1. Data Controller
The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:
Marian Kulisch
encirkl powered by CursusX
Republic of Korea
Email: contact@cursusx.de
A full postal address will be provided upon legitimate request.
This Privacy Policy applies to the service encirkl (available at encirkl.de / encirkl.com), which is operated on the CursusX technical platform.
Relationship to the app privacy policy: This page describes data processing on the websites encirkl.de / encirkl.com and, in summary and consistent with it, in the mobile encirkl app. The complete, technically authoritative description of app- and platform-side data processing is maintained in the CursusX Platform Privacy Policy at cursusx.de/privacy. It is the technically leading source for app-specific details and is updated first whenever the app changes.
2. Overview of Data Processing
This policy distinguishes between two data subjects with fundamentally different processing: anonymous end users (walkers, runners, wheelchair and stroller users — loop validation runs entirely on the user's own device; only a few, precisely defined elements per loop are stored server-side, see Section 3.2) and partners as business customers (regular business master-data processing under the partnership agreement, see Section 5). Unless stated otherwise, the following principles refer to the processing of end-user data.
Our Core Principle: Privacy by Architecture. The encirkl app is designed to process as much information as possible directly on your own device rather than transmitting it to the server. Where a feature requires it — for example real-time loop validation, leaderboards, or challenges — selected activity and location data (including approximate or precise position data, route and distance information, timestamps, and altitude data) may be transmitted to the CursusX Platform to provide the requested feature. We do not build persistent, cross-feature movement profiles of individual users. For details on app-side processing, see the note in §1 and Section 3.2.
2.1 Which services does this policy cover?
- encirkl: Urban loyalty programme — loop validation, badge system, wallet card, partner benefits, climate territories, green labels, CO₂ visualisation, team loops
- CursusX Platform: Technical infrastructure on which encirkl is operated — GPS validation, NFC waypoints, app delivery, partner API
3. Types of Data Collected
3.1 Usage Data (collected automatically)
| Data Category | Purpose | Legal Basis | Retention Period |
|---|---|---|---|
| Device ID (pseudonymised) | Session management, badge assignment | Art. 6(1)(b) GDPR (performance of contract) | Until account / app deletion |
| Browser and device type | App optimisation, compatibility checks | Art. 6(1)(f) GDPR (legitimate interest) | 90 days |
| IP address (truncated) | Security, abuse prevention | Art. 6(1)(f) GDPR | 7 days |
3.2 Location Data (GPS)
Particularly sensitive processing: Location data is only collected when you actively start a loop. Collection is based exclusively on your explicit consent (Art. 6(1)(a) GDPR). You can revoke location access at any time in your device settings.
| Data Category | Purpose | Processing |
|---|---|---|
| GPS coordinates during a loop (approximate or precise) | Real-time validation: distance, speed, continuity of the walking route; providing challenges, leaderboards and loop features | Depending on the feature used, selected location and activity data (incl. position data, route, distance, timestamps, elevation profile) may be transmitted to the CursusX Platform. Where technically possible, processing stays on-device. Authoritative technical detail: cursusx.de/privacy. |
| Loop completion | Badge award, climate territory assignment, CO₂ calculation, Top100 display (see 3.4) | Transmitted to the CursusX Platform and retained for the duration of the relevant feature or until account deletion (see Section 13 of the app privacy policy) |
| NFC scan events | Physical proof at waypoints | Linked to session, not to person |
3.3 Voluntarily Provided Data
| Data Category | Purpose | Legal Basis |
|---|---|---|
| Name / display name | Display on wallet card, leaderboards, personalised badges | Art. 6(1)(a) GDPR (consent) |
| Photo uploads (photo walks) | Community gallery, GPS-validated submission | Art. 6(1)(a) GDPR |
| Green labels (tree markings) | Citizen-driven urban green data, tree watering reports | Art. 6(1)(a) GDPR |
| Team membership | Team loops, collaborative badges | Art. 6(1)(b) GDPR |
| Invitation links | Community growth (anchor point badge) | Art. 6(1)(a) GDPR |
3.4 Top100 (public loop ranking)
The Top100 is an optional, public overview of completed loops. Participation is voluntary and set by you individually per loop — you decide, for each completed loop, whether it appears in the Top100 or stays private. No loop is shown publicly without your active opt-in.
A loop shared to the Top100 is displayed in a way that prevents inferences about your private home or starting address. The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time by revoking the share for that loop.
3.5 Data from Website Contact Forms
On encirkl.de and encirkl.com we offer four contact forms, each opened as a modal: beta sign-up, partner inquiry, cities & funding conversation, and general contact. Submission only happens when you actively send the form.
| Form | Fields collected | Purpose | Legal basis |
|---|---|---|---|
| Partner inquiry | First and last name, email, company, partner type, message | Processing your partner inquiry | Art. 6(1)(b) GDPR |
| Cities / funding conversation | First and last name, email, organisation, role, message | Scheduling a conversation and clarifying pilot projects | Art. 6(1)(b) GDPR |
| General contact | First and last name, email, subject, message | Responding to your inquiry | Art. 6(1)(a)/(f) GDPR (consent / legitimate interest) |
Two additional fields are submitted automatically: the form type (form_type) and the originating page URL (page_uri) — used only to route the inquiry.
Transmission: The data is sent via an encrypted HTTPS connection to our email endpoint at https://cursusx.de/email/ and delivered as email to contact@cursusx.de. The recipient and controller is the operator named in §1.
Fallback on transmission error: If the request fails (e.g. network error), your local email client is automatically opened with the entered data as a draft addressed to contact@cursusx.de. You then decide whether to send the email.
Retention: Data is retained for as long as necessary to process your inquiry and any follow-up questions, but no longer than 24 months after the last contact. Statutory retention obligations (e.g. commercial or tax law) remain unaffected.
3.6 Optional Information for Partner Challenges & Camera Access
Certain partner-operated challenges or reward programmes may request additional optional information, such as an email address, phone number, or date of birth. This information is collected only with your explicit consent (Art. 6(1)(a) GDPR) and only for the specific challenge or reward concerned.
The mobile app may also request access to the device camera — solely for functions such as scanning QR codes, redeeming rewards, or restoring an app identifier. Images are processed only for the requested action and are not stored permanently on the server unless explicitly stated otherwise (e.g. for voluntary photo uploads under Section 3.3).
4. Wallet Card and App
encirkl is delivered as a native app via the Google Play Store and the Apple App Store. The wallet card is stored locally on your device (Apple Wallet / Google Wallet). The following data is stored on your device:
- Display name (if provided)
- Badge status and unlocked badges
- Current partner benefit status
The wallet card communicates with the server via the CursusX API to update badge status in real time and to unlock partner benefits. This communication is encrypted (TLS).
5. Data Sharing with Partners
5.1 Anonymised Movement Reports
Anchor Partners (Tier 1) may receive anonymised, statistical movement reports. These contain exclusively anonymised metrics — never individual routes, location histories, or personal data.
5.2 Badge Status to Route Partners
When you redeem a partner benefit (e.g. a discount at a route partner), your current badge status is transmitted to the partner's point-of-sale system via the CursusX API. Only the following data is transmitted:
- Badge status level (e.g. "City Walker")
- Eligibility for the specific benefit (yes/no)
No names, location data, movement history, or other personal data is transmitted to partners.
5.3 Green Labels and Urban Green Data
Green labels (markings placed at trees and green spaces) may be shared in anonymised form with mission partners such as Insel Projekt Berlin or the city administration to support urban green maintenance. It is not possible to trace the marking back to the individual who placed it.
6. Cookies and Local Storage
We use only technically necessary storage mechanisms — no marketing cookies, no tracking pixels, no third-party profiling.
6.1 In the App
- Local cache: For offline capability of the app
- Session token: For assigning active loops (temporary)
- Wallet data: Local storage of badge status on your device
6.2 On the website (encirkl.de / encirkl.com)
- Browser localStorage
encirkl-theme: Stores only your light/dark mode preference (values:auto,light,dark). This information stays 100 % on your device, is never transmitted to our server, and contains no personal data. You can remove the entry at any time via your browser's developer tools or by clearing the website's site data. - No cookies: The website sets no cookies — neither first-party nor third-party.
6.3 Plausible Analytics
For anonymous analysis of website usage we use Plausible Analytics, operated by Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estonia. All processing takes place entirely within the European Union; no data is transferred to third countries.
Technical specifics: Plausible sets no cookies, writes nothing to browser storage (LocalStorage, SessionStorage, IndexedDB), and performs no device fingerprinting. IP address and user-agent are hashed with a daily-rotating server salt into an irreversible token — after 24 hours, re-identification is technically impossible.
Events collected: page views, referrers, device type, plus the following anonymous conversion events without content or personal identifiers: CTAClick, ModalOpen, FormSubmit (with form type beta/partner/cities/contact), VideoPlay, VideoComplete, ThemeToggle, AdLanded (UTM parameters from ad clicks), Outbound Link: Click, and 404.
First-party delivery: The Plausible scripts are served from www.encirkl.com/js/… and events are sent to www.encirkl.com/api/event (internally forwarded to Plausible). Your browser establishes no direct connections to third-party domains.
Legal basis: Because Plausible processes no personal data, no consent is required under § 25(1) TTDSG; to the extent a legal basis is nonetheless required for aggregated analysis, we rely on our legitimate interest (Art. 6(1)(f) GDPR) in statistical reach measurement. More information directly from Plausible: plausible.io/data-policy.
6.4 Self-hosted fonts
The typefaces Roca Two and Nunito are served locally from our server. No connection is made to Google Fonts, Adobe Typekit or other third-party providers — your browser does not contact external font CDNs.
7. Hosting and Data Processing
The technical infrastructure (CursusX platform) is hosted on servers within the European Union. A data processing agreement (DPA) pursuant to Art. 28 GDPR has been concluded with the hosting provider.
Hosting provider: Servers within the EU. Details available upon request at contact@cursusx.de.
8. Your Rights
Under the GDPR, you have the following rights:
- Right of access (Art. 15): You may request information about which data we process about you.
- Right to rectification (Art. 16): You may request the correction of inaccurate data.
- Right to erasure (Art. 17): You may request the deletion of your data, provided no statutory retention obligations apply.
- Right to restriction of processing (Art. 18): You may request the restriction of the processing of your data.
- Right to data portability (Art. 20): You may receive your data in a structured, commonly used format.
- Right to object (Art. 21): You may object to the processing of your data based on Art. 6(1)(f) GDPR.
- Right to withdraw consent (Art. 7(3)): You may withdraw any consent given (particularly for location data and photo uploads) at any time. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.
To exercise your rights, please contact: contact@cursusx.de
Right to Lodge a Complaint
You have the right to lodge a complaint with a data protection supervisory authority. As the Services are primarily aimed at users in Germany, any German state data protection authority has jurisdiction. For users based in Berlin, this is:
Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59–61, 10555 Berlin
www.datenschutz-berlin.de
9. Use by Minors
encirkl is intended for users aged 16 and older. We do not knowingly collect personal data from persons under 16 without parental consent. If we become aware that such data has been processed, we will delete it without delay. Parents or guardians can contact us at any time at contact@cursusx.de.
10. Security of Data Processing
We employ technical and organisational measures to protect your data against accidental or deliberate manipulation, loss, destruction, or unauthorised access. These include TLS encryption (HTTPS) on all websites, access controls on the CursusX platform, local processing of location data on the device, and self-hosting of fonts. Our security measures are continuously improved in line with technological development.
11. Updates to this Privacy Policy
We reserve the right to amend this Privacy Policy so that it always complies with current legal requirements or to implement changes to our services in the Privacy Policy. The new Privacy Policy will then apply to your next visit. Status: August 2026.