Privacy policy of Comercializadora de Valor Agregado SA de CV
Effective Date: January 1, 2020
Updated: January 1, 2020
Comercializadora de Valor Agregado SA de CV. And its subsidiaries ("we", "us", "our", "Comercializadora de Valor Agregado SA de CV") undertake to protect your privacy. This Privacy Policy (“Policy”) describes our practices in relation to the privacy of information about personal data that we process through the individual use made of the following related mobile services, products and applications (collectively, the “Products” ):
· MIRATI HOME mobile application
In this Privacy Policy, “Personal Data” refers to the information that can be used to identify a person, either from the information itself, or from that information added to other information that we can access about the person correspondent. "Smart devices" refers to non-standard computing devices produced or manufactured by hardware manufacturers , which include man-machine interface and the ability to transmit data via wireless connection to a network. These devices include: smart appliances, smart portable devices, smart air purification devices, etc. “Applications” refers to mobile applications developed by Comercializadora de Valor Agregado SA de CV that provide end users with remote control of Smart Devices and the ability to connect to the IoT platform of Comercializadora de Valor Agregado SA de CV.
In the case of mobile applications of other brands that work with technology developed by Comercializadora de Valor Agregado SA de CV, our Clients control all personal data collected through our Products. We collect the information under the direction of our Clients, and the processing of such information will be limited to the purpose of providing the service for which our Clients have hired us. If you are an end customer of one of our Clients and do not wish to receive communications from one of our Clients that use our service again, please contact the Customer with whom you interact directly.
What personal data we collect
In order to provide our services, we ask the user to provide the personal data necessary to provide these services. If you do not provide your personal information, we may not be able to provide you with 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 information, such as your email address, phone number, username and login credentials. During the interaction with our Products, we may collect additional information about your nickname, profile picture, country code, language preference or time zone that you have entered in your account.
· Comments : When you use the comments and suggestions features in our Products, we will collect your email address, mobile phone number and the content of your comment to address your problems and troubleshoot device failures on time.
2. Information we collect automatically
· Device information : When you interact with our Product, we automatically collect information from your device, such as: MAC address of your devices, IP address, wireless connection information, type and version of operating system, 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 related to visits, clicks, downloads, messages sent / received and other uses of our Sites and Services.
· Registration information : When you use our application, the system and the exceptions log may be loaded.
· Location information: We may collect information about your geographic location, in real time, accurately or inaccurately, when you use our specific Products or Services, MIRATI HOME.
3. Information related to Smart Devices :
· Smart Device Basic Information : 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, connection status, activation time, firmware version and update information.
· Information communicated by Smart Devices : Depending on the different smart devices that you decide to connect with our Products or Services, we can collect various information communicated directly by your smart devices.
Purpose and legal basis for the processing of personal data
The following describes the purposes that justify that we can process information about the user:
· Provide services to the user : We process your account and profile data, device information, usage data, location information and information related to smart devices to provide the user with the Products and Services that you have requested or purchased from us. The legal basis for this treatment consists in the fulfillment of our contract with the user under the Terms of use.
· Improve our services : We treat device information, usage data, location information and information related to Smart Devices in order to guarantee the functions and safety of our Products, develop and improve our Products and Services, analyze the effectiveness of our operations and avoid and track any fraudulent or inappropriate use. The legal basis for this treatment consists in the fulfillment of our contract with the user under the Terms of use.
· Communication not related to marketing activities : We treat your personal data to send you important information regarding the Services, changes in our terms, conditions and policies and / or other administrative information. You cannot choose not to receive these communications, as such information may be important. The legal basis for this treatment consists in the fulfillment of our contract with the user under the Terms of use.
· Marketing communication : We may process your personal data to provide marketing and promotional material about our Products and Services. In this case, each communication we send to you will include instructions that allow you to opt out of receiving future communications of that nature. The legal basis for this treatment is your consent . Additionally, if you agree to participate in our lottery, contest or other promotions, we may use your personal data to manage those activities.
· Personalization : We can process your account and profile data, usage data and device information to customize the product design and provide services tailored to your needs, such as recommending and displaying information and announcements about products suitable for your needs and invite you to participate in surveys related to your use of our products. The legal basis for this treatment is your consent .
· Legal compliance: We may treat your personal data as we deem necessary or appropriate to: (a) comply with current legislation and regulations; (b) comply with the legal process; (c) respond to requests from public and government authorities; (d) enforce our terms and conditions; (e) protect our operations, businesses and systems; (f) protect our rights, privacy, security or property and / or those of other users, including you; and (g) allow us to apply the available reparation measures or limit the damages we may suffer.
With whom do we share personal data?
In Comercializadora de Valor Agregado SA de CV, we only share personal data as described to the user. We may share your personal data with the following recipients:
· Our external service providers that perform for us specific functions related to business activity, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer service customer, email delivery services and other similar services that allow them to provide services.
· Our clients and other business partners that provide you, directly and indirectly, with their smart devices, and / or networks and systems through which you access and use our Sites and Services.
· A subsidiary or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other provision of all or part of our business, assets or shares (which includes, without limitation, everything related with any bankruptcy or other similar procedures). In such a case, you will receive a notification via email and / or a prominent notice will be published on our website about any change in ownership, incompatible new uses of your personal data and decisions that you can take in relation to your personal data.
· As we deem necessary or appropriate to: (a) comply with current legislation and regulations; (b) comply with the legal process; (c) respond to requests from public and government authorities, including public and government authorities outside their country of residence; (d) enforce our terms and conditions; (e) protect our operations, businesses and systems; (f) protect our rights, privacy, security or property and / or those of other users, including you; and (g) allow us to apply the available reparation measures or limit the damages we may suffer.
· Subsidiaries or subsidiaries within our corporate family, with the purpose of conducting ordinary business activities.
With the exception of the third parties described above, to other third parties exclusively with your consent.
International transfer of the information collected
To facilitate our operations, we may transfer, store and process your personal data in jurisdictions other than the one you inhabit. The laws in these countries may be different from the laws applicable in your country of residence.
Your rights in relation to your personal data
We respect your rights and control over your personal data. You can exercise any of the following rights:
Through the “Profile - Personal Center” section
Payment of any fees is not required and we aim to respond within 30 days. If you decide to send us an email, in your request clarify what information you want to be modified, if you want your personal data deleted from our database, or inform us about the limitations you want to impose on the use we make of your personal data. Please note that for security reasons, we may ask you to verify your identity before taking any action you request.
You can:
· Request access to the personal data we deal with about you,
· Request that we correct incorrect or incomplete personal data about you,
· Request the deletion of personal data about you,
· Request restrictions, temporarily or permanently, on the treatment we make of some or all of your personal data,
· Request the transfer of your personal data to you or a third party when we process the data under your consent or a contract signed with you, and when our processing is automated, and
· Choose not to participate or oppose our use of personal data about you when our use is based on your consent or our legitimate interests.
Security
We use commercially reasonable physical, administrative and technical protections to protect the integrity and security of your personal data. Comercializadora de Valor Agregado SA de CV applies various security strategies to effectively guarantee the security of user and device data. Regarding the access of the device, proprietary algorithms of Comercializadora de Valor Agregado SA de CV are used to guarantee data isolation, access authentication and authorization request. With regard to data communication, communication is used that applies security algorithms and encryption protocols for transmissions, and transmission with information encryption with commercial quality based on dynamic keys. With regard to data processing, strict filtering and data validation and complete data auditing are applied. With regard to data storage, all confidential user information will be securely encrypted for storage. If you have any reason to consider that your interaction with us is no longer secure (for example, if you feel that the security of any account that you can maintain with us has been compromised), you must immediately notify us of the problem through the email address electronic ghia.licencias@gmail.com
Data retention
We process your personal data for the minimum period necessary for the purposes stipulated in this Privacy Policy, unless there is a specific legal requirement that requires us to keep the data for a longer retention period. We determine the corresponding retention period based on the amount, nature and sensitivity of your personal data, and when the retention period ends, we will delete your personal data. When we cannot do it for technical reasons, we will guarantee that the appropriate measures are applied to avoid any future use of your personal data.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes that we implement in our information-related practices. If we make any material changes, we will inform you by sending a notification via email (to the email address specified in your account) or through a notice in the mobile applications before the change takes effect. It is recommended to check this page periodically for the most up-to-date information on our privacy practices.
Contact us
If you have any questions about our practices or about this Privacy Policy, please contact us through the address:
Comercializadora de Valor Agregado SA de CV
Mailing address: Av. Mariano Otero 2489 Col. Jardines de la Victoria CP44900 Guadalajara, Jalisco, Mexico
Email: ghia.licencias@gmail.com