DRAFT — requires legal review before publishing.
This template is a starting point and contains placeholders
([COMPANY], [ADDRESS], [EMAIL], etc.)
that must be replaced with real values. The authoritative version is the
German Datenschutzerklärung. Have both
reviewed by a German data-protection lawyer or DPO before publishing.
Privacy Policy
Applies to the Blitzride customer app
(package de.blitzride.customer) and Blitzride
Driver driver app (package de.blitzride.driver). Last
updated: [INSERT DATE].
1. Data Controller
The data controller responsible for processing personal data under the
EU General Data Protection Regulation (GDPR) is:
[If appointed:] You can reach our Data Protection Officer at
[DPO_EMAIL]. [If no DPO is required by law:
remove this section.]
3. Overview — What We Process
3.1 When you create an account (both apps)
Name
Email address
Phone number (for SMS OTP verification)
Profile picture (optional)
Language preference
3.2 When using the customer app (Blitzride)
Location data (precise and coarse, only while the app is in use, to
find nearby drivers and set pickup points)
Booking history (pickup and drop-off, timestamp, fare, rating)
Push notification token
Device data for diagnostics (app version, OS version, device model)
3.3 When using the driver app (Blitzride Driver)
Location data including in the background, only while
a ride is active or while the driver is online, for transmission to
dispatch and display to the customer
Ride history and earnings
Microphone recordings (push-to-talk communication with dispatch;
recordings are not persistently stored)
Camera and photo library access (for ride documentation and profile
picture)
Push notification token
4. Purposes and Legal Bases
Purpose
Data
Legal basis
Account creation and management
Name, email, phone
Art. 6 (1) (b) GDPR (contract performance)
Ride matching and execution
Location, booking data
Art. 6 (1) (b) GDPR
Ride-related push notifications
Push token
Art. 6 (1) (b) GDPR
Background location (driver app, only during active shift)
Location
Art. 6 (1) (b) GDPR
Error diagnostics and app improvement
Device data, crash logs
Art. 6 (1) (f) GDPR (legitimate interest)
Compliance with tax and legal obligations
Booking / billing data
Art. 6 (1) (c) GDPR
5. Sharing with Third Parties
We share personal data only with the following recipients:
Licensed local fleet operators in your region,
to the extent necessary to fulfil a ride (data processing
agreement under Art. 28 GDPR in place).
[BACKEND PROVIDER, e.g. Supabase / AWS / Google Cloud]
— hosting and database operation. DPA in place.
Google Maps Platform — maps and geocoding (Google
Ireland Limited).
Tax advisors and authorities, where legally required.
No further sharing takes place. We do not sell data.
6. International Transfers
Where data is transferred to processors outside the EU/EEA (e.g. Google),
the transfer takes place on the basis of EU Standard Contractual Clauses
(Art. 46 (2) (c) GDPR) and the European Commission's adequacy decisions
where applicable.
7. Retention
Account data: until the account is deleted by the user; afterwards in
accordance with statutory retention periods (e.g. § 147 AO, 10 years
for billing-relevant records).
Trip location data: 90 days after trip completion; afterwards only in
aggregated, non-personal form.
Error logs: 30 days.
Push tokens: until the app is uninstalled or notifications are
revoked.
8. Your Rights
You have the right at any time to:
Access your processed data (Art. 15 GDPR)
Correct inaccurate data (Art. 16 GDPR)
Erasure ("right to be forgotten") (Art. 17 GDPR)
Restrict processing (Art. 18 GDPR)
Data portability (Art. 20 GDPR)
Object to processing (Art. 21 GDPR)
Withdraw a given consent with effect for the future
You also have the right to lodge a complaint with a supervisory
authority. The competent authority for us is:
The Hessian Commissioner for Data Protection and Freedom of Information
Postfach 31 63, 65021 Wiesbaden, Germany
Phone: +49 611 1408-0
Email: poststelle@datenschutz.hessen.de
Web: datenschutz.hessen.de
9. Account Deletion
You can delete your account at any time within the app under Profile →
Delete account, or request deletion in writing at
[EMAIL]. We confirm deletion within 30 days,
subject to statutory retention obligations.
10. App Permissions in Detail
The apps request the following permissions. You can revoke any permission
at any time in Android Settings; individual features will then be
unavailable.
Permission
App
Purpose
Location (precise / coarse)
Both
Find nearby drivers / broadcast position
Background location
Driver
Live location during active ride
Foreground service
Driver
Location streaming when app is minimized
Microphone
Driver
Push-to-talk with dispatch
Camera
Both
Profile picture and ride documentation
Photo library
Both
Upload profile picture
Notifications
Both
Ride requests, status updates
Vibration / wake lock
Both
Notification signal, keep screen on during navigation
11. Changes to This Policy
We may update this policy if processing changes or legal requirements
demand it. We will notify you in-app of material changes.
This policy applies exclusively to
the Blitzride and Blitzride Driver apps. The Dispatcher web application is
covered by a separate, internally distributed privacy notice.