Airam Home Service Privacy Policy
Effective Date: 2021-02-10
AIRAM ELECTRIC OY AB, Sementtitehtaankatu 6, 04260 Kerava, Finland, tel. +358 207 545 600, business id 0733549-5, info@airam.fi (“Airam”, “we”) is committed to protecting Your privacy in accordance with the General Data Protection Regulation (GDPR) and the Directive on privacy and electronic communications of European Union (ePrivacy Directive) and the applicable data protection laws of Finland.
This Privacy Policy (“Policy”) describes our practices in connection with Your Personal Data we process based on Your purchase and use of the Airam Home Service (“Service”). “Personal Data” means any information which is identifiable to You, directly or indirectly.
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.
The Service consists of a mobile application (“App”) and related mobile and Internet services which enable users (“User or You”) to remotely connect, control and use the products manufactured, distributed or sold by Airam for use in the Service (“Smart Devices”). These Smart Devices have a human-machine interface and the ability to connect wirelessly to a network and transmit data to the Service. These Smart Devices include for example bulbs, sockets, ceiling lights, sirens, smoke alarms, remote controllers, cameras, and doorbells,
What Personal Data do we collect
1. Account Data
· Account Data: If You order a Smart Device or paid Service from us, we collect data about the sales and purchase event, order and contract, and delivery including Your name, contact information, shipping and billing address, and credit card information. When You download App or register an account with us, we may collect Your name and contact details, such as Your email address, phone number, account ID, username, and login credentials.
2. Profile Data
· During Your interaction with our Service, we may further collect profile information You provide us, for example Your nickname, profile picture, country code, language preference, time zone, local temperature degree (Celsius) of the day).
3. Feedback
· When You give us feedback, suggest features, or request support in our Service, we will collect Your email address, mobile phone number and the content of Your feedback or support request.
4. Mobile Device, App and Usage Data
· Mobile Device Information: With Your consent we automatically collect device information, such as the MAC address of Your devices, IP address, custom name, wireless connection information, operating system type and version, application version number, push notification identifier, time zone, language, log files, and mobile network information when You interact with our Service using App installed in Your mobile device.
· Usage Data: With Your consent, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Services during Your interaction with our Sites and Services.
· Log Information: When You use our App, the system and exception log may be collected.
· Location Information: With Your consent we may collect information about Your real-time precise or non-precise geo-location when You use our Services.
5. Smart Devices Related Data
· Basic Information of Smart Devices: When You connect an use Your Smart Devices with our Service, we may with Your consent collect basic information about Your Smart Devices such as device name, device ID, IP address, online status, activation time, connection times, firmware version and upgrade information, geo-location, city id, country code, time zone, and language.
6. Data Reported by Smart Devices:
· Depending on the different Smart Devices You decide to connect with our Service, we may collect data with the Smart Device and report it to You as requested by You in the Service for example, the picture or video taken by a smart camera or doorbell.
7. Data from Partner Services
· When You connect to and use our partners´ services for example voice control services of Google Assistant, Amazon Alexa Skill and Apple Siri we need to collect data necessary for the interoperation of our Service and the services of the partners.
Purposes and legal basis for processing Personal Data
We process Your Personal Data for following purposes:
· Performance of contracts with You: We process Your Account Data in order to process and fulfill Your order and to initiate and provide the Service to You and to authenticate You in the Service. This will also include performance of Your orders of our third-party partners´ services You opt to connect to our Services, for example voice control services of our third-party service partners like Google Assistant, Amazon Alexa Skill and Apple Siri. The legal basis for this processing is to perform contract with You in accordance with our User Terms and our partners contract terms.
· Provide You services: We process Your Personal Data to activate, manage and provide You with our Service and interoperate it with our third-party partners´ services which You have requested or purchased; to personalize Service design to match Your needs; give You support and address Your problems and solve device failures on a timely basis; and to ensure the functions and safety of our Products. The legal basis for this processing is our legitimate interest (provision of services, management of customer relationship).
· Improve Our Services: Except the data reported by Smart Devices, we process Your Personal Data to analyze the efficiency of our operations and to develop and improve our Services. The legal basis for this processing is our legitimate interest (customer relationship).
· Non-marketing Communication: We analyze and 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 our legitimate interest (customer relationship).
· Marketing: We may analyze and process Your Personal Data in order to display and send You information and advertisements regarding products and service personalized to Your needs:
o We may send advertisements by email and other electronic communications on our products and services which are similar to or belong to the same product group with Your previously purchased products or services. The legal basis for this processing is our legitimate interest (development of our customer relationship). With Your consent, we may send You electronic marketing of other Products and Services as well. Each communication we send You will contain instructions permitting You to opt-out of receiving future communications of that nature.
o With Your consent, we may display advertisements to you inside the App and at our website and other websites based on Your usage of our Services and websites.
o With Your consent to participate in our lottery, contest or other promotions, or surveys relating to Your use of our Products we may use Your Personal Data to manage such activities.
· 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.
· Fraud prevention: We process Your device information, usage data, location information and device related information to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is our legitimate interest (security).
Content of the data reported by Smart Devices (e.g. the picture or video taken by a smart camera or doorbell) shall only be reported to You and not used for any other purpose.
Who do we share Personal Data with?
We share Your Personal Data with the following recipients:
· our third-party service providers or sub-contractors who perform certain business-related functions on behalf 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. These sub-contractors include Tuya GmbH who provides the Service platform and its sub-contractors including but not limited to:
o Hangzhou Tuya Information Technology Co., Ltd.
o MS Azure (Microsoft Ireland Operations Limited)
o Nexmo Ltd.
o The Weatherbit LLC.
o Geetest Wuhan Jiyi Network Technology Co. Ltd.
o Google LLC.
o Apple Inc.
o Amazon Web Services, Inc.
· our third-party service partners (e.g. Google, Amazon, Apple) whose services You have opted to connect with our Service. Note that Airam is not responsible for processing of Your Personal Data by the partners. Please study their own privacy policies and notices.
· 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.
· 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
To facilitate our operation, we may transfer to, and store and process Your Personal Data in countries outside of the European Union (EU), the European Economic Area (EEA), and countries which has been found to ensure an adequate level of data protection by the European Commission (GDPR Article 45). Transfers to these third countries include transfers to ICT service providers in China and USA. These transfers shall be made only under the Standard Contractual Clauses (SCC) approved by European Commission for the transfer of personal data to processors or controllers established in third countries which do not ensure an adequate level of data protection.
To processors: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087
To controllers: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915
Airam and the importer of the data shall also agree measures that supplement the SCCs to ensure compliance with the EU level of protection of personal data and essential guarantees for surveillance measures in accordance with Recommendations 01/2020 and 02/2020 of the European Data Protection Board.
Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of Your Personal Data. As for device access, 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.
Data Retention
We retain Your Personal Data until the termination of the User Agreement or as long as your account is active or as needed to provide you the Service. We may for example periodically de-identify unused accounts, and we may regularly review and de-identify unnecessary data. Note that if you ask us to remove Your Personal Data, we will retain data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements
Your Rights Relating to Your Personal Data
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.
· If you consider that our processing of your personal data infringes applicable law, You may lodge a complaint with the relevant supervisory authority Data Protection Ombudsman in Finland.
You do not have to pay a fee for exercising Your rights 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 exercise part of Your rights via the “Profile – Personal Center” in our Service. If You want to exercise other rights or if you have questions about data protection, please contact us:
Airam Electric Oy Ab
Sementtitehtaankatu 6,
04260 Kerava, Finland
tel. +358 207 545 600
info@airam.fi