Privacy Statement
Effective Date: 2018-12-1 8
Date of update: 2019 -2-7
At Home Technologies BV (Chamber of Commerce number 73488410) and its subsidiaries (hereinafter referred to as: "we", "us", "our" or "Hihome") are committed to protecting your privacy. This privacy statement (hereinafter also referred to as: "Statement") describes which personal data and information we process through (your) use of our services, products, systems, website and related mobile applications (hereinafter referred to as: "Products").
We request that you read this Statement in its entirety and do not provide any information to us if you do not agree with this Statement.
Contents of this Statement
- Definition s.
- What Personal Data do we collect?
- Purposes and legal basis for processing Personal Data
- Who do we share Personal Data with?
- Your rights regarding your Personal Data.
- Information Security Guarantees.
- Information retention period.
- Changes to this Statement.
- Legal application and jurisdiction.
1. Definitions
In this Statement:
“ Personal Data ” means information that can be used to identify an individual, either from that information alone or from that information and other information we have access to about that individual.
“ Smart Devices ” refers to those non-standard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit Personal Data that connect (wirelessly) to a network, including: smart home appliances, smart wearable devices, smart air purification devices, etc.
“ Apps ” refers to those mobile applications developed by Hihome that provide end users with remote control of Smart Devices and have the ability to connect to the Hihome IoT Platform.
2. What Personal Data do we collect?
In order to provide our Products (technical and/or practical) to you, we need your Personal Data. If you do not provide your Personal Data, we may not be able to provide you with our Products.
- Personal data that you voluntarily provide to us
- Account or Profile Information : When you register an account with us, we may collect the contact information you provide, such as your email address, phone number, date of birth, and username. As you interact with our Products, we may further collect your nickname, profile picture, country code, language preference, or time zone information in your account.
- Feedback : When we use feedback and suggestion functions in our Products, we collect your email address, mobile phone number and your feedback content to resolve your problems and solve malfunctions in a timely manner.
- Personal data we collect automatically
- Device Information : When you interact with and/or use our Products, we automatically collect device information, such as your devices' MAC address, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
- Usage Data : As you interact with our websites and Products, we automatically collect usage data regarding visits, clicks, downloads, messages sent/received and other use of our Products.
- Log information : When you use our app, the application log and exception log may be uploaded.
- Location Information : We may collect information about your real-time precise or imprecise geographic location when you use our specific Products for which your geographic location is desirable for proper functioning, such as robot cleaning and weather service.
- Personal data through Smart devices:
- Basic Information from Smart Devices : When you connect your Smart Devices to our Products, we may collect basic information about your Smart Devices, such as device name and type, device ID, online status, activation time, firmware version and upgrade information.
- Information Reported by Smart Devices : Depending on the different Smart Devices you choose to connect to our Products, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BMM), BMI, and skeletal muscle mass (SMM); smart cameras may report images or videos they have captured.
Personal data of children
We do not knowingly collect personal data from children under the age of 16 (and in some countries under the age of 13).
Parents or guardians should monitor and supervise their children's use of our Products to ensure that their child(ren) do not share any Personal Data with us.
Cookies and other technologies
Our websites, online services, email messages and other Products may use cookies and other technologies such as pixel tags and other web beacons. These technologies help us understand the behavior of users of our Products, see which parts of our websites are visited, and measure and improve the effectiveness of advertisements and web searches.
When the information collected through cookies and other technologies can be traced back to an individual, we treat that information as Personal Information.
3. Purposes and legal basis for processing Personal Data
We may use your Personal Information for various legitimate reasons and business purposes. Below is an overview of the purposes for which we process your Personal Information:
- Providing our Products : We process your account and profile information, device information, usage data, location information and Smart Device-related information to provide you with our Products that you have requested or purchased. The legal basis for this processing is to perform our contract with you under our Terms of Use.
- Improving our Services : We process your device information, usage data, location information and Smart Device-related information to ensure the functions and security of our Products, to develop and improve our Products, to analyze the efficiency of our operations, and to track and prevent fraudulent or inappropriate use. The legal basis for this processing is to perform our contract with you under our Terms of Use and our legitimate interest to improve our Products.
- Non-marketing communications : We process your Personal Information to send you important information regarding the Services, changes to our terms, conditions and policies and/or other administrative information. While this information may be important, you may opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you under our Terms of Use.
- Marketing communications : We may process your Personal Data to provide you with marketing and promotional materials for our Products. If we do so, each communication sent to you will include instructions enabling you to opt out of receiving future communications of this nature. The legal basis for this processing is your consent and/or our legitimate interest in informing you as a user of our Products. In addition, if you participate in our sweepstakes, contest or other promotions, we may use your Personal Data to administer such activities.
- Personalization : We may process your account and profile data, usage data and device information to personalize product design and to provide you with tailored services, such as recommending and displaying information and advertisements relating to products that suit you, and inviting you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent and/or our legitimate interest to improve our Products.
- Legal obligation : We may process your Personal Data if we believe this is necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations, businesses and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
4. With whom do we share Personal Data?
In principle, we do not share your Personal Data with other parties without your permission. Only in line with the purpose for which we received your Personal Data, such as the optimal functioning of our Products, we may share your Personal Data with the following recipients:
- To our external service providers that perform certain business-related functions on our behalf, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer service, email delivery services, and other similar services, in order to enable them to provide services to us.
- To our business partners who directly or indirectly provide you with your Smart Devices and/or networks and systems through which you access and use our Products.
- To an affiliated company or other third party in the event of any reorganization , merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock. In such event, you will be notified via email and/or a prominent notice on our website.
- As we believe is necessary or appropriate : (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, businesses and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- To subsidiaries or affiliates within our corporate family, to conduct regular business operations.
In all other situations, we only share Personal Data with third parties with your consent. If you have a direct relationship or are a customer of a third party with whom we share Personal Data and you no longer wish to have contact with this third party, please contact that party directly.
Processing of your Personal Data in or to Abroad
Since Hihome operates internationally, Personal Data you provide to us may be transferred to, or accessed by, our affiliated companies abroad. This means that your Personal Data may be processed outside the country where you reside if this is necessary to achieve the purposes stated in this Statement.
If you live in a country that is a member of the European Economic Area, we may transfer your Personal Data to countries that the European Commission has decided provide an adequate level of protection. For transfers from the European Economic Area to countries other than those for which the European Commission has decided that they provide an adequate level of protection, we have or will take appropriate measures to protect your Personal Data, such as organizational and legal measures.
5. Your rights regarding your Personal Data
We respect your rights and control over your Personal Data. You can therefore exercise the following rights:
- Request access to the Personal Data that we process about you;
- Request for correction of incorrect or incomplete Personal Data;
- Request for deletion of your Personal Data;
- Request to process less Personal Data from you (temporarily or permanently);
- Request the transfer of your Personal Data to you or a third party designated by you;
- Object to our use of your Personal Data or
- Other questions about the protection of your Personal Data.
You will not have to pay a fee to exercise the above rights and we will aim to respond to you and/or implement your request within 30 days, provided we are not otherwise permitted or required to retain your Personal Data.
You can exercise your rights:
- through your account via “Profile – Personal Center” in our Products (for product version 3.2 and later);
- by sending an email to our Data Protection Officer via privacy@Hihome.eu (for product version before 3.2) or
- by post to the address: Postbus 42, 6860AA in Oosterbeek (Netherlands).
If you choose to send us mail or email, please make clear in your request which right you wish to exercise. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
If you are not satisfied with the response you receive, you can submit your complaint to the local supervisory authority in your country.
6. Information Security Guarantees
Depending on the state of the technology, the costs of implementation and the nature of the Personal Data to be protected, we take technical and organizational measures to prevent security risks surrounding your Personal Data.
In this context, Hihome offers various security strategies to effectively guarantee the data security of you and the Products:
- Regarding access to Products, algorithms are used to ensure data isolation, access verification and authorization.
- As for data communication, communication is supported using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys.
- Regarding data processing, strict data filtering and validation and full data auditing are applied.
- With regard to the storage of Personal Data or users' confidential information, it will be securely encrypted for storage.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem at privacy@Hihome.eu .
7. Information retention period
We will process your Personal Data for the minimum period necessary for the purposes set out in this Statement, unless there is a specific legal requirement for us to retain the data for a longer period. If you have created an account with us, we will retain your Personal Data for as long as your account is active and/or as needed to provide you with our Products. We will otherwise determine the appropriate retention period based on the nature and sensitivity of your Personal Data and after the retention period has expired, we will destroy your Personal Data. Where we are unable to do so for technical reasons, we will ensure that appropriate measures are in place to prevent any further use of your Personal Data. 8. Changes to this Statement
We may update and make changes to this Statement from time to time.
If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice in the Apps prior to the change becoming effective. We encourage you to periodically review this page for the latest information.
9. Legal application and jurisdiction
This Statement has been formulated in accordance with the laws of the Netherlands and shall be governed by the laws of the Netherlands.
If you have any questions about our practices or this Statement, please contact us:
Hihome - At Home Technologies BV
Postal address: PO Box 42, 6860AA Oosterbeek, The Netherlands.
E-mail: Privacy@Hihome.eu .