PRIVACY

Data protection

This is the privacy policy of tuluu GmbH and our affiliates (collectively "tuluu", "we", "us", or "our"). We value transparency and want you ("you" or "your") to be clear about how your information is collected, used, shared and protected by us. This privacy policy ("Privacy Policy") describes how tuluu stores and uses information related to the tuluu websites and the tuluu applications. Please also read our Terms of Service.

We reserve the right to change this privacy policy from time to time. If tuluu makes changes to this Privacy Policy, the updated Privacy Policy will be made available through our Services, and if we make material changes to this Privacy Policy, we will post a prominent notice and, if appropriate, notify you directly by email or other means in take notice.

The types of information we collect

We collect or solicit information in a variety of ways. The types of information we collect or collect depend on your use of and interaction in connection with our Services. In many cases, you can choose the information you provide to us, although certain information (like account information) is necessary for us to provide the Services and if not provided we cannot provide the Services. We use and share this information for the purposes described below. The types of information we collect include:

Account information such as B. Your name, your e-mail address, your telephone number, your date of birth, your gender, your address and your payment information such as your credit card details or EC card details.
We collect and process location data when you register and use the Services. For example, in order for us to appropriately show you tuluu partner restrooms near your location, we need to collect and record the physical location of your device. Data such as toilet location and usage status is also required for us to provide the Services. If you register your own toilet on our Services, we collect location data to show potential users the location of your toilet and allow you to make it accessible, or to block and unblock it from the public. tuluu also collects location data directly from tuluu users, including when a tuluu user is on their way to a restroom. This includes, for example, information on the distance to the toilet.
If you link, connect or log in to tuluu with a third-party service (e.g. Facebook), the third-party service may send us information such as your profile data or your friends list of that service.
If you request customer service, support or other assistance, you may choose to provide us with your contact information so that we can better respond to your requests and store information related to contacting our support services.
tuluu and third parties (such as Facebook) collect information from your browser, computer or mobile device that reveals technical information such as your device's source IP address and the time you accessed or used our Services. We use cookies and similar tracking technologies (like pixels and tags) to enable us to provide our Services. This includes protecting our service, saving your settings and collecting analytical data about you. Third parties may use the technical information to provide measurement services and targeted ads.
We collect information that you submit when using the Services, e.g. B. when you participate in discussions or otherwise on forums or make comments on our social media accounts or blog posts. Depending on your camera or photo settings, tuluu will receive the information you have approved for transmission, e.g. B. Photos of toilets used by tuluu partners.
We collect information about you when we use the services of third parties such as marketing and advertising partners such as social media networks.

In addition, we collect the following additional information if you are a toilet operator:

Information submitted as part of your registration as an operator;
Details of their restroom that you provide through tuluu such as: B. Information about the number or characteristics they have;
Your bank details so that we can pay you; and
Information required by law, such as B. Tax number or operator licenses.
Reviews that users give about your toilet in tuluu

How we use information

We use your information, including information about your location, for the following purposes:

To provide the Services to you upon request, including managing your account and toilet use. This includes when you access our Services through other services such as Google;
to manage payments, subscriptions or donations as well as discounts or special offers such as extra vouchers that we make available in the app;
to provide you with communications related to your account, your interactions, or your transactions, including service-related announcements, such as changes to our policies. Where permitted by local law, we may also send you surveys or marketing communications on behalf of tuluu and/or third parties, including information about features and improvements to our Services;
to personalize offers for you (see the "Advertising and Analytics" section below for more information);
to optimize, develop and improve our Services, including building and training machine learning models to optimize, develop and improve our Services. To this end, we may engage third-party analytics service providers to assist us in determining usage and improving our Services;
where necessary to comply with our legal obligations, including to comply with any regulatory or legal request;
to identify, investigate and prevent activities that violate tuluu's policies or Terms of Service or are illegal, including sharing information with governmental authorities outside of your home country, such as law enforcement agencies; and
to collaborate and share information with third parties such as universities, local authorities and other third parties to build or improve healthcare infrastructure, as described in the "Who do we share your information with?" section below; and

If you are an operator, we also use your data to: calculate your compensation and pay you; and to monitor the quality of the restrooms you provide through tuluu.

Who do we share your information with?

We may provide your information to tuluu affiliates, our service providers and other third parties as necessary to conduct our business operations and in accordance with this Privacy Policy. We pass on your information to the following recipients:

Our service providers and partners: We share your information with our trusted service providers, partners and their employees who provide services to tuluu, such as B. hosting our data and infrastructure, providing identification verification services, processing payments and donations, supporting and improving the Services, performing customer service, or providing marketing and advertising services. For example, we share information with credit card issuers so that we can process your payments and refunds.
Working with Third Parties: After we remove certain identifiers, such as your name, phone number, and email address (if provided), and combine the resulting information with similar information from other users, tuluu may use your information, including individual trip records and toilet usage history, use, license and share for research, business or other purposes.
Government, Regulatory, and Law Enforcement Authorities: We may share your information when we have a good faith belief that we reasonably need to do so by law, including to comply with any federal, state, regulatory, or local legal request, or as part of a legal process, or to detect, investigate, prevent and correct fraud and other illegal activities, security or technical problems, or to prevent injury or harm to you, fellow citizens, our employees, other third parties or ourselves; or when we need to do so to protect our legal rights or property, to take action against illegal activity or traffic violations, or to enforce our contracts, such as our Terms of Service.
Integrated partners: We may give your data to to third party services that offer restrooms through tuluu and/or integrate or provide access to the Services and/or to provide access to third party restrooms on the Services.
Cities, local authorities and public transport operators: We may share your data with to these recipients as necessary or conducive to operations in a particular city or location, or for the purposes of town planning and understanding public toilet usage.
tuluu Affiliates: We may share your information with tuluu Affiliates to enable the provision, maintenance, and improvement of the Services. As we continue to grow, we may expand our group of companies by establishing local subsidiaries or other affiliates as necessary to assist us in providing or marketing the Services.

Corporate Reorganizations: We may also share your information as part of a sale, merger, change of control, or in preparation for any of these events.

We may also share aggregated, depersonalized, or anonymized information with third parties that cannot be used to identify you, including the types of third parties listed above.

Advertising and Analytics

We may allow others to provide analytics services and serve advertising on our Services and on our behalf across the web and mobile apps. These companies may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, posted on or in mobile apps time spent, links clicked and conversion information. This information may be used by tuluu and others to, among other things, analyze and track data, determine the popularity of certain content, provide advertising and content on our Services and other websites tailored to your interests, improve the effectiveness of our advertising measure and better understand your online activities. You can potentially manage your preferences, find out more information about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes.

Where tuluu uses the Facebook pixel (a type of cookie) to serve you advertising, tuluu and Facebook Ireland are joint controllers of that processing. tuluu and Facebook Ireland have shared their responsibilities under the GDPR in relation to this joint processing, for example tuluu is responsible for providing this notice to you and Facebook Ireland is responsible for managing your individual rights in relation to joint processing. Information on how you can exercise your rights with Facebook Ireland in relation to joint processing and information on how Facebook Ireland subsequently processes your personal data as an independent data controller can be found at Facebook.

We work if necessary. also works with third parties to serve you advertisements as part of customized campaigns on third party platforms (such as Facebook and Instagram). As part of these advertising campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched to a user account on those platforms so that we can learn more about your interests and you Provide advertising tailored to your interests. Note that the third-party platforms may offer you choices about whether to see these types of customized ads.

We do not sell or share your personal information with third parties for their direct marketing purposes, except with your consent.

Our legal bases for using your information

In Europe we are required to disclose the purposes for which we process your personal data and the legal bases we rely on to do so. In order to collect, use, share and otherwise process your information for the purposes described in this Privacy Policy, the following bases apply: We process your information

when necessary to provide the Services and to perform our obligations when using tuluu Services. For example, we can only provide the Services if we collect and process basic information about you and your location;
if you have given us your consent to process your data (if this is the case, you can withdraw your consent at any time);
where necessary to comply with a legal obligation, including, for example, responding to requests for information from a government or law enforcement agency, or to establish, exercise or defend legal claims;
to protect the vital interests of our users, operators, employees and public figures both on and off the Services;
when it is in the public interest, where permitted by law; and or
where the processing is necessary for tuluu or a third party, where we have weighed it against your fundamental rights and interests.

How do we transmit your information?

Given that we aim to provide our Services in many locations around the world, we may transfer your information to or from those locations in order to provide the Services to you.

If you are a resident of the European Economic Area ("EEA"), Switzerland or the United Kingdom, we will transfer your information to the United States and other countries outside of your home country for storage, processing and the other purposes set out in this Privacy Policy or transferred. Countries located outside the EEA, Switzerland or the UK may not offer the same level of data protection as in your home country, for example there is currently no adequacy decision in relation to the United States. When the European Commission considers a country as a country has recognized that offers an adequate level of data protection, tuluu can rely on the Commission's adequacy decision for the transfer of data.

tuluu also relies on Standard Contractual Clauses approved by the European Commission to transfer data from the EEA, Switzerland and the UK to the United States and other countries outside of your home country.

How long we store information

We retain your information for as long as is reasonably necessary to provide the Services to you or until your account is deleted, whichever is later. This is subject to any longer retention period required by applicable law or notified to you. Examples of some of our retention periods are set out below.

type of data

retention period

Account Information

Account Lifetime. Certain information relating to transactions related to an account is retained for 7 years in accordance with tuluu's record keeping obligations.

Customer Support Requests

Account Lifetime.

If you decide to delete your account, it may take some time for us to completely remove your information from our databases and system logs. We also reserve the right to retain information from deleted accounts to prevent fraud, collect fees, enforce the Terms of Service, comply with our legal obligations, or protect our legal rights.

If you are a toilet operator, tuluu also stores certain information to the extent necessary to comply with our legal obligations. For example, tuluu may retain some of your information to comply with applicable tax, legal, reporting and auditing obligations and other requirements of the countries in which we operate.

Your rights

While some of these rights are universal, certain rights apply only in specific cases. Some of these rights may not apply to you if you reside outside of the regions identified below.

EEA, Swiss and UK Rights

If you are ordinarily resident in the EEA, Switzerland or the UK, you have a number of rights in relation to your information:

Right to object (marketing) – You have the right to object to processing for direct marketing purposes at any time.

Right to object (legitimate interests) – where we are processing your information based on legitimate interests, you can object to that processing in certain circumstances. Unless we can show compelling legitimate reasons or if this is not required for legal reasons, we will stop processing your data as a result of your objection.

Right of access - You can access a lot of your information by logging into your account. You can also request a copy of the information we hold about you and how the information is used.

**Right to Rectification** - You have the right to ask us to correct any inaccurate information about you.

Right to Erasure – You have the right, where we have legitimate grounds and applicable law, to request erasure of your information, and tuluu is required to do so, unless we have legitimate grounds and applicable law to do otherwise.

Right to restriction of processing – You have the right to temporarily restrict the processing of your information by us in certain circumstances where there are legitimate reasons to do so.

Right to data portability - As far as technically possible, you have the right to receive certain information about yourself in a structured, commonly used and machine-readable format and to have this data transmitted to another person responsible.

Right to withdraw consent – where you have previously given us your consent, e.g. B. so that we can send you direct marketing communications, you have the right to withdraw this consent at any time. However, the lawfulness of the processing based on your consent before the revocation remains unaffected. In addition, even if you opt out, we may continue to use your information to the extent permitted or required by law.

Right to instructions on how to manage your data after your death – You have the right to give us specific instructions about how we store and delete your personal data after your death.

Please contact us as set out in the "Who is responsible for my data?" section below if you wish to exercise any of these rights or if you have any concerns about how we process your data. For security reasons we may request that you follow specific steps to verify that you are the owner of a tuluu account For example, we may require that you have a verified email address associated with your tuluu account and that you sign in with us at contact the verified email address associated with your tuluu account.

Your Choices and How You Can Manage Your Information: We believe that you should have choices about how we collect, use and share your information. If you do not want tuluu to collect your information, you should not use the relevant services.

Emails and Other Communications: If you would like to change the type of communications we send you, including opting out of marketing communications, you can do so at any time by using the change the specified communication settings accordingly. However, we may continue to send you non-promotional communications and other information about your use of the Services.

Accessing and Managing Your Information: If you have an account with tuluu, you can view, change, or delete your information by logging into your account and editing your profile. You can change your mobile phone number or email address in the settings within the app. You can delete your tuluu account at any time by sending us a request at support@tuluu.app. If you are an operator and want to delete your account, please send an email to support@tuluu.app.