Policy on the processing of Personal Data
ULU B.V. (“we” or “ULU”) offers a platform and services, whereby real time information on usage and operations of a vehicle and driving is collected and analysed (“Services”). These connected services are enabled by use of the ULU device (an OBD dongle) (“Hardware”), which transmits data over a secure connection to the ULU cloud. By using the ULU application on your web browser, mobile phone, tablet and other wearable’s or using the ULU API, you have access to the collected data and analysis results.
This Policy on the processing of Personal Data (“Policy”) applies to information relating to you as an identified or identifiable natural person (“Personal Data”), which ULU collects and processes. With concern to the processing of Personal Data in relation to the Services, ULU qualifies as the data controller.
ULU respects your privacy and deals carefully with your Personal Data. We will process your Personal Data in accordance with European data protection laws and regulations, more specifically with the Dutch Data Protection Act (Wet bescherming persoonsgegevens) and Telecommunications Act (Telecommunicatiewet).
This Policy describes the types of Personal Data and other data we process in relation to the provision of the Services, how we use the data and with whom we share it. This Policy addresses our privacy practices relating to the provisioning of the Services.
Contact details of ULU
ULU Technologies (UK) Limited
16 Charles II st.
London SW1Y 4NW
+ 44 (0) 203828 7100
Personal Data and other data that ULU processes
In order to make optimal use of our Services, you should register an ULU account via the Website. With an ULU account, the generic data that is processed about your vehicle becomes accessible and can be linked to you (Personal Data). Without an ULU account, ULU cannot link the data to you. With the ULU application you can also easily access your Personal Data and feedback data regarding your vehicle. Currently, our Services are only available for Apple or Android mobile devices.
When you register with ULU and use our Services, you agree that ULU collects and processes the following types of Personal Data:
- name and surname;
- email address;
- home address details and country;
- bank- or credit card details;
- telephone number (not a mandatory field);
- age (not a mandatory field);
- gender (not a mandatory field);
- vehicles’ license plate number;
- type of vehicle.
Via the Hardware, ULU transfers the following data:
- information from your vehicle’s onboard computer (e.g. on-board diagnostics and trouble codes, malfunctions, fuel and air metering and auxiliary emission controls);
- information about your vehicle’s operation (e.g. battery voltage levels, speed, braking and acceleration metrics, engine start/stop and idle times);
- vehicle location information.
- If you have downloaded the ULU application, ULU may also collect and process your mobile device location information, depending on your privacy settings on your mobile device. If you do not allow your mobile device to share the location information with ULU, this may disable certain features of the Services.
Purposes for processing your (Personal) Data
ULU processes your Personal Data to provide you the Services as described above. The purposes for processing your Personal Data in that respect are described below.
Personal account and app
When you register for an ULU account via our Website, you will be required to fill in certain Personal Data, such as name, home address, email address and optionally your telephone number, age and gender. ULU will use this Personal Data to communicate with you regarding its products and services, updates, developments and new interfaces concerning the Services and to deliver to you the Hardware that connects your vehicle to the ULU cloud.
If you prefer not to receive our digital newsletter any more, you can inform us by clicking on the ‘unsubscribe’ link in the email or by regular mail.
As far as you apply online for a subscription with ULU in order to make use of the Services, your bank- and/or credit card details will be processed. In order to process the payment, we make use of the services of a payment service provider.
ULU will in principle use your email address to communicate with you, however, we may also communicate with you by SMS or telephone if specifically requested by you and/or for specific services, such as crash- or urgency alerts.
Enhance driving experience and improve vehicle performance
The information from your vehicle’s operation and onboard computer will be sent to the ULU cloud via the Hardware. If you have an ULU account you are able to access this data. The feedback on your vehicles operation and performance provides you with insight into your driving style, which can help you save on gas and vehicle wear and tear. We request for the details of your vehicle and license plate number so that we can provide you with more precise feedback based on your specific vehicle model.
The information on the location of your vehicle, including trip route and the parked location, allows you to review a particular route that you’ve driven, the associated fuel costs therewith and the duration of a specific route. The parked vehicle location feature on the ULU application also enables you to find your vehicle.
The location information and all other information about the vehicle while driving, is transmitted through the Hardware’s location services (GPS, WiFi, cell tower triangulation). If the Hardware is removed from the vehicle, the operation and performance information about your vehicle is no longer transmitted to the ULU cloud. Please note that this may also disable features of the Services, such as vehicle location sharing.
Analysis and market research based on de-identified or non-personally identifiable data
ULU will also conduct analysis with the information that is generated via its Services, for example information about driving habits, and combine it with information of other users. ULU will only conduct such analysis with de-identified (anonymized or pseudonymized) data, i.e. data that is not in any way linked to an identified or identifiable individual. We may, for example, also disclose aggregated driver statistics to current and prospective business partners in order to describe the Services of ULU. Examples of such aggregated data may include the average morning work commute time or the average monthly cost of gas.
Storage of your Personal Data
Your Personal Data and data derived from your vehicle’s operation is stored in the ULU cloud. We make use of the cloud hosting services of Amazon. Amazon’s cloud services have been given approval by the group of European Union data protection authorities, known as the Article 29 Working Party, for compliance with its data protection regulations worldwide, giving customers the assurance their data is being given the same level of protection whether it is stored in a data center in Europe or elsewhere. The data that ULU collects, are stored on Amazons servers within the European Union only.
We will not keep your Personal Data any longer than permitted by law and necessary for the achievement of the purposes of the processing or for the period of time for which you have provided permission to us. Also, if the subscription period ends without renewal, the Hardware will automatically stop transferring and upload new data.
Parties that have access to your Personal Data
ULU will use your Personal Data for the purposes as indicated under paragraph 4. Only engineers and personnel of ULU that require access to Personal Data in order to perform their job activities will have access to your Personal Data. We will not share your Personal Data with third parties, unless with your prior consent.
In addition to the aforementioned, ULU may disclose Personal Data in the following circumstances:
- when obliged by law;
- when necessary to protect your vital interests or those of another person where you are physically or legally incapable of giving your consent;
- when necessary for the establishment, exercise or defense of legal claims.
In the event of a corporate sale, merger, reorganization, dissolution or similar event relating to ULU, your Personal Data may be part of the transferred assets. You will be notified of any such change in ownership.
If you use the Crash Alert feature, we may share your location and other necessary Personal Data with emergency responders and your emergency contacts in the event of a reported crash.
The ULU application also allows you to share information regarding your vehicle with people you choose. This feature allows you for example, to share your vehicle’s parked location with the people with whom you share the vehicle.
Security and protection measures
ULU takes the secure storage and protection of your Personal Data seriously and will use appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing.
Examples of our security and protection measures include:
- Personal Data relating to your ULU account is logically segregated by account-based access rules. User accounts have unique usernames and passwords that must be entered when downloading the ULU application.
- Account passwords and email addresses, are stored in encrypted format;
- All communications through our Services are sent over SSL/TLS connections. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) technology protects communications by using both server authentication and data encryption. This ensures that data in transit is safe, secure, and available only for intended recipients.
- ULU applications and infrastructure are regularly tested for security vulnerabilities and hardened to enhance security.
- We use the approved cloud services of Amazon.
Although we take all commercially reasonable steps to secure and protect your Personal Data, we cannot guarantee the security of your Personal Data that you have provided to us for 100%. In the event of a breach of the confidentiality or security of your Personal Data, we will notify you as far as legally required. In any event, you should also take care with how you handle and disclose your Personal Data.
Via your personal account you have access to your Personal Data and the possibility to correct this data. Also, you can send us an enquiry or request to correct the Personal Data in your account by email (firstname.lastname@example.org). Following this, we will answer to your enquiry or request ultimately within 4 weeks after receipt of such request. We withhold the right to charge to you the legally permissible amount per request.
ULU uses functional analytical cookies in order to be able to provide you with the best possible services. Cookies are files that websites send to your computer or other Internet-connected devices to uniquely identify your browser or to store information or settings on your mobile device. The information the cookies collect include for example, the frequency of visits, browser type, pages visited on the website and the duration of the visit. At each visit to our website our web server automatically recognizes your domain name and if already known to us, your email address. When visiting our website, we keep
– All information concerning the pages you have visited on our site
– All the information that you provide voluntarily (eg research information and / or site registration)This information is used
– To customize the content and layout of our pages and optimize for each individual visitor
– In order to contact you for marketing purposes
The information is only used internally and is not passed on to other organizations for commercial purposes.
– To record your preferences
– To record information specific to you, such as the web pages you have consulted to reach our site
– To register your previous activities on the site
– To ensure that you do not repeatedly receive the same advertisements
– To adjust the content and presentation of the site based on your browser type or other information sent by the browser
We have no partnerships or special relationships with third parties on the Internet.
When we transfer or receive your data on our website, we always use encryption technologies that are recognized as accepted standards within the IT sector.
We have introduced the necessary security measures to avoid loss, misuse or prevent alteration of information that we receive on our site.
Updates of the Policy
The legislation on privacy and also our products and services may change from time to time. In order to keep this Policy up to data, ULU has the right to unilaterally amend the contents of this Policy. ULU advises you to regularly consult the Policy. Your continued use of our Services after any changes or revisions to this Policy represents your agreement with the terms of the revised Policy.
Eindhoven (NL), July 2015