Privacy Policy of the S-Bahn Berlin App

Thank you for your interest in our S-Bahn Berlin app. We take the protection of your personal data very seriously. The personal data you provide when using the S-Bahn Berlin app and our services is treated confidentially and in accordance with both statutory data protection regulations and this privacy policy. The following privacy policy will provide you with detailed information on the types of personal data we process, why we process it, whom we share it with, and what rights of control and information you have. To this end, we recommend that you read this privacy policy carefully.

S-Bahn Berlin GmbH is responsible for the collection and processing of your data. Where this does not apply, in certain cases, you will be alerted to this fact in the relevant section below.

Should you have any questions or suggestions regarding the data processing by S-Bahn Berlin GmbH, please contact:

S-Bahn Berlin GmbH Kundenbetreuung
Elisabeth-Schwarzhaupt-Platz 1
D - 10115 Berlin
Phone: +49 (0)30 297 43333
E-mail: kontakt(at)sbahn.berlin

Dr. Marein Müller is S-Bahn Berlin GmbH’s appointed data protection officer.

In certain cases, different contact options apply to the processing of your data. The relevant, differing contact information is then included in the respective information and notes on the specific processing cases described below.

Should you have any questions, suggestions or criticisms regarding our services, please contact:

S-Bahn Berlin GmbH
Datenschutz
Elisabeth-Schwarzhaupt-Platz 1
D -10115 Berlin

E-mail:
Datenschutz.Regio(at)deutschebahn.com

The S-Bahn-Berlin app combines journey planning and passenger information. Customers can search for connections and access a range of information related to their travel. We collect personal data from our users only to the extent necessary to ensure a functioning S-Bahn Berlin app and to provide our content and services, conditional upon you having given your consent for us to use other data processing methods.

• If the S-Bahn Berlin app is used purely for informational purposes (i. e. no user registration), we process data related to your device to enable use of the app. The legal basis for this data processing is Article 6(1)(b) of the GDPR.
• The first time you install the S-Bahn Berlin app, you can choose to enable additional features to increase the S-Bahn Berlin app’s usability. The legal basis for this data processing is Article 6(1)(b) of the GDPR.
• We process data for troubleshooting purposes to ensure the stability and security of the app and our IT systems. The legal basis in this case is Article 6(1)(f) of the GDPR.
• You can use the S-Bahn Berlin app to search for connections. If you do so, we will process your request data (in particular the starting and destination stop or station, connections, potentially also location data) for the purpose of displaying appropriate route suggestions. The legal basis in this case is Article 6(1)(b) of the GDPR.
• We use external service providers for some of these data processing operations.

When you use the S-Bahn Berlin app, we collect the following personal data. This is a technical requirement to let us provide you with the functions of the S-Bahn Berlin app and to ensure the stability and security of the app:

• IP address
• App language and version
• Operating system
• Date and time of request 
• Depending on request: date as well as intended departure time/arrival time
• Type of device, i. e. smartphone or tablet

This information is processed to enable your use of our app (Article 6(1)(b) of the GDPR) since we require automatically collected data to provide a functioning app (e. g. adapting the app to the requirements of your device). This information is also processed to allow us to pursue our legitimate interest in ensuring the stability and security of both the app and our IT systems (Article 6(1)(f) of the GDPR). The automatically collected data is stored in anonymised form for at least six months. If you use the app for timetable information, only your IP address will be stored for the time during which information is requested/processed. We store the IP address separately from any timetable information for a further 30 days to be able to recognize promptly if an extremely high volume of requests originates from individual IP addresses since this can not only cause disruptions but also violate the terms of use. After this period, the IP address is deleted again.

5.1. Features to improve usability

The S-Bahn Berlin app provides several features (location, address book, calendar) to increase the app’s usability. These features are only used if they are enabled during the initial app installation or later during use of the app. Once enabled, you can configure these features by accessing the settings of the S-Bahn Berlin app or by adjusting the settings of your operating system. We cannot offer you use of these features unless you consent. You can still use all the basic functions of the S-Bahn Berlin app without enabling these usability features.

5.2. Processing of your data for troubleshooting purposes

In case of connection issues between the S-Bahn Berlin app and the background system or when this connection is lost, we will save the data associated with the error (request, error) in your S-Bahn Berlin app account. This data is collected and processed to troubleshoot the error, optimise the app and safeguard system security.

The Google Play Store collects anonymised crash reports (number of crashes only), as does the Apple AppStore, if you have given Apple your consent. We can view the crash reports on a dashboard in the Google Play Store.

If a technical error occurs during use of the S-Bahn Berlin app or during the processing of data from journey planning requests in the technical systems used for this purpose (e. g. in the system used to improve S-Bahn Berlin’s service), we process information related to the error (including information on journey planning requests, if applicable). We do this to correct errors in the technical systems used to run the S-Bahn Berlin app where data from S-Bahn Berlin requests are processed and to safeguard system security.

This information is processed to allow us to pursue our legitimate interest in ensuring the stability and security of both the app and our IT systems (Article 6(1)(f) of the GDPR). The data is deleted when it is no longer needed, unless a longer period of storage is justified or required by law.

5.3. Journey planner

A. Connection search

When you search for a connection, we will collect the following data:

• Starting stop or station 
• Destination stop or station 
• Depending on the request: date and desired departure/arrival time
• Depending on the request: changes, walking sections, modes of transport, route numbers 
• Time of request 
• Device type (iPhone or Android)
• If applicable, location data (GPS data)
• IP address

We process this data to display connections based on your search criteria. We also use the data to determine the ticket required for the route. The legal basis is Article 6(1)(b) of the GDPR.

If you use the app for timetable information, only your IP address is stored and only for the time during which this information is requested and processed. We store this IP address separately from journey planning data for a further 90 days to quickly identify any IP addresses sending extremely high volumes of enquiries, which can not only cause disruptions but also violates the terms and conditions of use. After this period, your IP address is deleted.

B. Statistical analysis

Adobe Analytics technologies are used on our information pages to collect and store data for statistical analysis and optimisation purposes. Such data can be used to create anonymised user profiles that permit recognition of the internet browser during a repeat visit to the website. The data collected via Adobe Analytics technologies will not be used to personally identify visitors to this website without their specifically granted consent, nor will this data be merged with personal information. Users can object to this data collection and storage at any time.

S-Bahn Berlin GmbH uses the Adobe Analytics analysis service on its websites. For this purpose, usage information generated by the cookie (including your shortened IP address) is transmitted to an Adobe Analytics server in the European Union and stored there for use analysis purposes. Your IP address is shortened during this process to anonymise it. The transmitted information is used

• to evaluate the use of our websites,
• to compile reports on website activities and 
• to provide other services related to the website and internet use

to the website operator.

The IP address transmitted by your browser through Adobe Analytics is not merged with any other Adobe Analytics data. You may reject cookies by selecting the appropriate settings in your browser, but please note that in this case you may not have access to the website’s full functionality.

Opt-out:

You can object to the collection of personal data by Adobe Analytics here:
http://www.adobe.com/privacy/opt-out.html

More information on Adobe’s terms of use and privacy policy can be found here:
 
Terms of use: https://www.adobe.com/de/legal/terms.html 
Privacy policy: https://www.adobe.com/de/privacy.html

C. Saving favourites

When planning journeys in the S-Bahn Berlin app, you may save starting stops/stations and connections as favourites. This allows you to personalise the S-Bahn Berlin app to your needs and speed up the journey information process. The legal basis for saving favourites in the S-Bahn Berlin app is Article 6(1)(b) of the GDPR, as we are otherwise unable to offer this service. Favourites are stored until you change or delete your settings. The data is deleted if you delete or uninstall the app.

E. Activating location detection

Instead of manually entering a starting location, you can activate location detection to allow the app to determine your location. We will then suggest stops or stations located near your current location.

For this purpose, you need to allow the app to access location services through your device’s operating system and its permissions system (“location tracking”). In this case, however, we only collect the location determined by your device if you tap the location icon. Your device will indicate if location tracking is active. On an iPhone, for example, it is indicated by a compass symbol in the status bar. Android devices feature a similar function.

The legal basis of this data processing is set out in Article 6(1)(b) of the GDPR, as your location is only determined and transmitted to us if you use app functions that we can only provide if we are aware of your location. You can, however, enable or disable this function by accessing your operating system’s settings.

F. Calendar functions

If you like, the app can save connection information in your calendar. The app then checks the list of calendars installed on your device, but never accesses calendar entries.

To use the calendar function, you need to give the app permission for this.

Legal basis for this data processing case is your consent, Article 6(1)(a) of the GDPR.
You can revoke your consent at any time in the device settings. 

G. Use of the map function

The S-Bahn Berlin app includes the option to display a street map. This can be used to provide and/or access directions to reach a destination on foot or to provide and/or access information on the surroundings.On the Android operating system, the S-Bahn Berlin app embeds Google Maps. In addition to log data, this transmits your IP address to Google Inc.1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can find the relevant privacy policy here https://www.google.com/intl/de_de/policies/privacy/.

You can change your own privacy settings to the extent desired here https://www.google.com/intl/de_de/policies/technologies/productprivacy/.
 
On the iOS operating system, the S-Bahn Berlin app embeds a map service by Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, USA. Apple only receives your IP address after you have given your consent by using the map service. 

You can adjust your privacy settings in “settings“ > privacy. 

These permissions may be shown as follows on your device: Storage, Photos/Media/Data

The applicable legal basis is Article 6(1)(b) of the GDPR.

H. Address book function

To select an address from your contact data as the starting point and/or destination, the app requires access to your address book. By selecting a contact, the linked address is then copied into the start/destination field. During the search for suitable connections, this specified address is then transmitted as the start/destination point of the search query.

These permissions are solely used for the purposes described and only on the mobile device in question.

The applicable legal basis is Article 6(1)(b) of the GDPR.

6.1. Contracted service providers

Personal data may be disclosed to our contracted service providers for processing in accordance with the purposes for which it was originally provided, e. g. to provide offered services, evaluate user behaviour on our website and app or for technical support. Under statutory agreements (Article 28 of the GDPR), we contractually oblige our contracted service providers to use personal data solely for the agreed purposes and not to disclose your personal data to other parties without our consent, unless this is required by law. We make use of the following external service providers to process your data:

• Hacon Ingenieurgesellschaft mbH (Lister Str. 15, 30163 Hannover) – Frontend development of the S-Bahn Berlin app for collecting, processing and displaying the results of timetable/connection requests, provision of the system for improving the S-Bahn Berlin’s services, correcting technical errors in the provided system.
• Adobe Analytics (see 5. 3. A) processes data related to app usage like the version of the app used, device information, location data, user ID as well as information on individual requests within the app (events). This data is used to analyse user behaviour. The legal basis is your consent (Article 6(1)(a) of the GDPR).

6.2. Disclosure of personal data to the authorities

We will only transmit your personal data to public authorities if the information is requested based on statutory requests for information or if S-Bahn Berlin is otherwise legally obliged to transmit the data (Article 6(1) (c) of the GDPR).

General information

Cookies are small text files suitable for storing personal data. We want you to be able to make informed decisions for or against the use of cookies that are non-essential for the technical functioning of the website. 

To this end, we will describe the type and scope of cookies used on our website.

Depending on the cookie preferences set in your browser, we use the following types of cookies on our website:

Functional cookies:
These cookies are essential for the operation of our website and enable, among other things, security-related functions. For this reason, functional cookies cannot be disabled.

Cookies used for analysis & tracking:
These cookies collect anonymised data on user behaviour on our website. They are used for statistical evaluation and analysis. Data collected through these cookies allows us to determine the key interests of our users, which helps us to adjust and optimise website contents and functions accordingly.

Only cookies that are absolutely necessary are activated by default. If you do not want this either, you have the option to reject cookies in general.

You can revoke your consent at any time and deactivate inessential cookies. You can review and adjust your personal cookie settings here at any time: Page menu > imprint > cookie settings.

When you click on a link to third-party website, you are leaving the pages of the S-Bahn Berlin app and sbahn.berlin. This means that S-Bahn Berlin GmbH is neither responsible for the contents, services or products offered by the linked website, nor for the data protection and technical security of the linked website.

Your personal data will be stored as long as it is necessary for the fulfilment of the specific purpose. Subsequently, your data will be deleted, unless there are legal obligations to retain the data beyond this time or unless there is legal justification to do so.

The following time limits for storage and deletion generally apply:

• Data during informational use of the app: data is stored in anonymised form
• Journey planning data: data is stored for peak time analyses and predictions. The IP address is separated from this data.

You can request to know what data we have stored on you. You can demand the correction, deletion and restriction of processing (blocking) of your personal data as long as this is legally permissible and possible within the framework of an existing contractual relationship.

You have the right to lodge a complaint with a supervisory authority against the collection and processing of your data by S-Bahn Berlin GmbH. The supervisory authority responsible for S-Bahn Berlin GmbH is:

• Berliner Beauftragte für Datenschutz  
  und Informationsfreiheit  
  Friedrichstr. 219  
  D - 10969 Berlin
• E-Mail: mailbox(at)datenschutz-berlin.de

You have the right to the portability of data that you have provided to us based on consent or a contract (data portability). If you have given us consent to process your data, you can revoke this at any time by the same means by which you originally gave it. The revocation of consent does not affect the lawfulness of the processing carried out based on the consent until the revocation.

You can object to data processing for reasons arising from your particular situation if the data processing is based on our legitimate interests.
You can object to receiving advertising at any time with effect for the future (advertising objection).

To exercise your rights, simply send a letter by post to:

• S-Bahn Berlin GmbH,  
  Kundenbetreuung 
  Elisabeth-Schwarzhaupt-Platz 1,  
  D - 10115 Berlin 
• Phone: +49 (0)30 297 43333 
  or via e-mail to: kontakt(at)sbahn.berlin 

We adapt our data protection policy to reflect changes in website function or changes in the legal framework. We therefore recommend reviewing this privacy policy at regular intervals. Where your consent is required or where segments of this privacy policy touch on provisions of the contractual relationship with you, such changes will only be made with your consent.

Last updated: January 2023