EU Data Act transparency declaration
Identity of the data holder
- Company Name: Chipolo d.o.o.
- Address: Gabrsko 12, 1420 Trbovlje, Slovenia
- Contact: data@chipolo.net
- Website: chipolo.net
Nature of the data generated
The data generated varies depending on the ecosystem (mobile app) used with the product. The apps listed below are considered Related Services under the EU Data Act and collect and process the data related to your connected Chipolo products.
A. When used with the Apple Find My app or Google's Find Hub app:
- The respective platform operator (Apple or Google) acts as the data controller. Chipolo d.o.o. does not access, process, or store location or usage data generated within these third-party apps and finder networks.
- Apple: See Apple Data and Privacy and Apple Regulatory Information | EU Data Act
- Google: See Google Privacy & Terms
B. When used with the Chipolo app:
- Personal data: User account information (name, email address).
- Product status data: Battery status (level), timestamps of connection/disconnection events, device firmware version, device model and color.
- Customer usage data: Chipolo button-press events (e.g., for the “Call Your Phone” feature) and other app-usage related analytics events based on provided consent.
- General environment data: The device itself does not contain environmental sensors (e.g., temperature, humidity) and does not generate or infer such data.
Estimated volume of data inside the Chipolo app
- < 100 kB per day depending on usage frequency (e.g., number of disconnection and connection events).
Data format and generation by the Chipolo app
- Format: Data is transmitted via Bluetooth Low Energy (BLE) and stored on servers inside various databases.
- Real-time generation: The product generates data on an event-basis (e.g., button press, connection established). It does not stream data continuously in real-time.
Data storage and retention by the Chipolo app
- Storage location:
- Device: The Chipolo device itself does not store historical usage or environmental data. It only retains essential firmware and pairing information.
- Servers: For the Chipolo app, data is stored on secure servers located within the European Union (Hetzner Online GmbH, Germany), managed by Chipolo d.o.o.
- Retention duration:
- Functional data: Retained for as long as the user account is active to provide the service.
- Deletion: Data is deleted upon user request or when the account is deleted. Financial/transactional data (if applicable, related to any purchases made within the app) is retained for 10 years as required by Slovenian tax law.
How to access, retrieve, and delete data
A. For the Apple Find My app and Google’s Find Hub app
- View data: Users can view their device status directly within the Find My or Find Hub app.
- Export data: Users can use the privacy tools provided by those platforms (e.g., Apple Data and Privacy portal or Google Takeout).
B. For the Chipolo app
- View data: Users can view their device status directly within the Chipolo app.
- Export data: To retrieve a copy of your personal data and usage history, please contact data@chipolo.net or export the data via the Chipolo web app (Account settings > Data export).
- Delete data: Reach out to data@chipolo.net or start the deletion process directly from the Chipolo app, available inside the “Settings” section.
Terms of use and complaints
- Terms of use: Our full terms of use are available at chipolo.net/pages/terms-of-use
- Right to file a complaint: Users have the right to file a complaint with the competent supervisory authority if they believe their rights under the EU Data Act or GDPR have been infringed. In Slovenia, this is the Information Commissioner (Informacijski pooblaščenec); more information available at ip-rs.si.
Third-party sharing and trade secrets
- Sharing: We do not sell your data or share it with third parties for their own purposes. Data is only shared with third-party service providers (e.g., cloud hosting, email delivery) when strictly necessary in order to provide the service, as outlined in our Privacy policy.
- Trade secrets: The data accessible to the user does not contain trade secrets or proprietary algorithms of Chipolo d.o.o.