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This Privacy Policy (“Policy“) explains how TuningBot (“we“, “our“, “us“) collects, uses, stores, and protects personal information when you use our websites, software, and services (“Services“).
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1. General Provisions and Data Controller
This Policy applies to all personal data obtained by TuningBot in connection with your use of our websites, software and services (“Services“), and during the execution of any agreement with you.
The data controller is the operator of TuningBot (“TuningBot”, “we”, “us”), reachable at [email protected] for any request or question concerning personal data.
This Policy is an information notice provided under Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR“). Using the Services does not constitute consent to processing: where a specific processing activity relies on your consent (see Section 3), we will ask for it separately, and you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
2. Personal Information Collected
2.1 Definition
- Information provided by the User — data entered during registration or while using the Services, including name, email, company, billing and contact details. Mandatory fields are required for proper service delivery; other data is optional.
- Automatically collected data — IP address, cookie identifiers, browser and OS type, device specs, access time, requested URLs, and similar technical information.
- Additional data — information processed under specific terms of certain Services (e.g., payment processing, support tickets).
2.2 Scope
This Policy applies only to data collected through TuningBot Services. We are not responsible for the data practices of third-party websites that may be linked from our pages.
2.3 Data Accuracy
TuningBot assumes that the personal information you provide is accurate, complete, and up to date. Supplying false or incomplete data may limit access to certain Services.
3. Purposes and Legal Basis of Processing
| Purpose | Data involved | Legal basis (GDPR) |
|---|---|---|
| 3.1 Identify and authenticate users; manage accounts and orders | Name, email, company, billing details, order data | Performance of a contract — Art. 6(1)(b) |
| 3.2 Provide, deliver and maintain the Services, including processing of uploaded ECU files and support tickets | Uploaded files, vehicle/ECU data, ticket content, communications | Performance of a contract — Art. 6(1)(b) |
| 3.3 Communicate with you about your orders, tickets and service notices | Email, ticket history | Performance of a contract — Art. 6(1)(b) |
| 3.4 Issue invoices, keep accounting and tax records, comply with legal obligations | Billing details, payment records, invoices | Legal obligation — Art. 6(1)(c) |
| 3.5 Prevent fraud and abuse, secure the Services, establish, exercise or defend legal claims | IP address, technical logs, order and communication history | Legitimate interest — Art. 6(1)(f) |
| 3.6 Improve quality, develop new features, perform analytics on anonymised or aggregated data | Usage data, aggregated statistics | Legitimate interest — Art. 6(1)(f) |
| 3.7 Send marketing communications | Consent — Art. 6(1)(a) | |
| 3.8 Non-essential cookies and tracking (advertising, third-party analytics) | Cookie identifiers, browser data | Consent — Art. 6(1)(a), via the cookie banner |
Providing the data required for 3.1–3.4 is necessary to conclude and perform the contract; without it we cannot deliver the Services. All other data is optional.
TuningBot processes only the personal data necessary for these purposes and retains it for the periods indicated in Section 9.
4. Disclosure of Personal Information
TuningBot does not sell or rent your personal data to third parties. We may share information only in the following cases:
- Service providers — payment processors, hosting providers, email platforms, CDN and security providers, and other technical partners necessary for service delivery.
- Legal requirements — compliance with applicable laws, court orders, or government requests.
- Business transfers — in the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity.
- User consent — with your explicit permission for specific purposes.
All third-party processors are required to maintain confidentiality and data protection standards consistent with this Policy.
5. Your Rights
Under Articles 15–22 GDPR you have the right to:
- Access — obtain confirmation of whether we process your data and a copy of it.
- Rectification — have inaccurate or incomplete data corrected.
- Erasure — have your personal data deleted, subject to the exceptions in Article 17(3) GDPR. In particular, we retain order records, invoices, payment records, support tickets, uploaded files and related communications for as long as needed to comply with legal obligations (tax and accounting law) and to establish, exercise or defend legal claims, as detailed in Section 9.
- Restriction — request that processing be limited in the cases provided by Article 18.
- Objection — object to processing based on legitimate interest, and to direct marketing at any time.
- Data portability — receive the data you provided to us in a structured, commonly used, machine-readable format.
- Withdraw consent — where processing is based on consent, withdraw it at any time.
- Lodge a complaint — with a supervisory authority, in particular the authority of the EU Member State where you reside, work or where the alleged infringement occurred. For Italy: Garante per la protezione dei dati personali, www.garanteprivacy.it.
To exercise these rights, write to [email protected]. We may ask you to verify your identity. We respond without undue delay and in any case within one month of receipt; this period may be extended by two further months where necessary, taking into account the complexity and number of requests, in which case we will inform you of the extension and the reasons.
Requests after erasure. If you submit a new support request, place a new order, or reply to an existing ticket after an erasure request has been completed, TuningBot will necessarily collect and process new personal data relating to that communication or order. Such data will be retained only for the time necessary to handle the request, comply with legal obligations, and establish, exercise or defend legal claims, in accordance with Section 9.
6. Cookies and Tracking Technologies
- TuningBot uses cookies and similar technologies to improve functionality, analyze traffic, and personalize content.
- Cookies may also be used for advertising and statistical purposes.
- You can disable cookies via browser settings; however, some features may not function properly.
- Cookie structures may change without prior notice.
- Embedded tracking pixels may analyze cookie data to ensure technical performance.
7. Data Protection and Security
We implement technical and organizational security measures to prevent unauthorized access, alteration, disclosure, or destruction of personal data. These include encryption, restricted access controls, and periodic security audits.
Additional verification (e.g., for credit card transactions) may be requested to confirm legitimate use and prevent fraud.
8. GDPR Compliance – EU/EEA Users
The rights listed in Section 5 apply in full to users in the European Union and European Economic Area. Where personal data is transferred to service providers located outside the EEA, the transfer is based on an adequacy decision of the European Commission or on the Standard Contractual Clauses adopted by the Commission (Article 46 GDPR). The categories of service providers are listed in Section 4.
9. Data Retention and Minors
We retain personal data for no longer than necessary for the purposes for which it was collected. Retention periods:
| Category | Retention period | Reason |
|---|---|---|
| Invoices, payment records, accounting data | 10 years from the end of the financial year | Legal obligation (art. 2220 Italian Civil Code and tax law) |
| Order records and support tickets | 24 months after the order or ticket is closed | Contract performance; defence of legal claims |
| Uploaded and processed ECU files | 12 months after delivery | Warranty, re-delivery and dispute handling |
| Account data | Until account deletion, then as per the categories above | Contract performance |
| Technical server logs (IP, access data) | 12 months | Security, fraud prevention |
| Marketing consent and email | Until consent is withdrawn | Consent |
When a retention period expires, data is deleted or irreversibly anonymised. Where an erasure request is received before expiry, data subject to a legal retention obligation or needed for the defence of legal claims is restricted rather than deleted, and erased when the obligation or claim lapses.
TuningBot Services are intended for professional use and are not directed to persons under 16 years of age. We do not knowingly collect data from minors; if we learn we have done so, we delete it.
10. Updates and Contact
TuningBot may update this Policy at any time. The latest version is always available at https://tuningbot.com/privacy/. Significant updates will be communicated on our website.
For any privacy-related questions, please contact: [email protected].