Privacy Policy for the SiMO Application

1. Introduction

This Privacy Policy (hereinafter referred to as the “Policy”) describes how the Republic of Slovenia, Ministry of Infrastructure, National Traffic Management Centre (hereinafter referred to as the “Controller”), collects, uses, stores, and protects the personal data of users of the SiMO mobile and web application (hereinafter referred to as the “Application”). The Controller processes personal data in accordance with Regulation (EU) 2016/679 (GDPR), the Personal Data Protection Act (ZVOP-2), and other applicable regulations of the Republic of Slovenia. Use of the Application constitutes acknowledgment and acceptance of this Policy by the user.

This document describes the methods of processing information and data for various purposes and demonstrates the functionalities offered by the SiMO application. With the help of this Application, users can find places and addresses on the map, link them together, and obtain related content. The Application also allows users to locate themselves on the map.

All such data are used to provide the best possible service. Every effort is made to protect users’ privacy and ensure the adequate protection of personal data, with particular care devoted to the handling of location data.

2. About the SiMO Application

The Slovenian multimodal journey planner provides users with a comprehensive, reliable, and user-friendly platform.It is developed under the auspices of the Ministry of Infrastructure, National Traffic Management Centre (NCUP; www.ncup.si), and is based on data available through the National Access Point for Traffic Data (NAP; www.nap.si).

SiMO eliminates the fragmentation of information by integrating all modes of transport and mobility services into a single Application, with a special emphasis on public transport. Users can easily search for, compare, and plan their journeys, enabling them to make more informed and sustainable travel choices. By displaying timetables, real-time route updates, and accessibility information, SiMO ensures a seamless travel experience.

In addition to entering starting and destination points, users can adjust numerous parameters such as departure or arrival time, choice of transport mode, maximum walking distance, and accessibility requirements. The most relevant results are displayed first, highlighting key data for each option. Detailed travel information is available in descriptive form and via an interactive map. Users can also save favourite routes and share feedback.

SiMO is intended for daily commuters, tourists, and all those seeking flexible and environmentally friendly ways of travelling. In cooperation with international partners, NCUP is developing cross-border journey planning within a single advanced SiMO solution.

SiMO represents an important step towards improving sustainable mobility and user satisfaction.

The Application uses cookies and other forms of local data storage — small files placed on a user’s computer or mobile device upon visiting the Application. Local storage is used to retain user preferences and optimise the Application’s performance.

3. Types of Personal Data

Within the operation of the Application, the Controller may process the following data:

Data collected from users with a registered account:

When used without logging in (no profile), only anonymous or pseudonymised data that do not enable user identification are processed.

These data are required to provide the services offered by the Application and to ensure its correct functionality. A registered user may request complete deletion of their profile via the data management page.

4. Purpose of Processing

Personal data are processed solely for the following purposes:

The Controller does not use personal data for marketing, advertising, or profiling without the user’s explicit consent.

Personal data are processed based on the following legal grounds under Article 6 of the GDPR:

6. Data Retention

Personal data are stored for as long as necessary to achieve the purpose of processing. Data related to a user account are stored until the account is deleted. If an account remains inactive for more than two (2) years, the Controller may delete it. Anonymised statistical data may be retained permanently. Once the purpose of processing ceases, the data are deleted or anonymised, unless otherwise required by law.

7. Access and Transfer of Data

Access to personal data is granted only to authorised persons of the Controller and contractual processors providing technical support for the Application (e.g. server hosting, maintenance, analytics). These entities are bound by confidentiality and by GDPR-compliant processing obligations.

Personal data are not transferred to third countries outside the European Union or European Economic Area, unless an adequate level of protection is ensured in accordance with Article 45 of the GDPR.

8. Users’ Rights

Users have the following rights regarding their personal data:

Users may submit requests via e-mail to mzi.ncupapp@gov.si or in writing to the Controller’s address. If a user believes that their data are being processed unlawfully, they may lodge a complaint with the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, 1000 Ljubljana.

9. Location Data

The Application uses location data for proper operation (e.g. route calculation, display of nearby stops). Users may disable location access at any time in their device settings, though some functionalities may no longer work. The Controller does not record or store users’ movement history and does not use location data for profiling.

10. Data Security

The Controller applies appropriate technical and organisational measures to protect personal data from loss, misuse, unauthorised access, or disclosure (e.g. encryption, access control, secure communication channels, regular system updates). Nevertheless, complete security cannot be guaranteed; use of the Application is at the user’s own risk.

11. Age Restriction

A user creating an account in the Application must be at least 16 years old. If younger, the user must have consent from a parent or legal guardian to use the Application.

12. Cookies and Analytics

The web version of the Application may use cookies and similar technologies to collect anonymous statistical data on usage (e.g. access frequency, session duration). Users may delete or disable cookies in their browser settings at any time.

13. Amendments to the Privacy Policy

The Controller reserves the right to amend this Policy to ensure compliance with legislation or reflect changes in the operation of the Application. The amended Policy will be published within the Application and on the website www.simo.si. Continued use of the Application after publication constitutes consent to the new Policy.

14. Contact

Ministry of Infrastructure of the Republic of Slovenia

National Traffic Management Centre

Langusova Street 4, 1535 Ljubljana

E-mail: mzi.ncupapp@gov.si

Website: www.simo.si

Validity: This Policy enters into force on the date of its publication in the SiMO Application and on the website www.simo.si.