PRIVACY POLICY GREENFLOW APP

Dear visitor,

Thank you for using our GreenFlow App. In this Policy, we would like to inform you about how we handle your data.

This app is designed for trucks to be able to ask for priority and show the state of the traffic lights to enable improve traffic flow, predict the traffic light, demonstrate advisory speed, warn about roadworks, highlight emergency vehicles, and allow drivers to dive more economically. If you register the GreenFlow app at SWARCO, you can pay a monthly fee and get request priority at intersections. To do this, the app and SWARCO must process some of your personal and connect with the traffic grid.

Controller

The Controller for the data processing operations described below is [SWARCO Peek Traffic BV] (hereinafter referred to as SWARCO) part of the SWARCO Group[1].

Purpose and legal basis for processing:

By using our App, we may process, collect and store your personal data for the following purposes: 

• Account Registration (performance of contract);
• Vehicle registration via the identity code (performance of contract);  
• Location and GPS data via Station ID (performance of contract).

Processing and relevant personal data:

Your data will be processed in the following ways: 

• Account Registration: By registering on the GreenFlow website, you will be asked to provide personal data to build a profile within our systems, or link your registration to an existing partner. We may ask for the following information: [First name, Last name, Email address....]. This data will be stored for the length of your registration with SWARCO and for up to 1 year after your registration ends. 
• App installation: Once you install the app, a specific App ID is generated to allow you to request access to the SWARCO cloud platform register your priority requests. To fulfill this task, the following data will be processed: First Name, Last Name, License Plate. This ID is deleted once you delete the app. 
• Station ID: Through the use of our app, you are required to provide us with certain information that we compile as specific messages for a particular vehicle and send this data to the intersection, to keep track of your location and provide you with up to date information. The app is generating a random unique Station Id for your vehicle, this id  is not generated using personal information or any information on your phone. Therefor this id is pseudonymized. It will also regularly change to ensure that you may never be followed on a route. Information that we use is:  location of the vehicle, type of vehicle, length of the vehicle, speed, heading, timestamp and specific information filled in the app like use of dangerous goods.
• In case of a priority request also the identity code and the forecasted direction on how to pass the specific intersection is used and transferred. 

Data transfers:

SWARCO will have to transfer your personal data to third parties to be able to fulfill their services. The following data sets are transferred to third parties: 

1.     Station ID: The Station ID is processed and shared with the [local ministry of transport and relevant intersections]. This data is processed under Art. 6. (a) consent and Art 6. (f) legitimate interest. You provide your consent specifically on your device to share the GPS data with us, and the other data is required to properly provide the app’s functions and services. If you refuse to provide the information necessary or withdraw your consent, the app will not function properly and we cannot provide you with the service. You can object to this processing by canceling your SWARCO GreenFlow subscription or canceling your contract with us, or withdrawing your consent directly. 
2.    APP ID and Registration: The App ID and registration information is kept within SWARCO.

Storage, Retention and Security:

Unless otherwise specified, we will delete your personal data if they are no longer required for the relevant processing purposes and no legal retention obligations oppose deletion. 

All of our data is kept in the Microsoft Azure cloud services located in Western Europe. SWARCO ensures a TLS 1.2 encryption between the App and all cloud services communications and in transport to protect your information.

As a data subject, you may have the right to: 

• access your data as well as receive a copy of your data;
• rectification and erasure;
• restriction of processing;
• data portability;
• object, if the data is processed pursuant to the legitimate interests of SWARCO;
• lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes applicable data protection regulations.

If you have any questions or concerns, please contact SWARCO Peek Traffic BV.