4.3.1 Managing the analysis tools using Google Tag Manager
The advantage of the tag manager is that we can use it not only to manage Google services, but also to centrally manage other analytics services. In this way, we can better identify which tracking technology provides us with the information we need and avoid unnecessary data collection. The tag manager itself does not process any data, but helps us organise the data from Google Analytics, Facebook or Instagram.
We use the tag manager to make our website as useful, comfortable and usable as possible for you and other visitors. For this purpose, we need the analysis data. We use the tag manager on the basis of Art. 6 para. 1 lit. f GDPR, which allows processing on the basis of a balance of interests. We have a legitimate interest in seeing which content appeals to our prospective customers. This allows us to realign our marketing to attract more people to our offers. Please read section 6.2.5 for more information about this provider.
4.3.2 Cookies and other tools for the purpose of range measurement and statistics
4.3.3 Google Analytics and G4
The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics and G4 use so-called "cookies" and similar technologies. Cookies are text files that are stored on your computer and enable an analysis of your use of the website (target group reports, conversion reports, interaction and behaviour reports, real-time reports, etc.). The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. When using Google Analytics, your IP address is usually shortened to make subsequent identification more difficult.
Google Analytics and G4 cookies are stored on the basis of Art. 6 para. 1 lit. a GDPR, in accordance with the corresponding consent of the user.
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set, which will prevent the collection of your data during future visits to this website: Deactivate Google Analytics.
Our goal in using Google Analytics and G4 is to further optimise our service and offer more to potential users. The Google Analytics statistics help us to better understand our customers and support us in achieving this goal.
Google Analytics sets the following cookies:
Name: _ga (Google Analytics js) Purpose: Google uses this cookie to store the user ID and distinguish users. Expiry date: after 12 month
Name:_gid Purpose: Expiry date: after 24 hours
Name: gatgtag_UA_<property-id> Intended use: If Google Analytics is provided via the Google Tag Manager, this cookie is given this name. Expiry date: after 1 minute
Storage period: We have limited the storage period to 14 months in order to comply with the principle of storage limitation from Art. 5 GDPR. This retention period applies to data linked to cookies, user recognition and advertising IDs. Results of reports are based on aggregated data and are stored independently of user data.
In order to statistically evaluate visitor data, we use the analysis tool Hotjar on our website. This is offered by:
Hotjar Limited Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta.
Hotjar is a service that evaluates visitor behaviour and feedback through combined analytics and feedback tools. We receive heatmaps, conversion funnels, visitor recordings, incoming feedback, feedback polls and surveys.
We use these evaluations to optimise the usability and user experience of the site and to additionally collect customer opinions via the feedback channel. We receive reports and visual representations from Hotjar that show us where and how users "move" on our site. The personal data is automatically anonymised. Neither can we assign the interactions to a user nor is the data transmitted to Hotjar.
Hotjar automatically collects usage data. For this purpose, a tracking code of the website is linked to a cookie.
The following data is collected and stored:
Time of the visit
Screen size and resolution.
Approximate location (IP location)
Date and time of access to one of our sub-pages (web pages)
IP address (anonymised)
Purpose: The cookie is used to maintain a Hotjar user ID that is unique to the website in the browser. This allows user behaviour to be associated with the same user ID on subsequent visits. Expiry date: after one year.
You can find the list of cookies used or potentially used here:
4.3.5 Facebook tracking Pixel
This website uses the visitor action pixel from Facebook for conversion measurement. The provider of this service is Facebook Ireland Limited (4 Grand Canal Square, Dublin 2, Ireland; "Facebook"). Via this Pixel, the behavior of website visitors can be tracked after they have been redirected to the operator's website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimized.
The collected data is anonymous for us as the operator of this website. We cannot draw any conclusions about the identity of the users. However, the personal data is processed by Facebook. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.
Specifically, the following data is processed by Facebook and us:
Facebook user ID
Device information (device ID, device operating system).
Usage/click behavior, including content viewed and items clicked on
Facebook cookie information
Marketing information, including ads viewed and interactions with ads, services, and products
The use of the Facebook Tracking Pixel takes place exclusively with and on the basis of your prior consent, Art. 6 para. 1 lit. a GDPR. Your consent can be revoked at any time via the "Your cookie settings" function provided on our website, effective from this point forward. The legality of processing based on your consent prior to the revocation remains unaffected.
As long as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Facebook Ireland Limited, (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the forwarding is not part of the joint responsibility and is the sole responsibility of Facebook. Our joint obligations have been set forth in a Joint Processing Agreement. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for implementing the tool on our website in a privacy-secure manner. Facebook is responsible for the data security of the Facebook products. You can assert data subject rights (e.g. requests for information) regarding the data processed by Facebook directly with Facebook. If you assert the data subject rights against us, we are obliged to forward your request to Facebook.
According to Facebook, the collected data is also transferred to the US and other third countries, and processed there. Facebook bases the data transfer to the US on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum.
Please note: Despite the fact that Facebook Ireland Ltd. is based in Ireland, your personal data, including the IP address of the internet connection you are using, may be transferred to Facebook servers in the United States or other third countries if you consent to our performance cookies. The United States of America is currently classified as an unsafe third country, i.e. as a third country where neither an adequacy decision pursuant to Article 45 of the GDPR exists, nor a comparable level of protection can be assumed. The same applies to other third countries. With the transmission of your data, both Facebook and, if applicable, US or other third country authorities have access to the transmitted data. Facebook may combine your data with other data, such as your personal accounts, usage data from other devices, and any other data Facebook holds about you, and may also share your personal data with third parties. In addition, US or other third country authorities may access and process your data without notice or notification to you (during and after the processing is completed) or without providing you with similar remedies and data subject rights. Unfortunately, we have no influence on the processing by Facebook and US or other third country authorities in these cases.
If you wish, you can deactivate the "Custom Audiences" remarketing feature in the ad settings section at : https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen if you are registered with Facebook. If you do not have a Facebook account, you can also deactivate Facebook's usage-based advertising on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.
4.3.6 Newsletter dispatch
We send out mandatory information about the MILES Mobility Belgium BV offer via our newsletter. Furthermore, users of the app can subscribe to a newsletter and receive information about additional offers and promotions. To do this, we require your email address and consent to receive the newsletter, which we obtain via a so-called double opt-in procedure. Further data will not be collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties, apart from the respective newsletter senders.
In principle, the data is processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR). In some of the cases mentioned below, which are directly related to the sending of newsletters, the processing is based on our legitimate interests (Art. 6 para. 1 lit. f GDPR).
You receive all newsletters of an advertising nature on the basis of your consent to the storage and use of the data; you can revoke this consent at any time. You can unsubscribe at any time by clicking on the "unsubscribe" link in the newsletter. The legality of the data processing already carried out remains unaffected by the revocation.
We consider it imperative that this information reaches our customers, so you cannot automatically unsubscribe here. Your right to object according to Art. 21 GDPR remains unaffected, but in this case it is your duty to actively inform yourself.
We use the services of Braze Inc. and PostMark to send the newsletters.
Braze Inc 330 West 34th Street, 18th Floor New York, NY 10001 USA.
We have concluded a so-called "Data Processing Agreement" with Braze Inc. in which we oblige the service provider to protect our customers' data and not to pass it on to third parties.
We use a method to analyse the reach of our newsletter. When you open one of our emails, a file contained in the email connects to the servers of Braze Inc. in the USA. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). However, this information cannot be assigned to the respective newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients. If you do not want any analysis, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.
After unsubscribing from the newsletter distribution list, the email address is stored by us or the newsletter service provider in a blacklist, if necessary, in order to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR). The storage in the blacklist is not limited in time. You can object to the storage if your interest outweighs our legitimate interest. However, you may then be contacted by us again.
6.4.7 AdaChat - contacting and requesting via chat
Our website also embeds AdaChat, an AI-based communication and conversation service provided by Ada Support Inc. (371 Front Street W, Suite 314, Toronto, Ontario, M5V 3S8, Canada), to provide you with high-quality chatbot-based customer support and to respond to your inquiries efficiently, quickly, and with and resource-efficient way.
If you contact us via our chat, we process your information for the processing of your request and in case follow-up questions arise. The data processed in this context includes the information you provide when contacting us or in the course of follow-up communication. Note: In order to comply with the data minimization principle in the best possible way, we kindly ask you, to limit your information to what is necessary, as far as possible.
AdaChat also uses so-called "cookies". These are text files that are stored in your internet browser or by your internet browser on your terminal device as a result of your consent. By setting the cookies, we are enabled to collect and process the data listed below and to analyze the content and use of the chat. The collection and processing of this data is done for the purpose of providing, security and functionality of the chat, for the analysis of your data, for the purpose of answering your requests and for the purpose of further development of the service itself. You can find more information about cookies here: https://www.ada.cx/cookies. The following personal data is collected and processed by us by means of these cookies:
Time and date of chat request and use
Browser information (type, version, language setting)
Operating system information (type, version)
Device information (device identification number, type, hardware and software properties)
Location information (country)
The legal basis for the use of the tool and the data processing carried out on our behalf is your prior, voluntary and informed consent in accordance with § 25 TTDSG (German Telecommunications-Telemedia Data Protection Act) and art. 6 para. 1 lit. a GDPR, which we request via our cookie banner. Once you have given your consent, you can revoke it at any time with future effect using the "Your cookie settings" function on our website or by sending an email to email@example.com. Processing that has already taken place up to the time of the revocation remains unaffected by this. The chatbots used by us can "remember" a chatter from one conversation to the next ("chatter persistence"), provided that the conversations are not longer than 7 days apart. Within the scope and for the purpose of this reminder function, the chatter, the associated data and the chat history are recorded and stored by a bot. After the 7-day period selected by us has expired, the bot then automatically forgets the stored data.
Please note: Regardless of this automatic deletion after a certain period of time, your data may also be stored and processed by us, if and to the extent that this is required and permissible or we are subject to a legal obligation that requires further processing of your data. In order to ensure the data protection compliant processing and protection of your data in the context of the use of the tool, we have concluded an order processing agreement with Ada Support Inc. in the sense of art. 28 GDPR, which states in particular that your data may only be processed for the purpose of providing the service. The data transfer to Canada is covered by an adequacy decision of the European Commission, which certifies that Canada provides an adequate level of protection with regard to your data and data subjects' rights (art. 45 GDPR).