This privacy statement applies for the usage of the telematics solution CarLo® inTOUCH developed by Soloplan and provided to you.

CarLo® inTOUCH can only be used in combination with the main product CarLo® of Soloplan GmbH.

1. Responsible body for data processing

The responsible body for the collection and processing of data in connection with the app is Soloplan GmbH, Illerhöhe 1, 87437 Kempten, Germany.

2. Introduction

The privacy statement’s purpose is to inform you which data is collected in this app and for what reason. The goal is also to explain how this data is used, to whom it may be disclosed, and how you can assert your rights in the event of a potential breach.

It should be noted that personal data is only collected if you provide it to us voluntarily. No other personal data is collected.

To use the CarLo® inTOUCH app, you must log in to the app using your existing CarLo® login details. For this purpose, the app is made available exclusively via third-party distribution platforms, known as app stores. Downloading the app requires prior registration on the distribution platform and the installation of the relevant software. Soloplan GmbH has no influence over the collection, processing and use of personal data in connection with the respective app store and the app store software; in this respect, the operator of the respective app store is solely responsible under data protection law.

3. Purposes and legal basis of the processing

The data we receive from you will only be processed for the purposes for which you have transmitted it to us. The processing for other purposes can only be considered if the legal requirements in accordance with Art. 6 (4) GDPR are met. We will, of course, comply with the resulting information obligations according to Art. 13 (3) and Art. 14 (4) GDPR.

We process your personal data in accordance with the provisions of the European General Data Protection Regulation (EU GDPR) and the German Federal Data Protection Act (BDSG).

If you expressively consent to the processing of your personal data for certain purposes, the lawfulness of this processing is based on Art. 6 (1) lit. a GDPR. A given consent can be revoked at any time, with effect for the future. Should the consent also apply to the processing of special categories of personal data in accordance with Art. 9 GDPR, we will expressly point this out to you in advance. If it is necessary to provide personal data as part of the initiation or implementation of a contractual relationship or as part of the implementation of pre-contractual measures, this is legitimised by Art. 6 (1) lit. b GDPR.

If necessary and legally permissible, we process your data beyond the actual contractual purposes to fulfil legal obligations in accordance with Art. 6 (1) lit. c GDPR. In addition, processing may be carried out to protect our legitimate interests or those of third parties in accordance with Art. 6 (1) lit. f GDPR. We will inform you separately, indicating the legitimate interest, insofar as this is required by law. If your personal data has been processed on the basis of Art. 6 (1) lit. GDPR to protect the legitimate interest you have the right, in accordance with Art. 21 GDPR, to object to processing of your data for reasons arising from your particular situation, at any time. In such a case, we will not process your data unless we can prove compelling legitimate reasons for processing. These reasons have to outweigh your interests, rights and freedoms, or the processing has to serve to assert, exercise or defend legal claims.

 4. Categories of the collected and processed data

The following data is collected via the app:

• Identity data (information regarding registration in the app, username, name, account status)
• Usage data & log data (technical identifiers, operating system, device model, app version)
• Traffic data (GPS location data during the journey, date and time of the drive, number of drives recorded via the app, telematics data)

5. Purposes of data processing

Soloplan GmbH processes data with this app for the following purposes:

• Transmission of the telematics data from the app to the main product CarLo®
• Optimisation of the app functions through analysation of the driving and usage data, calculation of tour data, navigation, tour optimisation and fleet management
• Troubleshooting

The collection of this data is only carried out if you have enabled location authorisation in the system settings of your device. Once you close the app, the collection is only executed in the background if you have permitted this explicitly in the settings.

6. Data recipients/disclosure of the data to third parties

Within our company, we only pass on your personal data to those areas and persons who require this data to fulfil contractual and legal obligations or to implement our legitimate interests.

Furthermore, your personal data will be processed on our behalf on the basis of contracts regarding the processing pursuant Art. 28 GDPR. In these cases, we ensure that personal data is processed in accordance with the provisions of the GDPR.

Data will otherwise only be passed on to recipients outside the company if permitted or required by law, if the transfer is necessary for processing and thus for the fulfilment of the contract or, at your request, for the implementation of pre-contractual measures, if we have your consent or if we are authorised to provide information.

7. Storage duration/deletion of the data

Soloplan GmbH only saves your personal data as long as it is required for the purpose for which it was collected and if no other legal or contractual requirements (such as legal retention periods) for longer storage exist.

8. Assertion of your rights

Under article 15 of the GDPR, you may, upon request, obtain information regarding the personal data held about you, including the origin of such data, the recipients or categories of recipients to whom the data is disclosed, and the purpose of the storage. Under article 16 of the GDPR, you may also request the rectification of your data if it is inaccurate or incomplete. You may also have the right to have your data erased or locked if its collection, processing or use proves to be unlawful or no longer necessary. Please refer to the list in article 17 of the GDPR for the relevant grounds.

You have the right to obtain from the controller restriction of processing of your personal data if you contest the accuracy of the personal data; the processing is unlawful but you oppose the erasure and we do not require your data anymore, but they are required by you for the establishment, exercise or defence of legal claims; or if you have objected to processing pursuant to Art. 21 GDPR; Art. 18 GDPR.

You have the right to receive your personal data, provided to us, in a structured, commonly used and machine-readable format and to request transmission of the data to another controller; Art 20 GDPR.

In accordance with Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority. In general, you can contact the supervisory authority of the state of our registered office mentioned above or that of your usual residence or place of work.

At any time and with future effect, you have the right to revoke consent you have given with regard to the processing of your data; Art. 7 (3) GDPR. In the case of revocation, we will immediately delete the data concerned, unless further processing can be based on a legal basis for processing without consent. Revocation of consent does not affect the lawfulness of the processing carried out due to the consent up to the revocation.

Right to objection
If your personal data is processed by us on the basis of legitimate interests in accordance with Art. 6 (1) lit. f GDPR, you have the right pursuant to Art. 21 GDPR to object to processing of personal data if this is done for reasons arising from your particular situation. If you object to the processing of personal data for direct marketing purposes, you have a general right to objection without the requirement of specific reasons.

If you would like to make use of your right to objection or revocation of consent, you can contact our Data Protection Officer via e-mail to datenschutzbeauftragter@soloplan.de.

9. Automated decision-making

We do not use purely automated processing to make a decision.