• DOTS.move is part of ConnectLab srl, a company with headquarters in Viale Coni Zugna 71, 20144 Milan, Italy . All data is safely hosted by Amazon Web Services (‘AWS’) within two (2) regions: North Virginia (us-east-1) and Ireland (eu-west-1).
• DOTS.move provides a service to monitor, track and locate bikes
• This is a data-driven service
• This service will automatically collect the physical location from the device at all times when activated. DOTS.move also receives data about device and application usage
• DOTS.move will use this information to provide the location-based services and to contact owner and preset contacts regarding the service and other information

DOTS.move from ConnectLab srl (“DOTS.move”) provides the Mobile Application (the “DOTS.move App”) and the Tracking Device (the “DOTS.move Device”, collectively the “DOTS.move Service”). We have prepared this Privacy Policy so that you understand how data will be collected and used in connection with the DOTS.move Service.

By using the DOTS.move Service, you expressly consent to the collection and use of information as described in our full Privacy Policy below:
Last updated: April 2019 – GDPR Compliance


Personal information collected through the DOTS.move App: Through the DOTS.move App we may collect your name, email address, date of birth, billing information and other personal information. We do not collect personal information from you unless you voluntarily provide it to us.
Location-based information collected through the DOTS.move Service: DOTS.move’s paired automatically and constantly collects information about the physical location of the Device when it is activated. This information is acquired through numerous methods, including GPS, cell towers and wi-fi hotspots, which are enhanced over time as we follow the Device, collect more information and improve our tracking. We may also collect such location-based information through your use of the DOTS.move App.
To disable location based data collection, you need to switch off the device. Please note that by doing this, no product feature will work.

Non-personal or aggregate information that we collect: We automatically collect non-personal information from your use of the DOTS.move Service, such as IP host address, device-specific identifiers, computer or smartphone configurations, pages viewed, time and usage habits on the DOTS.move Service and similar data. It is possible at times when collecting non-personal information through automatic means that we may unintentionally collect or receive personal information that is mixed in with the non-personal information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If we do inadvertently collect personal information, we will not intentionally use such personal information as if we had collected it with your consent. We may also aggregate demographic information collected from our users (such as the number of users in a particular State) in a manner which does not identify any one individual.
Information Usage and Third Party Sharing: We will only use your information in a manner consistent with this Privacy Policy unless you have specifically consented to another type of use, either at the time such information is collected or through another form of consent from you or notification to you. Personal information and location-based information is treated as sensitive information by ConnectLab srl and are subject to a heightened standard for sharing, as opposed to non-personal or de- identified information which may be shared with a limited selected number of parties. Preferably the Network Provider or Wholesaler if our service is offered through them.
Therefore, we may use your information to:
• respond to your inquiries or requests;
• combine it with data from other sources outside of your use of the DOTS.move Service, such as data obtained from WiFi access points within range of your Device.
Auto-deletion of data: We may automatically delete data from a Device or from the DOTS.move App in connection with a returned or terminated account or device, or as necessary to protect against unauthorized access to the data.
According to recent European Commission laws (GDPR), all inactive account for a period of two years will be fully deleted.
Cookies: “Cookies” are pieces of information that may be placed on your device by a service for the purpose of facilitating and enhancing your communication and interaction with that service. To the extent possible depending upon your device, we may use cookies (and similar items such as clear gifs, web beacons, tags, etc…) to customize your experience, to make your visit more convenient or to enable us to enhance the DOTS.move Service. We may also use and place cookies on your device from our third party service providers in connection with the DOTS.move Service, such as an analytics provider that helps us manage and analyze DOTS.move Service usage. You may stop or restrict the placement of cookies on certain devices or flush them from your browser by adjusting your web browser preferences, in which case you may still use our DOTS.move Service, but it may interfere with some of its

functionality. Cookies and similar items are not used by us to automatically retrieve personal information from your device without your knowledge. Cookies are device and browser specific, so if you make a change to your environment we may reinstall a cookie.
Security: The security of your information is very important to us. We use reasonable efforts internally at ConnectLab srl to protect it from unauthorized access. However, due to the inherent open nature of the Internet and wireless communications, we cannot guarantee that your personal information will be completely free from unauthorized access by third parties, such when transferred over or through systems not within our exclusive control. Your use of our DOTS.move Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personal information. For more information on protecting your privacy, please visit www.eugdpr.org.

• Our servers are maintained in the United States of America. By using the DOTS.move Service, you freely and specifically give us your consent to export your personal information to the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA: Children’s Online Privacy Protection Rule (‘COPPA’). ConnectLab’s privacy and safety practices are certified COPPA- compliant by iKeepSafe. For COPPA-related inquiries, please contact COPPAPrivacy@ikeepsafe.org.

• Contact: For questions or concerns relating to privacy, we can be contacted at the following address: contact@ConnectLab.co.

Data retention: We may retain your information for as long as we feel that there is a business need or benefit to doing so. This will include retaining location-based information. Nonetheless, following two years of inactivity, all user data will be automatically deleted.
Data Access: DOTS.move Data collected through the use of the Device and/or the DOTS.move App, including location information, the frequency of use and emergency contact information is available to customers for their own, direct access. Please contact contact@ConnectLab.co for specific questions about access to any collected data.
Other services: As a convenience to you, Network Providers may provide links to third-party services from within our DOTS.move Service. We are not responsible for the privacy practices or content of these third-party services and such links should

not be construed as an endorsement of any such third party services. When you link away from our DOTS.move Service, you do so at your own risk.
Changes to this Privacy Policy: We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personal information or location-based data in a way that materially differs from this Privacy Policy, such as sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the DOTS.move Service following the posting of any changes to this Privacy Policy means you accept such changes.
Opt-Out Process: You may unsubscribe from our marketing messages. All unsubscribe or opt-out requests should be sent to us at unsuscribe@ConnectLab.co and we will process your request within a reasonable time after receipt. However, we are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent, such as a sponsor. You should contact such third parties directly.
If you no longer want any data collected by DOTS.move from the Device, then you will need to deactivate the service. Either by unpairing the device from the application to clear history. Or contact us to completely delete your user account. Nonetheless all user account will be deleted following 2 years of inactivity.
DOTS.move Terms of Service: Use of the DOTS.move Service is governed by, and subject to, the Terms of Service. This Privacy Policy is incorporated into such terms.
Contact: For questions or concerns relating to privacy or any other inquiry, we can be contacted at dpo@ConnectLab.co 

ConnectLab srl, Viale Coni Zugna 71, 20144 Milan, Italy.