Privacy Policy for the eTrucker App and Website We appreciate your interest in the eTrucker app and the accompanying website. The protection of your personal data is our top priority, Games4Future GmbH. In this privacy policy, we inform you about which personal data we collect, how we use it, and what rights you have regarding your data. This policy is directed at the users of the app and website (hereinafter "you").
1. Responsible body The responsible party within the meaning of the General Data Protection Regulation (GDPR) is:
Games4Future GmbH
Landsberger Str. 318a, 80687 Munich, Germany
Phone: 0049 174 6416988
Email: info@elektrotrucker.de
(Further information about the company can be found in the imprint.)
2. No data protection officer Due to our company size (fewer than 10 employees), we are not legally obligated to appoint a data protection officer. If you have any questions about data protection or wish to exercise your rights, you can contact us directly at any time – please use the contact details provided above.
3. Data collected, processing purposes and legal bases We process your personal data only to the extent necessary to provide the app and website, as well as our services. Below, we explain which data we process and for what purpose. In each case, we also state the legal basis according to Art. 6 (1) GDPR:
- Registration and account data: When you create a user account, we collect your email address and a password of your choice. Optionally, you can enter additional information such as your name or the name of your company (freight forwarding company). We use this data to set up and manage your account, identify you as an authorized user, and communicate with you (e.g., to send confirmation emails, service information, or password reset emails). Legal basis: Contractual fulfillment in accordance with Art. 6 (1) (b) GDPR (use of the app/website requires this data).
- Location data (GPS data): When you use the app, with your consent, we record your current location using your device's location functions. These precise GPS positions are required to provide you with location-based services - in particular for navigation, route guidance and displaying charging stations in your area. The location data is processed in real time, for example to display your current location on the map or to find the nearest charging stations. We do not permanently store your GPS history data, i.e. we do not continuously track you outside of navigation. You can deactivate location sharing at any time in the device settings; however, please note that essential functions of the app (such as the charging station search or navigation) are not available without location data. Legal basis: Your consent in accordance with Art. 6 (1) (a) GDPR (granted, for example, by granting location permission in the app) and - if location usage is necessary for the requested navigation service - additionally Art. 6 (1) (b) GDPR.
- Navigation and route data: When you use the route planning function in the app, we process the destination addresses or stopovers you enter. This information is used to calculate the optimal route for your electric vehicle and navigate you to your destination. We take charging-related requirements into account (e.g., we show charging stations along the route). The route data is used only to provide the navigation function and is not stored for any other purpose unless you consciously save a route yourself. Legal basis: Contractual fulfillment according to Art. 6 (1) (b) GDPR, as navigation is a core function of the app that you expressly use.
- Charging history and favorites: The app can save visited charging stations and favorites you've marked (e.g., preferred charging station operators or specific stations) to your user profile. This allows you to view a personal charging history and quickly find preferred stations or operators. For example, we can note which operators you've marked as favorites in order to provide you with appropriate filters or recommendations. Legal basis: Contractual fulfillment pursuant to Art. 6 (1) (b) GDPR, as these personalized functions are part of the service offered and are based on your input or usage.
- Usage data and app performance: We also collect technical usage data when you use the app and website. This includes, for example, log data (time and duration of use, functions or pages clicked, app settings), error reports in the event of crashes, and general statistical information about the frequency of use of certain features. We generally evaluate this data anonymously or in aggregate form in order to monitor and continuously improve the stability, security, and quality of our offering. Personal evaluations are not carried out – we do not create user profiles from your behavior. Legal basis: Legitimate interest pursuant to Art. 6 (1) (f) GDPR. Our legitimate interest lies in improving our product, troubleshooting, and ensuring IT security. (Example: We can see which app functions are generally used frequently in order to further develop them, without knowing which individual user did what.)
- Communication and support: We use your contact details to communicate with you. This includes service messages related to the app (e.g. information about updates, changes to the terms of use or technical information) as well as to respond to customer inquiries. If you contact us (e.g. by email to our support), we process the information you provide (such as your email address, name and content of your inquiry) to process and respond to your inquiry. We may also proactively inform you by email about important processes, e.g. security-relevant information or significant changes to the service. Legal basis: Depending on the reason for communication, Art. 6 (1) (b) GDPR (fulfillment of our contract or response to your inquiry as a pre-contractual measure) or Art. 6 (1) (f) GDPR (legitimate interest in maintaining our customer service and informing you about news relevant to the service).
- Newsletter and marketing: We only use your email address for newsletters or promotional emails with your express consent. If you sign up for a newsletter, for example, you will receive information about new features, offers, or company news at your email address. You can revoke your consent to receive newsletters at any time with future effect (see the section Revoking Consent below); you will find an unsubscribe link, for example, in every newsletter email. We will not send any advertising without your consent—service information in the narrow sense (see above) does not count as advertising. Legal basis: Art. 6 (1) (a) GDPR (consent).
- Website access data and cookies: When you use our website for informational purposes (i.e., when you only gather information without creating an account or otherwise entering data), we collect technically necessary access data. Our web server temporarily logs, for example, your IP address, the date and time of the page visit, the requested file/URL, the HTTP status code, and, if applicable, the browser type and operating system used. We use these server log files exclusively to enable the delivery of the website, ensure system security, and analyze any technical problems. This log data is not merged with other data sources; the log files are automatically deleted or anonymized after a short time. Legal basis: Legitimate interest pursuant to Art. 6 (1) (f) GDPR (proper operation and security of the website).
- Our website also uses cookies and similar technologies. Cookies are small text files that are stored on your device. We mainly use technically necessary cookies, e.g. to save your language settings or login session. These essential cookies are used on the basis of Section 25 (2) TTDSG (German Telecommunications Act) and Article 6 (1) (f) GDPR, as we have a legitimate interest in the functional provision of our services. If we also use optional cookies (e.g. for web analysis or tracking), we will obtain your prior consent via a cookie banner (Article 6 (1) (a) GDPR). You can adjust the cookie settings at any time via our website. Details on specific cookies (if used) can be found in our cookie information provided if applicable.
No disclosure for third-party purposes: In all of the above-mentioned cases, we process your data only for the stated purposes. Your data will not be used for any other purpose (especially for third-party advertising purposes) or sold.
4. Sharing of data and use of third parties We treat your personal data confidentially and never share it with unauthorized third parties without legal grounds. Data will only be shared if you have consented, the data is required to fulfill our contract with you, a legal obligation exists, or we can demonstrate a legitimate interest (and no overriding legitimate interest on your part conflicts). Within the scope of our services, data may be shared or external service providers may be involved in the following cases:
- Contracted service providers (contract processors): We may use external service providers to operate our app and website, e.g., in the areas of hosting (provision of server infrastructure), email delivery, maintenance/support, or analytics. These service providers process personal data exclusively on our behalf and in accordance with our instructions. We conclude contracts with all contract processors in accordance with Art. 28 GDPR to ensure that your data is treated with the same confidentiality and security as we do ourselves.
- Google Maps: Our app and website integrate Google Maps services, provided by Google LLC. Google Maps enables, for example, the display of interactive maps, the geocoding of addresses and the verification of locations. If you use the map or location search functions, your request (e.g. coordinates, address data and possibly your current location and device IP address) will be transmitted to Google's servers in order to retrieve the corresponding map data or route information. This is necessary in order to show you maps and directions. Note: Google also processes this data for its own purposes in accordance with the Google Privacy Policy. We have no influence on data processing at Google. Further information can be found in Google's Privacy Policy (available at https://policies.google.com/privacy ). Legal basis: Art. 6 (1) (b) GDPR (use of the map function as part of the service you have requested) and Art. 6 (1) (f) GDPR (our legitimate interest in providing a convenient map and address search). If necessary, we will obtain your consent before Google Maps is activated (Art. 6 (1) (a) GDPR), in particular on the website via a cookie banner.
- TomTom: The eTrucker app uses navigation and traffic data services from TomTom (TomTom NV, Netherlands) for route planning and navigation. This means that when calculating a route, certain data (start and destination points, current position, and vehicle parameters for electric trucks, if applicable) are transferred to TomTom to obtain an optimized route and traffic information. TomTom processes this data to provide the map service and is subject to European data protection regulations. Please note that TomTom's terms of use may also apply to the use of TomTom map data in the app. Legal basis: Art. 6 (1) (b) GDPR (route guidance is provided to fulfill the contract). TomTom handles the data in accordance with its own privacy policy (see TomTom's website for details).
- Eco-Movement: Information on electric charging stations (locations, technical details, availability) is provided to us by Eco-Movement. Eco-Movement BV (Netherlands) operates an extensive EV charging station database. When the app retrieves, for example, current availability or detailed data on a charging station, the Eco-Movement API is contacted in the background. It may be necessary to transmit your current location (for nearby searches) or specific station IDs to Eco-Movement in order to obtain the corresponding data. However, Eco-Movement does not receive any personal profile data from you, only the information necessary for the query (comparable to a database query). Legal basis: Art. 6 (1) (b) GDPR (display of charging station data as a requested core function). Eco-Movement acts as a data provider here; the forwarding of your request is necessary for the function. Eco-Movement does not store or use this request data for its own purposes other than to respond. (Further information on Eco-Movement's data protection can be found on the provider's website.)
- Payment service providers: If you purchase premium services within the app or website (e.g., additional features that will be subject to a charge in the future), your payment information will be processed to process the payment. Depending on the payment method selected, this may include credit card details, bank details, or a payment service account (e.g., PayPal). Payments are processed via external payment service providers. This means that during the payment process, we may forward you to an appropriate provider (e.g., the Apple/Google App Store or a payment provider such as PayPal, Stripe, etc.), who will accept and process your payment data. We do not generally store your complete payment data ourselves (except for possible partial information such as the transaction ID, selected payment method, or the last four digits of the credit card, if required for receipt purposes). The external payment service providers process your data under their own responsibility; their privacy policies apply. We only receive confirmation of successful payment and, if applicable, invoice information from the payment service providers. Legal basis: Art. 6 (1) (b) GDPR (contract execution, billing of premium services) and Art. 6 (1) (f) GDPR (legitimate interest in secure and efficient payment processing).
- Disclosure for legal reasons: In certain cases, we are legally obliged to disclose data to third parties, or disclosure is necessary to protect our rights or the rights of third parties. Examples: Upon official or court order, we must provide information about data in individual cases (e.g. to law enforcement authorities as part of investigations). We may also process and transmit data if this is necessary to clarify or prevent misuse of our service or fraudulent activities, or to enforce our legal claims (e.g. in the event of legal disputes). In such cases, data processing or disclosure is based on Art. 6 (1) (c) GDPR (legitimate obligation) or Art. 6 (1) (f) GDPR (legitimate interest in enforcing our rights or the rights of third parties).
Data transfer to third countries: Some of the external service providers mentioned are based outside the European Union or the EEA (e.g. Google LLC in the USA). We ensure that appropriate protective measures are always taken when transferring personal data to third countries in accordance with Art. 44 et seq. GDPR. This is done, for example, by concluding EU standard data protection clauses or through the existence of an adequacy decision by the EU Commission. Nevertheless, we would like to point out that additional risks may exist when data is transferred to the USA – for example, US authorities may access data without you being entitled to European legal remedies. If we transfer data to third countries, this only takes place in compliance with all data protection regulations.
5. Storage period and deletion We store your personal data only for as long as necessary for the respective purposes. The data will then be deleted or restricted (blocked) in accordance with legal requirements. The specific deletion periods depend on the different data categories and processing purposes:
- Account and profile data: We store your registration data (email, profile information) for the duration of your user account. If you delete your account or terminate the business relationship, we will delete this data from our active systems. Exception: If certain data must be retained for commercial or tax law reasons (e.g., invoice data for purchases made), we will store this data until the expiration of the statutory retention periods (usually 6 to 10 years in Germany) and block it until final deletion.
- Navigation and location data: Real-time data such as GPS positions and routes are not permanently stored on a personal basis (see above). Temporarily cached location or route data is generally deleted immediately or at the end of the respective session. Data on visited charging stations or favorites stored in your profile remains stored as long as your account is active (or until you manually delete these entries), as they are part of your usage history and settings. Of course, you can have such personal user data deleted upon request – for example, by deleting individual favorites in the app or completely deleting your account.
- Communication data: We retain information from your communication with us (e.g., support requests) for as long as necessary to process the request and any follow-up questions. Support emails may be temporarily stored for record-keeping purposes. Once there are no longer any reasons for retention, we routinely delete this correspondence as well.
- Log and technical data: For security reasons, website server log files with IP addresses are stored only briefly and typically anonymized or deleted after a few days (unless a security-related incident requires further retention). We may retain aggregated, anonymized usage statistics for longer, as they no longer contain any personal data.
If you exercise your right to erasure (see Your Rights below), we will immediately review the requirements and delete your data, unless an exception applies. In cases where we must retain data for a longer period due to a legal obligation or legitimate interests, we will restrict processing (i.e., the data will be blocked and used only for the prescribed purpose).
6. Your rights as a data subject As a user of our services and a data subject within the meaning of the GDPR, you are entitled to the following rights. You can exercise these rights informally at any time using the contact details provided above. Your rights include, in particular:
- Right to information (Article 15 GDPR): You have the right to request confirmation from us as to whether we process your personal data. If so, you can receive information about this data. This includes information about the purposes of processing, the categories of personal data, the recipients or categories of recipients, and – where possible – the planned storage period or the criteria for determining this. Upon request, we will provide you with a copy of the personal data being processed.
- Right to rectification (Article 16 GDPR): You have the right to immediately request the rectification of inaccurate or incomplete personal data concerning you. For example, if your email address changes or we have stored something incorrectly, we will correct it immediately.
- Right to erasure (Article 17 GDPR): You can request that we delete your personal data, provided the legal requirements for doing so are met. This is particularly the case if the purpose for storing the data no longer applies, you have revoked your consent (and there is no other legal basis), or the data was processed unlawfully. Please note that there may be legal exceptions – for example, if we are obliged to store the data (e.g., due to statutory retention periods) or if we need the data to assert, exercise, or defend legal claims. In such cases, processing will be restricted instead of deleted.
- Right to restriction of processing (Article 18 GDPR): You have the right to request restriction of processing of your data in certain cases. This means that we may continue to store your data, but may only use it to a limited extent (e.g., not for other purposes). This may occur, for example, if you dispute the accuracy of your data—you can request restriction for the duration of the review. You can also request restriction instead of deletion (e.g., if you need data for legal claims).
- Right to data portability (Art. 20 GDPR): You have the right to receive the data you have provided to us in a common, machine-readable format (e.g., CSV/Excel). Upon request—and where technically feasible—we can also transfer this data directly to a third party designated by you. This right exists if the processing is based on your consent (Art. 6 (1) (a) GDPR) or on a contract (Art. 6 (1) (b) GDPR) and is carried out using automated procedures. In practice, this primarily affects your basic profile data and, if applicable, other data that you have actively provided in the app.
- Right to object (Art. 21 GDPR): If we process data based on legitimate interests (Art. 6 (1) (f) GDPR), you have the right to object to such processing at any time for reasons arising from your particular situation. If you exercise your right of objection, we will cease the processing in question unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or we need the data to assert, exercise, or defend legal claims. You can object to the processing of your data for direct marketing purposes at any time without giving reasons – in this case, we will no longer use the data in question for advertising purposes. (Note: As described above, we only send direct marketing with your consent; however, a theoretical objection is still possible at any time.)
- Right to lodge a complaint with a supervisory authority (Article 77 GDPR): If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a data protection supervisory authority. You can do so with the authority responsible for us or with the authority in the EU member state in which you are resident. In Bavaria, for example, the Bavarian State Office for Data Protection Supervision (BayLDA) in Ansbach is the responsible supervisory authority for private companies. Your right to lodge a complaint is without prejudice to other administrative or judicial remedies.
To exercise your rights, you can contact us informally by email at info@elektrotrucker.de . Please state which GDPR right you are requesting and provide as much information as possible so that we can process your request efficiently. We will review your request promptly and respond within the statutory period of one month at the latest.
7. Revocation of consent Many data processing operations only take place with your express consent (Art. 6 (1) (a) GDPR) – for example, sending a newsletter or using GPS tracking in the app. You can revoke your consent at any time. Such revocation will apply from the time of your notification for the future. This means that the legality of the data processing carried out up to the time of revocation remains unaffected.
To revoke your consent, simply send us an informal message (e.g., by email to info@elektrotrucker.de ). You can also use the functions provided, where available, such as clicking the "unsubscribe" link in a newsletter to revoke your consent to receive the newsletter, or deactivating location sharing in the app/device settings to opt out of further tracking of your GPS location. Once you revoke your consent, we will no longer use the corresponding data for these purposes and, unless another legal basis applies, will delete it from our systems.
8. Data security We implement comprehensive technical and organizational security measures to protect your personal data from unauthorized access, loss, alteration, or disclosure. These include, for example, internal policies, access restrictions, state-of-the-art firewall and antivirus systems, and encryption technologies. Sensitive information (such as payment data) is transmitted via secure connections (HTTPS/SSL). We regularly adapt our security measures to the latest state of the art to provide the best possible protection for your data.
Please note, however, that data transmission over the Internet is never completely secure. For example, communication via email may be subject to security vulnerabilities. We therefore encourage you to handle your data with care (e.g., not sharing passwords). Despite all precautions, we cannot guarantee 100% security, but we assure you that we will protect your data with the utmost care.
9. Changes to this Privacy Policy This Privacy Policy will be updated as needed to reflect legal changes or changes to the functionality of the app/website. We will notify you of any significant changes (affecting your consent or your rights) in an appropriate manner (e.g., by email to registered users or as a notice in the app). The most current version of the Privacy Policy will be available in the app and on our website.
Status of this privacy policy: April 27, 2025.
10. Online dispute resolution (OS platform) The European Commission provides a platform for online dispute resolution (ODR), which you can find at the following link: https://ec.europa.eu/consumers/odr . Consumers have the opportunity to use this platform to resolve disputes with us.
However, we would like to point out that we are neither obligated nor willing to participate in dispute resolution proceedings before a consumer arbitration board. Should any disagreements or problems arise, we would appreciate it if you would contact us directly first – we always strive to find an amicable solution to your concerns.