Privacy Policy for the streamways App and Website
1. General Information
We provide you with the streamways app for driving students, which you can download to your device. We also process personal data when you visit our website at www.streamways.com.
Below, we inform you about the processing of your personal data when using our app and visiting our website. Personal data means any information that relates to you as an individual and by which you can be identified, e.g., name, address, or email address.
The controller pursuant to Art. 4 No. 7 of the EU General Data Protection Regulation (GDPR) is:
streamways GmbH
Marie-Curie-Ring 16
24941 Flensburg
Germany
Represented by the managing directors Christian Karstoft and Magnus Werner
Email: info@streamways.com
Website: streamways.com
You can contact our data protection officer via email at: datenschutz@streamways.com
2. Processing of Personal Data When Visiting Our Website
Our website is hosted by Squarespace. Squarespace collects personal data when you visit our website.
This includes:
* Information about your browser, network, and device
* Web pages visited before arriving at our site
* Subpages visited on our site
* Your IP address
Squarespace requires this data to operate, protect, and improve our website. Squarespace analyzes this data in anonymized form.
The legal basis for this data processing is Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest arises from the purposes listed above. Under no circumstances do we use the collected data to draw conclusions about you personally.
3. Processing of Personal Data When Contacting Us
When you contact us, we store the data you provide (e.g., your email address, address, name, and other contact information) in order to respond to your inquiry and for any required follow-up communication. We delete the data once your inquiry has been fully processed. If statutory retention obligations apply, the data will remain stored but will be restricted in processing and kept separate until they are no longer required.
The legal basis for this processing depends on the nature of the contact and is either Art. 6 (1) lit. b GDPR (contract performance) or Art. 6 (1) lit. f GDPR (legitimate interest). If a legal retention obligation exists, Art. 6 (1) lit. c GDPR is the legal basis.
4. Processing of Personal Data When Using Our App
When downloading the app, the necessary information is transferred to the app store, in particular your username, email address, customer number of your app store account, time of download, payment information (if applicable), and your device identifier. The app store may also independently collect various data and provide analysis. We have no control over and are not responsible for this data processing. We only process this data insofar as necessary for downloading the app to your device.
We process various personal data by signing up to streamways through the customer checkout or manual customer sign up by the driving school:
Master Data:
* First name
* Last name
* Date of birth
* Mobile phone number
* Nationality
* Language
* National ID
* Notes (optional)
* Address
Training Data:
* Registration date
* License class
* Associated pricing list
* Assigned instructor
* Location
* Purchased Package
* Education contract
* Education certificates
License Data (if license already exists):
* License class
* Issuing date
Financial Data:
* Billing address (if different)
* Payer (e.g., company, VAT)
* Digital Payment handled by Payment Provider Mollie
The legal basis for processing your personal data in relation to the initiation, execution, and termination of your user relationship with us is Art. 6 (1) sentence 1 lit. b GDPR. If you provide personal data as defined in Art. 9 GDPR (e.g., health data or biometric data), the legal basis is your consent under Art. 6 (1) sentence 1 lit. a GDPR, which can be withdrawn at any time for the future.
If you register using Google, Facebook, or Instagram login, we receive your data directly from the social network. Please note that the respective provider will also become aware of your registration. If you do not want this, please use the standard registration option.
We delete your personal data as soon as your user relationship ends, unless legal retention obligations prevent immediate deletion.
5. Disclosure of Data to Third Parties
Your personal data will not be shared with third parties except for the purposes outlined below.
We only disclose your data if:
* You have given explicit consent under Art. 6 (1) sentence 1 lit. a GDPR,
* It is legally permitted and required for the performance of a contract under Art. 6 (1) sentence 1 lit. b GDPR,
* A legal obligation exists under Art. 6 (1) sentence 1 lit. c GDPR.
If this is part of the services commissioned by you, we may share your data with your driving school.
We also use external service providers to support our services. Where they process data on our behalf, we have data processing agreements in accordance with Art. 28 GDPR.
Current service providers that may process your data:
5.1. AWS – Simple Storage Service (Amazon S3)
Used for storage and backup by Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg.
More information: [Amazon S3](https://aws.amazon.com/s3/)
5.2. Google
We use Google Forms, Google Drive, and Google Firebase provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. Google is certified under the EU-US Data Privacy Framework.
Privacy policy: [Google Privacy Policy](https://policies.google.com/privacy)
5.3. Freshworks
Used to manage support requests: Freshworks Inc., 2950 S. Delaware Street, Suite 201, San Mateo, CA 94403, USA. Certified under the EU-US Data Privacy Framework.
More info: [Freshworks GDPR](https://www.freshworks.com/gdpr/)
5.4. Atlassian
Used for ticketing and documentation: Atlassian Pty Ltd, Level 6, 341 George Street, Sydney, NSW 2000, Australia. Uses EU Standard Contractual Clauses.
More info: [Atlassian Data Processing Addendum](https://www.atlassian.com/legal/data-processing-addendum)
5.5. Slack
Used internally: Slack Technologies Ltd., Salesforce Tower, Dublin. Parent company Salesforce is certified under the EU-US Data Privacy Framework.
More info: [Slack Privacy Policy](https://slack.com/legal/privacy-policy)
5.6. Mollie
Used for payment services: Mollie B.V., Keizersgracht 126, 1015CW Amsterdam, Netherlands.
More info: [Mollie Privacy](https://www.mollie.com/en/privacy)
6. Cookies
6.1. General
We use cookies and similar technologies on our website. These are small files or texts downloaded to a device when a visitor accesses a website or app.
a) Technically Necessary Cookies
These are required for our site to function correctly. They enable basic features like navigation and access to secure areas. No user profiles are created from these cookies. Stored data includes language preferences, page settings, and session states.
These cookies are always enabled, as they are essential for Squarespace to operate the website securely. See more at https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses#toc-functional-and-required-cookies
b) Non-Essential Cookies
With your consent, we use non-essential cookies via Squarespace Analytics and Google Analytics. These cookies collect usage information, optimize the site, and help present interest-based content.
They are only used after you have given consent.
6.2. Legal Basis
* Technically necessary cookies: Art. 6 (1) sentence 1 lit. f GDPR
* Non-essential cookies: Your consent under Art. 6 (1) sentence 1 lit. a GDPR, which can be withdrawn anytime
6.3. Google Cookies
Use of Google cookies is based on your consent under Art. 6 (1) sentence 1 lit. a and Art. 49 (1) sentence 1 lit. a GDPR.
Provider: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland
Terms: [Google Terms](https://marketingplatform.google.com/about/analytics/terms/us/)
Privacy: [Google Privacy Policy](https://policies.google.com/privacy)
By consenting, you also agree to the potential transfer of your data to the USA, as per Art. 49 GDPR. Google is certified under the Data Privacy Framework.
6.4. Google Analytics
We use Google Analytics with your consent for website analysis and improvement. Google shortens your IP address within the EU; only in rare cases is it sent to the USA.
You may withdraw your consent at any time. You can also install the browser plugin to prevent tracking: [GA Opt-Out](http://tools.google.com/dlpage/gaoptout?hl=de)
6.5. Squarespace Analytics Cookies
Used only with your consent to analyze website traffic and user behavior. See more at https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses?platform=v6&websiteId=65365a43e6fb0c67c80690aa
6.6. Squarespace Analytics
Collected data:
* Browser, network, and device info
* Referral websites
* IP address
* User activity: clicks, scrolls, pages viewed, search terms, timestamps
This data is shared with Squarespace for analytics purposes.
7. Social Media Links
We maintain profiles on various social media platforms. We are generally not the data controller for processing on those platforms. For more details, see the privacy policies of the respective providers.
For Facebook pages, shared responsibility applies per the joint controller agreement with Meta.
8. Your Rights Under the GDPR
Under Chapter III of the GDPR, you have the following rights regarding your personal data:
8.1. Right of Access (Art. 15)
You can request information about your personal data and obtain a copy.
8.2. Right to Rectification and Erasure (Art. 16 & 17)
You may request correction of inaccurate data or deletion of your data if processing is no longer necessary.
8.3. Right to Restriction of Processing (Art. 18)
You may request restriction of processing under the conditions of Art. 18.
8.4. Right to Object (Art. 21)
If processing is based on Art. 6 (1) sentence 1 lit. e or f, you can object to the processing.
8.5. Right to Data Portability (Art. 20)
You may receive your data in a machine-readable format and have it transmitted to another controller.
To exercise these rights, contact our data protection officer at datenschutz@streamways.com. Exercising your rights is generally free of charge.
You also have the right to lodge a complaint with a data protection supervisory authority.
9. Changes to This Privacy Policy
We are constantly developing and improving our services. As a result, we may add new features that affect how we process your personal data. In such cases, we will update this Privacy Policy accordingly.
This Privacy Policy is current as of February 2025.