Privacy Policy
Whellz stores your trips, GPS routes, and driving data exclusively on your device. Your personal driving data is never transmitted to or accessed by the developer. The app uses a crash reporting service (Sentry, EU-hosted) to receive anonymous technical diagnostics when the app crashes or encounters an error. No GPS coordinates, routes, trip data, or personal identifiers are included in crash reports. See Section 8 for full details.
1. Controller (Art. 13 para. 1 lit. a DSGVO)
The controller responsible for data processing within this application is:
Ufuk Emre Fakioglu
hello@whellz.app
2. Data We Process (Art. 13 para. 1 lit. c DSGVO)
The following categories of personal data are processed exclusively on your device:
- Precise GPS coordinates (latitude and longitude) recorded during active trips
- Speed in km/h, derived from GPS or, when connected, OBD2 sensor data
- Timestamps for trip start, trip end, and individual location waypoints
- Accelerometer event counts: harsh acceleration events, harsh braking events, and cornering events, each stored as an integer count per trip
- Trip classification labels assigned by you: Business, Personal, Medical, or Unclassified
- Derived, on-device usage patterns computed from your own trips: frequently visited start and end areas (grouped by an approximate radius), time of day, and repeated routes, used only to suggest a trip type for a new trip
- When connected, the connected car audio device name, read locally to match a drive to a vehicle in your garage
None of the data listed above is transmitted to or stored on any server operated by the developer or any third party. When you export your trip log as a CSV file, that export is initiated exclusively by you and sent directly to the destination you select, for example email, iCloud Drive, or another cloud storage service you designate. For information on technical diagnostic data transmitted for crash reporting purposes, see Section 8.
3. On-Device Processing Only
All personal data listed in Section 2 is stored and processed exclusively on your device using Apple's on-device frameworks (CoreLocation, CoreMotion, SwiftData). The developer has no access to your personal data at any point, whether directly or through a backend service or intermediary.
Speed camera proximity data is sourced from OpenStreetMap and evaluated locally on your device within a defined geographic radius. No device identifier, location, or personal information is transmitted as part of this lookup.
To make trip logging faster, Whellz analyzes your own trips on your device to learn usage patterns, for example which areas you start and end in, at which times of day, and which routes you repeat. It uses these patterns only to propose a trip type (for example Business or Personal) for a new trip. Any such classification is only a suggestion: you always confirm the trip type yourself, and the app never sets it on your behalf. This analysis runs entirely on your device, is never transmitted to any server, and is derived from your stored trips. Deleting your trips removes the basis for these suggestions.
4. Legal Basis (Art. 13 para. 1 lit. c DSGVO)
Processing is carried out on the following legal bases:
- Art. 6 para. 1 lit. b DSGVO: processing is necessary for the performance of the contract between you and the developer. Trip logging, speed measurement, and route recording are the core functions of the app, which you request by using it.
- Art. 9 para. 2 lit. a DSGVO: your explicit consent, obtained in-app via a dedicated consent modal, for the processing of health-related data when you use the Medical trip classification (see Section 5).
- Art. 6 para. 1 lit. f DSGVO: legitimate interests of the developer in maintaining the stability and quality of the application. This basis applies exclusively to technical diagnostic data transmitted to the crash reporting service described in Section 8. No location data, trip data, or personal identifiers are involved in that processing.
5. Health Data: Medical Trip Classification (Art. 9 DSGVO)
Whellz allows you to classify trips as "Medical." The combination of a GPS route and a medical classification label may constitute health data within the meaning of Art. 9 para. 1 DSGVO and Recital 35, as it may reveal information about your health or medical situation.
Processing of such special-category data requires explicit consent under Art. 9 para. 2 lit. a DSGVO. Before you can use the Medical classification for the first time, the app displays a dedicated consent modal that reads: "Recording trips as Medical may constitute health data (Art. 9 DSGVO). This data is stored only on your device. I consent." You must affirmatively tap "I consent" to proceed. If you do not provide consent, the Medical classification option remains unavailable.
Your consent timestamp is stored locally on your device. You can withdraw consent at any time by deleting all Medical-classified trips and resetting the consent flag in app settings. On-device-only storage limits practical exposure, but does not remove the legal obligation to obtain consent prior to processing.
6. Your Rights (Art. 15-22 DSGVO)
You hold the following rights under the DSGVO. Because the developer holds no personal data, all rights are exercised directly by you within the app. No data subject request needs to be submitted to the developer:
- Right of access (Art. 15): all personal data is accessible to you at any time within the app.
- Right to rectification (Art. 16): you can edit trip details, classification labels, and any other stored fields within the app.
- Right to erasure (Art. 17): you can delete individual trips or all app data at any time. See Section 7 for retention obligations that may apply to Business trips.
- Right to restriction of processing (Art. 18): you can pause or stop recording at any time, and revoke location access in iOS Settings.
- Right to data portability (Art. 20): you can export your complete trip log as a CSV file at any time via the Trip Log screen.
- Right to object (Art. 21): you can revoke location access at any time in iOS Settings, which prevents further data collection.
For any questions about your rights or this policy, contact hello@whellz.app.
For diagnostic data processed by the crash reporting service (Sentry) described in Section 8, you may exercise the right of access (Art. 15), the right to erasure (Art. 17), and the right to object to processing (Art. 21) by contacting hello@whellz.app. Because crash reports are not linked to a personal identifier, it may not be technically possible to locate data relating to a specific individual within Sentry; in that case the developer will respond in writing explaining the limitation.
7. Data Retention and the Paragraph 147 AO Obligation
Whellz does not apply automatic deletion to any trip records. You control when records are deleted.
If you use Whellz to maintain a Fahrtenbuch under paragraph 6 para. 1 no. 4 sentence 3 EStG, your Business-classified trip records may be subject to a 10-year retention obligation under paragraph 147 AO. Before you delete any trip classified as Business, the app will display a warning reminding you of this statutory obligation. You are solely responsible for compliance with applicable tax retention law.
8. Crash Reporting and Diagnostics
Whellz uses Sentry, a third-party crash reporting and diagnostics service operated by Functional Software, Inc. (Sentry), to detect and diagnose application crashes and non-fatal errors. All data is processed on servers located in the European Union (Frankfurt, Germany) under Sentry's EU data residency configuration (ingest.de.sentry.io). No data is transferred outside the European Economic Area.
When a crash or non-fatal error occurs, the following technical data is transmitted to Sentry:
- Device model (for example "iPhone 15 Pro")
- iOS version
- App version and build number
- Crash stack trace
- Anonymized action breadcrumbs: short developer-defined labels describing which part of the app was active at the time (for example "trip_started" or "export_tapped"), containing no personal content
- A build environment tag identifying whether the session is a simulator run, a development build, or a production release
The following data is never transmitted to Sentry:
- GPS coordinates, latitude, longitude, or any location data
- Routes, trip logs, speed readings, or any driving history
- Your name, email address, or any personal identifier
- Screenshots of the app
- User interaction sequences or tap patterns
GPS coordinate fields are explicitly stripped from all Sentry payloads in code before transmission. No user identifier is assigned within Sentry, so crash reports cannot be attributed to an individual.
Performance traces and profiling data are sampled at a rate of approximately 5% of sessions each, to help identify performance regressions. This data is subject to the same exclusions listed above.
Legal basis: Art. 6 para. 1 lit. f DSGVO (legitimate interests). The developer has a legitimate interest in identifying and resolving crashes in order to maintain a functioning and reliable app. Given that no trip data, location data, or personal identifier is transmitted, and that sampling is limited to 5% of sessions for performance data, this interest is not overridden by your fundamental rights and freedoms.
Data processor: Sentry acts as a data processor within the meaning of Art. 28 DSGVO. A Data Processing Agreement governs its handling of the diagnostic data described above.
Retention: Crash reports and performance data are retained in Sentry for 90 days, after which they are automatically deleted.
Whellz does not use advertising SDKs, behavioral tracking tools, cookies, or analytics platforms. If an analytics service is introduced in a future version, this policy and the App Store privacy nutrition label will be updated before that version is submitted to the App Store.
9. App Store Privacy Nutrition Label
The App Store privacy nutrition label for Whellz declares the following in the Diagnostics category:
- Crash Data (Diagnostics, Not Linked to You): crash stack traces and device technical information collected via Sentry, as described in Section 8.
- Performance Data (Diagnostics, Not Linked to You): aggregate performance timing data collected for approximately 5% of sessions via Sentry, as described in Section 8.
Your personal trip data, GPS routes, and driving history remain in the "Data Not Collected" category because they are processed exclusively on your device and are never transmitted.
10. Supervisory Authority (Art. 13 para. 2 lit. d DSGVO)
You have the right to lodge a complaint with the data protection supervisory authority competent for the controller:
Bayerisches Landesamt fur Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach
Germany
www.lda.bayern.de
Changes to This Policy
If this policy is updated in a material way, the revised version will be published at this URL with an updated effective date. Where required by law, you will be notified within the app before the change takes effect.