These data protection regulations apply to the use of the CarLo connect Chat solution developed by Soloplan GmbH and made available to you.

CarLo Connect can only be used in conjunction with Soloplan GmbH’s main product, CarLo.

1. Responsible body

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

2. Our Data Protection Officer

If you have questions regarding the data processing carried out by us as the responsible body, you can reach our Data Protection Officer at the following contact details: [email protected]

3. General information

Due to the sensitive issue of data protection, it is particularly important for us to guarantee the protection of your personal data.

Soloplan GmbH therefore undertakes to process the data of users of this app in accordance with the provisions of the applicable laws, in particular the General Data Protection Regulation (GDPR),  Federal Data Protection Act (BDSG) and the Digital Services Act (DDG). This also applies to our employees, who are constantly urged to be extremely careful when handling data and are specially sensitized to this.

The data protection declaration is intended to inform you about what data is collected via this app and for what purposes. It is also intended to give you an understanding of how this data is used, to whom it may be passed on and how you can assert your rights in the event of a possible violation.

 4. Installation of CarLo Connect

To use the CarLo Connect app, you must register using our main app CarLo. For this purpose, the app is made available exclusively via distribution platforms operated by third parties, so-called app stores. Downloading the app requires prior registration on the distribution platform and installation of the respective software. Soloplan GmbH has no influence on the collection, processing and use of personal data in connection with the respective app store and the app store software. In this respect, the responsible body is solely the operator of the respective app store.

5. Required authorizations of the app

CarLo Connect can access various functions on your device. It is therefore necessary that your device grants the following permissions:

• Device & App History
  • Reading of confidential log data
• Location
  • Determination of the approximate location (network-based)
  • Determination of the exact location (GPS and network-based)
  • Access to additional location provider commands
• Photos/Media/Files
  • Reading USB memory contents
  • Changing and deleting USB memory contents
• Memory
  • Reading USB memory contents
  • Change or delete USB memory contents
• Camera
  • Recording of pictures and videos
• Other
  • Retrieving network connections
  • Access to all networks
  • Execution at startup
  • Control of the vibration alarm
  • Deactivation of the sleep mode

In order to provide you with this app and the associated functions, it is necessary to collect personal data from you.

Personal data is “individual information about personal or factual circumstances of a specific or specifiable natural person (data subject).

Personal data also includes data collected in the course of use by the App (such as GPS location information).

6. Type of data collected and processed

The following data is collected via the app

• Text messages
• Information about registration in the app (Name, Email-Adress)
• Smartphone data
  • Operating system
  • Device model
  • App version
• GPS location data while driving
• Date and time of the trip

7. Purposes of data processing

Soloplan GmbH pursues the following purposes with data processing via this app:

• Transmission of telematics data from the app to the main product CarLo
• Optimization of app functions by evaluating driving and usage data
• Troubleshooting

8. Transfer of data to third parties

As part of our business activities, we work together with various external organisations. In some cases, it is also necessary to transfer personal data to these external organisations. We only pass on personal data to external bodies if this is necessary for the fulfilment of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in the transfer in accordance with Art. 6 para. 1 lit. f GDPR or if another legal basis permits the transfer of data.

We use MS Azure for the Connect APP. MS Azure is certified ISO/IEC 27701:2019 Privacy Information Management – Microsoft Compliance / Microsoft Learn. MS’s contact details are: Microsoft EU Data Protection Officer, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland, Phone: + 353 (1) 706-3117

As Data Storage Location we have chosen the Netherlands (Europe West).

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service.

When using processors, we only pass on our customers’ personal data on the basis of a valid contract for order processing. In the case of joint processing, a joint processing agreement is concluded.

9. Storage period/deletion of data

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the deletion will take place after these reasons no longer apply.

10. Change of the privacy policy of the appp

Soloplan GmbH reserves the right to change these data protection provisions without notice. An up-to-date version can be found on our website at any time:

Each time you use the app, please inform yourself about the data protection regulations which apply at the time.

11. Assertion of your rights

In the following, you can find information on the data subject rights which the applicable data protection law grants you vis-à-vis the controller:

You are entitled to request information concerning the data processed by us; Art. 15 GDPR. In particular, you can request information about the purpose of processing; the category of personal data; the categories of recipients to whom the personal data has been or will be disclosed; the envisaged storage period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data is not collected from the data subject, any available information as to its source; the existence of automated decision-making, including profiling and, if applicable, meaningful information about their details.

Furthermore, you have the right to obtain from the controller without undue delay the rectification of inaccurate personal data or to have incomplete personal data completed; art 16 GDPR.

You have the right to obtain from the controller the erasure of personal data if it is not required for the processing of the exertion of the right of freedom of expression and information; for compliance with a legal obligation; for reasons of public interest; for the establishment, exercise or defence of legal claims; Art. 17 GDPR.

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, you have the right to revoke consent you have given, with future effect; Art. 7 (3) GDPR. In the case of revocation, we will immediately delete the data concerned, unless further processing cannot 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.

If your personal data has been processed by us on basis of legitimate interests in accordance with Art. 6 (1) lit. f GDPR pursuant to Art. 21 GDPR you have the right 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 [email protected].

12. Data security

We use state-of-the-art technical and organisational security measures to protect personal data from loss, falsification or access by unauthorised persons. Only authorised persons have access to your personal data, and only to the extent that this is necessary for the above-mentioned purposes.

To ensure data security, the app uses secure passwords and encrypted communication throughout between the end user and the recipient of the data. In addition, unauthorised access can be completely ruled out by linking the access data to the main CarLo software.