Politique de confidentialité

PRIVACY POLICY

 

OOONO A/S

Last updated: June 2026

 

1.     ABOUT THIS PRIVACY POLICY

 

OOONO A/S (“OOONO”) respects your personal data and takes its protection seriously. This Privacy Policy explains what personal data we collect when you use the OOONO app (“the App”), our website ooono.com (“the Website”) and our connected OOONO devices (“the CO-DRIVER”), why we collect it, how long we keep it and what rights you have.

 

OOONO A/S is the data controller for the processing described in this policy. Our main establishment is in Denmark and the Danish Data Protection Agency (Datatilsynet) is the lead supervisory authority for OOONO’s cross-border processing activities within the EU/EEA.

 

2.     DATA CONTROLLER AND CONTACT

 

Company	OOONO A/S
CVR No.	38863398
Address	Gearhalsvej 1, 2500 Valby, Denmark
Email	legal@ooono.com
DPO contact	Frank Hoelgaard Olsen — legal@ooono.com

 

If you have questions about how we process your personal data, you are welcome to contact us at legal@ooono.com.

 

3.     WHY WE COLLECT YOUR DATA

 

We collect personal data when you interact with our services. A purpose describes why we process your personal data — for example, to provide a service or fulfil a legal obligation. The table below gives an overview of each (1) purpose, the (2) data categories involved and the (3) legal basis under the GDPR.

 

Section 5 describes the data categories in detail. For certain processing activities where additional context is required — including our legitimate interest assessments and third-party arrangements — further detail is provided in Section 4.

 

Purpose	Data categories	Legal basis
Creating a user profile To grant you access to the App, we ask you to register basic information about yourself.	User data	Fulfillment of a contract — Art. 6(1)(b)
Using the App and Website To provide our services in accordance with our agreement with you.	User data Usage data	Fulfillment of a contract — Art. 6(1)(b)
Purchase of products To deliver products you have ordered and handle returns and complaints. We may also process purchase data to comply with accounting obligations.	User data Payment data	Fulfillment of a contract — Art. 6(1)(b) Legal obligation — Art. 6(1)(c)
Traffic warnings and location services To deliver accurate and timely traffic warnings via the CO-DRIVER, we collect your location on an ongoing basis while the App is active.	Location data Usage data	Fulfillment of a contract — Art. 6(1)(b)
In-app features and services To provide paid in-app features and services (such as Mileage Book), we collect and process the data necessary to deliver the relevant feature, including location data, trip details and subscription data where applicable.	User data Location data Usage data Payment data	Fulfillment of a contract — Art. 6(1)(b)
Improving and optimising services To evaluate and develop our products, we analyse how users interact with the App and Website, using anonymised or aggregated data where possible.	User data Usage data Location data	Legitimate interest — Art. 6(1)(f)
Customer support (incl. AI-assisted support) To respond to your support requests and resolve issues.	User data Usage data	Fulfillment of a contract — Art. 6(1)(b)
Marketing and newsletter To send you newsletters and targeted digital marketing materials, including advertising via social media platforms.	User data	Consent — Art. 6(1)(a)
Postal direct marketing To send you promotional mailings by post about our own products and services, including discount offers.	User data	Legitimate interest — Art. 6(1)(f)
Social media presence To operate and engage on social media platforms.	User data	Legitimate interest — Art. 6(1)(f)
System and product testing To conduct testing following your acceptance of an invitation.	User data	Fulfillment of a contract — Art. 6(1)(b)

 

4.     ADDITIONAL INFORMATION ON SPECIFIC PROCESSING ACTIVITIES

 

This section provides supplementary detail for processing activities where a fuller explanation is required. For a complete overview of all purposes, data categories and legal bases, please refer to the table in Section 3.

 

4.1 Mileage Book

 

Mileage Book is an optional paid in-app feature within the OOONO app. By default, trips are recorded automatically when your CO-DRIVER device is connected. When the CO-DRIVER is no longer connected to your OOONO app, no route tracking takes place. You can disable automatic recording at any time within the App, in which case trips are only recorded when you start them manually.

 

We record your full route for each tracked trip. Inside the App, your complete route history is visible to you. Your trip data is initially recorded locally on your device, then uploaded to our servers and deleted from your device.

 

Employer reimbursement and commute data: When you export a trip to your employer, the export file contains only the start point, end point and total kilometers driven. For trips marked as private, only the total distance is included — no route details, start point or end point are shared. When you submit data to your employer, your employer acts as an independent data controller for that data.

 

4.2 Payment and subscription services

 

When you purchase a product or subscribe to a paid in-app feature or service, payment is processed by an external payment service provider acting on our behalf. Full card details are never stored by OOONO — these are handled exclusively by the payment service provider.

 

OOONO stores only minimal payment reference data in connection with your account: your email address, card type, last four card digits and card expiry month. A reference identifier is stored in our system solely to link your account to your active payment relationship with OOONO.

 

If a payment attempt fails, you will be notified and given 7 days to update or reauthorise your payment details. If the issue is not resolved within this period, access to the relevant feature or service will be suspended automatically. Continued non-payment may result in termination of your subscription.

 

4.3 Improving and optimising our services

 

We process usage data and, in aggregated or anonymised form, location data to evaluate and develop our services. Our legitimate interest is to improve service quality and user experience by understanding how our products are used. We have assessed that this interest is not overridden by your rights and freedoms, in particular because we use anonymised or aggregated data wherever possible and do not use this data for profiling or advertising. The legal basis is Art. 6(1)(f) GDPR. You have the right to object to this processing at any time (see section 13.6).

 

4.4 Customer support and AI-assisted support

 

Our support service uses an AI-assisted support tool to help handle queries. When you use this channel, you are interacting with an AI system provided by an external data processor. Conversation data is used solely to resolve your support request and is not used to train AI models without your separate consent. No decisions with significant legal or similar effects are made solely on the basis of automated processing through the AI-assisted support tool.

 

4.5 Marketing and newsletter

 

With your consent we send you newsletters and targeted marketing, including advertising via social media platforms. The legal basis is your consent, cf. Art. 6(1)(a) GDPR and Art. 5(3) of the ePrivacy Directive and its national implementations. You may withdraw your consent at any time by using the unsubscribe link in our emails or by contacting us. Alternatively, you can adjust your settings for this yourself in your OOONO app under Profile > Notifications. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

 

4.6 Social media

 

OOONO is active on social media including LinkedIn, Facebook/Meta, TikTok and Instagram. When you interact with us on these platforms, we process the data you make available.

 

Facebook — joint controllership: OOONO and Meta Platforms Ireland Ltd. are joint controllers, within the meaning of Art. 26 GDPR, for the processing of data collected through Facebook Page Insights (statistical data about Page visits and interactions). The essence of our arrangement is as follows: OOONO is responsible for the content published on the Page and for complying with GDPR in relation to data that OOONO directly handles; Meta is responsible for the processing carried out on its own platform, including the collection of Insights data. For information about Meta’s processing and to exercise your rights vis-à-vis Meta, please visit Meta’s privacy center and the Page Insights Controller Addendum at facebook.com/legal/terms/page_controller_addendum. You may direct requests concerning processing for which OOONO is responsible to legal@ooono.com. Our legitimate interest in operating a Facebook Page is marketing and brand communication. You have the right to object to this processing at any time (see section 13.6).

 

4.7 Postal direct marketing

 

We may send you promotional mailings by post — for example, flyers or discount codes — relating to our own products and services. This applies only to customers who have purchased a product from OOONO. The legal basis is our legitimate interest in maintaining customer relationships and promoting our products, cf. Art. 6(1)(f) GDPR. You have the right to object to this processing at any time, free of charge and without giving reasons, by contacting us at support@ooono.com.

 

5.     WHICH PERSONAL DATA DO WE COLLECT?

 

Personal data is any information that can be directly or indirectly attributed to you. When you use our services, we collect and process various personal data about you. For a better overview, we divide the data we process into four categories: location data, user data, usage data and payment & purchase data.

 

5.1 Location data

 

When you use the App with a connected CO-DRIVER, we collect location data on an ongoing basis to deliver traffic warnings. For this purpose, GPS coordinates are collected at specific event-points during your journey: drive start, warnings received and reported, and drive end.

 

When you use the Mileage Book feature, GPS coordinates are collected continuously throughout your trip in order to record your full route. This is necessary to provide the trip recording service. Your trip data is initially recorded locally on your device, then uploaded to our servers and deleted from your device.

 

5.2 User data

 

We collect the data you provide when creating or maintaining your profile: name, gender and email address. We also process data you make available when interacting with us on social media, and your email address when you subscribe to our newsletter. For marketing purposes, we may additionally process your name, city, postcode and telephone number. When you contact support, we process your email address, the content of your messages and any other data you choose to provide. For system and product testing, we process identity data you share voluntarily, such as your name and email address.

 

5.3 Usage data

 

When you use the App or visit the Website, we process your user ID, IP address, network location, app version, device model and operating system. If you choose to share in-app log files to assist troubleshooting, we process those as well — log files are stored on your phone and shared only on your explicit request. Log files may include phone type, operating system, app version, timestamps, error reports and other diagnostic information. We also collect cookie data, including cookie IDs, IP address, browser type, device information, website activity, preferences and consent choices. Where you participate in beta testing, we collect backend usage data about how you interact with the beta application.

 

5.4 Payment and purchase data

 

When you purchase a product or subscribe to a paid in-app feature or service, we process the data you provide: name, address, email address, telephone number, payment method and purchase history. This also includes information about which products you have bought or returned, and data relating to any queries or complaints. We additionally store minimal payment reference data as described in section 4.2. Payment transactions are processed by an external payment service provider. We do not store full card details ourselves.

 

Providing your data: Providing the data marked as mandatory in the App or at checkout is required to enter into or perform our contract with you. If you do not provide this data, we cannot create your account or complete your purchase. Data collected on the basis of your consent is always voluntary.

 

6.     HOW LONG DO WE KEEP YOUR DATA?

 

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, and in any case no longer than permitted or required by applicable law. The table below describes the criteria we apply to determine the appropriate retention period for each of the four data categories. Where a specific legal obligation applies, this is noted in the legal basis column.

 

Category	Retention criteria	Legal basis
Location data CO-DRIVER and OOONO App	Identifiable location data is retained for a maximum of 54 weeks (378 days) from collection, after which it is anonymised automatically. Once anonymised, the data can no longer be linked to you and is no longer considered personal data. The 54-week period has been assessed as the minimum necessary for the purpose of providing the CO-DRIVER service and supporting traffic safety analytics.	Art. 6(1)(b) Art. 5(1)(e) GDPR
Location data Mileage Book (full route, coordinates, trip metadata)	Retained for as long as your Mileage Book subscription is active. Following termination of your subscription, trip data is retained for as long as required by applicable law.	Art. 6(1)(b) Art. 6(1)(c) where a legal obligation applies
User data Name, email, profile, support communications, marketing consent	Account data: Active account plus 30 days after deletion. Inactive accounts anonymised after 3 years without login. Support communications: For the period necessary to resolve your request. Marketing consent: Until consent is withdrawn.	Art. 6(1)(b) Art. 6(1)(a) for consent-based data
Usage data Device info, IP, app version, cookies, log files	Device and app data: For as long as necessary to provide and improve our services. Cookie and tracking data: Retained in accordance with your consent choices and our Cookie Policy. Consent-based cookies are deleted upon withdrawal of consent.	Art. 6(1)(b) Art. 6(1)(f) Art. 6(1)(a) for consent-based cookies
Payment and purchase data	Payment reference data: For the duration of your active subscription. Purchase records: For the period required by applicable bookkeeping and tax legislation in your country of residence.	Art. 6(1)(b) Art. 6(1)(c)

 

If technical constraints prevent immediate deletion — for example in backup systems — we restrict access to the data and ensure it is no longer actively processed.

 

7.     THIRD PARTIES AND DATA PROCESSORS

 

We use carefully selected third-party suppliers and service providers to help us deliver, operate and improve our services. Depending on the relevant processing activity, these third parties may act as data processors on our behalf, independent data controllers or, in limited cases, joint controllers together with OOONO.

Where a third party acts as our data processor, it may only process personal data on our documented instructions and in accordance with applicable data protection law. We have entered into data processing agreements with relevant processors.

 

Our third-party suppliers and service providers fall into the following categories:

 

–    Cloud infrastructure providers (hosting, storage and computing)

–    Payment service providers (processing subscription and product payments)

–    Analytics and product improvement tools

–    Customer support platforms, including AI-assisted support tools

–    Social media and marketing platforms

 

8.     WHERE DO WE STORE YOUR DATA?

 

We store your personal data securely within the European Union (EU) and the broader European Economic Area (EEA). Where data is transferred outside the EEA — for example, to a processor’s infrastructure in a third country — we ensure that an appropriate safeguard is in place, such as the EU–U.S. Data Privacy Framework, Standard Contractual Clauses approved by the European Commission, or an adequacy decision. You may request more information about the specific safeguards in place by contacting us at legal@ooono.com.

 

9.     SECURITY

 

We implement appropriate technical and organisational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures are reviewed and updated on an ongoing basis. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, you as a data subject.

 

10.    COOKIES AND TRACKING TECHNOLOGIES

 

When you visit our Website, we use cookies and similar tracking technologies. We use Cookiebot as our consent management solution — when you first visit the Website, Cookiebot will ask for your consent to any non-essential cookies and tracking technologies. You can review, change or withdraw your consent at any time via the cookie settings available on the Website.

 

For a full overview of the cookies and tracking technologies we use, please see our Cookie Policy available on the Website.

 

Please note that withdrawing consent for certain technologies may affect the functionality of the Website.

 

11.    CHILDREN’S DATA

 

Our services are not directed at children. We do not knowingly collect personal data from persons who are below the applicable minimum age for digital consent in their country of residence. Under EU law (Art. 8 GDPR), this age is 16 unless a Member State has set a lower age (minimum 13). Where our services involve consent-based processing, persons below the applicable age must obtain the consent of their parent or legal guardian.

 

If you are a parent or guardian and believe your child has provided us with personal data without the necessary consent, please contact us at legal@ooono.com and we will delete the data.

 

12.    AUTOMATED DECISION-MAKING AND PROFILING

 

OOONO does not make decisions that produce legal effects or similarly significantly affect you based solely on automated processing, including profiling, within the meaning of Art. 22(1) GDPR.

 

Our AI-assisted support tool helps our support team handle queries but does not make decisions with legal or similarly significant effects.

 

13.    YOUR RIGHTS

 

Under the GDPR you have the following rights in relation to our processing of your personal data. To exercise any of these rights, please contact us at legal@ooono.com. Requests are generally handled free of charge within one month.

 

13.1 Right of access

 

You may ask us what personal data we hold about you, the purposes of processing, the categories of data, the recipients, the retention periods and your other rights.

 

13.2 Right to rectification

 

If personal data we hold about you is inaccurate or incomplete, you may ask us to correct it.

 

13.3 Right to erasure

 

You may ask us to delete your personal data if we no longer have a legitimate purpose for processing it, or if you have objected to legitimate-interest-based processing and your interests override ours. In some cases we are required by law to retain data.

 

13.4 Right to restriction

 

You may ask us to restrict processing of your personal data, for example if you dispute its accuracy or if you have objected to processing based on legitimate interests.

 

13.5 Right to data portability

 

Where processing is based on your consent or our contract with you, you may ask to receive your personal data in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible.

 

13.6 Right to object

 

You have the right to object at any time to processing of your personal data that is based on our legitimate interests (Art. 6(1)(f) GDPR), including profiling based on those interests. If you object, we will cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defense of legal claims. To object, please contact us at legal@ooono.com.

 

13.7 Right to withdraw consent

 

Where we process your personal data on the basis of your consent, you may withdraw your consent at any time with effect for the future. Withdrawal does not affect the lawfulness of processing that took place before withdrawal. You can withdraw consent for:

 

–    Marketing and newsletters: use the unsubscribe link in our emails, change your preferences in your OOONO app or contact legal@ooono.com

–    Cookies and tracking: use the Cookie Policy page or your browser or device settings

 

13.8 Right to lodge a complaint

 

If you have concerns about our processing of your personal data, you may lodge a complaint with a supervisory authority. You may complain to:

 

–    Datatilsynet (Denmark — lead supervisory authority): Carl Jacobsens Vej 35, 2500 Valby — dt@datatilsynet.dk — www.datatilsynet.dk

–    The supervisory authority in your country of residence or place of work: A full list of EU/EEA supervisory authorities is available at edpb.europa.eu/about-edpb/about-edpb/members_en

 

14.    CHANGES TO THIS PRIVACY POLICY

 

We update this Privacy Policy when our data practices change or when required by law. If we make material changes, we will notify you at least 30 days in advance by email and through an in-app notification. The current version is always available on our Website and in the App.

 

If you do not accept a revised Privacy Policy, you may close your account by contacting us at legal@ooono.com.

 

Version: June 2026  |  EU version  |  Replaces all previously applicable privacy policies.  |  OOONO A/S, CVR 38863398