Privacy policy
1. Controller
The controller responsible for processing personal data is:
Lionswork Software Studio
Igor Wilhelm
Duvenacker 8 o
D-22523 Hamburg
Germany
Email: info@mallorca-routes.com
Phone: +49 (40) 2848 5698
We process personal data only in accordance with applicable data protection law, in particular the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
2. Scope and purpose of this notice
This privacy policy explains what personal data we process and in what context when you visit our website or use the “Mallorca Routes” app (the “App”). The app provides information on mobility services and public transport routing in Mallorca; no user account is required.
3. Website hosting and server log files
This website is delivered via the hosting provider IONOS SE. When you access pages, the server typically processes technically necessary information automatically, including IP address, date and time of the request, file requested, amount of data transferred and browser type/version (server log files). Processing serves to provide the website, ensure stability and security (e.g. abuse detection) and for error analysis.
We have a data processing agreement (DPA) with IONOS SE pursuant to Art. 28 GDPR, concluded on 4 April 2026. IONOS publishes the agreement here: https://www.ionos.de/terms-gtc/avv/
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure, functioning website).
Log files are kept only as long as necessary for these purposes or where statutory retention obligations apply; they are then deleted or anonymised.
4. Website: cookies, analytics and fonts
The website is largely static. We do not use tracking cookies or embed analytics tools (e.g. Google Analytics). We do not load fonts from third-party servers; the site uses your device’s system fonts.
If we introduce consent-based tracking or embedded content with separate processing in future, we will inform you separately and obtain consent where required by law.
5. Links (e.g. Apple App Store)
Our website may link to third-party offers (including downloading the app from the Apple App Store). After you follow such a link, only that provider’s privacy policy applies (e.g. Apple Inc.).
6. iOS app “Mallorca Routes” – overview
The app is distributed via the Apple App Store. Downloading and any in-app purchases may involve processing by Apple (e.g. Apple ID, payment handling). See Apple’s privacy information: www.apple.com/legal/privacy.
Below we describe processing carried out by us or services we use in connection with the app. We do not run user-level advertising tracking and do not build advertising profiles about you in the app.
7. Location data
If you allow it in iOS settings, the app may access your location while in use. Location is used to centre the map, use “My location” as a route start and support location-based features in Discover. We do not store your location on our servers; processing is primarily local on your device. You can restrict or revoke access anytime under Settings → Privacy → Location Services for the app.
Legal basis: consent (Art. 6(1)(a) GDPR) where you allow access; alternatively processing for pre-contractual steps or use of features you request (Art. 6(1)(b) GDPR).
8. Route planning and connection to our timetable server
When you search for a connection in the app, technically necessary data is sent to our server at mallorca-routes.com to calculate public transport routes, including in particular:
- coordinates or stop references for origin and destination,
- chosen departure or arrival time and search parameters (e.g. pagination of results),
- technical information required for communication (e.g. client IP address in HTTPS access, timestamps).
This data is needed to provide timetable and routing results. We do not use it to track you for advertising across sessions.
Legal basis: Art. 6(1)(b) GDPR (performing the service you request); alternatively Art. 6(1)(f) GDPR (operation and security of the routing service).
9. Apple services (maps, search, geocoding)
The app uses Apple features including MapKit (map display, map data), MKLocalSearch (place and address search) and CLGeocoder (reverse geocoding of coordinates to readable addresses, where used). Data may be transmitted to Apple; processing is governed by Apple’s terms. See: Apple privacy.
Legal basis: Art. 6(1)(b) GDPR (providing the app features you use).
10. Local storage on your device
Various settings and content are stored locally on your iPhone (e.g. via UserDefaults) without us having access to that data on our servers. This may include in particular:
- saved places such as home/hotel and favourites,
- recent route search destinations,
- saved tours/connections where you use that feature,
- data to resume active navigation,
- reference point and departure time for reachability in Discover,
- favourites for points of interest,
- app language setting,
- flags whether certain first-run information was already shown.
You can delete this data by removing app data in iOS settings or uninstalling the app.
Legal basis: Art. 6(1)(b) GDPR and/or Art. 6(1)(f) GDPR (technically necessary or user-friendly app functions on your device).
11. Live Activities
If you allow it, the app may show ongoing navigation information in a Live Activity on the Lock Screen or Dynamic Island. This processing happens within iOS via Apple and/or locally on your device; system settings and Apple’s privacy information apply.
12. Content and images in “Discover”
Where the app loads images or content from external URLs, your device connects to those servers. Any processing there is governed by the respective content provider.
13. Recipients and processors
Where we use hosting or infrastructure providers, this is done under a processing agreement pursuant to Art. 28 GDPR where the conditions are met.
Processor (hosting): We use IONOS SE to host the website and process personal data in server log files. The DPA was agreed on 4 April 2026; text and details: IONOS – data processing agreement.
Further recipients may include: operators of servers used for the app at mallorca-routes.com (where infrastructure is with IONOS or another provider and processing agreements apply), and Apple for platform and map services you use (independent responsibility or processing under Apple’s terms).
14. Transfers to third countries
A transfer to a third country (outside the EU/EEA) may occur in connection with Apple services and global IT infrastructure. Apple uses appropriate safeguards (e.g. EU standard contractual clauses). See Apple’s privacy policy.
15. Retention
Server log files are kept only as long as needed for operation, security and legal evidence. Data stored only locally in the app is under your control (delete app, reset app data). We do not permanently store routing requests linked to you for advertising purposes.
16. Your rights
Subject to legal requirements, you have in particular the right to:
- access your personal data (Art. 15 GDPR),
- rectification of inaccurate data (Art. 16 GDPR),
- erasure (Art. 17 GDPR),
- restriction of processing (Art. 18 GDPR),
- data portability (Art. 20 GDPR),
- object to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR),
- withdraw consent with effect for the future (Art. 7(3) GDPR).
To exercise your rights, contact us at the email address above. You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular where you habitually reside or where we are established.
17. Obligation to provide data
Simply browsing the website does not require you to provide special personal data. For some app features (e.g. location-based functions), providing location data is voluntary; without location permission, some features may be unavailable.
18. Automated decision-making
We do not use solely automated decision-making within the meaning of Art. 22 GDPR that produces legal effects concerning you or similarly significantly affects you.
19. Changes to this privacy policy
We may update this privacy policy if our processing or legal requirements change. The current version is always available on this website. Please check periodically, especially after major app updates.
20. Contact for privacy questions
For questions about processing of personal data or to exercise your rights, contact us at: info@mallorca-routes.com