Trumore AI Radio Privacy Policy

Data Controller: Togg Europe GmbH (“Togg”) Address: Schelmenwasenstr. 34, 70567 Stuttgart

On AIRadio Application Privacy Policy

Togg Europe GmbH, Schelmenwasenstr. 34, 70567 Stuttgart (hereinafter referred to as "Togg"), hereby provides information about how we process personal data as Controller regarding the Trumore AI Radio (“On AIRadio”) application.

You can contact our data protection officer via e-mail to: Volker Wodianka | Wodianka privacy legal volker.wodianka@privacy-legal.de

Below, we have compiled the most important information about the typical data processing during creation of an account and usage of the service of On AIRadio application. For certain types of data processing that only affect specific groups, the information obligations are fulfilled separately.

Wherever the term "data" is used in the text, it refers exclusively to personal data within the meaning of the EU General Data Protection Regulation (“GDPR”).

1. Account Creation

We process the following personal data during the first account creation process.

(i) On the Membership and Profile Creation screen, we process your

• Identity information (first name, last name, date of birth);
• Contact information (email address); and
• Transaction security information (username, password)
• Customer transaction information (Trumore ID; Apple Store ID; Google user information)

(ii) The legal basis for processing is Article 6 (1) (b) (necessary for the performance of a contract).

(iii) We collect this information in order to provide you with a unique account to use the On AIRadio service.

2. Additional Biographical Information

We process the following personal data, if you choose to add additional biographical information via the “Update Profile” page after creating a profile.

(i) Customer transaction information (biography, city of residence).

(ii) The legal basis of this processing is Article 6 (1) (f) of the GDPR (legitimate interest). We weigh that this information is necessary for personalizing your On AIRadio experience, creating an advanced profile (profiling), offering personalized products/services, campaigns, routes, and recommendations, conducting marketing, advertising, and promotional processes, and carrying out activities aimed at customer satisfaction.

3. Creation of Custom Playlists and Station Profiles

(i) When you create custom playlists and station profiles, we process your customer transaction data obtained through the mobile app and your smart device (your vehicle’s location, traffic, weather).

(ii) The legal basis of this processing is Article 6 (1) (b) of the GDPR (necessary for the performance of a contract) and Article 6 (1) (f) of GDPR (legitimate interest).

(iii) We process this information to customize your On AIRadio experience, creating your profile, generating and presenting personalized content, and creating guidelines for custom melody composition, lyric writing, compositional architecture, and instrumentation, as well as carrying out activities aimed at customer satisfaction.

4. Data Transfers to Third Countries

In some cases, we transfer data to recipients in third countries in accordance with appropriate safeguards pursuant to Art. 46 GDPR. In particular, Data transfers to Turkey are based on EU Standard Contractual Clauses (“SCCs”).

5. Rights of Data Subjects and further information

1. We do not use any methods of automated individual decision-making.
2. You have the right to request information at any time about all your personal data which we are processing.
3. If your personal data is incorrect or incomplete, you have the right to have it rectified and completed.
4. You can request the erasure of your personal data at any time, as long as we are not bound by legal obligations that require or allow us to continue processing your data.
5. If the applicable legal requirements are met, you can request a restriction to the processing of your personal data.
6. You have the right to object to the processing, insofar as the data processing is based on profiling or direct marketing purposes.
7. If the processing is carried out on the basis of the balancing of interests, you may object to the processing by stating reasons arising from your particular situation.
8. If the data processing takes place on the basis of your consent or a contract, you have the right to a transfer of the data provided by you, insofar as the rights and freedoms of others are thereby not impaired.
9. If we process your data on the basis of a declaration of consent, you have the right to revoke this consent at any time with future effect. The processing carried out prior to a revocation remains unaffected by the revocation.
10. Moreover, you have the right to file a complaint at any time with a data protection supervisory authority, if you believe that data processing has been carried out in violation of the applicable law.

Updates to the Privacy Notice

The Privacy Notice may be updated in line with changes to services and terms within the Trumore Mobile App, as well as regulatory developments. Notifications regarding updates to the Privacy Notice will be provided by Togg through the app.