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Legal Notice

No insurance coverage is provided as part of the Movingdots Coloride Pilot. You acknowledge and agree that you will provide data in your capacity as a private individual as part of this pilot and that Movingdots will not pay any compensation for your participation in this pilot. You are also responsible for obtaining and maintaining all appropriate and required licenses and insurance for your vehicle and all drivers. In addition, you are responsible for complying with all laws and conditions relating to your employment contract with your employer, including any applicable employer policies related to your vehicle and its use, whether used in connection with your employment and/or for personal purposes. This includes, but is not limited to, the following:

Movingdots shall not be liable for any loss or damage related to you, other persons, your device or vehicle resulting from your participation in the pilot.

By clicking, you acknowledge that you have read and understood this Legal Notice, the Terms of Use and the Privacy Policy, and by downloading the Movingdots Coloride Pilot App, participating in the Movingdots Coloride Pilot and using the physical device installed in your vehicle, you agree to participate in the pilot conducted by Movingdots GmbH in Germany, as well as to the Terms of Use and our processing of your information, including the use of tracking technology as defined in the Privacy Policy.

By clicking, you confirm that you explicitly consent to our use of your personal data and any sensitive personal data that you may provide to us.

Privacy Policy

This Privacy Policy relates solely to the collection and use of personal data by Movingdots GmbH in Germany in connection with the Movingdots Coloride Pilot (the “Pilot”). Movingdots GmbH, Lloydstr. 4-6, 28217 Bremen, Germany (“Movingdots”) is conducting the Pilot and is the data controller of all of the personal data collected and processed for the purpose of the Pilot

Name and contact details of the data controller:

Movingdots GmbH, Lloydstr. 4-6, 28217 Bremen

Managing Director: Melissa Ingram

Phone number: +49-421-964 990

E-mail address: coloride@movingdots.com

Contact details of the data protection officer: dataprivacy@movingdots.com
This Privacy Policy applies to any use of the Movingdots Coloride Pilot App.

Scope, Application and Purposes

This Privacy Policy sets out how Movingdots collects and uses the personal data of participants in the Pilot obtained via a smartphone app on mobile phones (the “Movingdots Coloride Pilot App”). The Pilot is being conducted to provide our business partners (typically insurance companies, “Insurers”) with the means to test and evaluate the Movingdots Coloride Pilot App and related services that Movingdots provides to Insurers. We assume that you, as a participant in the Pilot (“Participant”), are typically an employee, insurance advisor or other business partner of an Insurer and that you have been asked by an Insurer to participate in the Pilot at your own discretion.

The Movingdots Coloride Pilot App collects personal data about Participants as explained in the section below. The purposes for processing personal data during the Pilot are as follows: (i) to collect data about motor vehicle drivers, driving behaviour and data obtained using other means of transport (e.g. public transport) and to analyse these data and improve our algorithms and evaluation mechanisms; and (ii) to enable an Insurer to test and evaluate the Movingdots Coloride Pilot App and related services.

Please note that your participation in the Pilot is voluntary and at your own discretion. Movingdots will collect and use personal data only to the extent required to conduct the Pilot. Movingdots will not disclose personal data to third parties, except as (i) described in this Privacy Policy, nor will Movingdots disclose personal data to regulatory authorities, government agencies or courts of law, unless we are required by law and requested to do so. A pseudonymised dataset will be provided to the Insurer (i.e. your employer) for the Movingdots Coloride Pilot App assessment. Although Movingdots ensures that the data are pseudonymised (i.e. direct identifiers such as name, date of birth, etc. are removed from the data), we cannot exclude that the Insurer can identify you indirectly (e.g. by means of GPS data).

Movingdots Coloride Pilot App

a. What information does the Movingdots Coloride Pilot App collect during the user registration process and how is it used?

First, Movingdots collects information on the Movingdots Coloride Pilot App in the form of a questionnaire during the registration process. This information can be divided into the following categories:

Participant information - personal information such as first name, last name, age group, Movingdots username, e-mail address, etc. so that you can participate in the pilot and we can communicate with you in connection with the Pilot. We will also use these data for the purposes of analytics, e.g. by analysing data by region or age group. Additional information that may be provided on a voluntary basis includes a photo for your profile, a pseudonym and gender.

Rating factors - information that you are usually required to provide when applying for car insurance. This includes, for example, the type of vehicle, make, the year of vehicle registration, accidents in the past five years and any traffic fines (no criminal convictions). We use this information for the purposes of analytics, e.g. to establish a possible link between driving data and rating factors.

Driving behavior - information collected using social science-based questions designed to analyse your status and driving behaviour. We use this information for the purposes of analytics, e.g. to compare the driving behaviour of drivers participating in the Pilot with other comparable datasets.

Please note that data collected as part of the user registration process may include sensitive personal data. By providing these data, you explicitly consent to the use of these data for the purpose of the Pilot. The questionnaire will indicate in each case whether answering a question is voluntary or mandatory in order to take part in the Pilot.

b. What additional information do the Movingdots Coloride Pilot App and the dongle collect and how is it used?

The Movingdots Coloride Pilot App collects the following information via your smartphone: your location (GPS coordinates), movement data, GPS accuracy and accelerometer data (speed and acceleration), gyroscope information, and information about how you use your smartphone while driving. This includes the accurate real-time location information (i.e. a timestamp) of the device on which the Movingdots Coloride Pilot App is installed, as well as position and acceleration information at times when the hardware unit or Movingdots Coloride Pilot App has detected a potential collision. This information is used in conjunction with the data collected as part of the user registration process via the Movingdots Coloride Pilot App to analyse driving behaviour.

If you have received a hardware unit that is used in the vehicle, it also collects the following data: the start and end time of journeys that have taken place without a Bluetooth connection between the hardware unit and the Movingdots Coloride Pilot App at that time.

In order to continuously improve the quality of our app, we collect information on the use of the app, which is transmitted, for example, whenever errors occur, as part of the so-called crash reports. The aim of collecting these data is the quick and detailed error analysis of malfunctions and problems, as well as the improvement of the user experience in the Movingdots Coloride Pilot App. The data collected do not contain any personal information such as name, address or e-mail address. We only collect pseudonymised, technical information such as crash traces, device type, operating system, app version as well as data on the use of the app such as click behaviour and the time spent on individual pages. The Microsoft Visual Studio App Centre (https://appcenter.ms) is used for this purpose.

c. What other information is used to determine the driver rating?
Furthermore, other contextual information may be used to determine your driving score or rating. This includes environmental and contextual data such as type of road, speed limits, location in relation to bridges, tunnels, traffic flow and maps of the road network.

d. What information will I receive as part of the Pilot?
The Movingdots Coloride Pilot App will give you information about your driving profile in the form of visual statistics related to speed, acceleration, braking, cornering, abrupt manoeuvres and the use of your smartphone while driving. By using the Movingdots Coloride Pilot App, you can view the list of the trips recorded by the app and some details about each trip (route, start time, arrival time, duration, distance and visual statistics related to speed, acceleration, braking, cornering, abrupt manoeuvres and smartphone usage).

e. What happens if I want to cancel the pilot?
You can withdraw from the Pilot at any time by sending an e-mail to the following address: coloride@movingdots.com. Alternatively, you can also cancel your participation in the Pilot by clicking on “Withdraw consent”. This notification will delete any data that can be directly linked to you within one month of your request. However, please note that Movingdots, as well as any third party providers involved in the Pilot, will still have your anonymised information collected via Movingdots Coloride Pilot App and/or a hardware unit used (if any) afterwards. The collection of data can also be stopped by logging out of or uninstalling the Movingdots Coloride Pilot App. However, this will not immediately delete data that can be directly linked to you. In any event, personal data that can be directly linked to you will be deleted within three months from the end of the Pilot.

f. Cookies and other tracking technologies
The Coloride Pilot App uses a token to keep the App logged in permanently unless you proactively log out of the App. By using the Movingdots Coloride Pilot App, you agree that we may use this token on your device.

g. Who has my data and for how long?
Movingdots collects data via the Movingdots Coloride Pilot App, as explained above. Movingdots also retains these data for an indefinite period of time. Personal data that can be directly linked to you will be deleted within three months after the end of the Pilot.

Within Movingdots, only selected and traceable members of the Pilot test team (support staff, data experts and platform architects based in Germany or in the European Union) will have access to your identifiable data collected as part of the user registration process and to data collected via the App. These individuals have been made aware that these data are confidential and sensitive and must be handled as such.

The Insurer (i.e. your employer) will receive recorded datasets as well as access to user management solely for the purpose of evaluating the Movingdots Coloride Pilot App.

Please note that the anonymised dataset is used to improve Movingdots' algorithms and rating mechanisms and may be shared with other research and business partners under a non-disclosure agreement to enable them to produce their own analyses and improve their rating mechanisms. However, these datasets do not contain data that can directly identify the Participants.

h. What about data security?
We take reasonable steps to ensure the security of personal data collected via Movingdots Coloride Pilot App or via the hardware unit.

i. Where will my data be processed?
In connection with the Pilot, all data collected by the App will be stored at Movingdots GmbH, Lloydstr. 4-6, 28217 Bremen, Germany; its service provider, Swiss Reinsurance Company Ltd, Mythenquai 60, 8002 Zurich, Switzerland; and the cloud service provider, Microsoft, One Microsoft Way, Redmond, Washington 98052, USA, which uses a cloud infrastructure in the Netherlands. Data processing is carried out in compliance with the EU Commission's adequacy decision (2000/518/EC).

Personal data may also be transferred to our contracted service providers and consultants as well as research and business partners who may operate internationally. Therefore, we may need to transfer your personal data to other countries. Before this happens, we will take the requisite steps to ensure that your personal data are adequately protected in accordance with the relevant data protection laws. In any event, personal data collected via the Movingdots Coloride Pilot App as part of the user registration process and processed for the Pilot will be processed solely by Movingdots GmbH, Germany, without the involvement of any third party providers.

j. Can I access my data?
As explained above, you will receive driving ratings and data from the Movingdots Coloride Pilot App. You also have a right to know if we hold any personal data about you. If we do, you have access to these personal data and are entitled to request that they be deleted or corrected if they are inaccurate. In this event, please contact us at the following address: coloride@movingdots.com.

Legal basis of the data processing

Your data are processed on the following legal bases:

Your rights

You have the right - sometimes under certain conditions -

Last update of this Privacy Policy: March 2023

We reserve the right to change this Privacy Policy at any time with future effect.