Brass and Fittings S.L. Mobile Privacy Policy
Effective
Date: 01/03/2022
Updated:
Brass
and Fittings S.L. (“we”,
“us”, “our”, “Brass
and Fittings S.L.”)
are committed to protecting your privacy. This Privacy Policy
(“Policy”) 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”):
Before
you use our Products, please carefully read through this Policy and
understand our purposes and practices of collection, processing of
your Personal Data, including how we use, store, share and transfer
Personal Data. In the Policy you will also find ways to execute your
rights of access, update, delete or protect your Personal Data.
When
you accept this Policy when you register with your Personal Data, or
if you start to use our Products and does not expressly object to the
contents of this Policy, we will consider that you fully understand
and agree with this Policy. If you have any question r regarding this
Policy, please do not hesitate to contact us via:
(info@celerlighting.com)
Definition
In
this Policy, Personal Data means information generated, collected,
recorded and/or stored, electronically or otherwise, that can be used
to identify an individual or reflect the activity of an individual,
either from that information alone, or from that information and
other information we have access to about that individual.
Personal
Sensitive Data includes personal biometric information, communication
records and contents, health information, transaction information,
and precise location information. When we collect Personal Sensitive
Data from you, we will generate an explicit notification for your
consent before we collection personal sensitive data about you.
Smart
Devices refers to those 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 byBrass
and Fittings S.L. that
provide end users remote control to Smart Devices and with the
ability to connect to the supplier IoT Platform.
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 name and
contact details, such as your email address, phone number, user
name, and login credentials. 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
based on additional functions: In
order to offer you with more convenient and higher-quality Services
with optimized user experiences, we may collect and use certain
information if you consent to use additional functions in the App.
Please note, if you do not provide such information, you may
continue to use basic Services of the App and connected Smart
Devices, but certain features based on these additional functions
may not be available. These additional functions may include:
Additional
functions based on location information:
When
you enable the location-based functions through permission settings
on your mobile device, we will collect and process your location
information to enable these functions, such as pairing with your
Smart Devices. Also, we may collect information about your real-time
precise or non-precise geo-location when you use certain Smart
Devices or the Services, such as robot cleaner and weather service.
Based
on your consent, when you enable the geo-fence feature, your location
information will be generated and shared with Google Maps services.
Please note that Google has corresponding data protection measures,
which you may refer to Google Data Protection Terms for more details:
https://privacy.google.com/businesses/gdprservices/. You may reject
such use of your location information by managing the permission
settings in the Services, upon which we will cease to collect and use
your location information.
Additional
services based on camera:
You
may use the camera to scan the code by turning on the camera
permission to pair with a Smart Device, take video, etc. Please be
aware that even if you have agreed to enable the camera permission,
we will only obtain information when you actively use the camera for
scanning codes, video recording, etc.
Additional
services for accessing and uploading pictures/videos based on photo
albums (picture library/video library):
You
can use this function to upload your photos/pictures/videos after
turning on the photo album permission, so as to realize functions
such as changing the avatar, reporting device usage problems by
providing photo proofs, etc.. When you use the photos and other
functions, we will not recognize this information; but when you
report a device usage problem, we may use the photos/pictures you
upload to locate your problem.
Additional
services related to microphone-based service:
You
can use the microphone to send voice information after turning on the
microphone permission, such as shooting videos, waking up the voice
assistant, etc. For these functions, we will collect your voice
information to recognize your command. Please be aware that even if
you have agreed to enable the microphone permission, we will only
obtain voice information through the microphone when you voluntarily
activate the microphone in the App.
Additional
services based on storage permissions:
The
purpose is to ensure the stable operation of the App by utilizing the
storage permission. After you give or indicate the permission to
read/write your mobile device’s storage, we will access pictures,
files, crash log information and other necessary information from
your mobile device’s storage to provide you with functions, such as
information publications, or record the crash log information
locally.
Please
note that if you turn on any permission, you authorize us to collect
and use relevant personal information to provide you with
corresponding Services. Once you turn off any permission, we will
take it as canceling the authorization, and we will no longer
continue to collect Personal Data based on the corresponding
permissions, and the related functions may be terminated. However,
your decision to turn off the permission will not affect the previous
collection and use of information based on your authorization.
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 connectioninformation,
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 system and exception log may be uploaded.
Please
note that one cannot identify a specific individual by using Device
Information or Log Information alone. However, if these types of
non-personal information, combined with other information , may be
used to identify a specific individual, such non-personal information
will be treated as Personal Data. Unless we have obtained your
consent or unless otherwise provided by data protection laws and
regulations, we will anonymize and desensitize such non-personal
information.
Location
Information:
When you enable location-based functions through permission settings
on your mobile device, we will collect and process your location
information to enable certain functions, such as pairing with your
Smart Devices. Also, we may collect information about your real-time
precise or non-precise geo-location when you use our specific
Products or Services, such as CELER SMART
Based
on your consent, when you enable the geo-fence feature on the
Products, your location information will be generated and shared with
Google Map services. Please note that Google has corresponding data
protection measures, which you may refer to Google Data Protection
Terms for more details:
https://privacy.google.com/businesses/gdprservices/. You may reject
such use of your location information by managing the permission
settings in the Products, upon which we will cease to collect and use
your location information.
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, On-Off cycles.
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. At the same time,
we will also send you notifications related to the services you have
purchased, such as alert services. You can check the [App
Notification] in the App to manage these communications. When you
decide not to enable the Notifications function, we will no longer
process your information for such purpose. 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 the 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. If you
do not agree to Brass
and Fittings S.L.
sending you marketing communications, you may opt out when you enter
the App, or by changing your preferences in [Privacy Settings] of
the App. The legal basis for this processing is your consent..
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 the
Services. If you do not allow us to process your Personal Data for
personalization, you may opt out when you enter the App, or by
changing your preferences in [Privacy Settings] in the App. 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.
If
there is any change in the purposes for processing your personal
data, we will inform such change to you via email and/or a prominent
notice on our website of such changes of purposes, and choices you
may have regarding your Personal Data.
Who do we Share Personal Data
with?
At
Brass
and Fittings S.L.,
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 Data,
and choices you may have regarding 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,
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.
International
Transfer of Information Collected
Brass
and Fittings S.L.will
comply with applicable data localization requirements in
corresponding jurisdictions with respect to storage of data. To
facilitate our operation, we may transfer, store and process your
Personal Data in jurisdictions other than where you live. Laws in
these countries may differ from the laws applicable to your country
of residence. When we do so, we will ensure that an adequate level of
protection is provided for the information by using one or more of
the following approaches:
Agreement
on the basis of approved EU standard contractual clauses per GDPR
Art. 46. For more information,
see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If
you would like further detail on the safeguards we have in place, you
can contact us directly as described in this Privacy Policy.
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:
Confirm6:
please provide at least 2 approaches for individual user executing
their privacy rights, for instance, via the privacy office email
address; info@celerlighting.com, or via the route of Feedback
imbedded in the App: Me&rt;Personal Center&rt;Account and Security&rt;,
etc.
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 Data deleted from our database or
otherwise let us know what limitations you would like to put on our
use of your Personal Data. 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 Data 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 Data 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.
•Withdrawal
of consent: We will exercise your privacy right to withdraw consent
through the following approaches:
1)
For privacy permissions acquired through device system settings, your
consent can be withdrawn by changing device permissions, including
location, camera, photo album (picture library/video library),
microphone, Bluetooth settings, notifications and other related
functions;
2)
In the marketing communications that you agree to, the information we
send to you contains instructions that allow you to withdraw your
consent in accordance with the “unsubscribe” method described in
the information;
3)
Unbind the Smart Device through the app, and the information related
to the Smart Device will not be collected;
4)
By using product with the visitor mode, we will not collect any
personal data about you;
When
you withdraw your consent or authorization, we may not be able to
continue to provide you with the products or services
correspondingly. However, your withdrawal of your consent or
authorization will not affect the processing of personal information
based on your consent before the withdrawal.
5)
Account deletion can be at: Yo -&rt; Ajustes -&rt; Cuenta y seguridad
-&rt; Desactivar cuenta
Security
We
use commercially reasonable physical, administrative, and technical
safeguards to preserve the integrity and security of your Personal
Data. Brass
and Fittings S.L.provides
various security strategies to effectively ensure data security of
user and device. As for device access, Brass
and Fittings S.L.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 could
immediately notify us of the problem by emailing Brass
and Fittings S.L.Data
Retention
We
process your Personal Data for the minimum period necessary for the
purposes set out in this Privacy Policy, 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.
Children’s
Privacy
Protecting
the privacy of young children is especially important to us. The
Services are not directed to individuals under the age of thirteen
(13)(or such other age provided by applicable law in your
country/region of residence), and we request that these individuals
do not provide any Personal Data to us. We do not knowingly collect
Personal Data from anyone under the age of thirteen (13) unless we
first obtain permission from that child’s parent or legal guardian.
If we become aware that we have collected Personal Data from anyone
under the age of thirteen (13) without permission from that child’s
parent or legal guardian, we will take steps to remove that
information.
Changes to this Privacy Policy
We
may update this Privacy Policy 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 Policy,
please contact us as follows:
Brass
and Fittings S.L.
Postal
Mailing Address: Avenida Alcalde Caballero 16, 50010 Zaragoza
Email:
info@celerlighting.com