ASPIS GPS Privacy Policy

1. Introduction

ASPIS GPS is a GNSS security application developed and operated by WAY4WARD S.r.l.

ASPIS GPS processes raw Global Navigation Satellite System (GNSS) measurements made available by compatible Android devices in order to detect GNSS spoofing and, where supported by the applicable service level, provide continuity of trusted Position, Velocity and Time (PVT) information.

This Privacy Policy explains what information ASPIS GPS collects and processes, why such information is processed, the applicable legal bases, how information is transmitted and protected, how long information is retained, the service providers involved, how research datasets are handled, and how users may exercise their data-protection rights or delete their ASPIS GPS account.

ASPIS GPS has been designed according to the principles of data minimisation, privacy by design and storage limitation.

2. Data Controller

The data controller for ASPIS GPS is:

WAY4WARD S.r.l.
Via Ruggero Bonghi 11/B
00184 Rome (Italy)
Email for privacy and account-related enquiries: aspis@way4ward.eu

Additional company information is available on the WAY4WARD website.

If WAY4WARD appoints a Data Protection Officer or another dedicated privacy contact, this Privacy Policy will be updated accordingly.

3. Information We Collect

ASPIS GPS processes the following categories of information.

3.1 Account Information

To create and manage an ASPIS GPS account, the following information is processed:

  • email address;
  • ASPIS User ID;
  • authentication status;
  • account status;
  • account creation and account-management information.

ASPIS GPS follows a data-minimisation approach. The application does not require users to provide name, surname, age, date of birth, nationality, postal address, telephone number or demographic information.

The email address is used for authentication, account verification, password recovery, account management and service-related communications.

Authentication is provided using Amazon Cognito, part of the Amazon Web Services (AWS) infrastructure. Authentication credentials are processed through Amazon Cognito. WAY4WARD does not store users’ passwords in the ASPIS GPS application backend.

The user’s email address is not included in ABX GNSS log files. The ASPIS User ID is a technical identifier used for account and operational purposes and is not intended to represent the user’s real-world identity.

3.2 GNSS Measurement Data

ASPIS GPS processes GNSS information made available by the Android operating system and by the GNSS chipset of the device. Depending on the device and Android implementation, this information may include:

  • satellite and constellation identifiers;
  • GNSS frequencies and signal information;
  • pseudorange-related measurements;
  • carrier-to-noise density information (C/N0);
  • Doppler measurements;
  • automatic gain control (AGC) measurements;
  • GNSS receiver clock information;
  • satellite timing information;
  • carrier-phase-related information where available;
  • navigation and measurement status information;
  • other GNSS raw observables exposed by Android.

ASPIS GPS may also generate derived information, including:

  • spoofing-detection results;
  • integrity information;
  • GNSS processing diagnostics;
  • navigation-related information;
  • trusted PVT information, where supported;
  • processing and quality-control information.

Some GNSS measurements and derived information may, alone or in combination with other information, reveal or permit the inference of the geographic position or movement of the device. Such information may therefore constitute personal data during operational processing.

3.3 ABX Log Files

ASPIS GPS creates technical log files using the proprietary ASPIS Android Binary eXchange (ABX) format. Completed ABX log files may be automatically uploaded to WAY4WARD’s cloud infrastructure.

These files may contain:

  • GNSS raw measurements;
  • GNSS timing information;
  • PVT-related information;
  • ASPIS processing results;
  • spoofing-detection information;
  • diagnostic information;
  • technical device information;
  • processing and quality-control information.

ABX log files do not contain the user’s email address or name.

During temporary operational cloud processing, ABX logs are associated with the user’s ASPIS User ID. The ASPIS User ID is used for limited technical purposes including ensuring file uniqueness, avoiding file-name collisions, maintaining continuity between files belonging to the same acquisition, managing uploads and processing, and troubleshooting technical issues.

Because the ASPIS User ID can be linked to the corresponding account within WAY4WARD’s systems, and because GNSS information may allow location to be inferred, ABX files remain personal data in pseudonymised form during this operational phase. They are not treated as anonymous data.

3.4 Device and Technical Information

ASPIS GPS may process technical information required to interpret GNSS data correctly, including:

  • smartphone manufacturer;
  • smartphone model;
  • Android version;
  • Android API level;
  • application version;
  • GNSS capabilities exposed by the device;
  • technical calibration parameters;
  • diagnostic status;
  • processing status.

Such information is required because GNSS capabilities and raw-measurement behaviour can vary significantly between Android devices and GNSS chipsets.

4. Purposes of Processing

WAY4WARD processes information through ASPIS GPS for purposes including:

  • providing the ASPIS GPS service;
  • authenticating users;
  • managing ASPIS GPS accounts;
  • detecting GNSS spoofing;
  • providing trusted GNSS-related information;
  • producing trusted PVT information where supported;
  • processing and analysing GNSS measurements;
  • diagnosing software and GNSS receiver behaviour;
  • evaluating device-specific GNSS behaviour;
  • validating ASPIS performance across different devices and environments;
  • identifying false alarms and missed detections;
  • analysing spoofing and other GNSS anomalies;
  • troubleshooting technical problems;
  • improving ASPIS algorithms and machine-learning models;
  • testing compatibility with Android devices and GNSS chipsets;
  • improving the reliability, security and performance of ASPIS GPS and future ASPIS technologies.

WAY4WARD does not sell ASPIS GPS user data. ASPIS GPS does not use GNSS or location information for advertising or unrelated profiling.

5. Legal Bases for Processing

Different processing activities may rely on different legal bases under Article 6 GDPR.

5.1 Account Creation and Management

Processing required for account creation, authentication, account verification, password recovery and account management is carried out where necessary for the performance of the ASPIS GPS service or for steps taken at the user’s request before entering into that service relationship, pursuant to Article 6(1)(b) GDPR.

5.2 Core ASPIS GPS Functionality

Processing of GNSS measurements on the device for GNSS spoofing detection, integrity processing, trusted GNSS information and trusted PVT functionality where available is carried out where necessary to provide the ASPIS GPS service requested by the user, pursuant to Article 6(1)(b) GDPR.

5.3 Upload and Operational Processing of ABX Logs

Before operational use of ASPIS GPS, users are presented with a dedicated Data Collection & Processing disclosure describing the automatic upload and operational processing of ABX technical logs as part of the ASPIS GPS service.

The upload and operational processing of ABX log files is carried out as necessary to provide the ASPIS GPS service as requested by the user, pursuant to Article 6(1)(b) GDPR. The automatic upload of ABX files is a core technical component of the ASPIS GPS service as currently provided and is necessary for technical validation, troubleshooting, performance assessment and continued improvement of the ASPIS system.

Users are informed of this processing through the Data Collection & Processing disclosure presented before operational use of the application. Where specific research, validation, device-characterisation or model-improvement activities go beyond the immediate scope of providing the service to the individual user, such processing may additionally rely on WAY4WARD’s legitimate interests pursuant to Article 6(1)(f) GDPR, subject to the applicable balancing assessment and the safeguards described in Section 5.4.

5.4 Research, Validation and Anonymisation

WAY4WARD has a legitimate interest in improving the reliability and security of ASPIS, analysing technically relevant GNSS anomalies, validating detection algorithms, reducing false alarms and missed detections, and improving future ASPIS algorithms and models.

Where personal data is processed for research, validation, device characterisation or model-improvement purposes, such processing may rely on WAY4WARD’s legitimate interests pursuant to Article 6(1)(f) GDPR, subject to the applicable balancing assessment, retention rules and safeguards.

Research datasets are not assumed to become anonymous merely because account identifiers are removed. Depending on their technical content, including position, timing and continuous GNSS measurement sequences, a retained dataset may continue to constitute pseudonymised personal data and will be handled accordingly.

Data that has been validly and irreversibly anonymised so that it no longer relates to an identified or identifiable individual falls outside the scope of personal data under the GDPR.

6. Data Collection Disclosure and User Choice

Before operational use of ASPIS GPS, users are presented with a dedicated Data Collection & Processing disclosure informing them of the processing described in this Privacy Policy that forms part of the ASPIS GPS service.

The disclosure informs users that:

  • GNSS measurements and related technical information are processed;
  • completed ABX log files are uploaded to WAY4WARD’s cloud infrastructure;
  • operational files are temporarily associated with the ASPIS User ID;
  • cloud retention is limited;
  • selected technically relevant datasets may be transferred to a controlled R&D environment after removal of account-linked identifiers and may subsequently be retained either as pseudonymised research data or, where the applicable standard is met, as anonymous research data.

Users who do not wish to proceed on those terms may decline, in which case the operational features of ASPIS GPS will not be activated.

7. Temporary Cloud Storage and Retention

Uploaded ABX files are retained in WAY4WARD’s operational cloud environment only for the time strictly necessary for upload handling, technical processing, validation, troubleshooting, identification of technically relevant events and determination of research relevance.

In all cases, operational ABX files associated with an ASPIS User ID are retained for no longer than 7 days. During this operational period, files remain pseudonymised personal data.

Files that do not contain spoofing or other technically relevant events are not intended to become part of the ASPIS research archive and are deleted following processing and, in any event, no later than the applicable seven-day operational retention period.

The cloud environment is therefore used as temporary operational processing and transfer storage, rather than as the permanent ASPIS research archive.

8. Research Datasets, Device-Level Pooling and Anonymisation

Datasets containing spoofing or other technically relevant GNSS events may be selected for research, validation, device characterisation or model-improvement purposes.

ASPIS research is primarily organised around the technical behaviour of smartphone models, GNSS chipsets and device classes rather than around individual users. After operational processing, selected datasets are not intended to be maintained as user-centric histories.

Before selected data are moved from the temporary account-linked operational environment into the longer-term R&D environment, WAY4WARD applies a de-linking process designed to remove the direct association with the originating ASPIS account. This process includes, as applicable:

  • removal of the ASPIS User ID from the research dataset;
  • exclusion of account information such as the email address;
  • assignment of a new dataset identifier unrelated to the originating ASPIS account;
  • non-retention of a persistent lookup table or other permanent mapping between the research dataset identifier and the originating ASPIS User ID;
  • organisation and pooling of research data by technical characteristics such as smartphone model, device type or GNSS chipset rather than by user identity.

Device-specific research corpora may combine large numbers of GNSS measurements, positions, timestamps, trajectories and related technical observations originating from multiple independent users of the same smartphone or device class. The purpose of such pooling is to characterise the GNSS behaviour of the device and to train, validate and improve ASPIS models for that device class, not to reconstruct or analyse the movement history of an individual user.

For some ASPIS research and validation activities, absolute GNSS timestamps, PVT information, position information and continuous measurement sequences may be technically necessary. In particular, they may be required for spoofing analysis, time-consistency analysis, training of ASPIS models and validation or performance assessment of ASPIS-Based Trusted PVT. WAY4WARD therefore does not remove or materially degrade such information solely for the purpose of labelling a dataset anonymous where doing so would compromise the technical or scientific usefulness of the dataset.

Removal of account-linked identifiers and pooling by device type reduce the ability to associate research data with a particular ASPIS account, but do not by themselves guarantee that a dataset is anonymous under applicable data-protection law.

WAY4WARD will treat a retained dataset as anonymous only where, taking into account the content of the dataset and the means reasonably likely to be used for re-identification, it is assessed as no longer relating to an identified or identifiable individual. The assessment may consider, where relevant, risks including singling out, linkability, inference and linkage with other reasonably available information.

Where a technically useful research dataset does not meet the applicable anonymisation standard, it will continue to be treated as pseudonymised personal data. Such datasets will remain subject to applicable data-protection requirements, including an appropriate legal basis, access controls, security safeguards, retention rules and data-subject rights where applicable.

Where a dataset can be validly and irreversibly anonymised without compromising the required research purpose, it may be retained as anonymous research data and used for long-term research, statistical analysis, validation and development of ASPIS technologies.

9. Cloud Infrastructure and Service Providers

ASPIS GPS currently uses Amazon Web Services (AWS) infrastructure for services including Amazon Cognito authentication, backend services, secure API access, operational cloud storage and supporting processing infrastructure.

The ASPIS GPS operational backend and storage are configured in the AWS Europe (Milan) region (eu-south-1).

Where AWS or another provider processes personal data on behalf of WAY4WARD, the provider acts as a processor or service provider subject to contractual and data-protection obligations.

Use of such a processor for providing infrastructure services is not considered a sale of personal data. WAY4WARD does not provide ASPIS GPS user information to advertisers or data brokers.

10. International Data Transfers

WAY4WARD seeks, where available and appropriate, to process ASPIS GPS personal data using infrastructure located within the European Economic Area.

The primary ASPIS GPS AWS infrastructure is currently configured in the AWS Europe (Milan) region.

Cloud infrastructure, support services, subprocessors or remote-access arrangements may nevertheless involve circumstances in which personal data is accessed or transferred outside the European Economic Area. Where such a transfer occurs, WAY4WARD will ensure that it is carried out in accordance with applicable data-protection law using an appropriate transfer mechanism or safeguard, such as Standard Contractual Clauses adopted by the European Commission under Commission Implementing Decision (EU) 2021/914, where applicable.

11. Data Security

WAY4WARD applies technical and organisational measures intended to protect ASPIS GPS information against unauthorised access, alteration, disclosure, destruction or accidental loss.

Measures include, where applicable:

  • authenticated account access;
  • encrypted communications between the application and backend services;
  • restricted cloud-storage permissions;
  • controlled backend access;
  • temporary operational data retention;
  • separation of account data from GNSS technical data;
  • pseudonymisation during operational processing;
  • removal of account-linked identifiers as part of the anonymisation process.

Data transmitted between ASPIS GPS and WAY4WARD cloud services is protected using encrypted network communications.

12. Account Deletion and Data Deletion

Users may permanently delete their ASPIS GPS account directly from the application through Account Settings -> Delete Account.

When an account deletion is completed, WAY4WARD deletes the data that remains associated with that ASPIS GPS account, including:

  • the Cognito authentication account;
  • the email address associated with the account;
  • the ASPIS User ID;
  • the ASPIS GPS backend account record;
  • operational ABX log files and other operational cloud data still associated with the ASPIS User ID.

Users who no longer have access to the ASPIS GPS application may request account deletion through: https://way4ward.eu/aspis-gps-account-deletion/

Research datasets that have been validly rendered anonymous and no longer relate to an identified or identifiable individual are not personal data and are not deleted as part of an account-deletion request.

Research datasets that remain pseudonymised personal data continue to be subject to applicable data-protection, retention and deletion requirements. Where such data remain reasonably linkable to the requesting user, applicable data-subject rights will be handled in accordance with law. For research datasets that have been de-linked from the originating account and for which no persistent account mapping is retained, WAY4WARD will assess, upon receiving a deletion or access request, whether the requesting user’s data can be reasonably identified within the research archive. Where such identification is not reasonably practicable, WAY4WARD will inform the requesting user in accordance with applicable law.

13. Automatic Deletion of Operational Data

ASPIS GPS does not currently provide a separate in-app mechanism allowing a user to delete selected operational log data while keeping the ASPIS GPS account active.

Operational ABX data that remain in the account-linked cloud environment are subject to a maximum retention period of 7 days. Data that are not selected as technically relevant for research, validation or model-improvement purposes are deleted following processing and in any event no later than the end of that operational retention period.

Where a technically relevant dataset is selected for R&D use, it is removed from the temporary account-linked operational workflow and is subjected to the de-linking and device-level research processing described in Section 8. Depending on the resulting re-identification risk, the retained dataset may either remain pseudonymised personal data or, where the applicable standard is met, be treated as anonymous data.

14. Local Data on the Android Device

ASPIS GPS may store ABX log files locally on the user’s Android device.

Local copies remain on the device independently from copies temporarily uploaded to WAY4WARD’s cloud infrastructure.

Deleting an ASPIS GPS account or deleting data from WAY4WARD’s cloud infrastructure does not automatically remove copies that remain locally on the user’s device.

Users may remove locally stored application data using the relevant Android or device-management functionality.

15. Location and GNSS Permissions

ASPIS GPS requires Android location permission because Android protects access to GNSS raw measurements and related satellite information through its location-permission framework.

The permission is used for GNSS spoofing detection, GNSS security processing, navigation processing, GNSS diagnostics and related ASPIS GPS functionality.

Some GNSS measurements and derived outputs may reveal or allow the inference of the geographic location or movement of the device.

ASPIS GPS does not use location information for advertising, marketing profiling or unrelated behavioural profiling.

16. Children

ASPIS GPS is a specialist GNSS security and technical application and is not specifically designed or directed toward children.

WAY4WARD does not knowingly target ASPIS GPS at children for the purpose of collecting personal information.

17. User Rights

Under applicable data-protection law, including the GDPR where applicable, users may have the right to:

  • obtain information about how their personal data is processed;
  • request access to personal data concerning them;
  • request correction of inaccurate or incomplete personal data;
  • request deletion of personal data;
  • request restriction of certain processing;
  • object to certain processing based on legitimate interests;
  • receive personal data in a portable format where applicable;
  • withdraw consent at any time where a specific processing activity is based on consent;
  • lodge a complaint with the competent supervisory authority.

Where a specific processing activity is based on consent, withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Requests may be submitted to aspis@way4ward.eu. Users may also use the account-deletion mechanisms described above.

These rights apply to information that remains identifiable or linkable to the user. Information that has been validly and irreversibly anonymised and no longer relates to an identified or identifiable individual cannot generally be associated with a specific account for the purpose of exercising account-specific rights.

For users in Italy, complaints may also be submitted to the Garante per la protezione dei dati personali.

18. Changes to This Privacy Policy

WAY4WARD may update this Privacy Policy as ASPIS GPS evolves, including when new functionality is introduced, subscription services are introduced or changed, service providers change, processing activities change, or applicable legal or platform requirements change.

The current Privacy Policy will be made available through the WAY4WARD website and will indicate the date of the latest update.

Where required by applicable law or platform policy, material changes will be communicated to users and renewed acknowledgement or other appropriate action may be requested.

19. Contact

For privacy questions, data-protection enquiries, account-related privacy requests or questions concerning ASPIS GPS, contact:

WAY4WARD S.r.l.
Via Ruggero Bonghi 11/B
00184 Rome (Italy)
Email: aspis@way4ward.eu