Privacy Policy

1. Overview

Arelo (“the App”) is a real-time transit arrival prediction app for iOS. We are committed to protecting your privacy and being transparent about how data is handled. This privacy policy explains what information we collect, how we use it, and your rights under applicable laws (CCPA, CPRA, GDPR).

Key principle: Arelo does NOT collect, store, or maintain personal user accounts. You do not create a login, and we do not store a profile with your name, email, or other identifying information.

2. What Data Arelo Collects

2.1 Location Data (Required for Core Functionality)

When you use the Nearby Stops tab or Map view, Arelo requests permission to access your device's location (approximate, while using the app).

What happens to location data:

• Your location is used only on your device to calculate nearby transit stops and show them on a map
• Location coordinates are rounded to 2 decimal places (~100 meters precision) before being sent to third-party transit APIs
• Precise GPS coordinates are never logged, stored, or transmitted

APIs receiving location:

• 511.org SIRI API (Bay Area transit): latitude, longitude, and request for nearby stops
• MTA Bus Time OBA API (NYC buses): latitude, longitude, and request for nearby stops
• Open-Meteo Weather API (free service): rounded latitude and longitude to fetch local weather conditions (sunset time, precipitation chance, temperature, wind speed)
• MTA GTFS-RT Feeds (NYC subway, Metro-North, LIRR): No location data sent; these are static, subscription-based feeds

Location is NOT sent to:

• Arelo (we have no backend servers to receive it)
• Google AdMob or any advertising network
• Any tracking or analytics service

If you deny location permission, the app remains fully functional except for the Nearby Stops feature (Routes, Favorites, Map, and Settings all work).

2.2 Shelter Issue Reports (SF Only, Voluntary)

If you voluntarily submit a shelter damage report on a San Francisco stop via the “Report a shelter issue” button, the following data is sent to SF 311 Open311 API:

• Your rounded location coordinates
• Stop ID
• Street address
• Damage description (you write this)

No personal identifying information is required or collected. We do not ask for your name, email, or phone number for shelter reports. SF 311 may generate a service request token for tracking (displayed to you for your reference only).

NYC users: In NYC, the “Report a shelter issue” button links externally to the NYC 311 website; no data is transmitted through Arelo.

2.3 App Preferences (Stored Locally on Your Device Only)

Arelo uses iOS UserDefaults to store your personal preferences. This data is stored only on your device and never transmitted to Arelo servers (we have none):

Important: Favorites are stored in iOS's shared app group container, accessible to the Arelo widget. Both the app and widget read/write to the same UserDefaults, but this data never leaves your device.

2.4 No User Accounts or Sign-In

Arelo does NOT:

• Require you to create an account
• Request an email address, phone number, or username
• Maintain a user database
• Use analytics services that track user behavior (Sentry, Firebase, Mixpanel, etc.)
• Collect device identifiers beyond what Apple's advertising framework requires

3. Google AdMob Advertising

Arelo displays advertisements via Google AdMob to support free app development. AdMob collects and uses data for targeted advertising.

3.1 What Google AdMob Collects

• Apple Identifier for Advertisers (IDFA): A unique identifier used for ad personalization (only if you grant App Tracking Transparency permission)
• Behavioral signals: Information about your interactions with the app used to infer interests for ad targeting
• Device type and OS version: For ad delivery compatibility
• Approximate location (if you granted location permission): May be used for location-targeted ads

3.2 Is AdMob Data “Sold” or “Shared” Under CCPA/CPRA?

Arelo does NOT “sell” personal information to AdMob in the strict legal sense (CCPA § 1798.100). AdMob operates as a service provider that processes advertising data on our behalf, not as an independent buyer of personal information.

However, CPRA (effective January 1, 2023) expanded the definition to include “sharing” for cross-context behavioral advertising (CPRA § 1798.140(af)). When Arelo sends your in-app behavioral signals to AdMob for personalized ad targeting across apps and websites, this constitutes “sharing” under CPRA.

Summary for California residents:

• Arelo does not sell personal information (under CCPA definition)
• Arelo does share behavioral signals with AdMob for targeted advertising purposes (under CPRA definition)
• You have the right to opt out of this sharing — see Section 3.4 below

3.3 App Tracking Transparency (ATT)

When you first open Arelo, a native iOS dialog appears asking: “Allow Arelo to track your activity across other apps and websites?”

• You tap “Allow”: IDFA is enabled, AdMob can serve personalized ads using your device identifier
• You tap “Ask App Not to Track”: IDFA is disabled, AdMob still receives behavioral signals but cannot link them to your cross-app identity
• You can change this later: Go to iPhone Settings > Privacy > Tracking and toggle Arelo on/off

Important: ATT controls IDFA sharing (cross-app tracking), but does not control whether in-app behavioral signals are sent to AdMob. In-app behavior is shared with AdMob for ad targeting even if you decline ATT.

3.4 “Do Not Sell or Share My Personal Information” Option

Under CPRA, you have the right to opt out of “sharing” your behavioral signals with AdMob for cross-context targeted advertising.

To opt out: Go to Settings > Privacy > “Do Not Sell or Share My Personal Information” and enable this toggle.

What this does:

• Disables the sending of your in-app behavioral signals to AdMob for personalization
• AdMob will serve contextual ads only (based on the content of the page you are viewing, not your behavior)
• Non-personalized contextual ads still appear; you do not get fewer ads
• This setting is stored locally on your device and applies immediately
• This toggle is independent from Apple's ATT setting

3.5 Privacy Details for Google AdMob

• Google Privacy Policy
• Google AdMob Data Disclosure

4. Data Shared With Transit Agencies and Weather Services

4.1 511.org (Bay Area Transit)

Data sent: Route ID, Stop ID, rounded location coordinates, request timestamp.

511.org returns real-time arrival predictions for SFMTA Muni, BART, Caltrain, AC Transit, and SF Bay Ferry. It does not use this data for tracking or marketing. Governed by 511.org Privacy Policy.

4.2 MTA Bus Time (NYC Buses)

Data sent: Route ID, Stop ID, rounded location coordinates for nearby-stop searches.

Returns real-time bus arrival predictions. Governed by New York MTA's Privacy Policy.

4.3 MTA GTFS-Realtime Feeds (NYC Subway, Metro-North, LIRR)

No personal data is sent. Feeds are free to access; some require an API key for authentication, but no user identification is transmitted.

4.4 Open-Meteo Weather API

Data sent: Rounded location coordinates and timezone.

Open-Meteo explicitly states it does not track users or sell data. See Open-Meteo Privacy Policy.

5. Website Analytics (arelo.app)

The Arelo website (arelo.app) uses Vercel Analytics to understand how visitors use the site. This is separate from the iOS app and does not affect app data handling.

5.1 What Vercel Analytics Collects

• Page views: Which pages were visited and in what order
• Referrer: The URL of the page you came from (if any)
• Device type: Mobile, tablet, or desktop
• Country: Derived from IP address (IP is not stored)
• Browser and OS: General type and version

5.2 What Vercel Analytics Does NOT Collect

• No cookies are set
• No IP addresses are stored
• No cross-site tracking or fingerprinting
• No personally identifiable information

Vercel Analytics is designed to be privacy-friendly and does not require a cookie consent banner. See Vercel's Privacy Policy for full details.

6. Your Rights and How to Exercise Them

6.1 California (CCPA/CPRA)

If you are a California resident, you have the following rights:

• Right to Know: What personal information is collected, how it is used, and whether it is shared for behavioral advertising. See Sections 2 and 3.
• Right to Delete: You do not need to contact us — simply uninstall the app or go to Settings > General > iPhone Storage > Arelo. We have no servers storing your data. For AdMob data, see Google's CCPA deletion requests.
• Right to Opt-Out of Sharing: Go to Settings > Privacy > “Do Not Sell or Share My Personal Information” and toggle it ON.
• Right to Non-Discrimination: Privacy choices do not disable the app or reduce its functionality.
• Global Privacy Control (GPC): Arelo honors GPC as a valid opt-out signal. See globalprivacycontrol.org.

To submit a CCPA/CPRA request, email us at areloapp@proton.me. We will respond within 45 calendar days.

6.2 EU/EEA (GDPR)

If you are in the EU or EEA, you have rights under GDPR:

• Lawful Basis: Legitimate interest (transit arrival predictions) and consent (location permission, ATT).
• Right to Access: Email areloapp@proton.me to request a copy of any data we have.
• Right to Erasure: Uninstall the app for local data. For AdMob data, submit a request to Google.
• Right to Data Portability: You can export your favorites directly in the app via Settings > Data > Export Favorites.
• Right to Object: Disable ATT in Settings > Privacy > Tracking and/or disable AdMob sharing in Settings > Privacy > “Do Not Sell or Share”.
• International Data Transfers: AdMob may transfer data to the US based on Google's Standard Contractual Clauses (SCCs) under GDPR Article 46.

6.3 Other U.S. States

Some U.S. states (Virginia, Colorado, Utah, Montana, Delaware) have comprehensive privacy laws. If you are in these states, your rights are similar to CCPA (right to know, delete, opt-out). See Section 6.1.

7. Data Retention

8. Security

• All transit API calls use HTTPS (encrypted in transit)
• API keys are stored in the app bundle and never transmitted
• Location data is rounded before being sent to any third party
• No data is stored on Arelo servers (we have no servers)
• Favorites are stored in iOS's shared app group container

9. Contact Us

For questions about this privacy policy or to exercise your rights, email us at areloapp@proton.me. We aim to respond within 45 calendar days.

10. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of material changes by updating the “Last Updated” date at the top and posting a notice in the app if applicable. Your continued use of the app after changes constitutes your acceptance of the updated policy.

11. Compliance Details

11.1 Business Exemption Status (CCPA/CPRA)

As a small, free transit app with minimal data collection, Arelo likely qualifies for exemption under all three CCPA thresholds (revenue, data volume, data monetization). However, to be maximally transparent, this policy provides full disclosures and opt-out mechanisms as if we were subject to CCPA/CPRA.

11.2 App Store Compliance

• Guideline 5.1.1 (Privacy): Full privacy policy disclosed in SettingsView and on web
• Guideline 5.1.2 (ATT): ATT requested before AdMob SDK initialization
• Guideline 2.3.2 (Arrivals are estimates): Arrival disclaimer included in StopDetailView
• Guideline 2.5.18 (SKAdNetwork): 50 ad network IDs declared in Info.plist

11.3 Info.plist Declarations

<key>NSLocationWhenInUseUsageDescription</key>
<string>Arelo uses your location to find nearby transit stops and show them on the map.</string>

<key>NSUserTrackingUsageDescription</key>
<string>Tracking helps us serve personalized ads to support free development. You can disable this in Settings.</string>