This privacy policy takes effect on 29 July 2020. It describes what information we hold, why we hold it and how we use it. This policy applies to anyone who uses our website, www.Waymapnav.com (“Site”), our iOS or Android App (“Waymap App”) or our navigation software. We’ll refer to the Site and Waymap App together as “The App”. In this Privacy Policy, references to the App include both free and paid (if such versions arise in the future) versions of the App.

We are Waymap Limited (“we”, “our”, “us”), a company registered in the UK. We’re the data controller as defined by the General Data Protection Regulation. If you have any questions about this policy or want to contact our Data Protection Officer, please contact us through the App or send an email to privacy@waymapnav.com.

What information do we hold and why?

There are two types of information we process: (1) information you provide, and (2) information created when you use features in the App.

1. Information you provide

When you use our App, you might provide us with (a) personal information; (b) places and preferences; and (c) direct communications.

a. Personal Information

If you create a Waymap account, you provide us with your name and email address.
In general (without a Waymap account), we collect the information you provide us to support the features of the service including personally identifiable information such as phone number, address, mobility and accessibility requirements. The app collects and works out location and heading information and in so doing determines information about your gait and movement.

b. Places and Preferences

You may choose to provide us with information on your places and preferences, such as Home, Work, Saved Places, and other travel preferences. We use this information to develop personalised journey-planning services. We also analyse this data in aggregate to improve the App (for example, by ranking certain journey results more highly than others).

c. Direct Communications

When you communicate with us (for example when you respond to in-App survey questions, report problems, raise queries etc.) we may receive information about the type of phone you’re using, your service provider and, if you’ve enabled the location permissions in your device, the latitude and longitude of your location when you contact us. We use this information to fix problems in the App, to reply to your communications and to help keep you safe.

2. Information created when you use our App

The following are the types of information created when you use our App. We associate this information with an anonymous ID to collate the data we collect from you.

a. Location Information

We use the location data described in this “Location Information” section to improve results in the App and for the purposes identified below.

Users of the Waymap App: if you’ve enabled your device’s location services we may collect and use your start location information when you open the App.

When you start navigating in the Waymap App, we collect your location information throughout your journey. We use this data to provide on-trip support, such as alerting you when to get off a bus.

When the application is put in background whilst in active navigation to do other activities such as receiving a phone, replying an email etc., Waymap app continues to access your location information in order to provide you continuous navigation instructions to go from Place A to Place B. The application does not access location data in background if there is no active navigation session. Similarly, the application does not access any location data when the application is fully closed.

b. Device Information

We collect information about the devices you use to access our App, including the type of computer or device you use, the installation ID of the App on your device, the hardware model, operating system and versions, software, file names and versions, the preferred language, time zone settings, and device motion information. This information is necessary for us to diagnose bugs and improve the App. We do not collect any permanent device ID numbers.

c. Log and Usage Information

We use Firebase’s Analytics and Crashlytics to collect Log Data which may include your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app, your use of the service, and other statistics. We use this information solely to improve the Waymap service and no attempt is made to use this information to identify you. Please refer to https://firebase.google.com/support/privacy for Firebase’s privacy policy.

d. Cookies

The App uses cookies to store certain information. Cookies are pieces of information that a website or app transfers to your hard drive or mobile device to store and sometimes track information about you. Although they identify a user’s device, cookies do not reveal the name, email address or other obvious identifiers of users.

We try to make your experience of the App simple and meaningful. When you visit our App, our server sends a cookie to your computer or mobile device (depending on how you access the site or App). Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the site. A number of cookies we use last only for the duration of your web session and expire when you close your App. These are known as “session cookies”. Other cookies are used to remember you when you return to the App and will last for longer. These are known as “persistent cookies”.

We use cookies to:

• remember that you have visited us before, which allows us to identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get and to; customise elements of the promotional layout and/or content of the pages of the App; and
• collect information about how you use the App so that we can improve the App and learn which parts of the App are most useful.

Some of the cookies used by our App are set by us and some are set by third-party analytics and crash/error-reporting companies as described in this policy.

Most browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. By blocking or deleting cookies you may not be able to take full advantage of the App’s features.

How we use your information, summarised

In summary, we use the information we collect to only gather, store and process your personal data with your consent and where this is needed for us provide you with our services, including;

• to provide route options tailored to your needs,
• to provide support and emergency response services,
• to ensure that the service is secure,
• to research, develop and provide new features,
• where applicable, to accept and administer payment, and

• Provide and improve our App
• Build a profile of your preferences so we can personalise the Waymap App and provide you with relevant transport information;
• Recommend transport options that match your stated preferences and previous use of the App;
• Administer your account with us, if you have one;
• Respond to your emails to discuss your use of the App and answer any support queries you may have;
• Send you marketing communications by email or in-App notifications, and let you know about our policies and terms or when we launch in your city;
• Identify issues with the operation of the App, and provide crash reports in order to find resolution for performance issues;
• Improve the design, functionality and/or content of the pages of the App and customise them for you;
• Disclose to lawful authorities when required to do so by law, or when appropriate, in our opinion, to respond to their request.

We work hard to improve the App and add functionality, which we think will make it safer, more fun and more useful. New functionality may involve similar or incidental uses of your data to those set out above. We regularly review the way we use data and will update our privacy policy if anything changes.

What third parties receive your information?

From time to time we may share information with third parties to improve the App and enhance user experience. To the extent possible we pseudonymise (remove information that identifies you) and minimize the data we send to them.

• Analytics Vendors: We use third party vendor Firebase Analytics to understand what you’ve tapped or clicked on the App. They receive information showing only that someone has tapped or used certain features in the App. They organise that information and give it back to us so that we can make improvements to the App.
• Crash/Error Reporting Vendors: We use Crashlytics to report on crashes you experience with the App so we can fix those.
• Messaging Apps: If you decide to use certain sharing features in our App, then you may be sharing your information with those companies, depending on encryption policies used by the messaging company. For example, if you use the “Share Directions” feature in the App, a link with your start and end points will be sent via the messaging app. If the messaging app company you choose uses end-to-end encryption, your location link cannot be used or intercepted by that messaging app company.

What’s our legal basis for processing your information?

We’ll only process your personal information where we have a legal basis for doing so. Our legal basis to process your personal data includes processing that is:

• Necessary for our legitimate interests, which are:

• to research, develop, fix and provide new and tailored features for the App users;
• to provide on-trip support to users and to ensure that the App is secure for users;
• to verify users’ identity to prevent fraudulent or unauthorised use of our services; and
• to prevent breaches of our terms and policies or to prevent harmful or illegal activity;

• Necessary to comply with relevant legal and regulatory requirements; and
• Based on your consent (for example, where you provide us with marketing consents), which may be withdrawn at any time by contacting us at the email address specified below.

What are your rights in relation to personal data we hold about you?

Access

You have a legal right to request access to a copy of the personal information we hold about you. In order to do this, contact us at privacy@waymapnav.com. Please use the subject line “personal data request” and include details about what personal information you’re looking for. You will need to have created an account in order for us to provide you with your information because without an account, we are not able to connect your information to a verifiable email address. You must have access to the email address that you used when you created the account so that we can verify your identity.

Deletion

We store your personal information for as long as is necessary to provide our services and products. You have the right to request we delete your personal information if you believe that we no longer need it for the purposes for which it was provided, you wish to withdraw your consent (and we have no other lawful basis to use the data), or we are not using your information in a lawful matter. For legal reasons, we may not always be able to delete your information.

If you ask us to delete your personal information by emailing us at privacy@waymapnav.com, please use the subject line “personal data deletion”.
Note that residual copies may take longer to be removed from our backup systems which cannot be immediately overwritten. Where residual copies are still kept on our back-up systems, they are merely held on the system and are not used for any other purpose. We will keep a record of your request in order to ensure compliance with legal obligations.

We will keep a record of your request in order to ensure compliance with legal obligations.

Marketing opt-out

You have the right at any time to prevent the use of your personal information for direct marketing purposes. If you no longer want to receive marketing messages from us, please let us know by writing to us at privacy@waymapnav.com or clicking on the unsubscribe button at the bottom of marketing emails and you will be unsubscribed accordingly. Please note that sometimes it can take a short amount of time to refresh our records for these purposes. Also, we may still send you non-promotional, transactional messages, or information about your account.

Notifications

We may send you information we think you may find useful (e.g., tube line and subway disruptions) or which you have requested from us by push notification and/or by email (if provided). You can opt-out of receiving further notifications or emails if you wish.

How we keep your information secure

We place great importance on the security of all information associated with our users. As a result we strive to use commercially reasonable means of protecting it. We use measures such as encryption, pseudonymisation, information access controls, audit logs and firewalls.
Keep in mind that submission of information over the internet and mobile networks is never entirely secure. We cannot guarantee the security of information you submit via the App whilst it is in transit over the internet or mobile networks and any such submission is at your own risk.

How long we keep your information

By providing you with products or services, we create records that contain your information, such as customer account records, payment (only if relevant) and activity records. We manage our records to help us to serve our users well and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and are evidence of our business activities.

How long we keep records depends on the type of record, the nature of the activity, product or service and the applicable legal or regulatory requirements. How long we retain your information may change based on business or legal and regulatory requirements. In some circumstances, we may keep data longer if we need to (because it’s in our legitimate interest and/or if the law requires).

What countries will your personal information be sent to?

Personal information that you submit via the App is sent to and stored on secure servers located in the relevant regulatory region for the Appstore used to install the App. With your prior permission, we may share this information with third party organisations in order to provide specific services.

Do you collect children’s information?

We do not knowingly collect personal information from children under the age of 13. If you’re under the age of 13, please do not submit any personal information through the App or email. We encourage parents and legal guardians to monitor their children’s internet use and to help enforce our privacy policy by instructing their children never to provide personal information on our website without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us as specified below, and we will work to delete that information from our databases.

How will you know about changes to our privacy policy?

We may revise this privacy policy from time to time. Any changes and additions to this privacy policy will be posted in the App and are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal data. This privacy policy was last updated on 29 July 2020.

What if you have a complaint?

We work hard to handle your information responsibly. If you’re unhappy about the way we do this, please contact our Data Protection Officer by email to privacy@Waymapnav.com.