1. Introduction
The purpose of this privacy notice is to provide information about how we, Thule Sweden AB, process your personal data in connection with the use of our mobile application Thule. We respect your privacy and are committed to protecting the personal data we process about you.
Thule Sweden AB, reg. no. 556076-3970, Box 69, 335 04 Hillerstorp, Sweden (“Thule”), is the data controller of the processing of your personal data.
The following describes, among other things, how we collect, process and share your personal data and provides information concerning your rights and how you can exercise these.
2. Description of our processing of your personal data
Below you will find a description of the personal data we process about you, for which purposes we process your personal data, the legal bases for our processing of and for how long the personal data is processed. All processing described below is conducted by Thule as a separate data controller, except for the processing described in Section 2.2.1 which outlines the processing carried out together with bubl. under a joint controllership.
2.1 When registering and logging in to a user account
In order for you to be able to register and use a user account, which is necessary to use the Thule app, we process your e-mail address and your password, as well as country, consents, acceptance of documents and serial number of the products you register on your account. If you want to share products registered on your account with other users, we also store their e-mail address for 24 hours. If you want to tailor the App experience using the avatars representing third-party users of the products, we will store metadata related to this, including user, birth month and year.
The processing of your personal data for this purpose is based on our legitimate interest to be able to provide you with a user account and the features that follow from you registering for a user account. Thule has made the assessment that Thule’s interests outweigh any possible conflicting interests in not having the personal data processed. You can contact privacy@thule.com to receive further information regarding this assessment. The processing of your personal data is necessary in order to provide you with the Thule App.
The personal data will be stored for as long as your Thule account exists. If you do not wish continued processing, you can request that Thule deletes your Thule account, and your personal data will be deleted. Thule also collects data for App analytics, the purpose of collecting analytics data is to get an insight into users' behavior in the app. We collect various events that help us understand how our users are using the app. With that data, we can improve the user experience. The analytics data does not contain any personal data (PII) that could be used to identify individual users. It is possible to opt out of sharing analytics data in the app. For processing relating to your purchases, order history, returns etc., please see our privacy notice for e-commerce https://www.thule.com/en-us/legal-and privacy policy.
2.2 When you use an Air Purifier product
2.2.1 Joint controlling by Thule and bubl.
Processing related to your Air Purifier (the “Air Purifier Product”) is, to a certain extent, carried out together with bubl. AB, reg. no 559167-7678, address Gert Fredrikssons Väg 3S-611 35 Nyköping, Sweden (“bubl.”) as joint controllers.
Thule and bubl. are working together to provide the functionalities of the Air Purifier Product. This means that certain personal data processed in relation to your use of the Air Purifier Product is processed jointly by Thule and bubl., whilst certain processing is carried out by each party as separate controllers.
For personal data processing carried out as joint controllers, Thule and bubl. jointly determine the purposes and means of processing of personal data described in this section.
1. When using the Air Purifier Product, information about your GPS location is collected by Thule from your mobile device and MAC address is collected by Thule from the Air Purifier and transferred to bubl. for the joint purpose of providing the Air Purifier Product’s features, e.g. the provision of air quality data.
The personal data processed for these purposes will only be temporarily stored when the data is gathered.
2. For the joint purpose of enabling detecting and solving technical issues (such as bugs) in your Air Purifier Product and, subsequently, ensure that the Air Purifier Product’s functions efficiently and smoothly and that the services can continuously be improved, Thule collects and transfers the following diagnostics data from your Air Purifier Product to bubl.:
- Diagnostic event with timestamp
- Install Id
- MAC address for Air Purifier
- Operating system and version number
- SDK version of the bubl. SDK
- Local language codes from the mobile device
The personal data will be stored for these purposes only temporary.
The personal data will be processed on the legal basis of the legitimate interest of Thule and bubl. to provide you with; (1) the full range of features of the Air Purifier Product and Thule App, and (2) a functioning and efficient user experience.
Thule and bubl. have jointly made the assessment that Thule and bubl.’s interests outweigh any possible conflicting interests in not having the personal data processed. You can contact privacy@thule.com to receive further information regarding this assessment. The processing of your personal data is necessary for the Air Purifier Product to function properly.
2.2.2 Further processing by Thule
Thule continues to process, as a separate controller, your Air Purifiers diagnostic data after transferring it to bubl. for Thule’s own, individual purposes of enabling detecting and solving technical issues (such as bugs) in your Air Purifier and App and, subsequently, ensure that the Air Purifier functions efficiently and smoothly and that the services can continuously be improved. Such processing is based on our legitimate interest to provide you with a functioning and efficient user experience and will be stored for a period of 3 years.
2.2.3 Further processing by Bubl.
Any continued processing of your personal data by bubl. for additional, individual, purposes, is carried out by bubl. as a separate controller. For such further processing by bubl., including information on relevant retention periods, we refer to Bubl’s privacy notice, which can be found https://www.get-bubl.com/privacy-policy/.
2.3 When you use a Thule product
Thule process certain personal data in relation to your use of a Thule product. The data we process is described in this section.
1. When using the Thule Product, information about your location, speed and nearby Bluetooth devices are processed by the Thule App for the purpose of providing you with the Thule Product’s features. The personal data processed for these purposes is temporarily stored on your device and not transferred to Thule.
2. For the purpose of detecting and solving technical issues (such as bugs) in your Thule product and, subsequently, ensure that the Thule product functions efficiently and smoothly and that the services can continuously be improved, Thule collects and transfers the following diagnostic data from your Thule product and the Thule App.
a. Product usage including sensor values and timeline, logs, requests, IP address, timestamps, locale as well as error codes.
b. App usage including confirmations and user interactions.
The personal data will be processed on the legal basis of the legitimate interest of Thule to provide you with; (1) the full range of features of the Thule product and Thule App, and (2) a functioning and efficient user experience. (3) new product offerings.
2.4 When you sign up for Thule’s newsletter
In order to provide you with our newsletter, once requested by you, we process your e-mail address and country, as well as date and time of consent.
The processing of your name and e-mail address for sending newsletters is based on your consent. You may always withdraw your consent with future effect by contacting us at the contact information provided in section 6.6 or by using the link to unsubscribe from newsletters.
The personal data will be stored for two (2) years initially (provided you do not withdraw your consent). Thereafter, you will be asked bi-annually whether you wish that we continue the processing of your personal data in accordance with the above. If you do not wish continued processing or if you do not answer the request within the time frame stated in the request, your personal data will be deleted.
3. Who has access to your personal data?
The number of people who have access to your personal data is limited. Only people who need to process your personal data in accordance with the purposes stated above have access to the personal data.
- Your personal data is shared with other companies within the Thule Group if it is necessary to fulfil the purposes mentioned above. This includes Thule local entities listed here.
- We also transfer your personal data to suppliers and partners, including IT suppliers such as providers of cloud services, for example AWS, if required in order to conduct our business operations, as well as the service providers listed here.
- We transfer personal data relevant for your Air Purifier Product to bubl. which is processed by bubl. both as a joint controller subject to this privacy notice and as an independent controller as described in Section 2.2.1.
- If required by law or to protect our interests in a legal proceeding, we may also transfer personal data to other independent controllers such as legal representatives or law enforcement agencies.
4. Where is your data processed?
We aim to process your information in Sweden and within the EU/EEA. When required for the fulfilment of the purposes stated above, your information may be transferred to, and processed in, a country outside the EU/EEA by one of Thule’s business partners or their subcontractors. Thule will take all reasonable technical and organizational measures to protect your personal data in such transfers. Our transfers of personal data are based on Thule’s legitimate interest in fulfilling the purposes and conducting our business in an efficient manner.
When transferring personal data to countries outside the EU/EEA, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data, unless another legal basis for the transfer applies, such as an adequacy decision by the EU Commission. The standard contractual clauses can be found via the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Upon your request, you may receive a copy of those standard contractual clauses and a complete list of our third country transfers.
If you would like a full list of transfers of personal data to countries outside the EU/EEA and a copy of the applicable standard contractual clauses or information on whether there is an adequacy decision in place, please contact us at privacy@thule.com.
5. What are your rights?
Thule Sweden AB, reg. no. 556076-3970, is the data controller of the processing of your personal data. Please note that you may exercise your rights in relation to the joint processing towards both bubl. and Thule when applicable. If you wish to exercise your rights in relation to bubl. processing as separate controller, please be referred to contact information in bubl’s privacy notice. You may contact bubl. at info@get-bubl.com. The data controllers are responsible for your personal data being processed correctly and in accordance with applicable laws. Read more about your rights below.
- The right to access: You have the right to know which personal data we process about you, for what purposes the personal data is being processed and who we share your personal data with, etc. You also have the right to access the personal data and request a copy of the personal data being processed.
- The right to rectification: If you notice that we have inaccurate or incomplete personal data about you, you can always request that we correct this personal data without undue delay. Additionally, considering the purposes for which we process your personal data, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- The right to erasure: Subject to certain limitations, in the following cases, you may request that we delete your personal data;
(i) when the personal data are no longer necessary in relation to the purposes for which we collected or otherwise processed them;
(ii) when our processing is based on your consent and you withdraw such consent;
(iii) when you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes;
(iv) we have processed your personal data unlawfully; (v) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Thule is subject; Please note that deleting your personal data may result in us not being able to e.g. provide you with the services offered in connection with the product. - The right of restriction: Under the following circumstances, you have the right to request that we limit our processing for a certain period of time:
(i) if you contest the accuracy of the personal data, we shall restrict our processing until we are able to verify the accuracy of the data;
(ii) if the processing is shown to be unlawful and you request restriction of our use of your personal data instead of erasure;
(iii) if we no longer need the personal data for the purposes of the processing as stated in this notice, but we are required by you to do so for the establishment, exercise or defense of legal claims; and
(iv) if you objected to our processing, for the time pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where our processing of your personal data has been restricted, such personal data shall, with the exception of storage, only be processed by us with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
Please note that restricting your personal data may result in us not being able to e.g. provide you with the services offered in connection with the product. - The right to object: You have the right to object to the processing we perform based on our legitimate interest (Art. 6(1)(f) GDPR). To the extent we process your personal data for direct marketing purposes, you also have the right to, at any time, object to such processing.
- The right to data portability: In cases where we base our processing on your consent or on the fulfilment of an agreement, you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the personal data transferred to another controller.
- Withdrawal of consent: If you have given your consent to processing of your personal data, you always have the opportunity to withdraw your consent with future effect by contacting us using the contact information below.
If you have any questions about our processing of your personal data or wish to exercise any of your rights set out above, you are always welcome contact us at privacy@thule.com.
If you have any objections or complaints regarding how we process your personal data, you also have the right to contact or file a complaint with authority for privacy protection in your country or the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten www.imy.se).
6. Description of our processing of other data
In accordance with the EU Data Act, Regulation (EU) 2023/2854
When you use our connected products, data is generated automatically. Below you can see what information is recorded for each product, why it is needed, and how you can access it. This information is provided before usage so that you, as a user, can make an informed decision.
6.1 What data is generated and why do we collect it?
6.1.1 When using Thule Shine air purifier canopy or Thule Chariot air purifier cover
| What data is generated? | Why is this data collected? |
| Air quality sensor data | To display air quality readings |
| Sensor failure | To alert the user if a sensor is not working |
| Filter level |
To alert the user when it is time to replace the filter |
| Bluetooth status |
To manage the Bluetooth connection |
| Error logs & diagnostic data |
For troubleshooting and error handling |
6.1.2 When using Thule Alfi Connect
| What data is generated? | Why is this data collected? |
| Sensor data |
To ensure the base is correctly installed |
| Battery level | To alert the user of the battery level |
| Bluetooth status |
To manage the Bluetooth connection |
| Temperature |
To monitor temperature |
| Error logs & diagnostic data |
For troubleshooting and error handling |
6.1.3 When using Thule Elm Connect or Thule Maple Connect
| What data is generated? | Why is this data collected? |
| Sensor data |
To ensure the car seat is correctly installed |
| Battery level | To alert the user of the battery level |
| Bluetooth status |
To manage the Bluetooth beacon |
| Temperature |
To monitor temperature |
| Error logs & diagnostic data |
For troubleshooting and error handling |
6.2 Where is the data sent?
Data is transferred via Bluetooth from the product to the app on your phone, then transferred to the backend system managed by us at Thule (Thule Sweden AB).
6.3 Your rights
You can always view real-time data and information directly in the app.
You have the right to request all data generated by your connected product and the Thule app in a downloadable format. To exercise this right, please send us a request via email including:
- Full name
- Valid identification document (ID card, passport, or equivalent)
- Verification of ownership of the product or legitimate use of the product
- Serial number of the product
- Your Thule user account
The data will be provided in a structured, commonly used, and machine-readable format. The volume of data provided will depend on the specific amount of information generated and the requested period
You may request the data to be shared with a third party of your choice or revoke a previous sharing authorization.
You may request the deletion of the generated data, under the terms set out in the privacy notice.
In case of any breach of the Data Act, you have the right file a complaint to the relevant local authorities, in accordance with Article 37 of the regulation. The responsible local authority will be designated by the national government.
6.4 Sharing data with third parties
We may share your data with trusted third parties in order to further improve and develop our products and services.
6.5 Data erasure
Data is stored on our servers as long as you use the service, after this period, the data will be deleted.
6.6 Contact
If you have any questions about our processing of your data or wish to exercise any of your rights set out above, contact us at privacy@thule.com.
Thule Sweden AB
Box 69
335 04 Hillerstorp
Sweden
7. Changes in the privacy notice
If any changes are made concerning the processing of your personal data, we will inform you of the changes by publishing an updated version of this privacy notice in the App. However, if we make material changes to this privacy notice, we will inform you by active means, e.g. by sending you an email or similar.
This notice was last updated 2025-12-16