Privacy Policy

This policy also exists in German. Both versions say the same; if they ever differ, the German version applies.

1. Controller and scope

The controller responsible for data processing under the General Data Protection Regulation (GDPR) is:

Julian Henke, Two Wheels Apart Gleesener Hauptstraße 6 48488 Emsbüren Germany Email: support@twowheelsapart.com

This policy covers the “Two Wheels Apart” apps for iOS and Android and the website twowheelsapart.com. Two Wheels Apart is run by Julian Henke as a sole proprietor. No data protection officer has been appointed because there is no legal obligation to do so; for any privacy question, write to the address above.

You download the apps from Apple’s App Store or from Google Play. Apple and Google handle the download, your store account and its payment details under their own responsibility and privacy terms. We receive no personal data from the download itself, only the statistics described in section 15.

2. The short version

  • No ads, no selling of data, no tracking. The apps contain no third-party analytics or advertising software.
  • Others see your location only if you switch sharing on, and only displaced, never your exact coordinates (section 4).
  • Your device loads map pictures, satellite imagery (Esri) and elevation data directly from the map services (elevation data in the iOS app from version 1.4.37 through our server, section 12); official aerial images come through our server; searches, place details and routes our own routing server cannot answer go through our server to LocationIQ, without your account or your IP address (section 12).
  • Google Analytics runs only on the website and only if you agree in the cookie banner (section 17).
  • You can delete your account in the app at any time (section 22).
  • 3. What data we process (overview)

  • Account data: email address, password (only as a hash) or the identifier from Sign in with Apple or Sign in with Google, username, display name, confirmation times
  • Profile information and photos (bike, riding style, destination, status, languages, Instagram username, profile photo, photo posts, likes, comments)
  • Location data: your latest position while location sharing is on; positions for routes and offline data
  • Messages between users and with the support account
  • Content you share: spots with photos, tracks (GPX), expeditions, border crossing reports, host profile, stay requests and references
  • Reports, blocks and moderation decisions
  • Map requests (search text, coordinates, start and end of routes)
  • Technical data: server logs, crash and performance reports, app version and device model with feedback
  • If you buy Two Wheels Apart Pro: purchase confirmations from the App Store or Google Play (no payment details)
  • On the website: server logs, a cookie-free visit count and, only with consent, Google Analytics
  • 4. Location data

    Two Wheels Apart shows other travellers nearby on a map. Location sharing is voluntary and stays off until you switch it on yourself. The legal basis is your consent (Art. 6(1)(a) GDPR), which you give by switching sharing on and can withdraw at any time with effect for the future by switching it off in the app (the eye icon). Your pin then disappears from every other user’s map immediately.

    What is stored. While sharing is on, the app sends your current position to our server. Only your latest position is stored, never a movement history. Only you see your exact coordinates.

    What others see. Other users never receive your real coordinates, only a displaced point. To make it, the world is divided into a grid of cells about one kilometre across, shifted differently for every rider. For the cell you are in, our server uses a secret key to compute one fixed point nearby. As long as you stay in the same cell, your pin therefore always shows exactly the same place, so nothing can be “averaged out” of it over many updates or days. When you move into another cell, a new, independent point appears. The point shown is usually a few hundred metres to about one kilometre from your real position, at most just under two kilometres; by chance it can also land closer. Distances to you are measured from the displaced point as well.

    Signed-in users see your pin with your display name and profile, and when your location was last updated. Anyone who opens the app without an account sees only a nameless pin at the displaced spot. If you have blocked someone or they have blocked you, neither of you sees the other’s position any more: not on the map, not in the profile and not in live updates.

    When it is updated. In the Android app your position is only updated while the app is open or while you record a ride (then at most every five minutes or every two kilometres); the Android app does not ask for background location access. It gets your position from the location service of Google Play services on your device (fused location provider) and asks only for access while you use the app; you can allow your approximate instead of your precise location. Whether Google itself processes location data from your device depends on the Google location settings of your device; we receive nothing from that. In the iOS app you can additionally choose “Keep updating in the background” when switching sharing on. This needs the separate iOS permission “Always”: iOS then wakes the app on significant location changes, and the app sends your new position at most every three minutes and only after about one kilometre of movement, even while it is closed. For this, the device only remembers the last position sent, rounded to about one kilometre. It ends as soon as you switch sharing off, revoke the permission in the iOS settings, or sign out.

    Navigation and recording. For navigation, ride recording and placing a spot the app uses your location on the device. Recorded rides and your track library stay on your device until you explicitly share a track. During navigation, location keeps running with the screen off (on Android as a foreground service with a permanent notification; it starts only when you begin navigation, guidance to a place or a recording in the open app, and ends with it). Your position goes to our server only when a route is planned or recalculated (section 12), not continuously while you ride. The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR).

    5. Account and sign-in

    For an account we need an email address and a password, a username and a display name. The password is stored only as a cryptographic hash (bcrypt), never in plain text. By registering you confirm that you are at least 18 years old. We store that you accepted the terms of use and this privacy policy and confirmed your age, together with the version of the terms and the time, also when you sign in with Apple or Google for the first time. This is our proof of your agreement (Art. 6(1)(b) and (f) GDPR) and is deleted with your account. If the terms change, the apps ask you again. After you sign in, the app keeps a session token encrypted on your device (iOS keychain, or with the Android Keystore); it is valid for 30 days.

    Email confirmation. To confirm your address we send you one email with a link that is valid for two days (at most one such email per minute and five per day) and store the time you confirmed it. A confirmed address is shown as a “verified” badge on your profile; the address itself is never shown to others.

    Sign in with Apple. You can sign in with your Apple ID. Apple (Apple Distribution International Ltd., Hollyhill Industrial Estate, Cork, Ireland) then confirms your identity to us and passes on a stable identifier for this app, your name if you share it, and your email address or, if you choose “Hide My Email”, a private relay address. We store the identifier with your account. If you stop using Sign in with Apple for our app or delete your Apple ID, Apple informs our server, and your account is deleted in the same way as if you had deleted it yourself (section 22). So that deleting your account also ends our app’s access to your Apple ID, as Apple requires, the app passes our server a one-time code from Apple when you sign in; our server exchanges it with Apple for a token, stores it encrypted and uses it only to revoke that access when your account is deleted (Art. 6(1)(b) and (f) GDPR). The token is deleted with your account. Apple’s privacy policy applies: apple.com/legal/privacy. On Android, Sign in with Apple runs through Apple’s sign-in page, which the app opens in your browser (Custom Tab). Apple sends its answer to our server; the app then collects it with a one-time code that is valid for two minutes and works only together with a secret value the app created for this sign-in. Apple’s answer is kept for this in a temporary table on our server for one hour at most and then deleted. The token for ending the app’s access when you delete your account is obtained and stored in the same way as described above.

    Sign in with Google. Where the Android app offers sign-in with your Google account, Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) confirms your identity to us and passes on an identifier of your Google account, your email address and your name. We store the identifier with your account. In the Android app this runs through Android’s Credential Manager and Google Play services on your device: Google shows its own account selection and hands the app a signed token with this information, which our server checks against Google’s public keys. We receive neither your Google password nor access to anything else in your Google account. When you delete your Two Wheels Apart account, the identifier is deleted with it; you can also remove Two Wheels Apart from the connected apps in your Google account settings. Google’s privacy policy applies: policies.google.com/privacy.

    Forgotten password. If you ask for a new password, we email you a six-digit code. Only a hash of the code is stored; it is valid for 15 minutes, once, and for five attempts. Resetting your password confirms your email address and ends all other sessions.

    Protection against automated sign-ups. Signing in and registering include a small calculation your device solves in a second or two. It runs only between your device and our server, with no third-party service and no cookie.

    The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR) and, for protection against abuse, our legitimate interest in a secure service (Art. 6(1)(f) GDPR). Account data is stored for as long as your account exists.

    6. Profile, photos, likes and comments

    You can optionally add your bike, riding style, destination, current status, languages, your Instagram username and a profile photo. Signed-in users see your profile with these details, how long your account has existed and when you were last active. Your profile photo and the photos on your profile are shown only to signed-in users in the app and have no public web address. Every photo you upload is re-encoded on our server; any metadata it contains (EXIF data, e.g. the GPS coordinates of where it was taken) is removed. For your profile photo we also keep the uncropped original, cleaned the same way, so you can change the crop later; it is deleted with the photo or your account. The cleaned photos are stored with Hetzner in Germany (section 16), and the app loads them from there through a link that only works for a limited time.

    If you add your Instagram username, it appears on your profile as a link. Whoever taps it is taken to your Instagram profile in the Instagram app or the browser; only then does Instagram (Meta Platforms Ireland Ltd.) receive data, under its own privacy policy. We store only the username, never a password or any access to your Instagram account, and we do not check whether the account is yours. You can change or remove it at any time under Edit profile; it is deleted with your account.

    Photos on your profile can carry a caption. Other signed-in users who can see your profile can like a photo and comment on it. Captions, likes and comments are stored with the account that wrote them and shown with that user’s name and photo. You can edit or delete your captions and photos, delete your own comments, and remove any comment under your photos. Blocked users do not see each other in comments.

    The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR). The data is kept until you delete it, at the latest until your account is deleted.

    7. Messages

    When you message other users, we store the content, time, sender, recipient and whether a message was edited or withdrawn, so the conversation can be displayed. Only the two people involved see messages. They are encrypted in transit but not stored end-to-end encrypted on our server; we only look at them if a conversation is reported and we have to review the report, or if we are legally required to. The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR). Messages are deleted as soon as either of the two accounts is deleted.

    8. Spots

    When you create a spot (for example a wild camp, a water source, a workshop or a photo spot), its title, description, category, price where relevant, location and your account are stored. The title and category of a public spot can be seen by anyone who opens the app, even without an account, with the location only roughly (rounded to about 2 km); the exact location and everything else (description, photos, your display name and profile photo) is shown only to signed-in users. A public spot is deliberately shared information. Unlike your own location, a spot is not displaced for signed-in users but shown exactly where you placed it, so do not create a public spot at your home. A private spot is visible only to you. Photos added to a spot are re-encoded and stripped of all metadata, including where they were taken. You can remove a photo you added at any time. Others see how many users saved a spot, but not who. Some spots created before October 2026 are linked to a place in Google Maps; for these we store only the place’s identifier (place ID) and no longer load anything from Google. If you link a new spot to a mapped place, its name and position come from OpenStreetMap (section 12).

    Verified spots. When you add a photo to your own spot, it counts as verified and others see that on the spot. For this we store your account, the photo and the time. Your position is not sent for this.

    Created offline. Spots you create without a connection wait on your device and are sent as soon as there is a connection.

    Deleted spots. When you delete a spot or remove a photo from its gallery, it disappears for everyone immediately. So that a mistake can be undone, we keep a copy (including photos, verifications and saves) in a non-public archive; archived photos are no longer reachable online. In the app your deleted spots are listed under Profile → Spots → Deleted spots, where you can restore them or remove them from that list; the archived copy itself is kept until your account is deleted. Spots removed by moderation are archived in the same way, so that decisions stay traceable. The legal basis is our legitimate interest in restoring accidentally deleted content and keeping moderation decisions traceable (Art. 6(1)(f) GDPR). If you would like an archived spot erased completely earlier, email us and we will erase it, unless it is still needed to handle a report.

    Sharing a spot as a link. Anyone who can see a public spot in the app can pass on a link to it (twowheelsapart.com/s/…). Anyone who has the link can open the page behind it, also without an account. It shows the title, the category, the rough area (region and country, never the coordinates), a map of the whole country with the approximate place (rounded to about 10 km), and the spot’s newest photo only blurred, with the number of photos. The photos themselves are shown sharp only to signed-in users in the app. A preview image is made from the same blurred photo and the map. Our server makes these images once and keeps them in our object storage (Hetzner, Germany). Messengers and social networks such as WhatsApp, Telegram or Facebook load the page and the preview image when someone sends the link there; their own privacy policies apply to that. Your name, your description and the exact position are not on the page, and search engines are asked not to list it. When a spot is made private, deleted or hidden by moderation, its page disappears at once and the images within an hour at the latest; copies a messenger has already loaded are no longer with us. The legal basis is our interest and yours in passing on public spots (Art. 6(1)(f) GDPR).

    The legal basis for spots is the performance of the usage agreement (Art. 6(1)(b) GDPR). Spots and their archived copies are erased completely when your account is deleted.

    9. Tracks, expeditions and border crossings

    Shared tracks. When you share a track (GPX route), we store the file you upload (every point of the route and its marked places) together with its name, an optional description, its length, the coordinates of its start point, the time and the account that shared it, and your confirmation that you are allowed to share it. Signed-in users see the name, description, length and start point and can download the whole file; we count the downloads, but not who made them. A track can show where you live or park, and we do not cut anything from it, so do not share a track that starts or ends at your home, or cut it first. Removing the track in the app deletes our copy immediately; so does deleting your account. We keep the file in a non-public part of our Object Storage at Hetzner Online GmbH (Germany, our processor, section 16). Depending on the app, a download is either passed through our server or loaded by the device directly from Hetzner with a link that works for five minutes; Hetzner then processes the device's IP address to deliver it. Copies in our backups are gone within 70 days at the latest (section 16).

    Sharing a track as a link. A shared track can be passed on as a link too (twowheelsapart.com/t/…), and so can one of its segments (twowheelsapart.com/t/…/2). Anyone with the link sees its name, its length, the riding time and the climb recorded in the file, the number of segments, the countries it passes and a map of the route with its start and end, drawn from our own map data, next to a photo of ours. The file itself, its points and your name stay in the app. Otherwise the same applies as for spots: the images are kept in our object storage, messengers load the preview when the link is sent, search engines are asked not to list the page, and it disappears when you stop sharing the track or it is hidden. The legal basis is Art. 6(1)(f) GDPR.

    Expeditions. When you plan a trip as an expedition (name, optional start date, notes, list of places and track sections), the plan is stored on your device and on our server so it is not lost. Only if you switch on “Share with riders” is it shown on your profile to other signed-in users (not to blocked ones); they can view it, copy it and navigate it. You can delete plans at any time; all of them are deleted with your account.

    Sharing an expedition as a link. A plan you share with riders can also be passed on as a link (twowheelsapart.com/e/…) with the share button in the planner; if the plan is not shared yet, the button asks first. Anyone with the link sees its name, its length, the number of stops, the start month, the countries and a map of the route next to a photo of ours, never at a scale where single streets could be read and without marks at its places. The notes, the names of the places and your name stay in the app, and opening the plan itself needs an account. When you stop sharing the plan or delete it, the page disappears at once and its images within an hour at the latest. The legal basis is Art. 6(1)(f) GDPR.

    Opening a link in the app. When the app is installed, these links open in the app itself (universal links on Apple devices, App Links on Android). For that the phone loads a small file from our website that only names the app; it carries no data about you.

    Border crossings. When you report the state of a border crossing (open, restricted, closed, optionally a waiting time and a comment) or add a crossing, we store your report with your account and the time. The report is shown with your display name, username and profile photo at that crossing, to everyone who opens it in the app, even without an account. Reports are deleted with your account; a crossing you added stays on the map afterwards without any link to you. Entry and travel information for a country is fetched by our server from the open data service of the German Federal Foreign Office; no data about you is sent there.

    The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR).

    10. Hosting riders

    Riders can offer other riders a free place to sleep and ask hosts for a night. If you host, we store your host profile: the position of your home, how many riders and bikes you can take, what you offer, your house rules and, if you write one, a note on how to find you. Hosts and guests have to be verified (confirmed email address, profile photo, your own confirmation that you are 18 or older, the time of which we store, and an account at least seven days old). Others see your host pin only about two kilometres from your home; the offset is drawn once and kept. Your exact position and the note go only to a guest you have accepted, for the days of that stay and two days after. You can pause or stop hosting at any time, which removes your pin.

    If you ask a host to stay, we store the request (dates, number of riders and bikes, your message); it is also delivered to the host as a chat message. Requests unanswered for seven days expire. After a stay, both sides can leave a reference (a thumbs up or down and a short text); it becomes visible on the profile of the person it is about once both have written one, or after 14 days, with the author’s name and photo. If you report a host, we store the reporting account, the time and the reason; two reports pause the host until we have looked at it. We do not take part in any stay, and nothing is paid through the app.

    The legal basis is the usage agreement (Art. 6(1)(b) GDPR) and, for keeping hosting safe and verifiable, our legitimate interest (Art. 6(1)(f) GDPR). Your host profile, requests, references and reports about you are deleted with your account.

    11. Reports, blocking and moderation

    You can report spots, photos, tracks, hosts, profiles, photo posts, comments and conversations in the app; anyone, including people without an account, can also report illegal content by email. We store the reporting account or email address, the reason, the time, the content concerned and our decision with its reasons. If you report something with your account, we confirm the report by email to your account’s address and tell you our decision. Content reported by several different accounts is hidden automatically until a person has reviewed it; the final decision is always made by a person. If we remove content or restrict an account, we tell the person concerned why. If a rights holder writes to us, for example about a track, we process their message and the content to check the claim. Anyone who can be recognised in a photo can ask us to remove it, in the app or by email.

    If you block someone, we store that pairing so the block can be enforced; the block is also noted as a report so that we can spot abuse. The pairing is deleted when you unblock them or when either account is deleted.

    The legal basis is compliance with our obligations under the Digital Services Act (Art. 6(1)(c) GDPR in conjunction with Art. 16 and 17 DSA) and our legitimate interest in a safe platform and in respecting the rights of others (Art. 6(1)(f) GDPR). Reports are kept as long as they are needed for the review and to keep the decision traceable, at the latest until the content or account concerned is deleted.

    12. Map, search, routes and offline data

    The map uses several services. Whenever your device loads something directly from a service, that service technically receives your IP address and the area of the map being shown (tile coordinates), but not your account. Unless stated otherwise, the legal basis is our legitimate interest in a working map, search and route planning as core functions of the app (Art. 6(1)(f) GDPR).

  • Map picture: your device loads the map tiles, fonts and symbols, the hillshading and the contour lines directly from our storage at Hetzner Online GmbH (Germany, our processor). The map data comes from OpenStreetMap; Protomaps builds the tiles from it, and once a month we copy them into our storage, so Protomaps receives nothing from your device.
  • Satellite imagery (the default view in the app): your device loads it directly from Esri (Environmental Systems Research Institute, Inc., 380 New York Street, Redlands, CA 92373, USA), World Imagery of the ArcGIS Location Platform. Esri receives your IP address, the map tiles requested (and so the area being shown) and technical data such as the app version, not your account. Where national or regional mapping agencies publish aerial images as open data, the app shows them on top; these come through our server, which fetches them and keeps them in a cache, so the agencies see only our server, never your IP address. Our server also supplies satellite imagery when Esri cannot be reached and for use without a connection (Copernicus Sentinel-2 through the European Environment Agency and EOX IT Services GmbH, Austria). We store no IP addresses in the log of these requests. All sources are listed on the licences page.
  • Elevation profile and elevation data for offline maps: the Android app and the iOS app from version 1.4.37 load elevation tiles through our server, which fetches them from the open “Terrain Tiles” dataset at Amazon Web Services, Inc. (USA) and keeps them in a cache, so Amazon sees only our server. Older iOS versions load them directly from Amazon Web Services.
  • Map styles come from our own server at IONOS; offline maps your device downloads from our storage at Hetzner.
  • Apple Maps (iOS only): when you tap a place on the map, the app shows its details from Apple Maps; the place’s name and coordinate go to Apple for this. The map for choosing an offline area and the place name of a downloaded area also come from Apple.
  • Search, place details and routes outside Germany: LocationIQ (Unwired Labs (India) Pvt Ltd, Jubilee Hills, Hyderabad 500096, India; Search by LocationIQ.com ): search suggestions and search, place names for a coordinate, details of a place (name, address, opening hours, phone, website, all from OpenStreetMap), places around you, the suggestion of a mapped place when you add a spot, and routes and distances where our own routing server has no road data. The app sends these requests to our server, and our server asks LocationIQ’s servers in the EU (eu1.locationiq.com). LocationIQ receives only what the request needs: the search text and the language, a coordinate (rounded to about 100 metres for searches, place names and places around you) or the start, end and via points of a route. The requests come from our server, not from your device, and contain no account data: neither your name, email address, user number or login token nor your IP address. LocationIQ works for us as a processor under its data processing agreement, which is part of its terms of service. LocationIQ is a company in India. The European Commission has not issued an adequacy decision for India, and access to the data from India cannot be ruled out. Our server keeps answers for a few hours at most so that the same question is not asked twice.
  • Google Maps (only if you tap it): the apps can open a place in Google Maps. Only then does your device contact Google, and Google’s privacy policy applies: policies.google.com/privacy. Since 16 October 2026 our server sends no search, place or route requests to Google, and the apps no longer show photos of places from Google, older versions included.
  • Routes: in Germany, routes and distances are calculated by our own routing server (OSRM with OpenStreetMap data, at IONOS); elsewhere LocationIQ does (see above). Navigation runs on your device. Each time a route is planned or recalculated (for example after a wrong turn), your current position, the destination and, for a track, points along it go to our server. The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR).
  • Offline routes: if you make a track available offline, the app sends the points of the track and, once, your approximate current position (for the way to the track), or the rectangle you chose, to our server. It builds the road network and sends it to your device. The prepared file contains only road data, is not linked to your account and is deleted after seven days. Offline maps (map packs per region) are downloaded from our servers while you are signed in. The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR).
  • Spots offline and on the map: while you are signed in, the map loads the public spots from a file in our storage at Hetzner (Germany), through a link that is valid for a few hours; the server builds that file every few minutes from the public spots only. With every offline region the app also downloads the public spots of that region with their details and small preview photos (at most 320 pixels, without location data) and keeps them on your device. While you are online the app checks them against the server every six hours: spots that were deleted, hidden or made private disappear from your device with the next check, and spots that could not be checked for 60 days are removed, so they never stay on a device for longer than 70 days. The legal basis is the performance of the usage agreement (Art. 6(1)(b) GDPR).
  • Shared links and text: if you share a place from another app with Two Wheels Apart, the app sends the shared text to our server to recognise the place. The position comes from the link itself. For a short Google Maps link, our server opens the link once at Google to read the full address, so Google sees only our server. If the link contains only a name, our server looks that name up at LocationIQ.
  • Google LLC, Apple Inc., Amazon Web Services, Inc., Cloudflare, Inc. and Esri (Environmental Systems Research Institute, Inc.) also process data in the United States. According to their own statements they are certified under the EU-US Data Privacy Framework, for which the European Commission has issued an adequacy decision (Art. 45 GDPR).

    13. Two Wheels Apart Pro (in-app subscriptions)

    The map, riders, spots, messages and hosting are free. A “Two Wheels Apart Pro” subscription may be offered for additional features. Purchase, payment, renewal, cancellation and refunds are handled exclusively by Apple’s App Store or Google Play; their privacy terms apply. We never receive payment details.

    In the iOS app, the app currently checks on your device through Apple’s StoreKit whether a subscription exists; nothing is sent to our server for this. In the Android app, the purchase dialog comes from Google Play (Google Play Billing Library), and the app asks Google Play on your device which subscriptions are offered and whether you already have one. It does so only when you open the Pro page, start a purchase or restore one, or if you have Pro or bought it on this device; not simply because you open the app. The reports this library would otherwise send to Google about its own use are switched off in the app. The app passes your internal account number with us (a number, not your name or email address) to Google with the purchase and, after the purchase, sends the product bought and the purchase token to our server. The server verifies the purchase with Google and attaches Pro to your account, so it also applies on your other devices; the same check is prepared for purchases from Apple. For this we store the platform, the product, a purchase reference (for Google only a hash of the purchase token, for Apple the original transaction number), the status, the term, automatic renewal and the store’s verification answer. Apple and Google notify our server of renewals, cancellations and refunds so that Pro is switched on or off correctly. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR). This purchase information is deleted with your account unless statutory retention obligations apply.

    14. Feedback, support and email

    If you send feedback from the app, we store your message, your account, the app version, the device model and the operating system and its version. The message is emailed to us through our own mail server (on our server at IONOS), and a copy appears in your chat with the “twowheelsapart” support account, where our replies reach you too. Feedback is deleted with your account, and otherwise after 12 months at the latest.

    If you email us, we process your address and message to reply. Emails are kept in our own mailbox on the same server; we delete them when they are no longer needed for your request, unless statutory retention obligations (for example for business letters) require us to keep them longer.

    The legal basis is the performance of the usage agreement or answering your request (Art. 6(1)(b) GDPR), our legitimate interest in improving the app (Art. 6(1)(f) GDPR) and, where applicable, statutory retention obligations (Art. 6(1)(c) GDPR).

    15. Crash and performance reports

    The apps contain no third-party crash or analytics software. The Android app currently sends no crash reports. If the iOS app crashes, hangs or overloads the device, iOS hands it a technical report (Apple MetricKit) on the next start, which the app sends to our server. The iOS app also sends a short report when the map keeps stuttering (for example frame rate, number of items shown, selected map layers, low power mode). Both apps report when the calculated way to a track ends too early (only distances and numbers of points). Every report contains the device model, the operating system and app version and, if you are signed in, your account, but no location and no content. We use the reports only to find and fix errors and delete them after 90 days. The legal basis is our legitimate interest in a stable app (Art. 6(1)(f) GDPR).

    Statistics and crash reports from the app stores. If you installed the Android app from Google Play and your device shares usage and diagnostics data with Google, Google collects technical reports when the app crashes or stops responding (with device model, Android version, app version and the error trace) and shows them to us in the Google Play Console (“Android vitals”), together with statistics about installations, updates, uninstallations, ratings, countries, languages and devices. Apple does the same in App Store Connect if you have agreed on your iPhone to share analytics with app developers. We see these reports and statistics without your name, email address or account. Apple and Google collect this data under their own responsibility; you can switch the sharing off in the settings of your device. If you rate or review the app in a store, your review is published there under the name of your store profile, and we can read it and reply. We use this information only to find and fix errors and to improve the app (Art. 6(1)(f) GDPR).

    16. Hosting, server logs and backups

    The website, the apps’ interface, the mail server, the routing server and the offline maps run on servers of IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany, acting for us as a processor.

    Uploaded photos (profile photos, the photos on your profile and spot photos) are stored in the Object Storage of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, also acting for us as a processor. These photos are not public: only signed-in users of the app get a link to a photo, and it stops working after one to two weeks. With it, the app loads the photo directly from Hetzner. To deliver a photo, Hetzner processes the IP address of the device requesting it. Photos removed from a spot wait in a non-public part of this storage (section 8); deleted profile photos and photos of a deleted account are erased there straight away.

    If you download your data in the app (section 21), our server puts it together as a ZIP file and stores it in a non-public part of the same Object Storage at Hetzner. Only you get a link to it, and each link works for 24 hours. The file is deleted automatically after 7 days, and straight away if you delete your account.

    With every request the web server automatically processes technical connection data: IP address, time, address requested, status code, amount of data transferred, referring page and browser or app identifier. For requests from the apps we log the address without its parameters, so without coordinates or search text. These logs are deleted after 15 days at the latest. Error logs of the interface (without IP addresses) are deleted after nine weeks at the latest. The legal basis is our legitimate interest in secure, stable operation and in preventing abuse (Art. 6(1)(f) GDPR).

    To be able to recover from technical failures, the database, uploaded photos and the mailboxes are backed up every night. A copy of the database and the mailboxes stays on our server for up to 15 days. A second copy is stored encrypted in the Object Storage of Hetzner Online GmbH in Germany (processor, see above), in write-protected storage where nobody can change or delete anything for 30 days, so that neither an attack nor a mistake can destroy it. Changes to the database are also backed up there continuously, at most a minute apart, so that it can be restored to any point within the last 31 days. There we keep the backups of the last 31 days. Uploaded photos and other files that are deleted can also be restored from the Object Storage for 30 days; after that they are gone there for good. Data you delete is therefore gone from all backups no later than 70 days afterwards.

    17. Website: cookies, visit count and Google Analytics

    Without your consent the website sets no cookies and loads no content from third parties; we serve the fonts ourselves. Your cookie banner decision is stored in your browser’s localStorage. This is strictly necessary to respect your choice and needs no consent (Sec. 25(2) no. 2 TDDDG).

    Cookie-free visit count. Once an hour we count from the server logs (section 16) how many visits, page views and taps on the App Store buttons there were per day, what kind of source visitors came from (for example a search engine or Instagram) and with what kind of device (iPhone, Android, computer). For this, IP address and browser identifier are only compared in hashed form within one day; only the daily totals are stored. No cookies are set and no data goes to third parties. The legal basis is our legitimate interest in measuring reach without tracking (Art. 6(1)(f) GDPR). The App Store buttons go through a redirect on our website (/go/appstore) that serves only this count.

    Google Analytics (only with consent). If you agree in the banner, we use Google Analytics 4 by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics sets cookies (_ga, _ga_*) and creates pseudonymous usage statistics (e.g. pages visited, time spent, device type, taps on the App Store buttons); full IP addresses are not stored. We use Google Consent Mode: Google Analytics is only loaded after your consent, and every Analytics request then tells Google your consent status. Processing may also take place in the United States; Google LLC is certified under the EU-US Data Privacy Framework (adequacy decision, Art. 45 GDPR). The data is deleted after the retention period set in Google Analytics, at the latest after 14 months. The legal basis is exclusively your consent (Sec. 25(1) TDDDG, Art. 6(1)(a) GDPR). You can withdraw it at any time, as easily as you gave it: choose “Cookie settings” in the footer and decline. Analytics then stops and the Google Analytics cookies are removed. Withdrawal does not affect the lawfulness of processing carried out before it.

    Ko-fi (voluntary support). The “Support the project” button opens a window with the form of Ko-fi (Ko-fi Labs Limited, United Kingdom). The form is loaded only once you open the window. Ko-fi then receives your IP address and technical data such as your browser and may set cookies. If you support the project, Ko-fi and its payment providers handle the payment, and we receive the information Ko-fi passes on (for example your name or message, if you give one). Support is not a tax-deductible donation. The legal basis is your request by opening the window and the handling of your payment (Art. 6(1)(b) GDPR). The European Commission has issued an adequacy decision for the United Kingdom. Ko-fi’s privacy policy applies: more.ko-fi.com/privacy.

    18. Storage on your device (apps)

    The apps store on your device what the features you use need: the session token (encrypted), settings, saved spots, your tracks, recordings and expeditions, spots not yet sent, downloaded offline maps and a cache for images and map data. For offline use the app also keeps the displaced positions of other riders (at most 14 days) and host pins (at most 30 days) of the downloaded regions, and the public spots of the downloaded regions with small preview photos (see section 12). This storage is strictly necessary to provide the service you request (Sec. 25(2) no. 2 TDDDG). When you sign out, account-related data is removed from the device or set aside until you next sign in with that account. On iOS your tracks can be part of your device backup with Apple, depending on your iCloud settings (offline maps are not); the Android app is excluded from device backups. The optional app lock (Face ID, fingerprint or screen lock) runs only on your device. The apps use no push notification service (such as Firebase Cloud Messaging or Apple’s push service). The Android app shows notifications only while navigation, a recording or a download is running, and it fetches new messages itself while it is open.

    19. Recipients at a glance

  • Other users: what you share publicly or release to them (see above)
  • IONOS SE (hosting, processor, Germany)
  • Hetzner Online GmbH (storage of uploaded photos, of your data downloads and of the map data, processor, Germany)
  • Unwired Labs (India) Pvt Ltd, LocationIQ (search, place details and routes outside Germany, processor, servers in the EU, company in India)
  • Google Ireland Limited / Google LLC (Google Analytics only with consent; Sign in with Google; Google Play for downloads, purchases and crash statistics of the Android app; Google Play services on Android devices for sign-in and the location service)
  • Apple Distribution International Ltd. / Apple Inc. (Sign in with Apple; App Store for downloads, purchases and crash statistics; Apple Maps in the iOS app)
  • Environmental Systems Research Institute, Inc. (Esri, satellite imagery, loaded directly by your device)
  • Amazon Web Services, Inc. (elevation data in iOS versions before 1.4.37)
  • Ko-fi Labs Limited (website only, only if you open the support window)
  • Authorities, where we are legally required to disclose data
  • Your data is never sold or passed on for advertising purposes.

    20. Retention at a glance

  • Account, profile, message and spot data, border crossing reports, expeditions: until you delete them, at the latest until your account is deleted
  • Location: only your latest position, until you switch sharing off or delete your account
  • Shared tracks: until you stop sharing them or delete your account
  • Archived copies of deleted spots: until your account is deleted, or on request
  • Offline routes on the server: 7 days
  • Your data download (ZIP): 7 days
  • Crash and performance reports: 90 days; feedback: 12 months at the latest
  • Server logs: 15 days at the latest; error logs: 9 weeks at the latest; backups: deleted data is gone after 70 days at the latest
  • Google Analytics: 14 months at the latest
  • Consents (location sharing, cookie banner): until you withdraw them
  • Data we have to keep for tax or commercial law reasons: for the statutory period
  • 21. Your rights

    As a data subject under the GDPR, you have the following rights:

  • Access (Art. 15 GDPR) to the data stored about you
  • Rectification (Art. 16 GDPR) of inaccurate data
  • Erasure (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Withdrawal of any consent given, with effect for the future (Art. 7(3) GDPR)
  • Complaint to a supervisory authority: you can complain to any data protection authority; the one competent for us is the State Commissioner for Data Protection of Lower Saxony (Die Landesbeauftragte für den Datenschutz Niedersachsen, Prinzenstraße 5, 30159 Hannover, lfd.niedersachsen.de )
  • Right to object (Art. 21 GDPR). Where we process data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you can object to this processing at any time on grounds relating to your particular situation. We will then stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims. An informal objection to support@twowheelsapart.com is enough.

    Download your data yourself. In both apps you can download a copy of your data at any time under Profile → gear → “Info and privacy” → “Download my data”. You get a ZIP file with your profile and settings, your spots, your photos in their original form, your posts with their captions, the comments and likes you gave, your tracks as GPX, your expeditions, your host profile with stays and references, your messages, reports, blocks and consents and the ways you sign in, as JSON files with a description in German and English. Other people appear in it only with their display name; passwords and access tokens are never part of it. The file is usually ready within a moment and stays available for 7 days (section 16); you can ask for a new one once a day. We also let you know by email when it is ready. This serves your rights of access and to data portability (Art. 15 and 20 GDPR); the legal basis is Art. 6(1)(c) GDPR.

    For access or any of the other rights, write to support@twowheelsapart.com.

    22. Deleting your account

    You can delete your account yourself at any time, in both apps under Profile → gear → “Info and privacy” → “Delete my account”. This immediately and permanently deletes your account, all your profile data, your profile photo, every spot you created (including archived copies), your photos, comments and likes, your shared tracks and expeditions, your border crossing reports, your host profile, stay requests and references, your feedback and every message you were part of. Copies in our backups are gone within 70 days at the latest (section 16). Deleting your account does not cancel a Pro subscription; cancel it in the subscription settings of Apple or Google Play. If you can no longer use the app, you can also ask for deletion by email: how to delete your account.

    23. Obligation to provide data, automated decisions, minimum age

    You are not legally or contractually obliged to give us any data. Without an email address (or Sign in with Apple or Google), a username and a display name we cannot offer you an account; without location sharing you do not appear on the map, but all other features remain available.

    There is no automated individual decision-making within the meaning of Art. 22 GDPR. Automatically hiding content reported several times until a person has reviewed it is a provisional protective measure.

    Two Wheels Apart is only for people aged 18 or older. See our Terms of Service for details.

    24. Data security

    Transmission between your device and our servers is encrypted (TLS/HTTPS). Passwords are stored only as hashes, access to the servers is limited to the operator, and backups are readable only by him. As described in section 4, your real coordinates are never delivered to other users.

    25. Changes to this policy

    We update this policy when the apps, the website or the law change. The version published here, with the date shown above, applies.