One Smart Home Mobile Privacy Policy
Effective
Date: 28/07/2022
One Smart
Home, its affiliates and subsidiaries (“we”, “us”, “our”, “One Smart Home”) are
committed to protecting your privacy. This Privacy Statement (“Statement”)
describes our practices in connection with information privacy on personal data
we process through your individual use of the following services, products, and
related mobile applications (collectively, the “Products”)
• One Smart Home Mobile
Application
• Smart Life Mobile
Application
In this
Privacy Notice, “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 nonstandard computing devices produced or manufactured by
hardware manufacturers, with human-machine interface and the ability to
transmit data that connect wirelessly to a network, including smart home appliances,
smart wearable devices, smart air cleaning devices, etc. “Apps” refers to those
mobile applications developed by One Smart Home that provide end users remote
control to Smart Devices and with the ability to connect to One Smart Home IoT
Platform.
For other
branded mobile applications powered by One Smart Home, our Clients control all
the Personal Data collected through our Products. We collect the information
under the direction of our Clients and the processing of such information shall
be limited to the purpose of providing the service for which our Clients has
engaged us. If you are a customer of one of our Clients and would no longer
like to be contacted by one of our Clients that use our service, please contact
the Client that you interact with directly.
What Personal
Data do we collect
In order to
provide our services to you, we will ask you to provide necessary personal data
that is required to provide those services. If you do not provide your personal
data, we may not be able to provide you with our products or services.
Information
You Voluntarily Provide Us
• Account or Profile Data: When you register an
account with us, we may collect your contact details, such as your email
address, phone number, and username. During your interaction with our Products,
we may further collect your nickname, profile picture, country code, language
preference or time zone information into your account.
• Feedback: When using feedback and
suggestion features in our Products, we will collect your email address, mobile
phone number and your feedback content to address your problems and solve
device failures on a timely basis.
Information
We Collect Automatically
• Device Information: When you interact with
our Product, we automatically collect device information, such as the MAC
address of your devices, IP address, wireless connection information, operating
system type and version, application version number, push notification
identifier, log files, and mobile network information.
• Usage Data: During your interaction
with our Sites and Services, we automatically collect usage data relating to
visits, clicks, downloads, messages sent/received, and other usage of our Sites
and Services.
• Log information: When you use our app, the
application and exception log may be uploaded.
• Location Information: We may collect
information about your real-time precise or non-precise geo-location when you
use our specific Products or Services, such as robot cleaner and weather
service.
Smart Devices
Related Information:
• Basic information of Smart
Devices: When you
connect your Smart Devices with our Products or Services, we may collect basic
information about your Smart Devices such as device name, device ID, online
status, activation time, firmware version, and upgrade information.
• Information reported by
Smart Devices: Depending
on the different Smart Devices you elect to connect with our Products or
Services, 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 (BFM), BMI and skeletal muscle mass (SMM); smart cameras may
report images or videos captured by it.
Purposes and
legal basis for processing Personal Data
The purpose
for which we may process information about you are as follows:
• Provide You Services: We process your account
and profile data, device information, usage data, location information, and
Smart Device related information to provide you with our Products and Services
that you have requested or purchased. The legal basis for this processing is to
perform our contract with you according to our Terms of Use.,
• Improve Our Services: We process your device
information, usage data, location information and Smart Device related
information to ensure the functions and safety of our Products, to develop and
improve our Products and Services, to analyze the efficiency of our operations,
and to prevent and trace fraudulent or inappropriate usage. The legal basis for
this processing is to perform our contract with you according
to our Terms of Use.
• Non-marketing Communication: We process your personal
data to send you important information regarding the Services, changes to our
terms, conditions, and policies and/or other administrative information.
Because this information may be important, you may not opt-out of receiving
such communications. The legal basis for this processing is to perform
our contract with you according to our Terms of Use.
• Marketing Communication: We may process your
personal data to provide marketing and promotional materials to you on our
Products and Services. If we do so, each communication we send you will contain
instructions permitting you to opt-out of receiving future communications of
that nature. The legal basis for this processing is your consent.
Additionally, if you consent to participate in our lottery, contest or other
promotions, we may use your personal data to manage such activities.
• Personalization: We may process your
account and profile data, usage data, device information to personalize product
design and to provide you with services tailored for you, such as recommending
and displaying information and advertisements regarding products suited to you,
and to invite you to participate in surveys relating to your use of our
Products. The legal basis for this processing is your consent.
• Legal Compliance: We may process your
personal data as we believe to be 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, business 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.
Who do we
share Personal Data with?
At One Smart
Home, we only share personal data in ways that we tell you about.
We may share
your Personal Data with the following recipients:
◦ To our third-party service
providers who perform certain business-related functions for us, such as
website hosting, data analysis, payment and credit card processing, infrastructure
provision, IT services, customer support service, e-mail delivery services, and
other similar services to enable them to provide services to us.
◦ To our customers and other
business partners who provide you, directly or indirectly, with your Smart
Devices, and/or networks and systems through which you access and use our Sites
and Services.
◦ To an affiliate 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 (including without limitation in connection with any
bankruptcy or similar proceedings). In such an event, you will be notified via
email and/or a prominent notice on our website of any change in ownership, incompatible
new uses of your personal information, and choices you may have regarding your
personal information.
◦ As we believe to be
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, business 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 carry out regular business activities.
Except for
the third parties described above, to third parties only with your consent.
Your Rights
Relating to Your Personal Data
We respect
your rights and control over your personal data. You may exercise any of the
following rights:
◦ Via the “Profile – Personal
Center” in our Products (for Product version 3.2 and later)
◦ By emailing us at info@cdb.co.nz
You do not
have to pay a fee and we will aim to respond you within 30 days. If you decide
to email us, in your request, please make clear what information you would like
to have changed, whether you would like to have your personal information
deleted from our database or otherwise let us know what limitations you would
like to put on our use of your personal information. Please note that we may
ask you to verify your identity before taking further action on your request,
for security purposes.
You may:
◦ Request access to the
personal data that we process about you;
◦ Request that we correct
inaccurate or incomplete personal information about you;
◦ Request deletion of
personal data about you;
◦ Request restrictions,
temporarily or permanently, on our processing of some or all personal data
about you;
◦ Request transfer of
personal information to you or a third party where we process the data based on
your consent or a contract with you, and where our processing is automated; and
◦ Opt-out or object to our
use of personal data about you where our use is based on your consent or our
legitimate interests.
Information
Security Safeguards
We use
commercially reasonable physical, administrative, and technical safeguards to
preserve the integrity and security of your personal information. One Smart
Home provides various security strategies to effectively ensure data security
of user and device. As for device access, One Smart Home proprietary algorithms
are employed to ensure data isolation, access authentication, applying for
authorization. As for data communication, communication using security
algorithms and transmission encryption protocols and commercial level
information encryption transmission based on dynamic keys are supported. As for
data processing, strict data filtering and validation and complete data audit
are applied. As for data storage, all confidential information of users will be
safely 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 by info@cdb.co.nz
Information
Retention Period
We process
your personal data for the minimum period necessary for the purposes set out in
this Privacy Notice, unless there is a specific legal requirement for us to
keep the data for a longer retention period. We determine the appropriate
retention period based on the amount, nature, and sensitivity of your personal
data, and after the retention period ends, we will destruct your personal data.
When we are unable to do so for technical reasons, we will ensure that
appropriate measures are put in place to prevent any further such use of your
personal data.
Changes to
this Policy Notice
We may update
this Privacy Notice to reflect changes to our information practices. If we make
any material changes, we will notify you by email (send to the e-mail address
specified in your account) or by means of a notice in the mobile applications
prior to the change becoming effective. We encourage you to periodically review
this page for the latest information on our privacy practices.
Contact Us
If you have
any questions about our practices or this Privacy Notice, please contact us as
follows:
Email: info@cdb.co.nz