Effective Date: 2019-08-18
Updated: 2019-07-19
Conectoz, its affiliates and subsidiaries ("we", "us", "ours", "Conectoz") are committed to protecting your privacy. This Privacy Policy ("Policy") describes our practices in connection with Personal Data privacy information that we process through the individual use of the following related services, products and mobile applications (collectively, the "Products"):
· Connectoz smart mobile app
· Smart Life mobile app
In this Privacy Policy, "Personal Data" means information that may be used to identify an individual solely from such information or from that information and other information to which we have access to that individual. "Smart devices" refers to non-standard computing devices produced or manufactured by hardware manufacturers with a human-machine interface and the ability to transmit data that connects wirelessly to a network, including: smart home appliances, smart wearable devices, intelligent air cleaning devices, etc. “Applications” refers to mobile applications developed by Conectoz that provide end users with remote control for smart devices and the ability to connect to Conectoz's IoT platform.
For other Connectoz branded mobile applications, our customers control all personal data collected through our products. We collect information under the direction of our Customers and the processing of such information must be limited to the purpose of providing the service by which our Customers hire us. If you are a customer of one of our customers and no longer wish to be contacted by one of our customers using our service, please contact the customer with whom you interact directly.
In order to provide you with our services, we will ask you to provide the Personal Data necessary to provide these services. If you do not provide your personal data, we may not be able to provide our products or services.
1. 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 email address, phone number, username and login credentials. During your interaction with our products, we may further collect your nickname, profile photo, country code, language preference, or time zone information from your account.
· Feedback: Using the feedback and suggestion features in our products, we collect your email address, mobile phone number, and feedback content to resolve your issues and resolve device failures in a timely manner.
2. Information We Collect Automatically
· Device Information: When you interact with our product, we automatically collect device information such as your devices' MAC address, IP address, wireless information, operating system type and version, application version number, 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 related to visits, clicks, downloads, sent / received messages, and other use of our sites and services.
· Logging Information: When you use our application, the system and exception log may be loaded.
· Location Information: We may collect accurate or inaccurate geographic location information in real time when you use our specific Products or Services, such as robot cleaners and weather services.
3. Information related to smart devices:
· Smart Device Basics: When you connect your smart devices to 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 update information. .
· Information reported by smart devices: Depending on the different smart devices you choose to connect to 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 (BMI), BMI and skeletal muscle mass (SMM); Smart cameras can report images or videos captured by it.
The purpose for which we may process information about you is as follows:
· Provide services: We process your account and profile data, device information, usage data, location information, and smart device-related information to provide our products and services that you have ordered or purchased. The legal basis for this processing is to perform our contract with you in accordance with 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, develop and improve our products and services, analyze the efficiency of our operations, and prevent and track fraudulent or inappropriate use. The legal basis for this processing is to perform our contract with you in accordance with our Terms of Use.
· Non-Marketing Communication: We process your personal information to send you important information about the services, changes to our terms, conditions and policies, and / or other administrative information. Because this information may be important, you cannot opt out of receiving such communications. The legal basis for this processing is to perform our contract with you in accordance with our Terms of Use.
· Marketing Communication: We may process your personal data to provide you with marketing and promotional materials on our products and services. If we do, each communication we send to you will contain instructions that will prevent you from receiving future communications of this nature. The legal basis for this processing is your consent. In addition, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.
· Customization: We may process your account and profile data, usage data, device information to customize product design and provide you with personalized services, such as recommending and displaying product information and ads that are appropriate to you and inviting you to participate. research related to the use of our products. The legal basis for this processing is your consent.
· Legal Compliance: We may process your Personal Data as we deem necessary or appropriate to: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public and governmental authorities (d) to enforce our terms and conditions; (e) protect our operations, business and systems; (f) protect our rights, privacy, security or property and / or those of other users, including you; and (g) allow us to seek available remedies or limit the damages we may suffer.
At Conectoz, we only share Personal Data in the ways we report. We may share your Personal Data with the following recipients:
· To our third party service providers who perform certain business-related functions such as website hosting, data analysis, payment and credit card processing, infrastructure provisioning, IT services, customer support services, business delivery services and email and other similar services to enable them to provide us with services.
· To our customers and other business partners who directly or indirectly provide you with their 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 reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or shares (including, without limitation, connection to any bankruptcy or similar procedures). In this case, you will be notified by email and / or a prominent notice on our site of any change of ownership, incompatible new uses of your Personal Data, and choices you may have regarding Personal Data.
· As we believe it is necessary or appropriate to: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; (d) enforce our terms and conditions; (e) protect our operations, business and systems; (f) protect our rights, privacy, security or property and / or those of other users, including you; and (g) allow us to seek available remedies or limit the damages we may suffer.
· For subsidiaries or affiliates of our corporate family, to conduct regular business activities.
Except for the third parties described above, only to third parties with their consent.
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 in your country of residence. When we do this, we ensure that an adequate level of protection is provided for information using one or more of the following approaches:
· an agreement based on approved EU standard contractual clauses in accordance with art. 46. For more information, see here.
If you would like more details about existing safeguards, please contact us directly as described in this Privacy Policy.
We respect your rights and control over your personal data. You can exercise any of the following rights:
· Through the "Profile - Personal Center" in our Products (for product version 3.2 and later)
· Sending an email to adm@conectoz.com.br (for pre-3.2 product release)
You do not need to pay a fee and we will try to respond within 30 days. If you decide to email us, at your request, please clarify what information you would like to change, whether you wish to delete your Personal Data from our database, or let us know what limitations you would like to place 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 reasons.
You can:
· Request access to the Personal Data 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 the transfer of personal data to you or third parties, where we process the data based on your consent or agreement, and where our processing is automated; and
· Choose not to participate in or oppose the use of Personal Data about you, where our use is based on your consent or our legitimate interests.
We use commercially reasonable physical, administrative and technical safeguards to preserve the integrity and security of your Personal Data. Conectoz provides a number of security strategies to effectively ensure user and device data security. Regarding device access, Conectoz's proprietary algorithms are employed to ensure data isolation, access authentication and authorization request. As for data communication, communication using security algorithms and dynamic-key information-based encryption transmission and transmission encryption protocols are supported. As for data processing, strict data filtering and validation and full data auditing are applied. As for data storage, All sensitive user information 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 think the security of any account you may have with us has been compromised), please notify us immediately by sending an email to adm@conectoz.com.br.
We process your Personal Data for the minimum period necessary for the purposes set forth in this Privacy Policy, unless there is a specific legal requirement to maintain data for a longer retention period. We determine the appropriate retention period based on the quantity, nature and sensitivity of your Personal Data and upon the expiration of the retention period, we will destroy your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are taken to prevent any further use of your Personal Data.
We may update this Privacy Policy to reflect changes in our information practices. If we make material changes, we will notify you by email (send to the email address specified in your account) or via a notice in mobile apps before the change takes effect. We recommend that you periodically review this page for the latest information on our privacy practices.
If you have any questions about our practices or this Privacy Policy, please contact us as follows:
Conectoz Commerce Eireli
Postal address: Estrada Particular Sadae Takagi, 215, Cooperative, Sao Bernardo Do Campo - SP - Brazil - ZIP Code: 09852-070
Email: adm@conectoz.com.br