MVV GmbH attaches great importance to the protection of personal data when using the Amazon Alexa skill “MVV Timetable Information”. This page explains what data is processed and for what purpose. Please use the contact details provided if you have any queries.
Principles of data processing
The MVV skill can generally be used without entering any personal data. For technical reasons, there is only a brief temporary storage of data as part of IP-based communication.
If certain additional functions are used, the collection, processing or storage of personal data may be necessary. The following sections describe where and how such data is processed.
Purpose and scope of the data processed
The MVV Skill only processes data that is deliberately provided by the user, for example:
- Start and destination stops
- Route numbers
- Settings for route search
- Date and time (optional)
Further optional details:
- Saving a personal location as the start or destination point
- Access to the location saved in the Alexa app, provided the relevant permission has been granted
The saved location can be deleted at any time (command: “Location”, then “Delete”).
Saved journey settings such as “I need a wheelchair” can also be removed at any time (command: “Delete my settings”).
Data is stored anonymously and is based on the pseudonymised Amazon user ID.
No further personal data is stored.
All information required for enquiries must be re-entered each time the service is used.
For technical operations, calculations relating to timetable information (connections, departures, etc.) are logged on MVV’s servers. These logs:
- serve exclusively technical and security-related purposes,
- do not contain any personal data,
- do not allow any conclusions to be drawn about usage patterns or individuals.
All data transfers to MVV servers are encrypted (HTTPS).
Note on Amazon processing
The MVV Skill is provided via the Amazon platform (Alexa/Echo) and uses Amazon Web Services (AWS).
MVV has no influence over how Amazon processes data or what information is stored (e.g. conversation recordings).
Amazon promises EU-compliant data protection; however, the Consumer Advice Centre points out that:
- Amazon holds extensive rights over collected data,
- its use may pose a data protection risk,
- Alexa’s eavesdropping may also affect third parties.
Important Amazon guidelines:
- Alexa Terms of Use
- Amazon Privacy Policy
- Information on EU data protection at AWS
You can view and delete saved voice interactions in the Alexa app.
Legal basis for processing
Data processing is carried out in accordance with:
- Art. 6(1)(f) GDPR – legitimate interest of MVV GmbH, transport operators and public transport authorities in facilitating the use of public transport
- Art. 6(1)(a) GDPR – where consent is required (e.g. location sharing)
Consent given may be withdrawn at any time.
The withdrawal applies to future processing and does not affect the lawfulness of past processing.
Users’ rights (GDPR)
You have the right to:
- Access (Art. 15)
- Rectification (Art. 16)
- Erasure (Art. 17)
- Restriction of processing (Art. 18)
- Objection (Art. 21)
- Data portability (Art. 20)
Right to lodge a complaint
In accordance with Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority.
The competent authority for MVV GmbH is:
The Bavarian State Commissioner for Data Protection
PO Box 22 12 19
80502 Munich
www.datenschutz-bayern.de
Data controller and data protection officer
Data controller within the meaning of the GDPR
MVV GmbH – Management
Thierschstraße 2
80538 Munich
Email: info@mvv-muenchen.de
Data Protection Officer (external)
DSBOK – Data Protection Officer for MVV GmbH
Untergasse 2
65474 Bischofsheim
Email: datenschutz@mvv-muenchen.de