Privacy Statement | last change 6th January 2022
Turnn B.V. is the organization behind the Mobility as a Service (MaaS) travel planner Turnn – MaaS Suite, hereinafter referred to as the Turnn app, and the processor and administrator of your (personal) data. We are located at Iepenhoeve 7B, 3438 MR in Nieuwegein and are registered with the Chamber of Commerce under number 78111072. This Privacy Statement applies when you use the Turnn app, when you visit our website https://turnn.nl and when you contact our Customer Support department.
MaaS combines everything related to your trip and is about aggregating data from as many transport providers as possible. This data is displayed in the Turnn app to give you as a traveler information about all transport options, for example: public transport, cab, bicycle, shared car or e-scooter. We offer you a comprehensive mobility service where you can plan your trip in the Turnn app, buy digital transport tickets, book, pay for and use means of transport, and be informed about e.g. delays and parking options. Currently, the Turnn app is primarily intended for business use which requires a company code. Since it is not inconceivable that private use will be supported in the near future, this privacy statement already takes private use into account.
1. Your privacy is our starting point
We will clearly explain how we collect your data and what we use it for.
Choice and control
You decide as part of the registration process whether you give us permission to include your personal data collected by the app in the Turnn database, to process, store and analyze it. We distinguish between business use (as an employee) and private use of the transport services offered. You can change or delete your data about these services at any time. Depending on the means of transport you wish to use, certain personal data are mandatory. If you choose not to share specific personal data, it means that you will not be able to use certain means of transport; for example, no car or e-scooter if we do not have driving license data.
Turnn takes the protection of your personal information seriously and takes appropriate measures to prevent loss, misuse, unwanted disclosure and unauthorized modification. We use your personal data only for our services and do not share it with third parties for marketing purposes, unless you have given us your explicit prior consent. We secure our systems, on which your personal data are processed, in an adequate manner. For this we use up-to-date and internationally accepted information systems and methods. Your data is stored on servers in data centers within the European Economic Area (“EEA”). For the transfer of personal data outside the EEA, for example to an international organization, Turnn will put in place appropriate safeguards. Your data is only accessible by persons authorized by virtue of their position within Turnn and its suppliers.
Innovative and open
We are constantly looking for ways to improve our services and tailor them to your personal wishes and needs. We will continue to consider how we can improve your privacy. Turnn always adheres to the applicable privacy legislation, in particular the General Data Protection Regulation (AVG), the AVG Implementation Act and the Telecommunications Act.
Pay close attention yourself
What do we use your personal data for?
We process the personal data provided by you when you use our app, website or customer service and when you enter into an agreement to use your chosen means of transport. You thereby provide us with data, or allow us to record data, about your travel preferences.
2. Principles and purposes of processing your personal data
The processing of personal data takes place on the basis of the following principles of the General Data Protection Regulation (AVG).
|1||Permission||You give us explicit permission to process your personal data|
|2||Execution of an agreement||When you use our services, your personal data may be processed and shared with third parties, such as transport companies, cab companies, providers of bicycles, e-scooters, scooters, car sharing and rental services, payment providers and other service providers to the extent necessary to execute an agreement.
We process personal data to identify you, to keep in touch with you during the agreement to use our services and to enter into, implement and enforce this agreement.
|3||Legal obligation||We do not provide data to third parties for purposes outside of our services. An exception to this is if there is a legal obligation to do so. For example, in the case of a suspicion of a serious crime, data may be requested by means of a judicial order. Another example is the provision of data for the implementation of tax legislation.|
|4||Legitimate interest of Turnn or a third party||Our legitimate interests include marketing, advertising, security, (crime) prevention, IT management, (market) research on and analysis of our products or services, business administration, legal affairs and internal management.|
Turnn processes your personal data for the purposes listed below.
The number behind each purpose corresponds to the above-mentioned basis.
|Inviting you to use our services||We always do this on behalf of a third party (usually your employer) via a personal email invitation containing a unique company code.||4|
|Create user account and enter into agreement||Before you can use the Turnn app, you enter into an agreement with Turnn in the registration process.||1 en 2|
|Entering into an invoicing relationship||For business use, billing will usually go directly through your employer. For private use, we will enter into an invoicing relationship with you. Payment is done online through a payment provider. Turnn will not store your bank or credit card information. We do store your preferred payment method.||2 and 3|
|Use of transportation services||With your personal account, you can use the Turnn app (trip planner) to reserve, pay for and use transportation services/means from third-party service providers based on preferences you have indicated.||2|
|App usage and trip/travel history||Through our app, we provide you with travel advice based on your preferences, you can contact our customer support department, and you can consult your travel history.||2|
|Detecting and correcting errors and malfunctions||We check the operation of the app for errors and malfunctions to keep the quality, reliability and user-friendliness optimal for you||2 and 4|
|Inform||To inform you about Turnn products and services and to interview you so that services can be tailored to best meet your needs||1 and 4|
|Versturen promotionele berichten||Sending promotional messages||4|
|Analysis usage||Analyze usage of Turnn app, website and functionalities to provide you with an optimal user experience||4|
|Research and analysis||We do this to discover trends and, based on them or not, develop new products and services (e.g. the MaaS learning environment *)||4|
|Sending notifications and service messages||For example, messages to inform of system maintenance or public transportation delays||2|
|Customer Support||To be able to serve you and answer your questions, complaints and suggestions you have asked or reported to us via the app, our website, chat, telephone or e-mail, it is sometimes necessary to use your personal data. To improve our service or for training purposes, phone calls may be recorded (not standard; if applicable, we will clearly communicate this in advance).||2 and 4|
External service providers
With external service providers (e.g. Amber for shared cars and GO Sharing for electric scooters) we have individually concluded a sub-processor agreement for data exchange. These external service providers are sub-processors of personal data provided by us. We have taken measures to prevent a breach of your privacy. For example, we only pass on data that is necessary for the performance of their services. We receive travel information and trip data from external service providers. This includes the location, date, supplier and price of a travel transaction. These service providers act towards you as independent processors.
* MaaS learning environment
The goal of Mobility as a Service (MaaS) is to achieve better services for the traveler on the one hand, and to get a better grip on the total system of mobility by the government, in close cooperation with the mobility market, on the other. MaaS is a developing chain integration that currently focuses on combining transport offers. Before you as a traveler see all the information in a MaaS app, a lot of data has to be shared at the back end of the system. In one system, which all parties can connect to. That is why the government, together with seven regions, has started seven MaaS pilots. Each has its own objectives, but they do have a number of overarching conditions. One of these: standardization of data exchange. Turnn is the MaaS service provider in the MaaS pilot in Eindhoven.
In order to monitor the MaaS pilots in a uniform manner, the Ministry of Infrastructure and Water Management has set up a learning environment for this purpose. In the learning environment various data sources will become available for TNO to perform analyses. The most important data source is ‘flow data’. This data provides information about passenger flows within MaaS. Turnn provides anonymized flow data and reports on aggregated anonymized customer data. In this way, we learn together how the total mobility system can be optimized for policy purposes. Such as (contributing to) solutions for CO2 targets, congestion problems, pressure on public transport and affordability of the total system.
3. Personal data for account and use of means of transport
In the overview below, we briefly explain what personal data we collect, process and share in order to create your account and allow you to use different types of transportation. We also explain how and why we use the GPS location of your smartphone and check your driver’s license if you want to use a scooter or car.
|Personal data||Website||Account/App||Trip planner||Public
|First and last name||X||X||X||X||X||X||X||X|
|(Mobile) phone number||X||X||X||X||X||X||X||X|
|Make / model mobile device||X|
|Operating system and version||X|
|GPS location smartphone (1)||X||X||X||X|
|Driving Licence Details (2)
Date valid until
|Date of birth||X||X||X|
|Date and time||X||X||X||X||X||X||X|
|Pickup and/or delivery address||X||X||X|
(e.g., home and work address)
(1) GPS location
We use the GPS location of your smartphone to indicate what information and services are available in your immediate vicinity that may be relevant to planning your trip. Examples are bus stop information, available transportation and parking spaces. In addition, the GPS location is needed to give you access to e.g. a bicycle, scooter or car. We do not store or track the GPS location. The GPS location is only known to the app on your smartphone.
(2) Driving Licence Verification
To check your driver’s license, we use the services of our service partner DataChecker, specialists in online identification and verification solutions. With this we establish your identity and check your driver’s license (and possibly identity card or passport) for validity and authenticity. This goes as follows:
- You will receive a secureID link by email which will lead you to the DataChecker secure environment.
- After activating the link on your smartphone, you will receive instructions on how to take a picture of the front and back of your driving license. We do not store the photos in our system. DataChecker automatically deletes the photos after 48 hours.
- DataChecker collects the necessary data and checks your driver’s license for validity and authenticity. We store the driving license data listed in the driving license data and DataChecker automatically deletes this data from their system after 48 hours. NB: your BSN number is not stored.
- Only if you are a non-Dutch national can you be asked to also take photos of your ID or passport as an extra possibility to verify your identity. ID or passport data will not be stored and DataChecker will delete photos and data automatically after 48 hours.
- The Turnn app is currently primarily intended for business use which requires a company code. Should private use be made possible be made possible then, for additional verification, you will be asked to take a selfie that DataChecker uses for comparison with the image on your driver’s license and, if applicable, with the image on your ID or passport.
Whitepapers and knowledge documents
Through our website you can download so-called “white papers” and knowledge documents in which we answer questions we encounter in practice. Before you can download any documents, we will ask you for a few details so that we can contact you about the document.
When you fill in the contact form on our website, we always register the completed message. You have the opportunity to leave your name, company name and contact information such as e-mail and phone number so we can help you better. We only use this information to answer your questions and not for commercial purposes.
5. How long do we keep your data?
We will keep your personal data, including the personal data we have collected in the context of our contact and agreement with you, no longer than necessary to carry out the purposes for which they were collected, but no longer than 18 months after the termination of your account, unless a statutory retention period applies to (certain) personal data. Think for example of the tax retention obligation of 7 years.
Personal data which we have collected in the context of contact which you have made with us, in the event that you do not have an account with us, will not be kept longer than necessary for the execution of the purposes for which they were collected, but for a maximum of 18 months after the termination of your account, unless a statutory retention period applies to (certain) personal data.
Personal data that we have collected in the context of website visits (cookies) will not be kept longer than necessary for the execution of the purposes for which they were collected, but no longer than 18 months after the last visit, unless a legal retention period applies to (certain) personal data.
Data, which are collected for research purposes, are kept for a longer period. However, these data are anonymized and can never be traced back to a person. There is therefore no question of personal data within the meaning of the applicable laws and regulations on the protection of privacy.
6. What are your rights?
The processing of personal data is subject to the rules laid down in the General Data Protection Regulation (AVG). Turnn handles the data of users safely and carefully. The personal data we use, are and remain of course yours. Therefore, you also have the right to access, modify, delete, limit or transfer to someone else the data that we have on you. You have the right to request the following from us:
(a) Right of access
You have the right to know what we know about you. Therefore, you have direct access to some of your personal data via the Turnn app. At Customer Support (see the contact details under “Contact”) you can ask what other data of yours is registered.
b) Right to rectification
You can also submit a request to Customer Support to correct, supplement or block your personal data if they are factually incorrect, incomplete, irrelevant to the purpose for which they were collected and/or are otherwise used in violation of a law. You can also edit a number of data yourself in the app via Account/Edit Profile. If you use the app for business purposes via your employer, we usually receive changes automatically via your employer.
c) Right to object
If you do not agree with the way we process your personal data, you have the right to object. If you object, we will weigh your privacy interests against our business interests. If your interests outweigh your interests, your data will not be processed further.
d) Right to restriction of processing
You have the right to request the restriction of the processing of your personal data, when we use incorrect personal data, we use your personal data unlawfully, we no longer need your personal data or when you object to the processing. This right means that, with the exception of storage thereof, we may only process your data, in case of your consent, to support a legal claim, to protect rights of others or weighty reasons of public interest.
e) Right to erasure (‘right to be forgotten’)
You have the right to request the deletion of your personal data in the event that your personal data is no longer required, you have withdrawn your consent, you have objected to the processing, the processing is unlawful or the legal retention period has expired. If you submit this request, we will remove all data that can be traced back to you, unless one of the exceptions applies.
f) Right to data portability
You have the right to receive your personal data or have it transferred to a third party organization. This right applies to digital personal data, which we process on the basis of your consent or for the purpose of executing a contract.
g) Right with regard to automated decision-making and profiling
You will not be subjected to fully automated decision-making when there are personal legal consequences associated with this, unless certain conditions are met.
Do you want to exercise your right?
If so, please contact Customer Support or send an email to email@example.com.
7. Changes and complaints
Changes to this Privacy Statement
Turnn reserves the right to modify this Privacy Statement. It is recommended to regularly consult the Turnn Privacy Statement. In case of a change we will inform you via a notification in the app. The amended version can also be found on our website. We will clearly indicate the effective date of the change. This Privacy Statement applies to the data that we receive/collect during the validity of this Privacy Statement. An amendment of this Privacy Statement will never invalidate your rights to this information derived from a previously valid Privacy Statement. If this turns out to be insurmountable (for example due to a change in the law), we will explicitly inform you of this.
At any time you have the right, under the privacy legislation, to submit a complaint to the privacy supervisor, the Dutch Data Protection Authority, about the way we handle your personal data. However, we prefer to resolve this with you ourselves. If you have a complaint or if there are indications of abuse, please contact us using the contact details below.
Telephone: +31 (0)85 018 6590
Correspondence: Turnn B.V.
Attn: Customer Support – Privacy
P.O. Box 7095
3430 JB Nieuwegein, The Netherlands