Last updated: October 25, 2021
Who we are?
Voltas IT (company code: 303255404, address: Karaliaus Mindaugo pr. 38, Kaunas, 44307, Lithuania) is a controller of the personal data you provide to us.
What does this document mean?
Voltas IT (“us”, “we”, or “our”) operates the https://obdeleven.com/ website (“Website”) and the OBDeleven mobile application (“App”).
What principles we follow?
We process your personally identifiable information (“Personal Data”) in accordance with these data processing principles:
• we process Personal Data in lawfully, fairly and transparent manner in relation to the data subject;
• the Personal Data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• only adequate and relevant Personal Data are processed limited to what is necessary in relation to the purposes for which they are processed;
• we process only accurate and, where necessary, kept up to date Personal Data;
• Personal Data we process are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Personal Data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
What information we collect?
We collect and use the following information to provide, improve and protect our Services:
1. Personal Data
When you use our Services we collect certain Personal Data:
• When you use our Website:
o You can create Your Account. In such case we collect: your first name and last name, email address and phone number. This information is needed only if you want to create the account and facilitate the purchase of our products.
o In order to purchase our products, you do not need to create Your Account. However, we still need to collect the following information to be able to sell you our products: your first name and last name, email, phone number, shipping address and payment information.
• When you use our App:
- In order to be able to use our OBDeleven product with the App, you have to:
- Set up your App account by providing your email address and username; or
- Sign in through “Facebook” or Twitter”.
Through this option, you may choose to have personal information and other content about you available from such social networks, transmitted and shared through the Services.
When you connect to the social network account through the Services, we only collect such information which you allowed the social network(s) to share with third parties (such as your name, email address, list of friends, profile picture, other information available via the applicable social network). You understand and agree that the Services may access, make available and store (if applicable and as permitted by the third party social network) such information so that it is available on and through your App account, until your account is deleted.
o The user provides information on vehicle model, brand, and identification number (VIN) for the purpose of being able to use OBDeleven product with the App.
• When you agree to receive our newsletter, offers or other similar information, we collect your email address for direct marketing purposes.
2. Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").
This Usage Data may include information such as IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We may also receive information about your location.
3. Tracking Cookies Data
Why such information is collected?
• To provide and maintain the Services.
• To notify you about changes to our Services.
• To allow you to participate in interactive features of our Services when you choose to do so.
• To provide customer care and support.
• To provide analysis or valuable information so that we can improve the Services.
• To monitor the usage of the Services.
• To detect, prevent and address technical issues.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions;
• Process orders and to send information and updates pertaining to orders;
• We may also send you additional information related to your product and/or service.
Is the processing lawful?
• Processing of Personal Data is necessary for the performance of a contract to which the data subject is party (Article 6 (1) (b) of the General Data Protection Regulation), i.e. to purchase our products, install and use the App. The provision of such personal data is a contractual requirement and the data subject is obliged to provide the personal data, otherwise the data subject will not be able to purchase our products and/or use the App.
• Processing of Personal Data is also necessary when the data subject has given consent to the processing of his or her personal data for direct marketing purposes (Article 6 (1) (a) of the General Data Protection Regulation). The data subject is not obliged to provide such personal data. However, if such data is provided, the data subject has the right to withdraw consent at any time.
Is the Personal Data transferred?
We may share information as discussed below, but we won't sell it to advertisers or other third parties:
1. Post and Courier services
In order to be able to send you our products, which you purchased in our Website, we have to provide the delivery companies your personal information, such as: your name and surname, shipping address and telephone number.
We provide these shipping methods:
- Standard shipping. Package will be sent via Lithuanian post (AB Lietuvos paštas, company code: 121215587, address: 16 J. Jasinskio Street, 03500 Vilnius, Lithuania).
- Express shipping. Package will be sent via DHL express (UAB "DHL LIETUVA", company code: 111529785, address: 81 Dariaus ir Girėno Street, 02189 Vilnius, Lithuania).
- United Parcel Service (UPS). Package will be send via UAB „Skubios siuntos“, company code: 134678891, address: 3 Inovacijų Street, Biruliškės, Kaunas district, Lithuania, which is Authorised Service Contractor for UPS.
2. Others working for us
3. Law & Order
We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of us or our users; or (d) protect our property rights.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Lithuania and choose to provide information to us, please note that we transfer the data, including Personal Data, to Lithuania and process it there.
4. Manufacturer of supported vehicles
After each connection to the control unit, protected by SFD (Schutz Fahrzeug Diagnose / Vehicle Diagnostic Protection), some of your data (the pseudonymised user ID (name), pseudonymised workshop ID (if applicable), country and or the vehicle VIN code) will be transferred to the Volkswagen Group, which will analyse your actions.
If the Volkswagen Group detects violations of security requirements or other non-compliances and submits a request to us, we will also transfer to the Volkswagen Group and/ or investigative authorities your other personal data – full name, address, e-mail, telephone number and workshop ID and address (if applicable).
How long Personal Data is kept?
When you purchase our products, we will keep your Personal Data for no longer than 10 years (unless we need to keep the data longer under our agreement with the Volkswagen Group - as described below) after which time it will be destroyed. Your information we use for marketing purposes will be kept with us until you or your lawful representative notify us that you no longer wish to receive this information.
If you delete your accounts from our Services, we'll also delete this information. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
Please note that a different procedure than the one above applies to your personal data, which we must provide to the Volkswagen Group.
We will store your personal data, e. g. first name, surname and contact details (postal code, city, street, phone number and e-mail), as well as the vehicle’s VIN code and the pseudonymised ID code assigned to you, for 30 years from the last use of the SFD service (even after your account is removed from our system). The above storage and transfer of your data is required for the traceability of changes made to the SFD-protected control unit (the changes you can make using the Mobile Application and OBDevelen hardware).
The Volkswagen Group, after receiving your personal data, can analyse and store it in its system for 30 years from the last access to the SFD service. The Volkswagen Group will process your personal data, if necessary, under the ground of a legitimate interest (Article 6 (1f) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR) and in compliance with the legal obligations imposed on the Volkswagen Group by Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles.
As well as in other cases, when your personal data is processed for the purpose of providing it to the Volkswagen Group, you can exercise your rights as a data subject - to object to the processing of personal data, to request the deletion of personal data, correction of inaccurate data, etc.). In order to exercise the above rights, you must first contact us, Voltas IT, and we will forward your request to the Volkswagen Group.
Detailed information on how the Volkswagen Group can process your personal data can be found here
We will inform you each time when there is a change in the Volkswagen Group's data processing rules (as far as the processing of your personal data is concerned).
By deleting your account, you lose your vehicle’s history, PRO/ Ultimate subscription, and all credits. Used PRO/ Ultimate subscription that you have will not work anymore with another account.
How we protect children privacy?
Our Service does not address anyone under the age of 13 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
What rights do you have?
We respect your legal rights to Personal Data.
Your rights under law and measures we take to implement them are:
The right to access You have the right to access your information. You can receive the information about purposes of processing; Personal Data we keep; providers and receivers of your Personal Data; retention period and your rights if requested.
The right to rectification If the Personal Data we hold about you is inaccurate or not complete, you have the right to ask us to rectify it. If that Personal Data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data.
The right to erasure If we do not have a legal basis to continue processing your Personal Data, you can ask to exercise your “right to be forgotten”.
The right to restrict processing You have the right to ask for restriction on how we process your Personal Data This means we are permitted to store the Personal Data but not further process it.
The right to data portability We must consider your right to reuse gathered Personal Data for your own purposes across services in a safe and secure way without this affecting the usability of your data.
The right to object If the processing of Personal Data is based on your consent, legal obligation or legitimate interest you have the right to object such processing.
The right to withdraw consent If the processing of Personal Data is based on your consent you can reject your consent at any time.
The right to complain to a Supervisory Authority If you think your rights is being violated you can complain to Supervisory Authority of Republic of Lithuanian Valstybinė duomenų apsaugos inspekcija, L. Sapiegos str. 17, Vilnius, [email protected]
We will do our best to help you exercise your rights, All the requests regarding the your rights on Personal Data can be sent to us by email [email protected] or [email protected] or by mail Karaliaus Mindaugo str. 38, Kaunas, Lithuania, along with document proving the identity of data subject.
If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via email) of any such deal and outline your choices in that event.