Privacy Policy

This Privacy Notice for Elfa Labs LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (CarVitals), or any other application of ours that links to this Privacy Notice
• Use CarVitals. Our app is a personal vehicle journal: through health scoring, weekly check-ins, smart maintenance reminders, expense tracking and a document organizer, users can stay on top of the condition, upkeep and paperwork of the vehicles they own or use. The App requires a paid subscription or a one-time lifetime purchase.
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

1. What information do we collect?

Personal information you disclose to us

In short: we collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include the following:

• names
• email addresses
• passwords

Vehicle data. When you use CarVitals you can choose to add vehicles and log mileage, weekly check-ins, past problems, maintenance records, document details (titles and dates — no file uploads), expenses and reminders. This data is used only to provide the features you see in the App.

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by Apple's App Store. You may find their privacy notice here:apple.com/legal/privacy/data/en/app-store.

Sign-in data. We may provide you with the option to register with us using your existing Apple or Google account details. If you choose to register in this way, we will collect certain profile information about you from the sign-in provider, as described in the section called "How do we handle your social logins?" below.

Push notifications. We may request to send you push notifications regarding your account or certain features of the application(s), such as weekly check-in reminders, maintenance alerts and monthly summaries. If you wish to opt out from receiving these types of communications, you may turn them off in the App or in your device's settings.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: some information — such as your Internet Protocol (IP) address and/or device characteristics — is collected automatically when you use our Services.

We automatically collect certain information when you use the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, device characteristics, operating system, language preferences, device name, country, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, such as date/time stamps, features used, device event information (system activity, error reports — sometimes called "crash dumps" — and hardware settings).
• Device data. Information about your phone or other device you use to access the Services, such as device and application identification numbers, hardware model, operating system, and system configuration information.

We do not collect precise geolocation data.

2. How do we process your information?

In short: we process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver the App's features. Vehicle data you log is processed to compute health scores, predictions, reminders, expense summaries and your timeline.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In short: we only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms — for example, to analyze how our Services are used so we can improve them, and to diagnose problems and/or prevent fraudulent activities.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent — for example, for investigations and fraud detection and prevention, or if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

4. When and with whom do we share your personal information?

In short: we may share information in specific situations described in this section.

We use the following service providers, each of which receives only the minimum data needed for their role: Firebase / Google Cloud (authentication, database, push notifications), RevenueCat (subscription management), Sentry (crash reporting) and Apple/Google sign-in. A full sub-processor list is available on request.

We may also need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We never sell your data, and we never share it with car manufacturers, insurers or advertisers.

5. How do we handle your social logins?

In short: if you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your Apple or Google account details. Where you choose to do this, we will receive certain profile information about you from the provider, often including your name and email address. We will use the information we receive only for the purposes that are described in this Privacy Notice. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

6. How long do we keep your information?

In short: we keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. When you delete your account from the App, your vehicle, check-in, expense and document data is deleted; residual copies in backups roll off within 90 days.

7. How do we keep your information safe?

In short: we aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do we collect information from minors?

In short: we do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at[email protected].

9. What are your privacy rights?

In short: depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: if we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided below. However, please note that this will not affect the lawfulness of the processing before its withdrawal.

Account information: if you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or delete your account and all associated data directly from Profile → Delete account in the App. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at[email protected].

10. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. Do United States residents have specific privacy rights?

In short: if you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "What information do we collect?"

We will use and retain the collected personal information as needed to provide the Services, and for Categories A and B, as long as the user has an account with us.

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

How to exercise your rights

To exercise these rights, you can contact us by emailing us at[email protected], or by referring to the contact details at the bottom of this document. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. If we decline to take action regarding your request, you may appeal our decision by emailing us; if your appeal is denied, you may submit a complaint to your state attorney general.

12. Do other regions have specific privacy rights?

In short: you may have additional rights based on the country you reside in.

Australia and New Zealand. We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). At any time, you have the right to request access to or correction of your personal information by contacting us. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner or the Office of New Zealand Privacy Commissioner.

Republic of South Africa. At any time, you have the right to request access to or correction of your personal information by contacting us. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of The Information Regulator (South Africa).

13. Do we make updates to this notice?

In short: yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at[email protected] or contact us by post at:

Elfa Labs LLC
30 N Gould St Ste N
Sheridan, WY 82801
United States

15. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. You can delete your account and all associated data at any time from Profile → Delete account in the App, or submit a data subject access request via email:[email protected].