Privacy Policy

1. Controller

The controller is IMVESTY SARL, 23 Route du Pas de l'Ours, 3963 Crans-Montana, Switzerland, UID CHE-314.139.930, publisher of the PASS ROADS application and of the website passroads.com. Contact: contact@imvesty.com.

This policy applies to the PASS ROADS application for iPhone and CarPlay and to the website passroads.com. It is established in accordance with the Swiss Federal Act on Data Protection (FADP) and, to the extent applicable, Regulation (EU) 2016/679 (GDPR).

2. Data stored on the device

Where no account is used, the following data is stored solely in the application's private storage area on the user's device and is transmitted to no one: nickname and email address entered in the application, favourites, completed passes, road books, breaks and saved drives, GPS tracks, favourite addresses, garage cars and their photos, preferences. Where an account is used, part of this data is additionally synchronised under the conditions set out in article 3.

Photos chosen by the user are resized and re-encoded without their location metadata. Drive Cards are generated on the device; they are saved to Photos or shared only at the user's request.

This data is kept until deleted by the user (Profile, Settings, Reset local data; deleting a drive in My drives) or until the application is uninstalled.

3. PASS ROADS account and synchronisation

Creating an account is optional. It is required to use Convoy and Community, to load, save or share a road trip and to access the garage. The remainder of the application, in particular the road catalogue, the filters, the current road book, address search and drive recording, remains accessible without an account.

The account is created using an email address and a password, or through the “Sign in with Apple” service. In the latter case, Apple may transmit a private relay address instead of the actual address. The following are processed: the email address, the first name and the nickname chosen by the user, the last name where it is provided — it is optional —, a cryptographic hash of the password but not the password itself, a technical account identifier and the dates of creation and last sign-in. The first name, the last name and the nickname can be changed at any time under Profile, Settings, Name and nickname.

Where an account is active, the following data is synchronised between the device and the server: favourites, completed passes, road books, breaks, saved drives, favourite addresses, garage and selected car, starting point and route preferences. The purpose of this synchronisation is to restore those items on the user's other devices and after a reinstallation. It is based on the performance of the user agreement.

This data is hosted by Supabase, Inc. on infrastructure located in Frankfurt am Main, Germany, that is to say within the European Union. It is retained until the account is deleted.

The nickname and, where the user enables it, the selected car are visible to the other members of a convoy and of the community. The email address is never displayed to other users.

When the user posts a road trip, the following become viewable by anyone using the application, including without an account: nickname, car if the user chooses to show it, title, notes, passes, breaks and days, distance, duration, number of corners and, for a recorded drive, the GPS track with its first and last kilometre automatically removed. The starting point of a planned road trip is not published. The number of times a road trip has been driven again and its average rating are displayed without indicating who gave them. A posted road trip is retained until deleted by its author or until the account is deleted; it is hidden after three separate reports, pending review.

The user may delete the account at any time within the application, under Profile, Settings, Delete my account. Deletion erases the account and all related data on the server, with no retention period. Data stored on the device is not affected by this operation; it is erased through Profile, Settings, Reset local data, or by uninstalling the application.

4. Newsletter

Subscribing to the newsletter is optional and based on the data subject's consent, given by ticking a box that is unticked by default, in the application or on passroads.com. The following are recorded: the email address, the language, where the subscription came from, its date and the exact text of the consent.

This data is used solely to send information about PASS ROADS and its events. It is hosted by Supabase, Inc. in Frankfurt am Main, Germany; emails are sent by Resend, Inc. from its European region (Ireland). No open or click tracking is performed.

Consent may be withdrawn at any time through the unsubscribe link in every email or in the application, under Profile, Settings, Newsletter. The address is then kept as unsubscribed, to ensure that no further email is sent to it, and deleted at the data subject's request.

5. Location data

The device's location is processed, with the permission granted in iOS, to centre the map, sort roads by distance, estimate journeys, search for nearby places, record the track of a drive and take part in a convoy.

While a drive is being recorded and while location is shared in a convoy, location may continue in the background; the iOS location indicator is then displayed. The track of a drive remains on the device.

Location is transmitted to a third party only in the cases set out in sections 4 and 5.

6. Convoy

When the user joins a convoy and accepts location sharing, the application sends to IMVESTY SARL's server every four seconds: a random device identifier, the first name, the make and model of today's car if the user has chosen to show them, the GPS coordinates and the sharing status. This data is made available to the other devices that know the convoy code.

Convoy data is kept in memory only and deleted no later than two minutes after the last update. No history is kept and no data is written to disk. The user may stop sharing at any time (Invisible) or leave the convoy.

The application does not measure, record or transmit the user's speed. Convoy members see successive positions while sharing is active.

Legal basis: the user's consent.

7. Place search and Google information

The search for restaurants, cafés, hotels, fuel stations and car washes, and the display of ratings, opening hours and photos, rely on the Google Places service. Requests go through IMVESTY SARL's server, which sends Google the name and coordinates of the place viewed or, for a category search, the coordinates of the search point rounded to approximately one kilometre, the radius and the language.

Google's responses are not stored by the server, except for the place identifiers provided by Google. To prevent abuse, the device's IP address may be kept in memory for no more than one hour. Photos are loaded directly from Google's servers, which receive the device's IP address in doing so.

Name search, maps, directions and Look Around are provided by Apple (MapKit) and are subject to Apple's privacy policy.

Legal basis: performance of the service requested by the user; legitimate interest in preventing abuse.

8. Links to third-party services

Opening a route in Google Maps or Waze, a hotel booking or restaurant reservation link, or sharing via WhatsApp or the iOS share sheet takes place only at the user's request. The necessary data (in particular destination coordinates) is then transmitted to the service concerned, which processes it under its own responsibility.

The hotel booking button opens a Stay22 affiliate link leading to Booking.com, Expedia, Hotels.com or a similar platform. If a booking is made, IMVESTY SARL receives a commission. The application does not transmit the user's name or location; booking data is collected by the chosen platform.

Convoy and road book sharing links open the page passroads.com/ouvrir.html. The information in the link follows the "#" sign and is not transmitted to the website's hosting server.

9. Lock screen and CarPlay

The banners on the lock screen, in the Dynamic Island and on the CarPlay Dashboard, as well as the CarPlay application, display information computed on the device. They do not involve any additional transmission of data.

10. Recipients and processors

Data transmitted in the cases described above may be processed by the following providers: Fly.io, Inc. (server hosting, Paris data centre, France); Supabase, Inc. (hosting of accounts and synchronised data, Frankfurt am Main data centre, Germany); Apple Inc. (“Sign in with Apple” service); Resend, Inc. (sending account and newsletter emails, European region, Ireland); Google LLC (Google Places); Apple Inc. (mapping services); Netlify, Inc. (hosting of passroads.com); Stay22 (affiliate links, only when the link is opened); Apple Inc. (payment of the PASS ROADS Premium subscription, see below).

The PASS ROADS Premium subscription is purchased and paid for through Apple (In-App Purchase). Apple processes payment and billing data under its own responsibility, in accordance with its own privacy policy. IMVESTY SARL receives no card or payment data, only aggregated sales reports provided by Apple. The subscription status is checked on the device with Apple (StoreKit); no purchase data is stored on the PASS ROADS servers (Supabase).

Some of these providers are established outside Switzerland and the European Economic Area, in particular in the United States. Transfers take place on the basis of an adequacy decision or of the safeguards provided by applicable law, in particular standard contractual clauses.

IMVESTY SARL does not sell or rent any personal data and does not carry out profiling or automated individual decision-making.

11. Advertising and analytics

The application contains no advertising, no analytics tools and no advertising SDK, and does not access the device's advertising identifier.

12. Security

Communications with IMVESTY SARL's server are encrypted (HTTPS). Access keys to third-party services are kept on the server and are not included in the application.

13. Rights of data subjects

Subject to the legal conditions, the user has the right of access, rectification, erasure, restriction, objection and portability, and the right to withdraw consent at any time. Data stored on the device can be viewed, changed and deleted directly in the application.

The account and the synchronised data may be erased directly within the application (Profile, Settings, Delete my account). A copy of the synchronised data may be requested at the address below.

Requests may be sent to contact@imvesty.com. A response is provided within thirty days. The user may also lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or with the supervisory authority of their country of residence.

14. Minors

The application is intended for holders of a driving licence. It is not directed at children under 16.

15. Changes

This policy may be amended. The version in force is published in the application and on passroads.com, with its date. Any substantial change to processing based on consent will give rise to a new request for consent.