Privacy policy

1. Controller

The controller responsible for data processing is:

[NAME]
[ANSCHRIFT]
Email: [E-MAIL]

For all questions about data protection and the exercise of your rights, you can reach us at this email address.

2. Scope

This policy applies to

• the TD Portal (portal.track-of-the-day.com),
• the TD Cloud services (map tile, routing, licence and AI service, app interfaces),
• the programs Track of the Day and GS-Route (Windows and Mac) and the app Track of the Day Mobile (Android, iOS), insofar as they exchange data with the Portal or the TD Cloud.

Our website www.track-of-the-day.de is governed by its own privacy policy.

3. Hosting, server logs and security

The Portal and the cloud services run on Microsoft Azure (Microsoft Ireland Operations Ltd., Ireland): App Service, Azure SQL, Azure Storage and Azure Key Vault. Region: [AZURE-REGION].

With every request, the servers process technically necessary data: IP address, time, requested address, identifier of the browser or app (user agent) and language setting.

• We keep logs for error analysis and abuse prevention. Individual entries (e.g. for failed sign-ins, exceeded request limits or licence conflicts) contain the IP address.
• Logs and error messages of the Portal are sent to Azure Application Insights (Microsoft). Pairing codes are masked in the process.
• To limit requests per sender, we hold IP addresses briefly in memory; they are not stored permanently for this purpose.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure and stable operation). Retention period of the logs: [FRIST PROTOKOLLE/APPLICATION INSIGHTS].

4. User account

For an account, we process your email address, name, password (stored only as a hash value) and the time of registration. Optionally, you may provide a display name, profile text, profile picture, place of residence, languages, time zone, vehicles and interests.

• Settings: discoverability in the community (default: discoverable) and email notifications (default: on; unsubscribe via the link in every email). You can change both in your profile.
• While you are signed in, we store an activity entry with time and IP address at most once per hour (usage statistics, detection of abuse).

Legal basis: Art. 6(1)(b) GDPR (terms of use contract); for activity entries point (f). The data remain stored until you delete the account (section 15).

5. Licences, devices and pairing

One licence applies to all our programs. For this purpose we process:

• Licence: licence code (only as a hash value), email address, order number and line item number of the order, language, term and licence tier.
• Devices: device ID (a random identifier of the app installation, not a hardware serial number), device name, platform, app used, first and last connection. You can view and remove paired devices under “My devices”.
• Pairing: The QR code or pairing code is generated by the Portal; it is valid for a few minutes. In this context we store the IP address of the request and failed attempts. We delete used and expired codes after 7 days.
• Trial licence: To prevent repeated trial licences, we store the email address as a hash value and the device ID – even beyond deletion of the account.
• Usage events of the apps: device model, installation identifier, app version, IP address and time; for Track of the Day Mobile additionally kilometres driven and duration. During licence registration, Track of the Day and GS-Route for Windows also transmit the Windows user name, computer name, MAC address and IP address. Retention period: [FRIST NUTZUNGSEREIGNISSE].
• Cloud services: The apps receive a session of no more than 60 minutes (licence number, device ID, product, version). For quotas, we count requests per day, licence and service and store a truncated IP range (IPv4 /24, IPv6 /48). Retention period: [FRIST KONTINGENTZÄHLER – vorgesehen 400 Tage].

Legal basis: Art. 6(1)(b) GDPR (licence agreement); protection against abuse and costs point (f).

6. Tracks, routes, POIs and community

You can upload, plan and manage tracks, routes and waypoints (POIs). This includes coordinates, names, descriptions, comments, hashtags, country, ride statistics and attached files. Tracks show where you were and when – please share them consciously.

• Visibility: private, friends only or public. [Frage an Ansgar: Voreinstellung der Sichtbarkeit belegen – Portal-Upload ist derzeit öffentlich (GpxItem.EffectiveVisibility)] Public content is visible to others, e.g. in the community gallery, together with your display name.
• Sharing and collaboration: Persons invited via a share link or as collaborators can see the route; we store when a collaborator last opened it.
• Friends and following: friend requests, friendships, blocks and followed profiles.

Storage location: Azure SQL and Azure Files. Legal basis: Art. 6(1)(b) GDPR. The data remain stored until you delete them or your account.

7. Maps, routing, search and translation

Directly from the browser or app, map tiles and map libraries are loaded. The respective provider receives your IP address, the user agent and the displayed map section:

• OpenStreetMap Foundation (United Kingdom), OpenTopoMap, Bundesamt für Kartographie und Geodäsie (Federal Agency for Cartography and Geodesy, Germany), CARTO, Esri (USA),
• HERE Global B.V. (Netherlands) for map, traffic, routing and search in the planner,
• Google (tiles and Street View in the planner),
• in the apps additionally Azure Maps (Microsoft) and HERE with short-lived access tokens that we issue for this purpose.

Via our servers (your IP address is not passed on, but the content of the request, user agent and language are) we forward requests to: HERE (routing, address search), Google (Maps, Roads), Microsoft Azure Maps, GraphHopper GmbH (Germany, routing) and DeepL SE (Germany, translation of texts you have translated). Coordinates, start and destination, search terms or the text to be translated are transmitted.

Map tiles contain no personal reference. For route preview images, the Portal caches them for up to 30 days; our tile service caches retrieved tiles without a fixed time limit. Legal basis: Art. 6(1)(b) GDPR (provision of the functions), for loading the base maps point (f).

8. AI functions

• Help assistant (Portal help): Your question, up to ten preceding messages of the conversation and the language are sent to Anthropic PBC (USA, model “Claude”). We transmit neither your IP address nor account data. Please do not enter any personal data in your questions.
• Translation of public route descriptions in the gallery: The description is transmitted to Anthropic for translation.
• Aiden (AI route suggestions): Your input text is sent via the TD Cloud to OpenAI (USA). We do not store the text, only the licence number (none for Free use in the apps; in the Portal, Aiden requires a valid licence in your account), language, time, duration and success. For the free daily quota in the apps, we count requests per device and IP address in memory.

Legal basis: Art. 6(1)(b) GDPR (requested function), protection against costs point (f). AI results may be inaccurate.

9. Emails

We send system emails (e.g. trial licence, “Device paired”, password reset, account deletion, notifications from the community) via Brevo (Sendinblue SAS, France). In doing so, the email address, where applicable the name, and the content of the email are processed. Legal basis: Art. 6(1)(b) GDPR; community notifications point (f), which you can unsubscribe from in every email and in your profile.

10. Assignment of purchased licences

We assign licences obtained via our web shop (www.track-of-the-day.de) to your account. For this purpose, the Portal receives the order number, item and email address from the shop. Payment data do not reach the Portal; the shop is governed by its own privacy policy. Legal basis: Art. 6(1)(b) GDPR.

11. Error reports from Track of the Day Mobile

Only if you send an error report in the app does it transmit a package containing the route, recorded track (GPS positions), event log, settings, diagnostic logs and screenshots. Access keys are removed beforehand. We store the package in Azure Files and use it only for error analysis. Legal basis: Art. 6(1)(a) GDPR (you trigger the sending yourself). Retention period: [FRIST FEHLERBERICHTE]; on request we will delete your reports immediately.

12. Videos (YouTube)

Help videos are embedded using a two-click solution: Only when you consent and start the video is it loaded in the privacy-enhanced mode (youtube-nocookie.com) of Google Ireland Limited. In doing so, Google receives, among other things, your IP address; a transfer to the USA is possible. Your browser remembers your consent until the end of the session. Legal basis: Art. 6(1)(a) GDPR, Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).

13. Program libraries from content delivery networks

The Portal loads the map library Leaflet from unpkg.com, and the route planner additionally loads a sorting library from cdn.jsdelivr.net. The operators receive your IP address and the user agent. Legal basis: Art. 6(1)(f) GDPR (fast, reliable delivery).

14. Cookies and local storage

We do not use advertising or analytics cookies. All cookies and entries in local storage serve the functioning of the Portal (Section 25(2) no. 2 TDDDG):

The browser's local storage (localStorage/sessionStorage) contains only display and work states, e.g. the selected map layer, gallery filters, intermediate states of the AI route planner and your YouTube consent. They do not leave your device.

15. Deleting your account

Under “Delete account” (/Account/Delete, also accessible from the apps) you can delete your account yourself after confirmation by email. The following are deleted or disconnected:

• tracks, routes, files, versions, history and collaboration,
• profile with profile picture, vehicles, interests, friendships and followed profiles,
• device pairings; licences are disconnected from the account and blocked, and the email address is removed.

The following are retained: an anonymised account record without name and email address, the hash value of the email address for the trial licence block (section 5) as well as logs and usage events until their retention period expires. Statutory retention obligations for orders concern the web shop. Finally, you will receive a confirmation at your previous address.

16. Recipients and transfers to third countries

Recipients are the service providers named above: Microsoft (Azure, Application Insights, Azure Maps), Brevo, HERE, Google, GraphHopper, DeepL, Anthropic, OpenAI, Esri, CARTO, OpenStreetMap, the operators of unpkg and jsDelivr and, for videos, Google/YouTube. Data processing agreements (Art. 28 GDPR): [ZU PRÜFEN: AV-Verträge je Anbieter].

Anthropic, OpenAI, Google, Esri and other providers are based in the USA or may transfer data there. Basis for the transfer: [ZU PRÜFEN: DPF-Zertifizierung bzw. Standardvertragsklauseln je Anbieter]. We only pass on other data if we are legally obliged to do so. We do not sell any data.

17. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and withdrawal of consent given, with effect for the future (Art. 7(3)).

Right to object (Art. 21 GDPR): You may object at any time, on grounds relating to your particular situation, to processing based on Art. 6(1)(f).

An email to [E-MAIL] is sufficient. You can also view and change much of the information yourself in your profile, under “My devices” and when exporting your tracks and routes.

18. Right to lodge a complaint

You may lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. The authority competent for us is: [ZUSTÄNDIGE AUFSICHTSBEHÖRDE].

19. Obligation to provide data, no automated decision-making

Without an email address and password, no account can be used, and without device pairing, no licence can be used in the apps. All other information is voluntary. No automated decision-making within the meaning of Art. 22 GDPR, including profiling, takes place.

20. Changes

We adapt this policy when our services or the legal situation change. The version published here at any given time applies.