GDPR Compliance

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Your Data Protection Rights

  • GDPR Coverage: Under the General Data Protection Regulation (GDPR), you have specific rights regarding your personal data.
  • Scope: These rights apply to EU residents using our website and mobile application, though data practices differ between platforms.
  • Mobile App: The StayStat mobile app processes location data locally and collects anonymous crash reports (with consent).
  • Website: Our website uses standard cookies and processes contact form submissions through Formspree.
  • Commitment: We are committed to respecting and facilitating the exercise of these rights across both platforms.

Right of Access (Article 15)

  • What it means: You can request confirmation that we process your data and access to that data.
  • Information provided: Categories of data, processing purposes, recipients, retention periods.
  • How to exercise: Email us at [email protected] with your request.
  • Response time: We will respond within one month of receiving your request.

Right to Rectification (Article 16)

  • What it means: You can request correction of inaccurate or incomplete personal data.
  • Mobile app: Most data can be corrected directly within the app settings.
  • Website data: Contact us to correct any information we may have collected.
  • Verification: We may ask for verification before making corrections to ensure data accuracy.

Right to Erasure - "Right to be Forgotten" (Article 17)

  • What it means: You can request deletion of your personal data under certain conditions.
  • Mobile app data: Delete the app from your device to remove all locally stored travel data. Your data is stored using Core Data and Keychain on-device.
  • Crash reports: Disable crash reporting in app settings to stop future collection. Existing reports are anonymous and handled by Firebase Crashlytics retention policies.
  • Website data: Request deletion of any data we may have collected through our website contact forms.
  • Limitations: Anonymous crash data may be retained for technical purposes according to Firebase policies.

Right to Restrict Processing (Article 18)

  • What it means: You can request that we limit how we process your data.
  • When available: If you contest data accuracy, object to processing, or if processing is unlawful.
  • Effect: We will store but not actively process the data until issues are resolved.
  • Notification: We will inform you before lifting any processing restrictions.

Right to Data Portability (Article 20)

  • What it means: You can receive your data in a structured, machine-readable format.
  • Mobile app: Export features within the app allow you to download your travel data.
  • Formats available: PDF, CSV, or other structured formats as technically feasible.
  • Scope: Applies to data you provided and that we process automatically.

Right to Object (Article 21)

  • What it means: You can object to processing based on legitimate interests or direct marketing.
  • Marketing: We do not engage in direct marketing, but you can object if this changes.
  • Analytics: You can object to website analytics through browser settings or ad-blockers.
  • Balancing test: We will stop processing unless we have compelling legitimate grounds.

Right to Withdraw Consent

  • What it means: You can withdraw consent for processing that relies on your consent.
  • Mobile app: Revoke location permissions through device settings to withdraw location consent.
  • Website: Clear cookies or adjust browser settings to withdraw website consent.
  • Effect: Withdrawal does not affect the lawfulness of past processing.

Automated Decision-Making Rights (Article 22)

  • Current practices: StayStat does not use automated decision-making with legal effects.
  • Algorithm transparency: Our app uses simple algorithms for travel tracking, not profiling.
  • Future changes: We will notify you if we implement automated decision-making features.
  • Your rights: Right to human intervention, explanation, and challenge of automated decisions.

How to Exercise Your Rights

  • Email us: Send requests to [email protected]
  • Include details: Specify which right you want to exercise and provide sufficient identification.
  • Verification: We may ask for additional information to verify your identity.
  • No charge: Exercising your rights is free, except for excessive or unfounded requests.

Data Controller Information

  • Data Controller: STAYSTAT
  • Location: Montreal, Quebec, Canada
  • Contact: [email protected]
  • EU Representative: Not required as we do not regularly offer goods/services to EU residents

Legal Bases for Data Processing

Under GDPR Article 6, we process your personal data based on the following legal grounds:

Data Type Purpose Legal Basis
Precise Location Country change detection, travel notifications (a) Consent (iOS permission prompt)
Crash Data App stability and reliability improvements (a) Consent (Opt-in, disabled by default)
Device Identifier Crash diagnostics, app reliability (f) Legitimate Interest (LIA: stability outweighs impact)
Camera/Photos Boarding pass scanning (on-device OCR) (a) Consent (iOS permission prompt)
Biometric Data App security (Face ID/Touch ID) (a) Explicit Consent (Art. 9(2)(a) - special category)
User Preferences App functionality (settings, themes) (f) Legitimate Interest (LIA: necessary for basic features)
  • Consent: You can withdraw consent at any time through iOS Settings or in-app privacy controls.
  • Legitimate Interest: We have conducted Legitimate Interest Assessments (LIAs) balancing our interests against your rights.
  • Special Category Data: Biometric data (Face ID/Touch ID) is processed by iOS Secure Enclave, not directly accessed by our app.

Supervisory Authority

  • Right to complain: You have the right to lodge a complaint with a data protection authority.
  • EU Residents: Contact your national supervisory authority listed at edpb.europa.eu
  • UK Residents: Information Commissioner's Office (ICO) - ico.org.uk
  • Canadian Residents: Office of the Privacy Commissioner (OPC) - priv.gc.ca
  • Cross-border processing: You may also contact the authority where you believe a violation occurred.
  • Before complaining: We encourage you to contact us first at [email protected] to resolve any concerns.

Data Retention

  • Mobile app travel data: Stored locally on your device using encrypted Core Data and Keychain; automatically deleted when you uninstall the app.
  • Location data: Used only for real-time country detection and processed entirely on-device; not transmitted or stored remotely.
  • Crash reports: Anonymous crash data retained by Firebase Crashlytics according to Google's data retention policies (typically 90 days).
  • Website analytics: Anonymous website usage data retained for up to 26 months for analytics purposes.
  • Contact form data: Processed through Formspree and not permanently stored by us.

International Data Transfers

  • United States (Firebase Crashlytics): Anonymous crash data may be transferred to Firebase (Google LLC) in the United States.
  • Legal Mechanism: Standard Contractual Clauses (SCCs) approved by EU Commission Decision 2021/914.
  • Google Cloud Data Processing Terms: Available at cloud.google.com/terms/data-processing-addendum
  • Supplementary Measures: AES-256 encryption, access controls, and limited data retention (90 days) ensure Schrems II compliance.
  • Data Location: Crash reports stored in Google Cloud data centers in the United States.
  • No Other Transfers: All other app data (travel entries, location, preferences) is stored locally on your device and never transmitted.
  • Your Rights: You can request a copy of the SCCs or opt out of crash reporting entirely in app settings.

Contact for Data Protection Inquiries

  • Privacy Officer: [email protected]
  • General Support: [email protected]
  • Response Time: We aim to respond to all privacy inquiries within one month.
  • Complex Requests: Response time may be extended to three months for complex requests.