Privacy policy app

  1. WHO WE ARE

The controller for the information described in this privacy policy is E-TRAILER B.V. – Molengraaffsingel 12, 2629 JD Delft, the Netherlands (hereinafter referred to as “E-Trailer” or “we“).

  1. TO WHICH THIS PRIVACY POLICY APPLIES

This privacy policy applies to the E-Trailer App (“App“) offered by us. This privacy policy describes the processing and use of your personal information by us in connection with the App.

  1. DATA WE COLLECT

In order to use the App, we collect certain personal information from you, such as login and profile information provided by you, and the information generated in the course of using the App. Below you will find more information about the personal data we collect, process and store about you.

Registration details

When you create an account, you will provide us with at least your login details (“Registration Details“) including your:

    • e-mail address;
    • password;
    • first name;
    • last name;
    • address;
    • country; and
    • language.

In addition, when creating your account, you have the option (but not the obligation) to provide the following information (“Additional Profile Information“):

    • profile picture(s);
    • picture of your vehicle;
    • license plate number;
    • brand of the vehicle (e.g. Burstner, Hobby, Eriba, etc);
    • type of vehicle (e.g. 465, Bianco, etc.);
    • model of the vehicle (e.g. Nova SL, 500fu, Sudwind 450, etc.);
    • kind of vehicle (e.g. motorhome, caravan, etc.);
    • the different weights related to the vehicle (e.g. total weight when full, total weight when empty, etc.); and
    • sizes of the vehicle (e.g. wheelbase, distance between axes, overall length, overall width, etc.).

You can voluntarily post this information on your profile. If you provide such information about yourself, it will appear on your profile and you agree that we may disclose it to other users.

The Registration Details we collect are what we need in order to offer the App to you and together with the Additional Profile Information they help us optimize the App.

Sensor data

Depending on which types of sensors you have purchased from E-Trailer, we will collect certain information from those sensors. We collect this information to provide you with the App (and to help us optimize the App). Depending on the type of sensor, we will collect different information, as set out in more detail below:

  • E-Level
    • Vehicle orientation
  • E-Pressure
    • Pressure
    • Temperature
    • Voltage of the sensors
  • E-Temperature
    • Temperature
    • Humidity
    • Voltage of the sensors
  • E-Switch
    • Door open or door closed
    • Voltage of the sensors
  • E-Volt
    • Voltage battery
  • E-Waterlevel
    • Water level
    • Temperature
    • Voltage of the sensors
  • E-Gaslevel
    • Gas tank level
    • Temperature
    • Voltage of the sensors
    • Photo of gas bottle
  • E-Load
    • Weight on jockey wheel
    • Temperature
    • Voltage of the sensors
  • E-GPS
    • Location E-Connect+ (latt, lung)
    • Time
    • Temperature
    • Telephone location (latt, lung)
    • Speed
    • Height
  • E-Luminate
    • Lights on / off
    • Temperature
    • Voltage of the battery

Usage data

When you use the App we will use the information you provide to provide and optimize the App. In addition, we collect hardware and software information (such as IP address, model, language settings, crashes and operating system) about the device you are using to access the App. This information is only processed to ensure the proper functioning of the App and to optimize (your user experience of) the App.

To measure the success of our App and to further improve the App, we also keep aggregated statistics on the total number of matches and downloads, as well as statistics related to promotions in the App. This information is aggregated and cannot be traced back to our users.

Other data

  • If you have given us your consent, we will process your contact details to notify you of promotions and offers (for example, by sending push messages in the App).
  • If you participate in our promotions, events or contests, we collect the information you provide for registration or participation. Such participation is entirely voluntary.
  • When you contact us, we receive information from you (such as your email address) which we use to correspond with you and to fulfill your possible requests. We keep these conversations for 5 years (including complaints from others about you or vice versa).
  1. HOW WE USE YOUR INFORMATION

We have already described a number of purposes for which we use your personal data. For the sake of completeness, the following is a list of all the different purposes and on what basis we do this.

  • To create your account, manage it and deliver the App to you;
  • To be able to participate in contests or other promotions;
  • To communicate with you and possibly fulfil your request if you contact us;
  • To offer you (if you have given your permission) relevant promotions, offers and advertisements (e.g. via push messages;
  • To improve the App and possibly develop new services or applications (g. adapting certain functionalities based on feedback and/or user behaviour);
  • To prevent, detect and combat fraud or other illegal or unauthorised activities (e.g. analysing uses to prevent or address misconduct or other fraudulent activities);
  • To comply with our legal obligations (g. for tax or similar obligations).

In order to process your information for the purposes described above, we rely on the following legal principles:

  • To fulfil a contract we enter into with you: For example, when you create a profile, and when you participate in a competition organised by us.
  • To protect the legitimate interests of E-Trailer or other third parties (not overriding your interests and fundamental rights): In the event of fraudulent use of the App, but also in the context of improving and protecting the App, for investigating complaints and answering questions (raised by you).
  • To comply with legal obligation(s): In the context of tax obligations or where E-Trailer is obliged to respond to enforcement requests.
  • With your permission: For example, when we want to send you further promotions or offers, or in cases where you enrich your profile with (not required) (sensitive) data. When we ask for your consent, we will clarify the purpose at that time. You can withdraw your consent at any time by contacting us using the contact details in paragraph 8.
  1. HOW WE SHARE YOUR DATA

In order to offer you the App, your personal information will be shared with third parties whom we engage to assist us in running and offering the App.

With our service providers and partners

We use third parties to help us run and improve the App. These third parties assist us with a variety of tasks including data hosting and maintenance, analytics, customer service, marketing, advertising, payment processing and security activities.

We may also share information with partners who distribute advertisements and help us advertise the App. For example, we may share limited information about you in broken-down, non-human-readable form with advertising partners.

We follow a strict screening before hiring a service provider or working with a partner. All our service providers and partners must agree to strict confidentiality obligations.

  1. CROSS-BORDER DATA TRANSFERS

Personal data collected for the purposes of the App will be processed exclusively within the European Economic Area (“EEA”).

  1. YOUR RIGHTS

Where possible, you can access, modify, correct or delete your personal data yourself, using the following solutions and tools:

  • In the App. If you are logged in to the App you can access or correct your e-mail address and/or password, you have provided to us through your account settings.
  • Device settings. Most devices/telephones have authorization systems for specific types of data, notifications, and (push) messages. You can change the settings on your device to collect the information or display push messages (for example, by accepting or refusing to display messages from the App). However, please be aware that the App (or certain features therein) may lose limited or full functionality if you refuse or discontinue your collection permission.
  • Uninstall. You can stop the collection of personal information by uninstalling the App using the default uninstall process on your device. If you uninstall the App from your mobile device, the unique ID associated with your device will remain stored. If you then (at a later date) reinstall the App on the same mobile device, we will be able to re-associate this ID with previous activity.
  • Removal. You can delete your account by sending a deletion request to info@e-trailer.nl.

Under applicable privacy and data protection laws, you have a number of rights that you can invoke (in whole or in part). You have the right to ask us for a copy of your personal data; to correct, delete or restrict the processing of your personal data; and to obtain the personal data you provide for a contract or with your consent in a structured, machine-readable format and to ask us to pass (transfer) this data to another data controller.

In some cases, you may also object to the processing of your personal data (especially if we do not need to process the data in order to comply with a contractual or legal requirement, or if we use the data for commercial communications).

These rights may be limited, for example, if fulfilling your request would disclose personal information about another person, if it would violate the rights of a third party (including our rights), or if you ask us to delete information that we are required to keep by law or where we have compelling legitimate interests in keeping it. When we respond to a request you have made, we will, of course, inform you of the relevant (legal) waivers that we rely on for that particular request.

In order to exercise your rights, or to obtain other information, please contact us. Please note that for your own protection, or the protection of other users, we may ask you to provide proof of identity before we can respond to a request submitted.

If you have (further) unresolved issues, you have the right to complain at any time to the data protection supervisory authority where you live, work or where you believe a breach has occurred.

  1. HOW TO CONTACT US

If you would like to know more about how we process personal data, if you are concerned about how we process your data, or if you would like to unsubscribe from direct marketing, you can do so:

  • email to: info@e-trailer.nl; or
  • write to: E-TRAILER B.V., Molengraaffsingel 12, 2629 JD, Delft.

As previously indicated, before we can provide you with information or correct possible errors, we may ask you to confirm your identity and/or provide us with additional information so that we can comply with your request.

  1. HOW WE PROTECT YOUR INFORMATION

We are committed to protecting the personal data we process about you from unauthorised access, alteration, disclosure or destruction and to processing your personal data in accordance with applicable privacy and data protection laws.

We regularly monitor our systems for potential vulnerabilities and attacks and regularly review our procedures for collecting, storing and processing information to update our physical, technical and organizational security measures. While we take every precaution to protect your personal information, we cannot guarantee that your personal information, chats and other communications will always be secure.

We may therefore suspend your use of all or part of the App without notice if we suspect or detect a breach of security. If you believe that your account or information is no longer secure, please contact us as soon as possible using the contact details provided in this Privacy Policy.

We disclaim any representation or warranty, express or implied, relating to any breach of security, damage to your device or any loss or unauthorized use of your registration data or other data.

  1. HOW LONG WE KEEP YOUR DATA

We only retain personal data for as long as we need it for the purposes (as set out in paragraph 4) and as permitted by law. We will process your account information for as long as you are an active user of the App and for one year thereafter. Your account information will therefore be retained for up to one year after your account has been deleted, although the account will of course no longer be (publicly) visible in the App.

Our starting point is that we will delete or anonymise your data (i) one year after deletion of your account or (ii) after four years of continuous inactivity. Exceptions to this are if:

  1. we need to retain the data longer to demonstrate compliance with applicable law (e.g., records of consents to our terms, and other similar consents are retained for five years);
  2. there is an outstanding issue, claim or dispute that requires us to retain the relevant information until it is resolved; or
  3. the information is retained for our legitimate business interests, such as fraud prevention and improving user safety and security. For example, information may need to be retained to prevent a user who has been banned because of unsafe behaviour or security incidents from opening a new account.

Please note that even if you delete the data from your profile, or delete your entire account, copies of that data may be visible to the extent that it is shared with others, stored by other users of the App or shared with search engines. We cannot verify this, nor can we accept any liability for it. If you have given third party applications or websites access to your personal data, they may also retain such data.

  1. PRIVACY POLICY CHANGES

This policy may be reviewed from time to time. The most current version of this privacy policy can be found in the application. We will communicate any changes as appropriate.

This privacy policy was last updated on: September 29, 2020

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