as modal splits or transport volumes, as well as to identify centers of use for individual means of transport (hot spots). The data recorded helps us to improve the quality of the methods by which we determine this key data, and thereby improve the Service itself.


3 Collection Methods

3.1 Trip data
We use the App to collect your trip data (hereinafter referred to as “trip data”). We complete traffic analyses based on this trip data. These allow us to derive key data related to mobility (e.g. modal split). Furthermore, we determine trip purposes using activity patterns recorded over multiple days and spatial analyses.

Traditional approaches are no longer sufficient to precisely record trips which use various methods of transportation (intermodal trips). The app records mobility behavior psdeudonymously. Over a long period of time, this allows us to quantify indications of a change in mobility behavior, and to improve the Wheelcoin service using your feedback.

As soon as you start recording in the App, we collect data points that contain spatial coordinates, times, and states of movement. We have developed algorithms that interpret groups of these data points as stages using various methods of transportation, and determine other associated attributes like duration and distance. If you record over multiple days, the app can create multi-day movement profiles.

Although movement profiles are recorded pseudonymously, revisiting the same location multiple times can allow conclusions to be drawn regarding residences, places of employment, and individual persons. Even if no attempt is made to identify users, recorded mobility profiles are personal data. Accordingly, we treat these with the same sensitivity as we do your personal registration data (user name, email address).

Both the apps for iOS and Android operating systems transmit information on your smartphone model, operating system version, app version, location data, and movement activities pre-analyzed by the mobile phone (e.g. “motorized” or “walking”), as well as the data listed here. All further attributes, such as the means of transportation used or the trip purpose, are calculated using algorithms based on these input data, as well as through a comparison with geodata (geomatching). Geodata includes data from the OpenStreetMap project and other internal, vehicle-related car sharing and taxi usage data for the entire vehicle fleet (not individualized).

3.2 Type and Scope of Data
The following list provides an overview of the data collected:

Primary identification data:

  • User name and email address for establishing contact, recruiting, and potential incentives.
  • Registration information for registering through the app

Smartphone application:

  • Time of localization
  • GPS coordinates and precision (determined by GPS chip)
  • Acceleration values (determined by sensors in smartphone)
  • Gyro sensor values (determined by sensors in smartphone)
  • Barometer / air pressure data (determined by sensors in smartphone)
  • Magnetometer (determined by sensors in smartphone)
  • Movement activities from operating system
  • Detection reliability (confidence) for movement activities
  • User agent device type, operating system version, app version)

4.3 Processing trip data
After being recorded by the App, data is transmitted via Wifi connection or, if activated, through mobile data to our server in an ISO certified computing center, where it is saved in a data bank. Transmission of data recorded by the app occurs exclusively through encrypted procedures. Raw data is processed on our server using the analyses described above.

4.4 Saving Data in the App
Besides the data points collected, the App itself saves only the email address for the login of the last user. This makes it easier to log in again, since users do not need to re-enter their email addresses. Passwords and other user information are not saved. After data points are transmitted to the server, they are deleted in the App.

4.5 Establishing Contact
We would like to keep you informed of important information such as new features, changes to the Privacy Policy, or new matching projects. We would like to use the email address you provided during registration to do so. To ensure we do not annoy you with excessive communication.


4 Transfer to Third Parties

In general, we never share your personal data with third parties outside of Wheelcoin with the exception of third party services that we run partnership campaigns with and with the exception of our affiliates. External service providers who process data for us under contract are subject to strict contractual obligations as well as all our partners.

We transmit data to service providers through an encrypted and secured connection. We use computing centers certified in accordance with ISO 27001.


6 Saving and Deleting trip data

You can block or delete all of your trip data at any time. To do so, you can simply send us an email to [email protected] with the subject “Please delete trip data” from the email address with which you registered for our service. We will then remove your data from the live system, so that it will not be included in further assessments.

Deletion of data is irreversible, and data will be deleted from all data media, including back-up memories. For technical reasons, however, deletion from back-up memories will be subject to a time delay.
All data saved in the app will be deleted when you uninstall the App.

Your stages are displayed on a map in the app. You can also use the App to correct your analyzed stages.


7 Individual Rights

Independently of the above mentioned provisions it is your right at all times (in accordance with Art. 7(3) and Art. 21 GDPR) to contradict the use of your data and revoke any previous given consent for your data being processed.

In case of revocation of consent to process your data or use of any data obtained, legality of data processing up to the date of revocal cannot be disputed.

Right of adjustment, blocking and limitation

Moreover, you can ask us to adjust, block or delete data collected by us (Art.16, 17, 180 GDPR). We would like to explicitly point out that there may be legal obligations to continue storing data – in this case this data can only be blocked.
Right for data portability and complaint to a regulatory body
Since May 25, 2018 you furthermore have the right to data portability (Art. 20 GDPR) and the right to complain to the responsible regulatory body in accordance with Art. 77 GDPR.

Contact person for exercising individual rights

According to Art. 15 GDPR you are entitled to receive information on what data of you is stored (right to information). The responsible party of the processing of data is Iomob Technologies OU. To exercise the above mentioned rights please contact [email protected] or send a mail to us.


8 Contact

[email protected]
Attn: Legal
Iomob Technologies OU
Address: Katusepapi tn 6-502, 11412, Tallinn, Estonia