Privacy Policy for the Customer Account

Privacy Policy for the Customer Account and the Use of Mobility Services

This privacy policy provides comprehensive information on the processing of your personal data in connection with the creation and use of a customer account with barely digital GmbH & Co. KG, as well as the utilisation of mobility services. It applies solely in this context and is independent of the use of our website. A separate privacy policy applies to our online presence.

1. Controller under the GDPR

The data controller responsible for the processing of your personal data in accordance with Article 4(7) of the General Data Protection Regulation (GDPR) is:

barely digital GmbH & Co. KG
Konrad-Adenauer-Str. 8
86836 Klosterlechfeld
Germany

Phone: +49(0)8232 / 76 899 76 – 40
Email: service@vintrica.com
Managing Directors: Tobias Hübner, Jan Kofoet

2. Scope of this Privacy Policy

This privacy policy applies to all data processing activities related to the creation, management, and use of a customer account. The customer account enables the handling of a range of mobility services via our platform, including but not limited to:

  • Purchase and use of digital toll products (e.g. vignettes, post-paid options),
  • Use and payment for parking services (e.g. on-street or in car parks),
  • Use of ferry services,
  • Fuel payments,
  • Use of food services, such as drive-through options,
  • Purchase of mobility-related insurance.

We may expand this offering over time. You will be informed appropriately about new services and any related changes in the handling of your personal data.

3. Categories of Personal Data Processed

In connection with your customer account, we process the following categories of personal data:

Mandatory data for registration and use:

  • Email address

Optional data (voluntary):

  • Vehicle registration number
  • Country of vehicle registration
  • Vehicle model, type, VIN
  • Billing address (e.g. for generating tax-compliant receipts)
  • Payment method (e.g. SEPA, credit card, PayPal)

The provision of optional information is voluntary and not necessary to maintain a customer account. However, if such data is provided, it will be processed based on your consent or within the framework of the existing user relationship.

4. Purposes and Legal Bases of Processing

4.1 Contractual Obligations (Art. 6(1)(b) GDPR)

Your personal data is processed primarily to establish, carry out, and manage the contractual relationship with you. This includes in particular:

  • Setting up and managing your customer account,
  • Authenticating you when using services,
  • Collecting and forwarding information to mobility service providers,
  • Invoicing and payment handling,
  • Communicating with you in relation to the use of our services.

4.2 Legitimate Interests (Art. 6(1)(f) GDPR)

We also process your data where necessary to protect our legitimate interests, such as:

  • Continuous development and improvement of our mobility services,
  • Ensuring technical functionality and service security,
  • Detecting and preventing misuse or fraud,
  • Internal statistical and operational analyses.

4.3 Consent (Art. 6(1)(a) GDPR)

If you provide certain optional information or activate specific features (e.g. preferred payment methods or add-on options), your data will be processed based on your consent. This can be withdrawn at any time with future effect.

4.4 Legal Obligations (Art. 6(1)(c) GDPR)

In some cases, we are legally obliged to process personal data, particularly to comply with tax and commercial retention requirements or official reporting duties.

4.5 Processing on Behalf of Mobility Service Providers (Including for Debt Collection)

If you have created a customer account, we may also process personal data on behalf of mobility service providers in order to manage the use of their services via our platform or in connection with a vehicle registered with us.

This may apply to providers of:

  • Toll systems (e.g. for motorways, bridges, tunnels),
  • Parking services,
  • Ferry transport,
  • Fuel stations,
  • Drive-through restaurants,
  • Mobility insurance or similar services.

If instructed by a mobility service provider, we may process your data to identify and contact you, e.g. as part of debt recovery where no valid payment has been made for a recorded transaction.

We only use the following stored data:

  • Vehicle registration number,
  • Email address,
  • If available: name and billing address,
  • If available: payment method.

We will only make contact if there is a specific service incident, such as a detected transaction involving a registered vehicle without proper payment.

Legal Basis: The processing is based on Article 6(1)(f) GDPR (legitimate interest).

Balancing of Interests: Processing is limited to clearly defined, legitimate purposes and only uses data voluntarily provided within your customer account. Identification via the vehicle registration number is used when no other allocation is possible. Your rights and freedoms are protected through limited use, purpose restriction, and the right to object.

5. Data Sharing with Third Parties

We only share your personal data when necessary to fulfil contractual obligations or when you have given your explicit consent. Recipients may include:

  • Providers of toll, parking, ferry, fuel, and food services,
  • Payment service providers (e.g. banks, online payment platforms),
  • Mobility insurance providers,
  • IT and hosting service providers under data processing agreements,
  • Public authorities if required by law.

Data transfers to third countries outside the EU/EEA only occur where necessary for service provision or if appropriate safeguards (e.g. adequacy decision or Standard Contractual Clauses) are in place.

6. Data Retention Period

Your personal data is stored only as long as required for the purposes stated above, particularly for the duration of your customer account and for the fulfilment of individual services. Data will be regularly deleted when these purposes cease, unless:

  • Legal retention obligations prevent deletion,
  • Data is needed for legal claims or defence.

7. User Control and Customisation

You may activate or deactivate specific mobility services at any time within your customer account settings. Services not required do not need to be used. Deactivation is managed by you through the account’s online settings. Full account deletion is also possible at any time.

8. Your Rights as a Data Subject

You have the following rights under the GDPR:

  • Right of access (Art. 15)
  • Right to rectification (Art. 16)
  • Right to erasure (Art. 17 – “right to be forgotten”)
  • Right to restriction of processing (Art. 18)
  • Right to data portability (Art. 20)
  • Right to object (Art. 21), especially to processing based on Art. 6(1)(f)

If processing is based on your consent, you may withdraw it at any time with future effect (Art. 7(3) GDPR).

To exercise your rights, contact:

Email: service@vintrica.com
Post:
barely digital GmbH & Co. KG
Konrad-Adenauer-Str. 8
86836 Klosterlechfeld
Germany

You also have the right to lodge a complaint with the relevant data protection authority:

Bavarian Data Protection Authority (BayLDA)
Promenade 18, 91522 Ansbach
Phone: +49 (0)981 53 1300
Email: poststelle@lda.bayern.de

9. Automated Decision-Making / Profiling

We do not use automated decision-making as defined in Article 22 GDPR. No profiling is conducted for evaluating personal aspects.

10. Validity and Amendments

This privacy policy is valid as of 18 September 2023.
We reserve the right to update it due to changes in law, data processing, or service scope. The current version is always accessible in your customer account.