PRIVACY POLICY

for using Ulmon’s Apps, Ulmon User Accounts, Ulmon’s Websites, and the Ulmon Hub

Effective as of 25 May 2018

At Ulmon GmbH we are committed to ensuring and protecting your privacy at any time you are using our apps, websites, or registered via your email or Facebook account on our communication platform “Ulmon Hub” (in the following “platform” or “Ulmon Hub”) which is part of our apps and websites.

We process personal data exclusively in compliance with the statutory provisions of the European General Data Protection Regulation (GDPR), the national data protection regulations based thereon, and the Austrian Telecommunications Act (TKG).

In this privacy policy, we therefore inform you about the most important aspects of data processing in connection with the use of our apps or in the case of your visit to our websites. We provide you with a detailed overview of how we use your information that you provide us with or that we lawfully obtain in accordance with the conditions set out herein.

1. What personal data do we collect from you?

Data can be collected and processed when our platform (Ulmon Hub), apps, or website is used by you. The following are approved methods of collection:

2. Legal basis and purpose of data processing

Your data will be stored and processed solely for the purpose of offering our platform, our apps and related services to you and to offer and improve our websites.

  1. Contract fulfillment: The processing of your email addresses, your Facebook account data, or the user-generated content provided by you is required to fulfill the contract (article 6 (1) (b) GDPR): We collect your data for processing, if you voluntarily decide to enter this data. Your data will therefore be processed if you enter it in our apps or websites, e.g. because you use one of our apps and create content (photos, lists, bookmarks, saved places, ratings, reviews, notes etc). In this case, your created data will be processed solely for the purpose of carrying out the respective service and are therefore necessary for the fulfillment of the App Usage Agreement.

  1. Legitimate interest: We have legitimate interest in the processing of mobile app and website usage logs, server logs, device identifiers and IP addresses (article 6 (1) (f) GDPR). We use this data for the proper operation of our apps, platform and websites, in particular to detect and eliminate errors. Our legitimate interest within the meaning of the GDPR is also the security and optimization of our services and websites. In this case, we also provide data for statistical and analytical purposes, as well as for the optimization of interest-based advertising to third parties in order to improve our services and products (see Annex).

Ultimately, we have legitimate interest in processing email addresses, Facebook account data, user-generated content, mobile app logs and website usage logs and for direct marketing purposes. Only data that you voluntarily make available to us and that we dispose of from the contractual relationship are processed. The primary goal of this data processing is customer retention and customer acquisition. We may use this information to notify you about updates, notifications about our apps, products or services that may be of interest to you. We may use your information to recommend services, products, or offers related to travel on our platform, within our apps or websites. Furthermore, we will send your contact details (email address) to selected external service providers, as these provide email and message service services in connection with direct mail advertising purposes (see Appendix).

  1. Explicit consent: If you explicitly consent in our apps, we process precise location data also with the help of third-party software components (mobile "SDKs"), we may use precise location data by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and share location data with third parties, for purposes related to advertising, attribution (e.g., measuring ad performance) analytics and research including research to benefit non-profit causes (siehe Appendix). We will ask for your explicit consent before using or sharing location informations. You are not required to consent and you can withdraw it at any time (see section 3).

3.  Opt out

4.  Storing and processing your personal data / data protection

We process personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live or outside the European Union if you live in the European Union. We take all reasonable processes to ensure your data is secure and in agreement with our Privacy Policy as outlined here.

We use secured servers to ensure proper data storage. All communication containing personal information is kept encrypted for safety measures.

Transmission of data on the Internet can never be ultimately secure. We do not and cannot guarantee security of information collected electronically or transmitted; however, we take all necessary steps to provide the best security available. As a result of our inability to guarantee safety, you are submitting information to us at your own risk. Where needed a password may be necessary to access areas of our apps or website. You are responsible for the safety and confidentiality of the password you generate.

5.  Disclosing your information

In addition to the cases mentioned in section 2, your data may be passed on to third parties under the following conditions:

6.  Third party links

Any third party web site or app that can be accessed through our platform, our apps or our web pages generally has an own privacy policy. We recommend that you check the conditions defined there. Our privacy policy therefore does not apply to websites or apps that are accessible via hyperlink on our platform (Ulmon Hub), in our apps or on our websites. The content of the linked pages or apps are the sole responsibility of their operators. We expressly exclude any liability and responsibility for the handling of third parties with your data. We point out that third-party websites or apps are beyond our control, we have no control over their data and data processing activities, nor are we aware of the scope of the data collection, the purposes and the retention periods.

8. Contact Informations and Rights

You have a right to information about the personal data that we process (Article 15 of the GDPR), the right to rectification (Article 16 of the GDPR), Deletion (Article 17 GDPR) and the restriction of personal data processing (Article 18 GDPR).

In this case, please contact Ulmon GmbH, Schikanedergasse 2, Top 7, 1040 Vienna, Austria, or send an email to privacy@ulmon.com .

Furthermore, you have a right to appeal to the

Austrian Data Protection Authority,

Wickenburggasse 8-10, 1080 Vienna,

phone: +43 1 52 152-0,

email: dsb@dsb.gv.at

as the competent supervisory authority.

9. Changes to this Privacy Policy

Updates of our Privacy Policy may be completed frequently, thus you should peruse this Policy habitually.

APPENDIX:

For the purpose of contract fulfillment (see section 2a), we work with partners who process personal data for us. These are the following partners:

 Amazon Web Services, Inc., 1200 12th Avenue South, Suite 1200, Seattle, WA 98144, USA, https://aws.amazon.com/privacy/

 Mapbox Inc., 740 15th St. NW, 5th Floor, Washington DC, 20005, USA, https://www.mapbox.com/privacy/

Localytics Inc., 2 Center Plaza, 3rd Floor, Boston, MA 02108, USA,  https://www.localytics.com/privacy-policy/ 

Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA,  https://www.facebook.com/about/privacy 

 Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, https://policies.google.com/privacy   

Due to legitimate interest (see section 2b), we work together with partners who process personal data for us. These are the following partners:

 adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany, https://www.adjust.com/gdpr/ 

 Amazon Web Services, Inc., 1200 12th Avenue South, Suite 1200, Seattle, WA 98144, USA, https://aws.amazon.com/privacy/

 Taplytics Inc., 488 Wellington St W, Suite 204, Toronto, ON M5V 1E3, Canada, https://taplytics.com/privacy/ 

Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA,  https://www.facebook.com/about/privacy 

 Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, https://policies.google.com/privacy 

Localytics Inc., 2 Center Plaza, 3rd Floor, Boston, MA 02108, USA, https://www.localytics.com/privacy-policy/ 

AddApptr GmbH, Alsterufer 4, 20354 Hamburg, Germany, https://www.addapptr.com/impressum-legal-info 

 MoPub (a division of Twitter Inc.), 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, https://www.mopub.com/legal/privacy/ 

 InMobi Pte Ltd, InMobi PTE Ltd, 45 The Brew Eagle House, 163 City Road, London EC1V 1NR, United Kingdom, https://www.inmobi.com/privacy-policy-for-eea/ 

After your consent (see section 2c), we work with partners who process personal data (especially location data). These are the following partners:

 TAMOCO Ltd., 58 Bloomsbury Street, London, WC1B 3QT, United Kingdom, https://www.tamoco.com/data-transparency/

 predict.io GmbH, Engeldamm 64b,10179, Berlin, Germany, https://www.predict.io/privacy-policy/ 

 Areametrics Inc.,1601 5th Avenue #1100, Seattle, WA 98101, USA, https://areametrics.com/privacy-policy/ 

 X-Mode Social Inc., 11955 Freedom Dr, Reston, VA 20190, USA,  http://xmode.io/privacy-policy.html 

 Safegraph Inc., 182 Howard Street, Suite 842, San Francisco, CA 94105, USA,  https://www.safegraph.com/privacy-policy 

 Factual Inc., 1999 Ave of the Stars, Los Angeles, CA 90067, USA, https://www.factual.com/privacy/

 Cuebiq Inc., 45 W 27th Street, 3rd Floor, New York, NY 10001, USA, https://www.cuebiq.com/privacypolicy/ 

 Unacast Inc., 12 East 33rd Street, 10th Floor, New York, NY 10016, USA, https://www.unacast.com/privacy 

 Fysical Labs, Inc., 1 Hallidie Plaza, 2nd Floor, San Francisco, CA, 94102, USA, https://fysical.com/privacypolicy/index.html