viaaq mobile – Privacy Policy
Last updated: 03.10.2026
What we do not have access to
We do not have access to your vehicle state, vehicle data, or any other information that flows between your TCU and any server. We provide the connection only.
The only exception is limited diagnostic information that we capture after you give explicit consent for that specific case, used only to fix the problem you reported and then deleted (see Section 2.2).
1. Who is responsible for your data
1.1 The controller of personal data described in this Privacy Policy is Ravi-On Solutions, a company registered in Finland (business ID 3636996-9), address Vetokuja 4, 01610 Vantaa, Finland ("viaaq mobile", "we", "us").
1.2 Contact for privacy matters: [email protected]
1.3 This Privacy Policy applies to the connectivity service offered at https://mobile.viaaq.eu and the customer portal at https://mobile.viaaq.eu/dashboard (the "Service"). It forms part of our Terms & Conditions.
2. What this policy does not cover
2.1 We provide connectivity. We do not see, store or control the content of the data your telematics unit (TCU) exchanges with the server it connects to, such as an OpenCARWINGS server, except in the limited troubleshooting case described in Section 2.2. The operator of that server, which may be you or a third party, is responsible for how it processes your data, and you should review that operator's privacy practices.
2.2 Troubleshooting with your consent, case by case. If you ask us for help with a connection problem, we may capture or produce diagnostic information about your SIM's data traffic, which may include a portion or snippet of the data transmission itself. We do this only after asking for, and receiving, your explicit consent for that specific case. Consent is never general or ongoing, and consent given for one case does not apply to any later case. The following rules apply:
- a) Consent each time: before any capture, we ask you in writing (for example by e-mail or in the portal) and explain what we intend to capture, for which SIM, for how long, and why. We start only once you have clearly agreed. Agreeing to these Terms, creating an account, or requesting support does not count as consent. Declining does not affect other support we can give you, but we may be unable to diagnose some faults without a capture.
- b) Purpose: the captured data is used only to diagnose and fix the problem you reported. We do not use it for any other purpose, such as marketing, profiling, analytics or sharing with third parties.
- c) Scope: we capture only what is needed, for the shortest time needed, and only for the SIM named in your consent. If the scope needs to change, we ask you again.
- d) Access: only authorised persons working on your case, and Network Partners where they are needed to solve the fault, can access the data.
- e) Deletion: we permanently delete the captured data when the troubleshooting for that case is complete, and in any case within 3 of your consent. We do not keep copies. We may keep a record that the troubleshooting took place and that you consented, but not the captured content.
- f) Withdrawal: you can withdraw your consent at any time by telling us at [email protected]. We will then stop capturing and delete what we have collected.
2.3 Partners. If you buy a SIM from, or have it installed by, a Partner (for example the Viaaq Workshop), the Partner is a separate controller of the personal data it collects for its own sales and services and has its own privacy policy.
3. What data we collect, why, and on what basis
The table below summarises our processing. "Contract" means we need the data to provide the Service you ordered (GDPR Art. 6(1)(b)). "Legal obligation" is Art. 6(1)(c). "Legitimate interest" is Art. 6(1)(f). "Consent" is Art. 6(1)(a).
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Account data: name, e-mail, login credentials (password stored in hashed form), account settings | Creating and managing your account and the portal; communicating with you about the Service | Contract | While your account exists, plus 6 after it ends |
| SIM and subscription data: ICCID or other SIM identifiers, plan, activation, pause and cancellation history | Provisioning and operating the SIM, linking it to your subscription, managing changes of vehicle owner | Contract | While the subscription is active, then 6 months |
| Connection and usage data: connection status, data volume used, wake-up SMS delivery records, network and roaming country, timestamps | Delivering the Service, showing usage in the portal, billing, fair-use checks, fault diagnosis | Contract; legitimate interest (service quality and abuse prevention) | 6 for detailed records; summaries as long as needed for billing |
| Payment and billing data: top-up and transaction records, balance, invoices or receipts, payment status. Card or bank details are handled by our payment provider and not stored by us | Processing payments, keeping your balance, issuing receipts, refunds | Contract; legal obligation (accounting) | Accounting records for the period required by Finnish law (six years from the end of the financial year in which they were made) |
| Diagnostic data (only with your explicit consent for each case): traffic logs or snippets of the data transmission captured to troubleshoot a connection problem | Diagnosing and fixing the specific fault you reported | Consent (Art. 6(1)(a)), given separately for each case | Deleted when the troubleshooting is complete, and at the latest within 3 days |
| Support correspondence: messages you send us and our replies | Answering questions, solving problems, keeping a record of the case | Contract; legitimate interest | 12 months after the case is closed |
| Technical and security data: IP address, device and browser type, portal log-ins and activity logs | Operating and securing the portal, preventing fraud and abuse, investigating incidents | Legitimate interest; legal obligation where applicable | 12 months |
| TCU identifier: the serial number of your telematics unit (TCU ID) | Pairing your TCU with your SIM and subscription, and providing telematics functionality, for example relaying SMS messages (such as wake-up messages) from the server to your TCU | Contract | While a SIM is paired with TCU ID, deleted immediately upon request via e-mail. |
3.1 Location. We do not collect GPS or vehicle location data. Our network partners necessarily know which network or country your SIM is using for roaming and billing, and we may see this as part of usage records. We do not use it to track your vehicle.
3.2 Vehicle and TCU data. We collect the TCU ID, as described in the table above, but we do not collect other vehicle data such as battery status or climate settings, because that traffic goes between your TCU and your chosen server. The TCU ID identifies a device, not a person, but it is linked to your account and SIM, so we treat it as personal data. We do not use it to identify or locate you, or for any purpose other than those listed above.
3.3 Required data. You must provide the account, TCU ID and payment data we need for the Service. Without it we cannot provide the Service.
3.4 We do not use your data for automated decision-making that has legal or similarly significant effects on you, and we do not sell personal data.
3.5 Roaming. The Service includes roaming on various networks. When your SIM connects through a network operated by another operator (a "visited network"), for example when you drive abroad, the following applies:
- a) the visited network operator carries your SIM's data traffic and SMS over its network and therefore processes this traffic in transit, together with the SIM's technical identifiers (such as the IMSI) and the connection and usage data needed to connect the SIM and to bill us for the traffic. The operator does this under its own legal obligations and privacy policy, and as an independent controller for its own network purposes. We do not control how it handles this data;
- b) we and our Network Partners see which country and network the SIM is using, and the volume of data and any SMS used there, as part of usage and billing records. This is network-level information; we do not collect GPS or vehicle location, and we do not use roaming information to track your vehicle (see 3.1);
- c) we use roaming records only to deliver the Service, to bill, to check fair use under Section 7 of our Terms, and to investigate faults or abuse; and
- d) we do not access the content of the data your TCU exchanges with its server, in roaming or otherwise (see Section 2). We cannot, however, control what visited networks can technically see of the traffic passing through them. If the data between your TCU and server is not encrypted, it may be exposed to the networks it passes through, which is why we recommend using encrypted connections where your TCU and server support them.
4. Where the data comes from
We collect data from you directly (when you order, use the portal, pay or contact us), automatically from the SIM and the networks while the Service is used, from the server you connect your TCU to, and from our payment provider and Partners (for example order and installation information, where a Partner has sold or fitted a SIM).
The data we receive from your server is limited to the TCU ID and the requests, such as, relaying an SMS message to your TCU. We do not collect or store the contents of these SMS messages. They are passed on to your TCU automatically and are not kept. We keep only technical delivery records, such as the time of the request and whether it was delivered.
5. Who we share data with
Our network partners do not know who you are
We do not give our network and IoT connectivity partners, or the operators of any network your SIM uses, your name, contact details, account information, TCU ID, or any other information that identifies you as a person. They see only the technical identifiers of the SIM (such as its ICCID and IMSI) and the connection and usage data needed to run it.
5.1 We share personal data only as needed and only with the following recipients:
- Network and IoT connectivity partners ("Network Partners"): to activate and run the SIM, route traffic and SMS, and bill for usage. We share with them only the technical SIM identifiers and usage data described above. We do not share your name, contact details, TCU ID or any other customer or account information. To a Network Partner, a SIM is a technical identifier and not a person. They act under their own legal obligations as network operators, and may also be independent controllers for the technical data they need to run their networks. The only exception is limited diagnostic information, which we may share with a Network Partner where needed to solve a fault, only for a case where you have given explicit consent (see Section 2.2).
- Visited network operators (roaming): the operators of the networks your SIM connects to when roaming carry your SIM's traffic and receive the SIM's technical identifiers and the usage data needed to do so (see Section 3.5). They do not receive information that identifies you.
- Payment service providers (Stripe): to process billing, payments and balance top-ups. They process your payment details as part of their own service.
- Partners: only information needed to fulfil an order or installation that you requested through them, which consists of TCU ID.
- Professional advisers (accountants, lawyers, auditors) where necessary.
- Authorities: where required by law, a court order or a lawful request, for example from the police, tax authorities or telecommunications regulators.
- Successors to our business, if we are involved in a merger, sale or reorganisation. We would tell you and ensure the new owner follows this policy.
5.2 Our service providers act on our instructions under data processing agreements.
5.3 We do not sell your personal data, transmit or share it with anybody.
6. Transfers outside the EU/EEA
We store and process your data within the EU/EEA.
7. How long we keep data
7.1 We keep personal data only as long as needed for the purposes in Section 3, to comply with law (for example accounting rules) and to handle claims. The retention periods are in the table above.
7.2 After the retention period, we delete the data or anonymise it so that it can no longer identify you. Anonymised statistics may be kept.
7.3 When a subscription ends, for example when a vehicle changes owner, your account data and balance are handled under our Terms & Conditions. Usage records linked to the SIM are not shared with the new owner, who starts a separate subscription.
8. Your rights
8.1 Under the GDPR you have the right to:
- access your personal data and receive a copy;
- have inaccurate data corrected;
- have your data erased, where there is no longer a reason for us to keep it;
- restrict processing in certain situations;
- object to processing based on legitimate interest;
- receive data you provided to us in a structured, commonly used format, and have it transferred where the processing is based on contract or consent (data portability);
- withdraw consent at any time, without affecting earlier processing.
8.2 To use your rights, contact us at [email protected]. We may need to verify your identity first. We will respond within one month, and may extend this by up to two further months for complex or numerous requests, and will tell you if so. Requests are free unless they are clearly unfounded or excessive.
8.3 Complaints. You have the right to complain to a data protection authority. In Finland this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto). If you live in another EU/EEA country, you can also contact your local authority. We would appreciate the chance to resolve your concern first.
9. Security and confidentiality
9.1 We use appropriate technical and organisational measures to protect personal data, such as access controls, encryption of data in transit, hashed passwords and separation of duties. No system is completely secure, and you should keep your portal credentials confidential and use a unique password.
9.2 We handle communications and related traffic data in line with the confidentiality rules that apply to electronic communications services in Finland and the EU.
9.3 If a personal data breach is likely to put your rights and freedoms at risk, we will notify the Data Protection Ombudsman and, where required, you.
10. Cookies and similar technologies
The portal uses only cookies and local storage that are strictly necessary, for example to keep you signed in and to protect against abuse. These do not need consent. We do not use any cookies for statistics or profiling purposes. You can block cookies in your browser, but the portal may then not work.
11. Children
The Service is intended for adults. You must be at least 18 years old (or the age of majority in your country) to subscribe. We do not knowingly collect data from children. If you believe we have, contact us and we will delete it.
12. Changes to this policy
We may update this Privacy Policy, for example when the Service or the law changes. The current version is always on this page with its date. For material changes we will notify you by e-mail or in the portal.
13. Contact
Questions about privacy: [email protected]
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