Privacy Policy

1. Controller and contact details

Controller for all processing activities described in this Policy:

We regularly review whether we are legally required to appoint a data protection officer under Articles 37 et seq. GDPR. If we appoint a data protection officer, we will update this Policy with the relevant contact details.

2. Scope and definitions

This Policy applies to:

• our mobile application "Dashcam" and any related in-app features and services
• our website at dashcam.berlin and any web based features, including support and information pages.

For the purposes of this Policy:

3. Categories of personal data we process

3.1 Data you provide directly

We process personal data that you provide when you use the Service, in particular:

• Account and profile data, for example name, username, profile photo and any other profile details you choose to add. Depending on the sign-in method you choose, either your phone number or your email address serves as the primary and mandatory identifier for your Account. Phone numbers are used exclusively for authentication via one-time SMS code. Where you sign in using Sign in with Apple, we receive an email address from Apple, which may be a private relay address if you choose to hide your real address. No password is stored.
• Content you create and share, for example Clips, captions, comments and other information associated with your posts.
• Group data, for example the Groups you create or join, their names, and their membership over time.
• Communication data, for example messages you send to us by email or via support channels and any information you provide when you participate in surveys or feedback rounds.

3.2 Media data

When you choose to create or upload content in the Application we process:

• photos, videos and audio that you record or select within the Application, in particular Clips
• associated technical information, such as time of creation and device metadata, to display and organise your content.

Access to camera and microphone is requested through the operating system permission dialogue. Media data is only captured if you grant the respective permission and actively use a feature that requires it. You can withdraw these permissions at any time in your device settings.

3.3 Usage and device data

When you access or use the Service we automatically collect usage and device data, for example:

• IP address, device identifiers, operating system, app version, browser type and settings
• log data such as timestamps of visits, pages and screens viewed, features used, taps, scrolls and other in-app interactions
• diagnostic and crash data collected via Sentry, including device model, operating system version, app version, and anonymised stack traces, to help us identify and fix technical issues.
• push notification delivery tokens (device tokens) generated by Firebase Cloud Messaging (FCM) and Apple Push Notification Service (APNs), which are required to deliver push notifications to your device, including the recurring prompts that invite you to record a Clip. These tokens are device-specific pseudonymous identifiers associated with your account solely for notification delivery.

3.4 Cookies and similar technologies

On our website and, where applicable, in the Application we use cookies and comparable technologies to:

• enable basic technical functions
• store your preferences
• collect statistics on how the Service is used
• improve performance and security.

Where required by law, in particular in the European Economic Area and the United Kingdom, non-essential cookies and analytics tools are only activated on the basis of your consent, which you can withdraw at any time via our cookie banner or in-app privacy settings. Where required, in particular under § 25 TDDDG (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz) and the EU ePrivacy Directive, we only store information on or access information from your device with your consent or where strictly necessary for the provision of the Service.

3.5 Download links and install measurement

We use our own short links of the form download.dashcam.berlin in our own channels, for example social media profiles, QR codes and messages we send. When you follow such a link, our redirect service records:

• the time of the request
• which link was followed
• whether your device is recognised as iOS, Android or other, derived from the browser identification string
• the browser identification string sent by your device
• the address of the page that referred you, without its query string
• any campaign parameters contained in the link.

We do not store your IP address for this purpose. Your IP address is used only as a short-lived counter that limits the number of requests per minute and is discarded when that window expires. We do not set cookies, we do not store anything on your device and we do not read anything from it, we do not collect location data, and we do not use device fingerprinting, advertising identifiers or a third-party attribution provider.

You are then redirected to the Apple App Store, to Google Play or to our website. The store address carries a campaign identifier. Apple and Google process that identifier under their own privacy policies. For iOS we receive from Apple only aggregated install counts per campaign, never information about an individual person.

If you install the Application from Google Play, Google Play passes the campaign identifier of the link you used to the Application when you first start it. We store that identifier and the campaign values it contains on your Account, so that we can see which of our own channels an account came from. It is a single string supplied by Google Play. It contains no advertising identifier and no information about you personally.

4. Purposes and legal bases of processing

We process personal data only where a legal basis applies under Article 6 GDPR and only for specified, explicit and legitimate purposes.

5. Camera and microphone access

We only access your camera and microphone if you start a feature that needs them, for example recording a Clip in the Application. If you deny access, you can still browse other parts of the Service that do not require these permissions. You can change camera and microphone permissions at any time in your device settings.

6. Upload and storage

When you record and share a Clip, the media and associated information are encrypted in transit and uploaded to secure servers located in the European Union.

7. Retention periods and deletion

As a rule, we store your personal data for as long as your Account exists. When you delete your Account, we delete or anonymise the associated personal data, unless we are legally obliged or entitled to retain it, for example to comply with statutory retention obligations or to establish, exercise or defend legal claims.

In addition:

• Content is removed from active systems without undue delay after deletion and is removed from backup systems during the regular backup rotation, usually within up to 30 days.
• Analytics data referencing your account is removed from our analytics pipeline within 30 days of account deletion, as described in section 4.5.
• Interactions you have left on other users' content are deleted upon account deletion. The content of other users on which you interacted is not affected.
• Artefacts that other users have already saved to their own Devices or shared outside the Service are outside our control and cannot be recalled by us.
• Communication data, for example support requests, is stored for the time necessary to handle your request and, where applicable, for the duration of statutory limitation periods for documentation and legal defence.
• Records of clicks on our download links are stored for up to 24 months and are then deleted.
• The campaign values stored on your Account as described in section 3.5 are stored for the lifetime of the Account and are deleted with it.

8. Recipients and data sharing

We only share personal data with third parties where this is necessary for the purposes described in this Policy, where we are legally obliged to do so or where you have given your consent.

9. International data transfers

Our main servers are located in the European Union. In some cases service providers may process personal data in countries outside the European Economic Area and the United Kingdom.

Where such transfers take place, we rely on the following safeguards:

• Google LLC and Apple Inc. are certified under the EU–US Data Privacy Framework (European Commission adequacy decision, July 2023). Transfers to these entities are therefore lawful without additional contractual safeguards.
• PostHog Inc. is certified under the EU–US Data Privacy Framework. All data is hosted in the EU (Frankfurt).
• Functional Software, Inc. (Sentry) is certified under the EU–US Data Privacy Framework. All data is hosted in the EU (Frankfurt).
• Twilio Inc. is certified under the EU–US Data Privacy Framework.
• Lovable Labs Incorporated AB is established in Sweden and is subject to EU law. Lovable engages sub-processors, some of which are established outside the European Economic Area. Transfers to those sub-processors are covered by the standard contractual clauses contained in our data processing agreement with Lovable.
• Scaleway SAS is established in France and is subject to EU law. No international transfer takes place.

You can contact us using the details in section 1 if you would like to receive a copy of the standard contractual clauses that apply to your data.

10. Security of processing

We use appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include in particular:

• encryption in transit and at rest where appropriate
• strict access controls based on the need-to-know principle
• regular security updates and monitoring
• internal policies and training on data protection and information security.

No system can be fully secure. You are responsible for keeping your Account credentials confidential and for limiting access to your Device.

11. Children and age restrictions

The Service is not intended for children and may only be used by individuals who are at least 16 years old. We do not knowingly allow persons under 16 to register for or otherwise use the Service.

If we become aware that personal data of a person under 16 has been collected, we will delete this data without undue delay. If you believe that a person under 16 has provided personal data to us, please contact us using the details in section 1.

12. Your rights under data protection law

If you are located in the European Economic Area or the United Kingdom, you have the following rights under the GDPR in relation to your personal data:

• Right of access: You can request information about whether we process your personal data and obtain a copy of that data.
• Right to rectification: You can request correction of inaccurate or incomplete personal data.
• Right to erasure: You can request deletion of your personal data in the cases provided for by law.
• Right to restriction: You can request restriction of processing in certain circumstances.
• Right to data portability: You can request that we provide personal data you have provided to us in a structured, commonly used and machine-readable format or transfer it to another controller where technically feasible.
• Right to object: You can object at any time, on grounds relating to your particular situation, to processing based on Article 6 paragraph 1 letter e or f GDPR. We will then no longer process the personal data unless we demonstrate compelling legitimate grounds. You can also object at any time to processing for direct marketing.
• Right to withdraw consent: If processing is based on your consent, you can withdraw that consent at any time with effect for the future.

To exercise your rights, contact us at admin@anothersocial.media. We will respond within the time limits set by applicable law. You may also lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement.

You can also delete your Account at any time in the Application, or request deletion via https://dashcam.berlin/account-deletion.

In Germany, the competent authority for our registered office is:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61
10555 Berlin, Germany.

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act, as amended, including the right to request information about our collection and use of your personal information, the right to request deletion or correction of certain information and the right to non-discrimination for exercising these rights. You can exercise these rights by contacting us at the email address above.

13. Cookies and analytics details

On the website, you can manage your cookie preferences via our cookie banner. In the Application you can manage analytics and similar settings in the in-app privacy or settings section, if available.

If you disable or reject non-essential cookies, the basic functionality of the Service will remain available, but some features that rely on analytics or personalisation may not function optimally.

Where we use PostHog for analytics (including session replay) and Sentry for error monitoring, all data is hosted exclusively in the EU (Frankfurt). Both providers are certified under the EU–US Data Privacy Framework, as described in sections 8 and 9.

You can withdraw your consent to in-app analytics at any time via the privacy or settings section of the Application.

14. External links

The Service may contain links to external websites, apps or services that are not operated by us. We have no control over their content or privacy practices. Before providing personal data to such third parties, please read their privacy policies carefully.

15. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in law, our services or processing activities. The date of the latest update is indicated at the top of this document.

If we make material changes, we will inform you in an appropriate manner, for example by displaying a notice in the Application or on the website.

16. Contact

If you have any questions about this Privacy Policy or about how we process personal data, you can contact us at: