TESIO CONTROL SYSTEMS privacy policy V4
Effective Date: 24rt
September 2018
Updated: 21st April
2022
Tesio Control Systems and subsidiaries (“we”, “us”, “our”, “Tesio Control
Systems”) 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”):
TESIO Mobile Application
Before you use our Products,
please carefully read through this Policy and understand our purposes and
practices of collection, and 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 questions r
regarding this Policy, please do not hesitate to contact us via:
Email: info@tesio.us
or Contact us through phone at +1
5616901933 and you can Write us at M/S Tesio Control Systems, 5155 NW 106 Ave,
Doral 33178, Miami, Florida, USA. 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
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 collect 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 refer to those mobile
applications developed by Tesio Control Systems 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
To provide our services
to you, we will ask you to provide the 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.
1. Information
You Voluntarily Provide Us
·Registered Account 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.
·If you authorize login
to the Products with a third-party account, we will obtain from such third
party your account information (such as portrait, nickname, region, gender,
etc.) which may be bound with your Tesio Control Systems account for quick
login. We will ensure compliance with applicable data protection laws and
regulations, as well as agreements, policies, or documentations, agreed with such
third party regarding sharing personal information, in processing your Personal
Data.Non-registered Account: If you do not want to
provide your account data when you start to use any of the Services, you may
use the App without logging in or creating an account, namely the “Try Now”
mode, and you may still use certain Services, such as searching and browsing
any features on the App by creating a guest ID. When you are using the
In "Try Now" mode, we will not collect Personal Data related to your
account. Collection and use of the Personal Data collected here will be limited
to: the time of entering the App, the operating system of your mobile phone, and
the purposes you have authorized in using the additional functions of the App
and/or the Smart Devices. For instance, if you enable the location setting in
In the "Try Now" mode, the location data will be uploaded for supporting
the function. Once you exit from the "Try Now" mode, we will remove
your data instantly and permanently.
However, if the Services you request or purchase are based on
your account, please go to the registration/login page for guidance.
·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:
Confirm: the system permissions
that allow in your App
To offer you 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, that 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:
1)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: a) real-time and precise location, for instance when you choose to use
the automation scenarios for controlling your Smart Devices, or b) 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 a corresponding
data protection measures, which you may refer to as Google’s Data Processing and
Security Terms for more details.
You may disable the collection
and use of your location information by changing your mobile device settings ("My
- Setting - Privacy Right Setting - Switch on/off Location Information"), upon which we will cease to collect and use your
location information.
2)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.
You may opt out of the use of
camera permission: "My - Setting - Privacy Right Setting -
Switch on/off Camera".
3)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,
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.
You may opt-out of the use of
photo album permission: "My - Setting - Privacy Right
Setting - Switch on/off Photo Album".
4)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.
You may opt-out of the use of
microphone permission: "My - Setting - Privacy Right
Setting - Switch on/off Microphone".
5)Additional
services based on storage permission (Android):
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.
You may opopt-outf the use of
storage permission: "My - Setting - Privacy Right Setting -
Switch on/off Storage".
6)Additional
services based on Notification permission:
The reason why we ask you for
the permission is to send you notifications about using the Smart Devices or
Services, especially if you have purchased security services and you require an
alert or message so that you can capture the real-time status.
You may opt out of the use of the App
notifications: "My - Message Center - Setting - Switch
on/off Notifications".
7)
Additional services based on Alert Window permission:
You may choose to bind a camera
in the App and require the App to display the real-time image of the camera in
a separate window.
You may opt-out of the use of
alert window information: "My - Setting - Privacy Right
Setting - Switch on/off Alert Window".
8)
Additional services based on Bluetooth permission:
You can enable Bluetooth
functions after turning on the permission, including controlling the Smart
Devices, acquiring the status of, discovering, and configuring Smart Devices. In
these functions, we will communicate with Smart Devices via Bluetooth. Please
be aware that even if you have agreed to enable the Bluetooth permission, we
will only use Bluetooth for communication in these scenarios: a display device
status on the home page and Smart Device panel; perform device control on the
home page and Smart Device panel; discovering Smart Devices on the home page
and the add device page, Smart Device distribution network.
You may opt-out of the use of
Bluetooth via "My - Settings - Privacy Setting -
Disable/Enable Bluetooth permission".
9)Additional services based on HomeKit permission
(iOS):
You can enable related functions
after enabling HomeKit permissions, including discovering Smart Devices,
enabling Smart Device network configuration, controlling Smart Devices, and checking
device status. Among these functions, we will process data with the "Home“
An app that comes with the iOS system through HomeKit. Please be aware that even
if you have agreed to enable the HomeKit permission, we will only use it in
these scenarios: on the home page, to discover HomeKit devices, HomeKit device
network configuration; in "Settings - HomeKit" for discovering
HomeKit devices, HomeKit device network configuration.
You may opt-out of the use of
HomeKit permission via "My - Settings - Privacy Settings-Turn
off/on HomeKit permission".
10)Additional services based on HealthKit (iOS):
You can proactively enable
related functions after enabling HealthKit permission, including statistics on
weight, height, running and swimming. In these functions, we will exchange
data with the health-related functionalities that come with the iOS system
through HealthKit. Please be aware that even if you have agreed to enable
HealthKit permission, we will only use them in these scenarios: when you use
the health-related Smart Device, such as body fat scales, bracelets, watch and
consent to use the HealthKit, the data reported by the Smart Device will be
transferred to HealthKit.
You may opt-out of the use of
HealthKit permission via "My - Settings - Privacy Settings
- Turn off/on HealthKit permission".
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.
2. Information
We Collect Automatically
·Mobile Device Information:
When you interact with our Services, to provide and maintain the
normal operation of our Services, to improve and optimize our Services, and to
protect your account security as well, we automatically collect mobile device
information, such as mobile device model number, IP address, wireless
connection information, the type, and version of the operating
the system, application version number, push notification identifier, log
files, and mobile network information. Meanwhile, we will collect your software
version number. To ensure the security of the operating environment or
to provide services, we will collect information about the installed mobile
applications and other software you use.
·Usage Data: During your interaction
with our websites and Services, we automatically collect usage data relating to
visits, clicks, downloads, messages sent/received, and another user of our
websites and Services.
·Log Information: When you use the App,
to improve your user experience, the system and exception log maybe
uploaded, including your IP address, language preference setting, operating
system version, date or time of access, so that we can facilitate and
accurately identify problems and help you solve them promptly.
Please note that
we 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 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 aggregate or desensitize such information.
3. Smart
Devices Related Information:
·Basic Information of Smart Devices:
When you connect your Smart Devices with the 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 collected during the process of connecting to a
Smart Device: Based on the type of Smart
The device you need to connect, the basic information collected includes: Wi-Fi
information, device MAC address, etc.
·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, Please
enter information about the smart device report.
·Please note that when
you actively agree to enter the App name and the application is connected to
the Apple Health(or some other Health-related platform, name
it?), we will share your measurement data with
Apple Health (including only your BMI, height, weight, and body fat% data). The
purpose of sharing data is only to measure and analyze health-related
indicators related to you, and it will never be disclosed to other third
parties. You can close at any time by managing the HealthKit settings page.
Purposes
and legal basis for processing Personal Data
The purpose for which we may
process information about you are as follows:
·Provide You with Our Services:
We process your account data, mobile device information, usage data, location
information, and Smart Device related information to providing you with the
Services that you have requested. The legal basis for this processing is to
perform our contract with you according to the user
agreement or some other terms of the user? Confirm.
·Improve Our Services: We
process your mobile device information, usage data, location information and
Smart Device related information to ensure the functions and safety of the
Services, to develop and improve the 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 user agreement or some other terms of the user? Confirm.
·Non-marketing Communication: We
process your 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 ("Me
&rt; Message Center &rt; Setting &rt; Notification Setting”) 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 user agreement or some other terms of
user? Confirm.
·Data Analysis: To analyze the
usage of the products we provide and improve your user experience, we will
analyze the data you provide us, a) we need to check your problems when you
encounter any malfunctions during the usage of the product, under such
circumstance, you may not able to opt-out because it is highly related to your
functionalities and quality of using our product and service, and b) analyze
data about how you interface with the product or under particular scenarios so
that you can better enjoy the convenience brought by our Services, under such
circumstance, if you do not agree to data analysis of your data, you can enter
the privacy settings of the opt-out app (“My &rt; Settings &rt; Privacy
Settings &rt; Data Analysis”) to opt-out your
selection. The legal basis for such processing is based on your consent.
·Marketing Communication and Personalization: We may process your account 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” (“Me&rt;
Settings &rt; Privacy Settings &rt; Personalization”)
in the App. The legal basis for this processing is your consent.
·Legal Compliance. We disclose
information if we are legally required to do so, or if we have a good faith
the belief that such use is reasonably necessary to:
·comply with a legal
obligation, process, or request;
·enforce our User
Agreement and other agreements, policies, and standards, including
investigation of any potential violation thereof;
·protect the rights,
property or safety of us, our users, a third party, or the public as required or
permitted by law; or
·detect, prevent or
otherwise address security, fraud, or technical issues.
If there is any change in the
purposes for processing your data, we will inform you of such changes 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?
At Tesio Control Systems, 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
websites and Services.
·To subsidiaries or
affiliates within our corporate family for purpose of regular business
activities based on our instructions and in compliance with applicable law,
this Policy and other appropriate confidentiality and security measures.
·To an affiliate or other
a 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, and
choices you may have regarding your Personal Data.
·As we believe in good
faith that accesses to, or use, preservation, or disclosure of the information is
reasonably necessary or appropriate to:
(a)Comply with applicable law, regulation, legal process, or
lawful governmental request;
(b)Enforce our User Agreement and other agreements, policies,
and standards, including investigation of any potential violation thereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property, or safety of us, our users, a
third party or the public as required or permitted by law; or
(e)Perform risk management, screening, and checks for unlawful,
fraudulent, deceptive, or malicious activities.
Except for the third parties
mentioned above, we only disclose your Personal Data to other third parties
with your consent.
International
Transfer of Information Collected
Tesio Control Systems will comply with applicable data localization requirements in
corresponding jurisdictions concerning the storage of data. To facilitate our
operation, we may transfer, store and process your 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 based on 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:
We are providing 2 approaches for the individual user to execute their
privacy rights, for instance, via the privacy office email address; info@tesio.us, or via the route of
Feedback is embedded in the App. You do not have to pay a fee and
we will aim to respond to 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: "My-Setting-Privacy
Settings-Personal Data Export";
·Request that we correct
inaccurate or incomplete Personal Data about you: 1) Modify your account number
(email address or phone number): "My-Setting-Account and
Security-Change your Account"; 2) Modify the
nickname and/or time zone: "My-Personal Information";
·Request deletion of
Personal Data about you: "My-Setting-Account and
Security-Delete Account", when you confirm the
deletion of your account, your Personal Data will be deleted accordingly.
·Request restrictions,
temporarily or permanently, on our processing of some or all Personal Data
about you: Please send over your request through "My-FAQ
& Feedback", or send over the email request to Confirm: the email box.
·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: Please
send over your request through "My-FAQ & Feedback", or send over the email request to Confirm: the
email box.
·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 Confirm the following
details: 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 confirming: location, camera,
photo album (picture library/video library), microphone, Bluetooth settings,
notification settings and other related functions;
2)You may opt out the
non-marketing communication through “Me &rt; Message Center &rt;
Notification Settings” to manage your selection;
3)You may opt-out of the data
analysis features through “Me &rt; Settings &rt; Privacy
Settings”;
4)You may opt out the
Personalization feature through “Me &rt; Settings &rt; Privacy
Settings &rt; Personalization”;
5)Unbind the Smart Device
through the App, and the information related to the Smart Device will not be
collected;
6)By using products with the
"Try Now" mode, and not enable certainly
location setting for a particular smart scene, we will not collect any
Personal Data about you;
7)If you previously agreed to
associate App account with a third-party service, such as a health platform,
please unbind it on the third-party platform.
When you withdraw your consent
or authorization, we may not be able to continue to provide you with certain
products or services correspondingly. However, the withdrawal of your consent
or authorization will not affect the processing of personal information based
on your consent before the withdrawal.
About Deletion of the Account: You can find the Delete function through “Me
&rt; Settings &rt; Account and Security &rt; Delete Account” (Deactivate
Account)
Security
Measures
We use commercially reasonable
physical, administrative, and technical safeguards to preserve the integrity
and security of your Personal Data. Tesio Control Systems provides various
security strategies to effectively ensure data security of user and device. As
for device access, Tesio Control Systems' proprietary algorithms are
employed to ensure data isolation, access authentication, applying for
authorization. As for data communication, communication using a 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 audits 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 Please
enter your private email address.
Data
Retention
We process your Personal Data
for the minimum period necessary for the purposes set out in this 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.
·For as long as you
require us to fulfill the products and services you request from us as defined
in the Confirm user agreement or some other terms of use;
·Personal Data will no
longer be retained when you request to remove your Personal Data, we will
accordingly, complete the task.
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 any child unless we first obtain permission from that
child’s parent or legal guardian. If we become aware that we have collected
Personal Data from any child 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 using a notice in the mobile applications before 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:
Tesio Control Systems
Postal Mailing Address: 5155 NW 106 Ave, Doral 33178, Miami, Florida,
The USA.
Email: Info@tesio.us