Privacy Policy

1. Data controller

TRULINU Trade GmbH
Steinbacher Straße 7 A-8075 7434 Redlschlag Österreich
Email: [email protected]

If you have any questions regarding data protection or wish to exercise your rights, simply send an informal message to the contact address given above.

2. Key points at a glance

• Your location and journey details remain on your device: position data from the browser’s location service is processed locally only to estimate speed and acceleration. Coordinates, individual speed readings and routes are neither transmitted to our server nor stored – only the average and maximum speeds per journey (see ‘Internal usage statistics’).
• We only store what is necessary for your account, settings, subscription and internal usage statistics.
• A live chat (Chatwoot on our own server) is available on the home page, the dashboard, the diagnostics page and the subscription page for support enquiries.
• Google Analytics only runs if you give your consent via the cookie banner.

3. Hosting (Railway)

The application and database are operated by Railway Corporation, Market548 St, PMB68956, San Francisco, CA94104, USA. When the website is accessed, the host processes technically necessary connection data (IP address, time, requested address, browser identifier) in order to deliver the page and protect it against misuse. The legal basis is our legitimate interest in secure, reliable operation (Art. [...], para6. [...], lit1. f GDPR). A data processing agreement is in place with Railway (Art. [...], GDPR28). For transfers to the USA, we rely on the EU Standard Contractual Clauses. Further information: Railway’s privacy policy.

4. Account and settings

An account is required to use the service. We store:

• Email address, a securely hashed password (scrypt), the time of registration, email confirmation and the last login,
• Acceptance of the Terms and Conditions (date, version),
• Favourites, most recently selected engine, volume, intensity, gear-changing sounds.

The legal basis is the performance of the user agreement (Art. 6para. 1lit. b GDPR). The data will be deleted when you delete your account; unconfirmed registrations are automatically removed after 7days.

5. Sending emails

For verification codes and subscription notifications (e.g. thank-you emails, payment issues, cancellation confirmations), we use the email delivery service Resend (Resend, Inc., 2261Market Street #5039, San Francisco, CA94114, USA). In doing so, your email address and the content of the message are transmitted to Resend; the EU Standard Contractual Clauses apply to transfers to the USA. Further information: Resend’s privacy policy. The legal basis is the performance of a contract (Art. 6para. 1lit. b GDPR).

6. Premium subscription and payments (Stripe)

Payments for Premium are processed by Stripe Payments Europe, Ltd., Lower Grand1 Canal Street, Grand Canal Dock, Dublin, D02 H210, Ireland. You enter payment details such as card numbers directly with Stripe; we do not receive them. Stripe processes, amongst other things, your name, email address, billing address, payment details, IP address and device information – including for fraud prevention – and may transfer data to Stripe, Inc. (USA) (EU Standard Contractual Clauses, EU-US Data Privacy Framework). We only store your Stripe customer number and subscription status (e.g. active, cancelled, payment outstanding, end of term), as well as any reason for cancellation provided voluntarily. The legal basis is the performance of a contract (Article (b1) 6of the GDPR) and statutory retention obligations (Article (61c) of the GDPR). Further information: Stripe’s Privacy Policy.

7. Internal usage statistics

To help us see which sounds are popular and when the service is used, we store simple events linked to your account, along with the time: logging in, selecting a sound, playing a preview, and the start and duration of a journey, specifying whether the car was driven in the car (GPS) or in demo mode. For journeys in the car, your browser also calculates the average and maximum speeds of the journey and transmits only these two values. For partner campaigns, we also count how often a partner pop-up is displayed and a partner button is clicked – using your account details, or, if you are not logged in, using only an irreversible session identifier, so that we can count people rather than clicks. Locations, individual speed histories, routes and IP addresses are not included; no cookies are set for this purpose and no data is passed on to third parties. The legal basis is our legitimate interest in improving our service (Art. para6. 1lit. f GDPR); you may object at any time. Events are deleted after 400days; when you delete your account, they are retained only in the aggregate totals, without any reference to you.

8. Translation (DeepL)

If you select a language other than German, the text on the website and in our emails is automatically translated using DeepL (DeepL SE, Maarweg165, Cologne50825, Germany). Only the German text from the pages is sent to DeepL – email addresses, numbers and links are removed beforehand; account, location or usage data are not transmitted. We store the translations so that each text is translated only once. We store your chosen language in the ‘lang’ cookie and, if you are logged in, in your account, so that emails are sent in that language. The legal basis for this is our legitimate interest in providing a multilingual service (Art. [...], para6. [...], lit1. f of the GDPR). Further information: DeepL’s Privacy Policy.

9. Cookies and consent

We set technically necessary cookies on the basis of Section (1651) of the Telecommunications Act (3TKG) 2021or Section (125) of the Telecommunications Data Protection Act (2TDDDG) and Article (16)(1b) and (f) of the GDPR. All other services (external media, statistics) are provided only with your consent (Article 6(1a) of the GDPR), which you may withdraw at any time via the cookie settings.

In addition, the browser stores individual display settings locally without any personal reference (e.g. in driving mode).

10. Google Analytics

We will only use Google Analytics, provided by4 Google Ireland Limited, Gordon House, Barrow Street, Dublin4, Ireland, if you consent. Google Analytics analyses how the website is used (e.g. pages visited, time spent on the site, approximate region, device type). IP addresses are truncated by Google within the EU and are not stored; Google Signals and advertising functions are disabled. Data may be transferred to Google LLC (USA); Google is certified under the EU-US Data Privacy Framework. The legal basis is your consent (Art. 6para. 1lit. a GDPR), which you may withdraw at any time with future effect. The data will be deleted after 14months. Further information: Google’s Privacy Policy.

11. Live chat (Chatwoot)

We integrate a chat widget on the home page, the dashboard, the diagnostics page and the subscription page. It runs on our own Chatwoot instance (open-source software), which, like the application itself, is hosted by Railway (see the ‘Hosting’ section) – no external chat provider is involved. When you visit these pages, your browser loads the widget from our chat server; in the process, your IP address, browser and device information, as well as the page you have accessed, are processed, amongst other things. If you use the chat, we also store your messages and – if you provide it – your email address so that we can reply to you. The legal basis for this is our legitimate interest in providing a straightforward support channel and in processing your enquiry (Art. [...], para6. [...], lit1. b and f of the GDPR).

12. TikTok videos on the home page

On the homepage, we display videos from TikTok users via TikTok’s embedded player (TikTok Technology Limited, 10Earlsfort Terrace, Dublin, D02 T380, Ireland). The player is only loaded if you consent to ‘External media’ in the cookie banner (including via ‘Accept all’) or click on a video placeholder – no connection to TikTok is established before this. Thereafter, your browser transmits, amongst other things, your IP address, browser and device information to TikTok; TikTok may set cookies and also transfer data to third countries. The legal basis is your consent (Art. [...], para6. [...], lit1. a GDPR), which you may withdraw at any time via the cookie settings. Further information: TikTok’s Privacy Policy.

13. Fonts and content

Fonts, scripts, images and sounds are served from our own server. No content is loaded from Google Fonts, CDNs or advertising networks. The chat widget loads from our own chat server (see above). Another exception is the TikTok videos on the homepage, which are only loaded with your consent (see above).

14. Retention period

We only store personal data for as long as is necessary for the purposes stated or as required by statutory retention periods (e.g. up to 7years for invoices). Sessions end after days14 of inactivity at the latest.

15. Your rights

You have the right to access (Art. GDPR15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You may withdraw any consent you have given at any time (Article 7paragraph 3). You may also lodge a complaint with a data protection supervisory authority, e.g. the Austrian Data Protection Authority, Barichgasse 40–42, 1030Vienna, dsb.gv.at.