Last updated: June 16, 2026
1. Data Controller
Smart Travelling Web UG (haftungsbeschränkt)
Nicola Bramigk
Lückhoffstr. 24
14129 Berlin
Germany
Email: info@smart-travelling.net
Data Protection Officer
No Data Protection Officer has been appointed, as there is currently no legal obligation to do so.
2. Data We Collect
We may collect the following personal data:
• Name
• Email address
• Date of birth
• Postal address
• Location data
• Payment information
• Device identifiers and technical information
• App usage information
• User preferences and settings
3. Purposes and Legal Bases
3.1 Performance of a Contract
• Providing and managing your account
• Delivering app content and services
• Processing purchases and payments
• Customer support
3.2 Consent
• Location-based services
• App analytics
• Marketing and conversion measurement
• Push notifications
• Marketing communications
3.3 Legitimate Interests
• Security and fraud prevention
• Technical troubleshooting
• Stability and functionality of our services
3.4 Legal Obligations
• Compliance with tax, accounting and other legal obligations
4. Sharing Data with Third Parties
4.1 Payment Processing
Payments are processed by platform providers and payment service providers. We do not store
complete credit card details.
4.2 Google Maps
The app uses Google Maps. Location and device data may be transmitted to Google.
https://policies.google.com/privacy
4.3 Meta SDK
We use the Meta SDK provided by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2,
Ireland, to measure app installs, registrations and purchases resulting from Meta advertising
campaigns.
The Meta SDK is activated only after you have provided your consent.
Data processed may include device information, advertising identifiers and app event information.
Data may be transferred to Meta in Ireland and, where applicable, to servers in the United States.
Meta is certified under the EU-US Data Privacy Framework.
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR.
4.4 Google Analytics for Firebase
We use Firebase Analytics and Google Analytics for Firebase provided by Google Ireland Limited.
These services help us understand how users interact with the app and improve our services.
Processing is based exclusively on your consent pursuant to Art. 6(1)(a) GDPR.
4.5 Firebase Cloud Messaging
We use Firebase Cloud Messaging (FCM) to deliver push notifications.
A pseudonymized device identifier is processed for this purpose.
Processing is based on your consent to receive push notifications.
5. International Data Transfers
Where data is transferred outside the European Union or European Economic Area, we rely on
appropriate safeguards, including Standard Contractual Clauses and the EU-US Data Privacy
Framework.
6. Data Retention
• Account data is stored for the duration of your use of the app.
• Personal data is generally deleted within 90 days after account deletion unless legal retention
obligations apply.
• Payment data is retained according to applicable legal requirements.
• Location data is not permanently stored.
7. Consent Management
When first launching the app, users may choose whether to consent to analytics and marketing
services.
Google Analytics for Firebase and Meta SDK are activated only after consent has been granted.
Consent may be withdrawn at any time within the app settings.
8. App Tracking Transparency (iOS)
On Apple devices, tracking and marketing-related processing takes place only after permission has
been granted through Apple’s App Tracking Transparency (ATT) framework where required.
9. Your Rights
You have the rights of access, rectification, erasure, restriction of processing, data portability,
withdrawal of consent and the right to lodge a complaint with a supervisory authority.
Contact:
info@smart-travelling.net
10. Data Security
We implement appropriate technical and organizational measures, including encrypted data
transmission (TLS/HTTPS), access controls, role-based permissions and regular security reviews.
11. Children and Minimum Age
The Smart Travelling App is intended for users aged 16 and above.
We do not knowingly collect personal data from children under the age of 16.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services or legal
requirements.
Material changes will be communicated through the app or by email.