Privacy Policy of tlog.plus

Version 1.0 - March 1 2019

tlog.plus is committed to your privacy. In this privacy policy we explain how we collect, disclose, retain and protect your personal information.

Scope

This privacy applies to the tlog.plus website and any applications, services or tools (collectively "Services") where this Privacy Policy is referenced, regardless of how you access or use the Services, including on mobile devices.

Personal information

Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We do not consider personal information to include information that has been anonymised or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

We collect personal information about you when you use our Services.

For what purposes is your personal information used

To provide our (personalized) Services

We use your personal information to provide the Services to you. We need your Tesla email and a valid token set to be able to retrieve data for your car(s) from Tesla. If you elect to generate the token set by providing your Tesla account password, this password is only used once to generate the token set and is immediately discarded afterwards. We use your TLog+ email address and password to authenticate yourself and to make sure that no other persons have access to your car account and the data associatted with it.

We store and use the data we collect from your car to provide a personalized experience of the Services.

For statistical purposes

We use your data also for statistical purposes, to analyse and improve the use and general operation of our Services. Furthermore, we use your data to generate statistical reports of the usage of the Services.

For customer service

We use your data to get in contact with you for providing support for our Services. We use your name and e-mail address for this.

For detecting and investigating abuse

We use your data to detect, prevent, mitigate and investigate fraudulent or illegal activities or any type of abuse of the Sevices. This is done on a legitimate intrest or legal basis.

Ways to access, control and correct you personal information

We respect your right to access, correct, request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.

Data Collected

We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of our services, fill out a form, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, postal address and other contact or identifying information you choose to provide.

We collect anonymous data from users of the Services to monitor traffic and fix bugs. For example, we collect information like web requests, the data sent in response to such requests, the Internet Protocol address, the browser type, the browser language, a timestamp for the request, etc....

We also use various technologies to collect information, and this includes sending cookies to your computer. Cookies are small data files stored on your hard drive or in your device memory that helps us to improve our services and your experience, see which areas and features of our services are popular and count visits. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our services or emails and to track count visits or understand usage and campaign effectiveness.

We collect data that is available about your Tesla car(s) via the Tesla API. This data is not considered as personal information. It is information about the vehicle, not a uniquely identifiable person. For example: we record the car's location over time, but this cannot be linked to a certain person as anybody could be present (or not) in the vehicle at any time. This data we collect about the car(s) includes the following:

• Vehicle Information: id, vehicle_id, vin, display_name, option_codes, color, tokens, state, in_service, id_s, calendar_enabled, api_version, backseat_token, backseat_token_updated_at
• Charge State: battery_heater_on, battery_level, battery_range, charge_current_request, charge_current_request_max, charge_enable_request, charge_energy_added, charge_limit_soc, charge_limit_soc_max, charge_limit_soc_min, charge_limit_soc_std, charge_miles_added_ideal, charge_miles_added_rated, charge_port_cold_weather_mode, charge_port_door_open, charge_port_latch, charge_rate, charge_to_max_range, charger_actual_current, charger_phases, charger_pilot_current, charger_power, charger_voltage, charging_state, conn_charge_cable, est_battery_range, fast_charger_brand, fast_charger_present, fast_charger_type, ideal_battery_range, managed_charging_active, managed_charging_start_time, managed_charging_user_canceled, max_range_charge_counter, not_enough_power_to_heat, scheduled_charging_pending, scheduled_charging_start_time, time_to_full_charge, timestamp, trip_charging, usable_battery_level, user_charge_enable_request
• Climate State: battery_heater, battery_heater_no_power, driver_temp_setting, fan_status, inside_temp, is_auto_conditioning_on, is_climate_on, is_front_defroster_on, is_preconditioning, is_rear_defroster_on, left_temp_direction, max_avail_temp, min_avail_temp, outside_temp, passenger_temp_setting, remote_heater_control_enabled, right_temp_direction, seat_heater_left, seat_heater_rear_center, seat_heater_rear_left, seat_heater_rear_left_back, seat_heater_rear_right, seat_heater_rear_right_back, seat_heater_right, side_mirror_heaters, smart_preconditioning, steering_wheel_heater, timestamp, wiper_blade_heater
• Drive State: gps_as_of, heading, latitude, longitude, native_latitude, native_location_supported, native_longitude, native_type, power, shift_state, speed, timestamp
• GUI Settings: gui_24_hour_time, gui_charge_rate_units, gui_distance_units, gui_range_display, gui_temperature_units, timestamp
• Vehicle State: api_version, autopark_state_v2, autopark_style, calendar_supported, car_version, center_display_state, df, dr, ft, homelink_nearby, is_user_present, last_autopark_error, locked, notifications_supported, odometer, parsed_calendar_supported, pf, pr, remote_start, remote_start_supported, rt, sun_roof_percent_open, sun_roof_state, timestamp, valet_mode, valet_pin_needed, vehicle_name
• Vehicle Config: can_accept_navigation_requests, can_actuate_trunks, car_special_type, car_type, charge_port_type, eu_vehicle, exterior_color, has_air_suspension, has_ludicrous_mode, motorized_charge_port, perf_config, plg, rear_seat_heaters, rear_seat_type, rhd, roof_color, seat_type, spoiler_type, sun_roof_installed, third_row_seats, timestamp, trim_badging, wheel_type
• Streaming Data: timestamp, speed, odometer, soc, elevation, est_heading, est_lat, est_lng, power, shift_state, range, est_range, heading

By signing up for the service, you give your explicit consent that this information is collected. Without your permission to collect this data, we cannot provide you the Services to the extent that it would not serve any purpose to sign up without having given consent to collect and store this data.

Are my data at risk?

Information exchange via the Internet has certain inherent risks. Hackers and viruses are unfortunately an integral part of it. That is why we cannot with certainty guarantee that loss or access by unauthorized individuals will not occur. Off course we do our utmost best to protect you personal information in the best possible way. We use many diverse security technologies and measures to guarantee your privacy. Furthermore, these technologies and measures are under permanent evaluation in order to protect our systems against viruses and malware.

How can I check the information TLog+ keeps about me?

You have a right of access. This means that you can access the personal information we have about you. You can access this information through the different menu choices offered by the Services. For any information we could have and that are not available in the menu choices, you can contact us via the contact page and we will treat your demand within 30 working days.

You also have a right to rectification. In case the personal information we have about you is (no longer) correct, for example you have changed your email address, you can easily adapt your information in your Account settings page.

You have to right to erasure. If you want that we no longer store or use your data (including car data), you can request that this data be erased. For this you can file a request via our contact page. Please note that we are not always required to meet such requests. We are only required to do so in cases determined by law. Please note that such removal is definite and irreversible. Removal of data can under no circumstances result in any type of refund of any amounts paid, nor does it give any entitlements in the form of credits or other obligations from the Service Provider towards the User. When User requests removal of a User Account, User loses every item of information related to that account, including any (pre-)paid subscription time.

You have to right to restrict processing of your personal information. Should you choose to do so, we will keep your data stored, but will restrict its processing. For this you can file a request via our contact page. Please note that we are not always required to meet such requests. We are only required to do so in cases determined by law.

You have the right to object against the use of your personal information. This will result in the erasure of all your data. For this you can file a request via our contact page and we will treat your demand within 30 days.

You have the right to object against use of your data for direct marketing purposes. TLog+ does not currently do direct marketing based on the personal informtion collected from you. In any case, should you object to such marketing, you can file a request via our contact page and we will treat your demand within 30 days.

TLog+ does not create any individual profiling, nor do we do automated individual decision making.

You have the right to withdraw your consent for the processing of your personal data if the processing is done based on your consent. For this you can file a request via our contact page and we will treat your demand within 30 days. Such a request will result in arasure of all your data. Please note that such removal is definite and irreversible. Removal of data can under no circumstances result in any type of refund of any amounts paid, nor does it give any entitlements in the form of credits or other obligations from the Service Provider towards the User. When User requests removal of a User Account, User loses every item of information related to that account, including any (pre-)paid subscription time.

Right to data portability of your personal data. This offers you the possibility to transfer your personal data from one processing entity to another. For this you can file a request via our contact page and we will treat your demand within 30 days. Please note that we are not always required to meet such requests. We are only required to do so in cases determined by law.

Data retention

Your persnoal data will not be retained longer than is needed for providing the Services.

We will retain any car data 3 months after your subscription has expired. After these 3 months, all your car data (personal and other) will be premanently erased. This gives you plenty of time to renew your subscription without losing your historical data.

All other data will be kept for no longer than 14 months after the user's last usage of the Services. This period is reset whenever the user re-visits the Services (even without logging in). Please note that 14 months is the maximum, but this is by no means a guarantee that data will be kept for 14 months.

Who is responsible for the collection and use of my data

The responsible for the collection and processing of your data is Kurt Vanderlinden, Marie Popelinlaan 3, 3001 Leuven, Belgium.

Sharing of your personal information

We do not disclose your personal information to any third parties.

Aggregated, anonymized data is periodically transmitted to external services to help us improve the Services.

We may allow third parties to provide analytics services. These third parties may use cookies, web beacons and other technologies to collect information about your use of the services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information.

We do not sell, rent or otherwise disclose your personal information to third parties for any purpose including for marketing and advertising purposes without your consent.

We do not share personal information you have provided to us without your consent, unless:

• Doing so is appropriate to carry out your own request
• We believe it's needed to enforce our legal agreements or that is legally required
• We believe it's needed to detect, prevent or address fraud, security or technical issues

About Children

The Website is not intended for children under the age of 13. We do not knowingly collect personally identifiable information via the Website from visitors in this age group.

Cookies

Our Services make use of "cookies". Cookies contain unique codes that for example allow your browser to recognize you while you make use of our services.

Where do cookies come from?

• First party cookies: these are cookies that TLOG+ directly manages. They are specific for the Services and allow the Services to function correctly.
• Third party cookies: these are cookies that TLog+ does not manage directly. A third party manages them. These cookies are created/used when you make use of the Services. Through these cookies, certain data are sent to third parties by making use of the Services. Examples are social media cookies or Google Analytics cookies. Although we do not create or control these cookies, we do our utmost to retain streamline their creation by third parties via our Services as much as possible.

We use cookies primarily to enhance the user experience and the general functioning of our Services. Cookies facilitate the interaction between the user and the Services.

We also use cookies to map you surfing behaviour. How did you find your way to our Services for example. Thanks to statistical analysis, we can improve our Services where needed and adapt to specific needs users might have. Furthermore, we use this analysis to make aggregated reports on the usage of our Services.

What types of cookies do we use?

• Functional cookies: Cookies needed for the basic functioning of the Services. Example: we store the email address you use to login to the services in a cookie so that you do not need te enter it over and over again when you login. For this type of cookie, no permission is required and as such these cookies cannot be disabled.
• Statistical cookies: These cookies collect general statistical information about the way our Service are used. They allow us to make statistical analyses of the information we collect in this manner. Examples: how did you find our Services? In what part of the Serices do you spend most time? Using these statistics, we are able to improve the structure, navigation and content of our Services. For this type of cookie, no permission is required and as such these cookies cannot be disabled.
• Marketing cookies: These cookies follow your usage of our Services and are used to allow 3rd parties to provide you with personalized advertising. These cookies can only collect information about what parts of the Serives you use. No personal identification information such as your email address, your name or billing information will be used for these purposes. That information is never shared with third parties.

Cookie lifetime. There are two types of cookies: temporary and permanent cookies. Temporary cookies are stored temporarily on your device. They are removed when you close your browser or your (mobile) application. Permanent cookies remain on your device, even after you close you browser or (mobile) application. They remain until a certain enddate is reached, until a new cookie is installed or until you remove them via the functionality of your browser, (mobile) application or device.

How can you manage the cookies ued for the Services? When you first use the Services, you give your consent to this Policy by continuing to use the Services. In case you want to retract your consent, use your browser, (mobile) application or device functionality to remove the cookies and stop using the Services. By using the service again, you will have provide your consent again.

Changes to the Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.

If we make major changes in the way we collect or use information, we will notify you by posting an announcement on the Website or sending you an email. We will also ask for your permission if it is required to do so.