Privacy Policy

1. Introduction

The https://www.veturilo.io/ website (the “Website”) is provided by Veturilo LLC, based in 1209 Orange Street New Castle Wilmington DE (“Veturilo”, “We”). Veturilo and its affiliate are committed to respect your privacy and respective data protection laws and regulations. This Privacy Policy (the “Policy”) intends to inform you about the way we use your personal data (i.e. any data related to an identifiable natural person, either directly or indirectly), either we collect them, when you visit our Website or when ordering and using our Services through the Veturilo App.

By accessing and using this Website, you confirm that you have read and fully understood this Policy, that you agree to the collection and the usage of your own and others’ personal data in accordance with the Policy and that you have the authority to provide Veturilo with all information submitted by you via the website, including but not limited to the personal data of third parties.

2. General Principles of the Processing

We collect and process personal data in a transparent manner, to the extent necessary for specified, explicit and legitimate purposes, and do not process it further in a manner incompatible with those purposes. We take care that the data we collect are accurate and, when necessary, updated. We take all reasonable steps to immediately delete or rectify personal data, if inaccurate. We process data in a way that guarantees their security, including their protection against unauthorized or unlawful processing and accidental loss, destruction or degradation, using appropriate technical or organizational measures. We are ready to prove at any moment how we adhere to the above principles. We take the appropriate technical and organizational measures for the security, confidentiality, integrity and availability of the data. These measures ensure that, by definition, personal data are not made accessible without the intervention of the natural person to an indeterminate number of natural persons. We respect your rights under the General Data Protection Regulation (GDPR) and applicable data protection laws and regulations.

3. Usage of data we collect about you

3.1 When visiting our Website

Veturilo is the “Data Controller” of all personal data collected through the Website. This means that Veturilo determines the means and the purposes of the processing and is responsible to reply to your requests about the usage of your personal data.

3.1.1 Cookies

A cookie is a small data file stored by your browser at your device’s hard disk for record-keeping purposes, namely it records information about the use and activity on the Website. This information may include, but is not limited to, your Internet Protocol address, browser type, but also user’s web browsing history before visiting the Website, our Website’s search history. Some cookies are “first party cookies”, which means that they are set by us. Cookies set by parties other than us are called “third party cookies”.

Cookies are used for different reasons.

There are the necessary cookies, which are required for technical reasons in order for a website to operate. Some cookies are used to enhance the performance and functionality of a website, but are non-essential to their use. However, if you decide not to accept such cookies, certain functionality may become unavailable. Such cookies are called preferences cookies. Some cookies collect information that is used in aggregate form to help a website owner understand how a website is being used. Such cookies are called statistic cookies and they are either first party or third-party cookies. A third party, for example Google stores a Google Analytics cookie in order to be able to differentiate between users and be able to show a website owner how many times people visit a website on average (not individually) and information on what pages they’ve seen, how long the duration was, and so on. Some cookies are used for marketing purposes. These are the “marketing cookies” and are third-party cookies. Third-party cookies are placed by providers (e.g. by Google, Facebook), who a website owner may have engaged to provide advertising services on his/her behalf. If, from the analysis of information collected by third-party cookies, visitors of a webpage are interested in one of the services, then advertising material would be projected on third party websites. To see how data is collected and analyzed by third party cookies, you can visit third parties’ respective websites.

When you visit our Website, you are asked to consent to the use of cookies, and our Cookies Notice informs you about the type of Cookies we use, their provider, the type of data they collect, their purpose (eg session, personalization, marketing etc) and their expiry. You may choose to consent to none, one or more of the above cookies. You may withdraw your consent to the use of cookies any time during your visit to our Website freely and easily by clicking on “Manage Cookies Settings” button next to our “Privacy Policy” button.

Additionally, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

Further details on our specific use of cookies are contained in the following table:

Type	Purpose	Who Provides the Cookie?	Settings and Opt-out
Optional	Advertising	Google Adwords	https://adssettings.google.com/authenticated
Optional	Advertising and Social Media	Twitter	https://twitter.com/personalization
Optional	Advertising and Social Media	LinkedIn	https://www.linkedin.com/psettings/advertising/actions-that-showed-interest
Optional	Advertising and Social Media	Facebook	https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
Required	Analytics	Google Analytics	https://support.google.com/analytics/answer/6004245?hl=en-GB
Required	Analytics	HotJar	https://www.hotjar.com/blog/hotjar-approach-privacy/

3.1.2 Newsletter

If you wish to receive our Newsletter, for example announcements about new offers and actions of Veturilo, you may enter your e-mail address on this Website. Your email address is solely used for the purpose of sending our Newsletter and you are removed from the Newsletter recipient list, once you choose to unsubscribe. You may be removed from this list, easily and without cost, by selecting the “unsubscribe” link within the e-mail content. You can also send an email at info@veturilo.io.

To send the Newsletter, we use Mailchimp, a US based company, registered under the Privacy Shield list, as a provider of electronic communication platform. The location of the facilities used for our files is defined by Mailchimp. For the privacy policy of Mailchimp see here.

3.1.3 Contact Form

If you wish to communicate with us by using the contact form, you may enter your name, e-mail address, your telephone number, the matter you would like to discuss about with us and write your message in the dedicated space. Such personal data is used solely for the purpose of responding to you, and we keep your data only as long as it is necessary to respond to your request.

3.2 When ordering our Services

Veturilo is the “Data Controller” of all personal data collected when ordering our Services. We collect data for your personal identification, namely your email address, your name and surname. We collect your Tax Registration Number and billing address for billing purposes, as well as your shipping address to send you the OBD II device. These personal data is necessary for the conclusion of the Subscription Services Agreement between us and the billing of the Services. Your credit card data is not collected by us, but by Stripe, a third party payment platform. To view the privacy policy of Stripe, please click here.

We keep the above personal data for the duration of the Subscription Services Agreement and after termination of the agreement for as long as it is required by law for accounting and tax purposes, and in case of a judicial challenge to defend our claims.

3.3 When using our Services

3.3.1 Roles and responsibilities

Veturilo is the “Data Processor” for all personal data you provide to us, when using our Services, or that the Veturilo App collects for the provision of the Services. This means that these personal data is collected on the Customer’s/Account Owner’s behalf for his/her own purposes, that Customer/Account Owner is solely responsible for the legality of these purposes and the necessity of the processing to serve these purposes, and that the Customer/Account Owner is the Data Controller of personal data processed, while using the Services. Therefore the Customer/Account Owner is responsible to satisfy the requests of the data subjects, whose personal data is processed through the Veturilo App, for example the personal data of the driver. Additionally the Customer/Account Owner is responsible to inform the drivers (and any other person whose personal data is processed by usage of the Veturilo App) about the scope, the purpose, the duration and the means of the processing, and to acquire the consent of the data subjects (drivers/employees etc.) whose personal data is being processed through the Veturilo App. Veturilo executes a Data Processing Addendum with the Customer/Account Owner as an integral part of the Subscription Services Agreement, whereby also the security measures implemented by Veturilo and Veturilo App are described.

Veturilo may also use traffic and behavioral data in aggregated and anonymous form collected by the Veturilo App to improve the Services.

Attention: If the Customer/Account Owner is an employer, then the employees must be aware that the information Veturilo App collects about them, the vehicle, and their driving behavior will be available to their employer, including their vehicle location and its use and manner of operation (including but not limited to trip distances, acceleration, deceleration, turning, speed and revolutions per minute).

If Customer has allowed the use of the Services by a Customer ‘s employee, contractor, agent or any other individual or affiliate legal entity and affiliates’ employees, contractors, agents or other individuals by generating new user’s accounts, then, before signing in to their new account, Users of the Veturilo App will have to acknowledge that they have read and understood the Privacy Policy of the Veturilo App. However, Customer remains fully responsible to inform the Users about the scope, the purposes, the duration and the means of the processing through the Veturilo App.

3.3.2 Types of personal data processed

We collect the type of your vehicle and the driver’s name for the operation of the Services. Optionally, you may also provide us with the Vehicle Identification Number (VIN). Once you have downloaded the Veturilo App and you have installed the OBD II device provided by us by plugging it into your vehicle’s OBD II port, the OBD II device collects data from your vehicle’s brain-box (ECU) and sends it to the cloud via a SIM card. Data — such as vehicle speed, fuel levels, RPM, battery level, trip distance, and much more — are sent to the cloud, namely to our third party cloud provider, at regular intervals. The OBD II device collects information about your vehicle’s use, operation, location, performance, speed (for calculating miles driven and for providing driving tips), braking and other driving behavior information (also for driving tips), diagnostic codes, and maintenance status. Location status is reported periodically, every 30 seconds. In this way Customer/Account Owner knows the exact spot of the vehicles, whether they are travelling or are parked. Alerts are reported in real time. Save snapshots of their current status and share their location. Customer/Account Owner can track the mileage, complete with log history, get historical data per trip with behavioral indicators and malfunction alerts, and see the routes on the map.

Veturilo App produces alerts and notifications, in real time, concerning

driving behaviors such as hard braking, fast accelerations, sharp turns, speed or RPM
for crucial and minor events related to the vehicle’s status such as battery power, fuel levels and more,
for unexpected external events
for crucial malfunctions concerning your vehicles (DTC). Veturilo App sends an alert whenever a dashboard indicator light turns on, in order for you or your mechanic to assess the problem.
towing and OBD removal alerts.

Use the Business trip indicator for deductible expenses

We keep the above personal data for the duration of the Subscription Services Agreement. In the meantime you may delete any personal data stored in the Veturilo App by clicking the available deletion buttons in the dashboard of the Veturilo App. After termination of the agreement, you may choose to either have the data stored in the Account deleted or returned to you.

4. Security

Either we collect personal data as Data Controllers or as Data Processors, we take appropriate technical and organizational security measures to protect the integrity, accessibility and confidentiality of personal data. These measures are physical and environmental security measures, as well as IT security measures, including but not limited to the use of updated anti-virus and firewalls, safe protocols, user authentication processes, encryption, data separation, vulnerability and penetration tests etc. We also have in place specific procedures for incident management and a Data Breach Policy.

5. Sharing your Data – International Data Transfer

5.1 Sharing of Data for the provision of the Services

We do not share personal data with any third party,

unless required to do so by law; in such a case, we shall inform you of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest, e.g. to protect confidentiality of a criminal investigation.
unless in the case of our affiliate: Veturilo R&D Center (Athens – Greece) as well as our associates, solely for the provision of the Services.

We have made sure, by means of a written contract or assignment that our processors and sub-processors comply with this Privacy Policy, and provide at least the same level of data protection as we do, for example they follow reliable technical and organizational security measures.

You may see a full list of our non-affiliate sub-processors, their location and addresses by clicking here.

5.2 Social media

You may be able to access third party social media services through our Website by using social media plugins on our website. In that case personal data may be transferred to this third party, based on this party’s Privacy Policy. Make sure you read the Privacy Policy of this third party, before you proceed to the plugin. Our website reminds you of that, before it activates the uses of the relevant social media plugins.

6. Your Rights

We respect your rights as a data subject under the GDPR and under other applicable data protection laws and regulations. Bear in mind that we are entitled to answer to your requests, when acting as Data Controllers. When we are acting as Data Processors the Data Controller, our Customer is responsible to address your requests. However, we shall provide any reasonable assistance to the Data Controller for the satisfaction of your rights.

You should know that you have the following rights under the GDPR.

6.1 Information and Transparency

You have the right to be informed about any processing of your personal data (the purpose, scope, duration and means, as well of data sharing). We adhere to the principle of transparency in processing. For any question regarding this Policy you may contact us at info@veturilo.io. We will respond without delay and in any case within one month upon receipt of the request.

6.2 Access

You have the right to receive from us confirmation on whether your personal data are processed and in case this happens, all required information thereof (processing means, goal, records etc.). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

6.3 Rectification

You have the right to require the rectification of incomplete or inaccurate data relating to you without undue delay, as well as to fill in incomplete data, if necessary for processing.

6.4 Erasure

You have the right to ask for the erasure of personal data concerning you without undue delay. We shall erase the data where one of the following grounds applies: a) personal data is no longer necessary in relation to the purposes of processing; or b) the person requesting the erasure withdraws consent on which the processing is based (for example in case of our newsletter) and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased in compliance with a legal obligation. We shall not proceed to the erasure of the personal data, if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment, exercise or defense of legal claims. You can also choose to delete data stored in your Account or your Account itself in the way described earlier in this Policy.

6.5 Restriction of processing

You have the right to request restriction of processing, if the accuracy of personal data is disputed, for that period of time that allows Veturilo to verify the accuracy of personal data or based on any other legitimate reason specified in applicable data protection laws. For example, you may ask us to suspend the processing of your personal data, if you want us to establish its accuracy or the reason for processing it.

6.6 Data Portability

You have the right to receive your Personal Data in a structured, commonly used and machine-readable format as well as the right to request the direct transmission of personal pata by another to another (controller or processor), if this is technically feasible.

6.7 Right to Object

You may oppose the processing of personal data, which takes place based on an overriding legitimate interest of a Data Controller without your consent. In this case, we no longer process your personal data, unless it demonstrates imperative and legitimate reasons for the processing that outweigh the interests, rights and freedoms of you as a data subject or for the establishment, exercise or defense of legal claims.

If you have ordered and receive our Newsletter, you can, easily and without cost, remove yourself from the recipients list by selecting the “unsubscribe” link within the e-mail content. You may also oppose to processing at any time by contacting us at the email provided at the end of this Policy.

6.8 No automated individual decision-making

We fully respect your right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You have the right to object to such automated individual decision-making.

6.9 Consent Withdrawal

In case you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. In this case we will notify you. For example you can withdraw your consent to our use of personal data by deleting your Account in the way already described in this Policy. You may withdraw your consent to the use of cookies by clicking on the button “Manage Cookies Settings” or choose not to accept cookies by your browser settings.

6.10 Children

Our services are not directed to children. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will immediately delete such information. If you become aware that a child has provided us with his/her personal data, please contact us at the contact information below.

6.11 Complaint to a Supervisory Authority

You have the right to lodge a complaint with a Supervisory Authority, i.e. a Data Protection Authority in a European Union Member State, if you consider that the processing of your personal data infringes the GDPR and applicable data protection laws.

7. Changes to this Privacy Policy

Our Privacy Policy may change from time to time and any changes to this Policy will be updated so as to describe these changes. You are expected to check our website from time to time to take notice of any changes in this Policy.

If you have any further questions about this Policy or how we handle your personal data, which are eventually not dealt with here, please get in touch with us by writing e-mail to info@veturilo.io.

Veturilo R&D Center

1, Lykourgou Str.
GR 10551
Athens – Greece