Privacy Policy (App)

3.1 Account and profile

We process your e-mail address, your password (only as a hash value at Firebase Authentication), your username, an internal user ID, the time of registration, the app version, your device’s operating system, the time you last used the app, the people you block and, on a voluntary basis, display name, profile text, website, profile picture and cover image. If you sign in with Google or Apple, we receive from them an identifier, your e-mail address (with Apple, a relay address if you wish) and, if included, your name and profile picture; Google and Apple are separate controllers for the sign-in itself. The legal basis is Art. 6(1)(b) GDPR.

Visible to all logged-in users are your profile details, whom you follow and who follows you, your points, your level, your badges, your collection (series, train types and locations rounded to about one kilometre), your rank, your posts, sightings, public albums, comments and likes, and a supporter badge if you have a subscription and do not hide the badge. If a link is shared, people who do not have the app can also see the name and profile picture for profiles, the photo and caption for posts, and the train, route and date, without photo and name, for sightings.

3.2 IP address at registration

When you choose your username, we store the IP address and the time in order to detect multiple accounts and the circumvention of suspensions. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is protecting the community from abuse.

3.3 Invitations and prize draws

For both accounts, we store who invited whom and when, and credit points for this (Art. 6(1)(b) GDPR). To prevent points from self-created accounts, we count invitations per person and flag conspicuous accounts for review (Art. 6(1)(f) GDPR; interest: fair allocation). If you tap “Open in the app” on the invitation page, we place an invitation code on the clipboard; only if you state during registration that you were invited does the app read the clipboard once (consent, Art. 6(1)(a) GDPR, § 25(1) TDDDG, the German Telecommunications Digital Services Data Protection Act). For prize draws among inviters, we store for each invitation the ID of the inviting person and the ID, username and display name of the invited person as a ticket, and notify the winner in the app and, where applicable, also by e-mail (for inviters Art. 6(1)(b) GDPR, for invitees point (f); interest: conducting the prize draw). We only name winners publicly with their consent.

3.4 Posts, sightings, comments, likes and albums

We process what you publish: photos, captions, train details, date taken, photo spot with place name and viewing direction, camera and shooting settings; for sightings, the train, route, additional text, optionally a photo and a map point; as well as comments, likes, “Thumbs down”, albums and saved posts. From a selected photo, the app reads the capture data (EXIF) on your device; only what you confirm is stored, and the stored image file contains no EXIF data. Posts, sightings, comments, likes and public albums are visible to all logged-in users. We show no one who gave a “Thumbs down”; only you can see your saved posts. Posts that many rate with “Thumbs down” are hidden in the feed. In accordance with § 6(2) of the Terms and Conditions, we also show individual pieces of content with your username on our own social media channels; you can object to this at any time. The legal basis is Art. 6(1)(b) GDPR.

If you delete your account, your sightings are retained without name, profile picture and photo, because confirmations, comments and alerts of others refer to them (Art. 6(1)(f) GDPR; interest: a complete set of sightings). If you do not want this, delete them beforehand.

3.5 Automatic content checks

We transmit the texts of comments, posts, albums, profiles, usernames, group names and forum posts to an AI model from Google (Gemini API), for comments, posts, albums and profiles together with the internal ID of the content, which for profiles is your user ID. We check images in posts, sightings, profiles and groups with Google Cloud Vision for adult, violent or suggestive content; in images of posts and sightings, we blur detected faces in the process without identifying anyone. We block certain internet addresses and terms using fixed lists. The legal basis is Art. 6(1)(f) GDPR and, insofar as we thereby fulfil obligations under Regulation (EU) 2022/2065 on digital services (Digital Services Act), also point (c); our legitimate interest is a platform free of harassment, unlawful content and dangers to minors.

3.6 Personalised feed

If you open, like or save a post, the app stores in your account the series, train type, rough map area and the ID of the person who published it, in order to order your own feed accordingly; at the start, it takes over the series from your collection. The profile can only be read by you and is not passed on. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is a feed that matches your interests. You can object under “Settings › Tailor feed to me”; we will then delete the profile.

3.7 Points, leaderboards and photo contest

We store what you received points and badges for, keep public leaderboards with rank, points, username and profile picture, and select public posts for the weekly photo contest; we store your vote with your ID. The legal basis is Art. 6(1)(b) GDPR. You can switch off both in the settings (“Appear in the leaderboard”, “Take part in Traintrack of the Week”).

3.8 Location

The app only uses your device’s location with your permission in the operating system, when a feature needs it, for example to set a map point or for the “nearby” filter (Art. 6(1)(a) GDPR, § 25(1) TDDDG). We do not store it; only a point that you confirm is stored. For place names, the app transmits coordinates to your operating system’s location service (Apple or Google, each a separate controller), and on the spotter map the map section to Algolia.

3.9 Push notifications

If you allow push notifications, our service provider OneSignal receives your user ID, the push token, technical device data (device type, operating system, language, time zone, app version, IP address) and the title and text of each push; for chats, the sender’s name and up to 80 characters of the message, for forums, the name and title of the topic. Delivery takes place via Apple and Google. The legal basis is your consent (Art. 6(1)(a) GDPR).

3.10 Newsletter

If you tick the newsletter box, we transmit your e-mail address, display name and username to Klaviyo, which sends you an e-mail for confirmation; Klaviyo records whether you open newsletters and which links you click. The legal basis is your consent (Art. 6(1)(a) GDPR).

3.11 Sighting alerts

For alerts (part of a subscription), we store your rules, quiet hours, matches and technical counters (Art. 6(1)(b) GDPR). So that fake sightings do not trigger alerts, before an alert we automatically assess the account of the reporting person by account age, previous and objected-to sightings, suspensions and internal indications of abuse; the result only decides whether and when a sighting triggers alerts (Art. 6(1)(f) GDPR; interest: protection against false alerts and against attempts to lure people to a location).

3.12 Subscriptions

You buy subscriptions via Apple or Google; they process the payment as separate controllers. Our service provider RevenueCat receives your user ID and the purchase receipts (product, price, currency, times) and tells us which subscription benefits you have (Art. 6(1)(b) GDPR). If you voluntarily give a reason when closing the subscription page, we store it with your ID (Art. 6(1)(f) GDPR; interest: improving our offering).

3.13 Operation, security and search

• Server logs: Every call to our servers is logged with time, function, result and full IP address in order to find errors and fend off attacks (Art. 6(1)(f) GDPR; interest: secure operation). This also applies to the pages at app.traintrackapp.de; they set no cookies and embed no third-party services.
• Authenticity check (Firebase App Check): The app has its authenticity confirmed by Google Play Integrity or Apple App Attest (Art. 6(1)(f) GDPR, § 25(2) no. 2 TDDDG; interest: protection against abuse).
• Crash reports (Firebase Crashlytics): In the event of a crash, the app sends technical error details, device model, operating system and a random installation ID, no account data (Art. 6(1)(f) GDPR, § 25(2) no. 2 TDDDG; interest: a stable app). To switch off: “Settings › Analytics settings › Send crash reports”.
• Search (Algolia): Algolia receives public profile and post details, your search terms, filters, map sections and your IP address (Art. 6(1)(b) GDPR).
• Maps (Google Maps): To load the map, Google receives your IP address, the map section and device data as a separate controller (Art. 6(1)(b) GDPR).
• Our own ads: In order to bill how many people have seen an ad, we store your user ID, the ad and the date per day; without advertising IDs and without ad networks (Art. 6(1)(f) GDPR; interest: billing with advertising partners).

3.14 Usage analysis, only with consent

If you agree to “Allow pseudonymous analysis”, we use Google Analytics for Firebase to record pseudonymously, with your user ID, which areas and features you use, which of our ads you see and tap, device type, operating system, app version, usage times, and country and region derived from the IP address. With the same consent, Firebase Performance Monitoring measures the app’s loading times and the duration and result of its network calls, with an installation ID, device data, type of network connection, app version and the country derived from the IP address. The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). We store your decision with the time and text version as proof.

3.15 Measuring ad success, only with consent

If you agree to “Measure ad success” (on the iPhone, additionally to the iOS tracking permission), we measure which of our ads on Meta and Google lead to installations, registrations and subscriptions. For this purpose, AppsFlyer, as our service provider, processes an AppsFlyer ID, your device’s advertising ID, on the iPhone the IDFV, IP address, device type, operating system, app version, installation, registration with sign-in method, the opening of the subscription page and, via RevenueCat with your user ID, your subscription events with product, price and currency. AppsFlyer passes these events on to the network through which you came (Meta or Google); we store the campaign on your subscription account at RevenueCat. We pass nothing on to TikTok, which the dialog also mentions, before we have added TikTok to this policy. We do not transmit e-mail address, name or content. We do not allow the networks to use your data for personalised advertising or audiences. With consent to analysis (3.14), Google additionally uses the events “Trial started” and “Subscription purchased” from Google Analytics for measuring success. The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). We store your decision with the time, text version and status of the iOS tracking permission as proof.

Joint controllership with Meta. For the collection of these events and their transmission to Meta Platforms Ireland Ltd. (Merrion Road, Dublin 4, Ireland), we are joint controllers with Meta (Art. 26 GDPR). We inform you; Meta fulfils your rights for the data that Meta stores after the transmission; you can contact both us and Meta. Agreement: facebook.com/legal/controller_addendum; privacy policy: facebook.com/privacy/policy. Meta alone is responsible for further processing. Google receives the events as a separate controller (business.safety.google/adscontrollerterms).

3.16 Reports, moderation and authorities

If you report content, we store the reason, your free text, your ID, the ID of the reported person and a reference to the content, and for chat messages and forum posts a copy as at the time of the report. Anyone who reports by e-mail without an account gives us their name and e-mail address. The reported person does not find out who reported them, unless we are legally obliged to disclose it. For decisions and appeals, we store who in the team decided what and when. If we have indications of a criminal offence that endangers the life or safety of a person, we transmit the content, username, ID, e-mail address, registration date and, if still available, the registration IP to the law enforcement authorities. The legal basis is Art. 6(1)(c) GDPR in conjunction with Arts. 16 to 18 of the Digital Services Act, and for evidentiary copies Art. 6(1)(f) GDPR (interest: proof and protection against abuse).

3.17 Chats

We process your messages with time and sender, memberships, group name, image and description, read status, daily counters, declined requests and your confirmation of the chat rules and the minimum age (Art. 6(1)(b) GDPR). Messages are subject to the secrecy of telecommunications (§ 3 TDDDG): the server automatically checks every message against a list of blocked internet addresses, hides matches and presents them to our team with a copy. If someone reports a message, our team sees the reported message and, upon an explicit click, up to ten messages before and after it, in groups including those of third parties; every such view is logged. Beyond this, we take no notice of the content. All participants consent to both by accepting the chat rules; to that extent, the legal basis is Art. 6(1)(f) and (c) GDPR (interest: protection against spam and abuse). No AI system analyses messages. If you delete your account, the text of your messages is retained for your chat partners without your ID, your name and your picture (Art. 6(1)(f) GDPR; interest of the chat partners in readable conversations).

3.18 Forums

What you write in forums is visible to all logged-in users with your username and profile picture, but not to people outside the app. We process your posts, memberships, subscribed topics, your read status and your confirmation of the forum rules and the minimum age (Art. 6(1)(b) GDPR). To protect against spam and abuse, we also process your writing level, daily counters, checksums of your recent posts, automatically detected rule violations, suspensions and how many of your reports were justified (Art. 6(1)(f) GDPR; interest: forums free of harassment, exposure and dangers to minors). If you delete your account, we delete the text of your posts; a placeholder remains so that replies from others remain readable.

3.19 Support

If you write to us in the app or by e-mail, we process your message, your contact details and, if you are logged in, your ID in order to handle your request; we store feature suggestions with your ID. The legal basis is Art. 6(1)(b) GDPR insofar as it concerns your account or a subscription, otherwise point (f) (interest: answering your request).