Data privacy policy

This privacy policy explains how Connected Cars A/S (“we” or “us”) processes your personal data in connection with the Connected Cars service.

1 - Data controller

The legal entity responsible for the processing of your personal data is:

Connected Cars A/S Company registration no.: 3815 3080 Borgmester Christiansens Gade 50, 2450 København Denmark Email: hello@connectedcars.io

2 - Introduction

It is important to Connected Cars A/S (“Connected Cars”) that your personal data is collected and processed securely and lawfully.

We have drafted this privacy policy (“Privacy Policy”) to describe how we collect and process your personal data. We urge you to read the Privacy Policy thoroughly, and you will be asked to confirm that you have read and understood the Privacy Policy when you sign up for Connected Cars services via the Connected Cars application (“Application”), via the Connected Cars website or via the website of your preferred garage (“Websites”).

“You” means the owner and/or the primary user of the vehicle in which the Connected Cars unit is installed. The Connected Cars unit is the physical box (OBD unit) collecting and transmitting data from the vehicle to Connected Cars.

3 - Processing

3.1 - Creating a user account and general use of the app

Activating your vehicle, the OBD box installed in your vehicle and you creating a user in our system, enables you to use the app and enables us to communicate with you about the app.

This involves the following objectives:

1. Creation of user and collection of master data.
2. Distribution of marketing materials, including targeting our communication with you.
3. Optimisation of the user experience in the app and on the Websites: Personal data is collected when you use our Websites. We use this data to further develop and optimise the user experience in the app and on the Websites. For more information, please see our Cookie Policy.
4. Business and product development: Preparation of statistics concerning our services and further development of our services. For more information, please see our Cookie Policy.

We process the following personal data about you:

1. General personal data:
   • Name
   • Address
   • Email address
   • Telephone number
   • Facebook account in case of login via Facebook
   • Your preferred workshop
   • Master data about the registered vehicle, including its brand, year, model and VIN
   • Technical data about the registered vehicle, including information about the vehicle’s equipment and configuration
   • Information about the OBD box
   • Data on the use of the app (please see Cookie Policy).
2. Sensitive data
   • None
3. Personal data about criminal offences and sentences
   • None

We collect information from the following sources:

• Directly from you
• Dealerships/workshops
• The Central Register of Motor Vehicles

We process the personal data for this purpose on the following basis:

• Article 6(1)(a) of the General Data Protection Regulation (GDPR) (consent)
• Article 6(1)(f) of the GDPR (necessary for the purposes of the legitimate interests pursued by us). Our legitimate interests are to be able to provide the services requested by you, to target and distribute marketing, and to further develop the services as regards the user (website and apps) as well as the system (functionality, etc.).

We share the personal data with the following parties:

• Dealerships/workshops
• Suppliers and dealers, including IT suppliers, support, suppliers of goods and financial institutions with whom we collaborate to carry on the activities.

We shall process the personal data as long as it is deemed necessary for the purposes stated.

This means that we shall process the personal data listed in accordance with the above description.

• We shall process your master data as long as you have a user account with us.
• Master data and technical information about the registered vehicle is stored as long as the vehicle is supported by the Connected Cars service.
• If you delete a vehicle from your user account, data will be deleted in accordance with the below description. The reason for this is that “my journeys” and other data in a vehicle might still be relevant to you even though the vehicle has been deleted from the user account.
• If you close your account, all information about you will be deleted within 7 days.

3.2 - Provision of Connected Cars service

Once you are registered as a user and have started using the service, personal data will be processed for the following purposes:

1. Provision of a service requested by you.
2. Business and product development: Preparation of statistics concerning our services and further development of our services.

We process the following personal data about you:

1. General personal data:
   • Information about workshop bookings, etc.
   • Information from the OBD box. Please see table showing services and data points.
2. Sensitive personal data
   • None
3. Personal data about criminal offences and sentences
   • None

We collect information from the following sources:

• Directly from the vehicle
• Dealerships/workshops

We process the personal data for this purpose on the following basis:

• Article 6(1)(a) of the GDPR (consent)
• Article 6(1)(f) of the GDPR (necessary for the purposes of the legitimate interests pursued by us). Our legitimate interests are to be able to provide the services requested by you, to target and distribute marketing, and to further develop the services as regards the user (website and apps) as well as the system (functionality, etc.).

We share the personal data with the following parties:

• Dealerships/workshops.
• Suppliers and dealers, including IT suppliers, support, suppliers of goods and financial institutions with whom we collaborate to carry on the activities.

3.3 - Sharing of personal data to partners

Connected Cars A/S can share your personal data with partners who wish to provide an independent service for you. This will only take place if you have given your consent beforehand in the app or if you have consented to the relevant partner to obtain your personal information from Connected Cars A/S.

3.4 - Storage

We shall process the personal data as long as it is deemed necessary for each of the services selected by the app user. Please see table showing services and data points.

4 - Consequences of processing

By means of the processing activities described, you can gain detailed insight into the use and general condition of the vehicle. It is important to be aware that some of the services offered require the collection of a vast amount of data from the vehicle and that using the “my journeys” function will provide a detailed overview of a person’s use of their vehicle in terms of history as concerns time and place, but also as concerns speed and fuel consumption as a derived consequence of the detailed data collection. Further, the patterns identified in the technical data from the vehicle, such as error codes, may potentially reveal particular patterns of use of the vehicle, such as when the vehicle is used as well as driving style patterns causing excessive strain on the vehicle.

5 - Transfers to countries outside the EU/EEA

Some of the Third Parties with whom we share personal information, may be located outside the EU and the EEA.

For example, we use services from Google LLC., including Google Suite, Google Cloud and Google Analytics, which is why personal information may be transferred to countries outside the EU. You can see a list of locations where Google may process personal information here: https://www.google.com/about/datacenters/inside/locations/index.html.

In some cases, the country is approved by the European Commission as a so-called “Safe Third Country”, otherwise the transfer takes place on the basis of the EU Commission’s standard contractual clauses. You can get a copy of the standard contractual clauses by contacting us at the contact information listed above.

6 - Mandatory information

Information marked with an * is mandatory. If you do not provide this information, you cannot create a user account for the service.

7 - Your rights

You have the following rights:

• You have the right to request access to, rectification of or erasure of your personal data.
• You also have the right to object to the processing of your personal data and to have the processing of your personal data restricted.
• In particular, you have an absolute right to object to the processing of your personal data for direct marketing purposes.
• If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Such withdrawal shall not affect the lawfulness of the processing carried out prior to the withdrawal of your consent.
• You have the right to receive the personal data provided by you in a structured, commonly used and machine-readable format (data portability).
• You have the right to lodge a complaint with a data protection supervision authority such as the Danish Data Protection Agency (Datatilsynet) at any time.

If you wish to invoke your rights, please contact us at hello@connectedcars.dk.

These rights may be subject to conditions or restrictions. Accordingly, you may not have a right to data portability in a specific matter – this will depend on the specific circumstances of the processing activities.

8 – Changes

In the event of any changes to the Privacy Policy, you will receive en email.

Latest update: October 27th 2020