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ACCUFLOW DISTRIBUTION LTD (IN RECEIVERSHIP) T/A Smartzone Privacy Policy

Issued: 02/04/2020
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Scope

If you are a resident of the EEA (specifically, any country in the European Union, Liechtenstein, Norway, Iceland) or a resident of Switzerland, this Privacy Notice to Data Subjects in the EEA and Switzerland (“Privacy Notice”) explains what personal data we collect about you, how it is used, with whom it is shared, and rights you may exercise in relation to your personal data.

This Privacy Notice applies to our privacy practices for your use of (i) this website and any mobile sites or applications operated by Smartzone (the “User Interfaces”) and (ii) any combination of Smartzone’s products and services purchased or accessed via any User Interface (the “Services”), and all personal data we directly receive or collect from you in the course of doing business. Smartzone’s business address is Unit 12 Southside Business Park, Togher, Cork, Ireland.

Smartzone’s Services are provided by licensed and Authorised service providers (“Authorised Service Providers”). If you are a customer of an Authorised Service Provider, your information will be processed by Smartzone acting as a data processor and your Authorised Service Provider will remain responsible for the handling of any personal information it collects from you and for compliance with any applicable data protection and/or privacy laws. You should refer to the Authorised Service Providers’ privacy notice for more information on the Authorised Service Providers’ privacy practices.

Data Collection and Use

Data You Provide to Us

If you are an owner, agent, or employee of an existing or prospective Authorised Service Provider, you may provide us with personal data when you register with Smartzone, engage with customer support or marketing, and transact business with Smartzone.

If you are an existing or prospective customer of an Authorised Service Provider, you may provide us with personal data when you set up your account with Smartzone and use Smartzone User Interfaces or Services.

We may use this information for our business operations, to communicate with you or your Authorised Service Provider (as applicable), to comply with the law, and to protect the security and integrity of the User Interfaces and Services.

Data We Collect and Process on Behalf of Authorised Service Providers

When using the User Interfaces, you may provide us with personal data including, but not limited to, your name, home or business address, phone number, email address, location, or post code.

When using our Services, you or your Authorised Service Provider may provide us with certain additional information (e.g., unit description, home or business size, home or business system configuration, sensor names, appliances or other devices monitored by Smartzone, account information, schedule, mode, automation settings, and device settings) in order to help us personalize your Services. Smartzone may also receive personal data that you have provided to our partners, including emergency contact information and user profile information, to enable Smartzone to provide our Services.

On behalf of you or your Authorised Service Provider, Smartzone may process information regarding your use of the Smartzone Services, including but not limited to: performance of any security or other device monitored by Smartzone, electrical usage or consumption, heating and cooling information, light or other fixture settings, and usage and alert logs. We receive this type of information from your devices that are monitored by Smartzone and your computer or other electronic device through which you may access, browse, download, receive, or otherwise use the Smartzone User Interfaces or Services (each a “Personal Device”), and we may also receive and collect such information from third parties.

Smartzone will process all personal data received by Authorised Service Providers via contractual arrangements and may use compiled aggregate statistics about the User Interfaces and Services to improve our Services.

Location-based Information

Some features of our Services, such as location-activated arming reminders, thermostat adjustments, vehicle diagnostics, and other location-based Services (collectively, “GeoServices”), use location information. Before certain GeoServices information can be used, you must first opt-in to activate these Services. If you enable these features, we will automatically collect and store location information from your Personal Device or vehicle you designate which is capable of producing location data (e.g., mobile device, GPS device, or vehicle). This location information may include your current location or places you have recently visited. We also may aggregate this information, but this information will only be used for Smartzone’s internal purposes and to provide information requested by you. If you do not wish for us to collect and store this information, do not enable these features.

Video and Audio Data

When you (i) subscribe to Smartzone’s video monitoring or video monitoring add-on Services (such as the Visual Verification services), (ii) use a connected doorbell, camera, image sensor, or other connected device or wearable that is capable of recording video and/or audio recordings, or (iii) subscribe to two-way voice, you may enable us, certain of our third-party service providers, or your Central Station (as defined below), to record, store, view and process video and/or audio recordings from your monitoring equipment. This may include capturing and sending to you portions of this data as part of a notification or analysing the data to identify motion or other events. We may process information from your monitoring equipment so that we can send you alerts. In addition, if you have the recording features enabled, we will capture, process and store video and audio data recordings from your device and you may be able to access those recordings. As used herein, a “Central Station” is a third party selected by your Authorised Service Provider to receive alarm signals and coordinate emergency response.

Data protection and privacy laws in your country may impose certain responsibilities on you and your use of security cameras, connected doorbells and other devices with recording capabilities. You (not Smartzone) are responsible for ensuring that you comply with any applicable laws. For example, you may need to display a notice that alerts visitors to your home or business that they may be recorded using security cameras and other devices with recording capabilities. Smartzone takes no responsibility for your compliance with these laws.

Data We Collect Automatically

We employ “cookie” technology and “web beacons” to help you move faster through the User Interfaces, to help improve the functionality of the User Interfaces, to collect information for advertising of our Services and to optimize your use of our User Interfaces. A cookie is a string of information sent by a User Interface and stored on your hard drive or temporarily in your Personal Device’s memory. A “web beacon” is an electronic image placed in the code of a web page. Our third-party suppliers, subcontractors or business partners may employ cookies and web beacons to tailor Smartzone’s advertising to the interests of its users and target audience, monitor the traffic patterns of users from one Smartzone page to another or to improve site performance. We also use cookies to identify you on future visits to our site and to other sites. When you access the Smartzone User Interfaces, we place a cookie on your computer. This allows the User Interfaces to recognize you as you navigate through the User Interfaces. At your discretion, Smartzone may store and access cookies on your Personal Device to allow you to bypass the process of re-entering certain information each time you access the Smartzone website. You can also delete cookies from your website browser at any time.

We may collect personal data relating to customer trends and patterns and use cookies and software tools to measure site usage and related information.
You may access, browse, download, receive, or otherwise use the Smartzone Services through your Personal Device. We may permit third parties to place or modify cookies on your Personal Device on our behalf. The third parties can use these “tracking cookies” (also known as “third party cookies”) to determine if you have visited certain pages on our site or other sites and may use tracking cookies to present targeted advertisements to you as you visit other sites. You can configure your browser to reject tracking cookies.

If you access our Services or the User Interfaces through your Personal Device, we may automatically collect certain information about your Personal Device that could include usage information and statistics, an IP address, Personal Device type and model, browser type, device ID, domain names, access times, referring website addresses, Personal Device settings and history, and other information collected about your access of the User Interfaces or receipt of communications or notification from Smartzone.

Our website and mobile apps may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our website and mobile apps and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal data. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to Client websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google may use the data collected on our website to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Client websites, please review “How Google uses data when you use our partners’ sites or apps,” (located at https://policies.google.com/technologies/partner-sites or any successor URL).

Legal Basis for Processing Personal Data

We will only collect and process personal data about you where we have a legal basis. Legal bases include consent (where you have given consent), contract (where processing is necessary for entering into or the performance of a contract with you), compliance with a legal obligation, and “legitimate interests.”
Where we process personal data based on consent, we will ask for your unambiguous consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.

We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. Please keep in mind that if you object this may affect our ability to perform certain services for your benefit. We process your personal data based on legitimate interests in order to:

Protect you, us, or others from security threats by enhancing the security of our network and information systems;
Identify and prevent fraud;
Comply with applicable laws and industry regulations;
Enable or administer our business, such as for invoicing Authorised Service Providers and maintenance of User Interfaces; and
Improve our User Interfaces and Services by enabling us to enhance, modify, or personalize them for your benefit.

Data Sharing

Smartzone will not disclose your personal data to any other entity except:

as is necessary to provide the Smartzone User Interfaces and Services to you;
to your Authorised Service Provider (also referred to as your Smartzone Dealer), the company through which you subscribed to our Services;
to the Central Station selected by your Authorised Service Provider to receive alarm signals and coordinate emergency response;
when you have opted in to share the information;
to third party suppliers, subcontractors or business partners who work or perform services on our behalf and are only permitted to use the minimum amount of information necessary to assist in providing the Services;
if you are an existing user of Smartzone Services, to provide notifications of additional Smartzone-supported products or Services that may be of interest to you;
as necessary in connection with other lawful business purposes; and
as otherwise necessary when required or permitted by law.

In addition, we may disclose your personal data when the personal data has been converted to a form that cannot be used to identify you. It may also be necessary for us to disclose your personal data in case of a merger or combination with, or acquisition of a portion of our business by, another company or entity, in which case personal data collected by Smartzone would be expected to be one of the transferred business assets.

International Data Transfers

Our servers and offices are located in the EU and the United States, so your personal data will be transferred to, stored, or processed in the both the EU & the United States. We rely on legally-provided mechanisms to lawfully transfer personal data across borders, including the European Commission-approved “Standard Contractual Clauses” or “Model Clauses” and the EU-U.S. Privacy Shield and U.S.-Swiss Privacy Shield Frameworks (the “Privacy Shield”) for EU to U.S. data transfers. You can find more information about our participation in the Privacy Shield program by reading our Privacy Shield Privacy Notice).

Exercising Your Rights

Right to Access, Correct, Update and Delete Personal Data

You may view, update, or delete certain personal data at any time by following the links at www.Smartzone to your profile and address book pages. These changes will be immediately made to our records. If you wish to stop Services notifications, you may do so through the User Interfaces. For customers of Authorised Service Providers, changes you make to your user profile on the Smartzone User Interfaces to your user profile may not automatically change the records of your Authorised Service Provider. You should contact your Authorised Service Provider directly to make changes to its records.
By contacting your Authorised Service Providers, you can also exercise the following rights:

Deletion. You can ask to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Object to, or Limit or Restrict, Use of Data. You can ask to stop using all or some of your personal data (e.g., if there is no legal right to keep using it) or to limit use of it (e.g., if your personal data is inaccurate or unlawfully held).
Take Your Data. You can ask for a copy of your personal data provided in a machine readable form.

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
We do not make use of automated decision-making. As defined under current data protection laws, automated decisions are defined as decisions about individuals that are based solely on the automated (i.e., no human involvement) processing of data and that produce legal effects or that significantly affect the individuals involved.
You have the right to register a complaint with a European data protection or supervisory authority about our collection and use of your personal information. For more information, please contact your local data protection authority. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA and Switzerland are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm ).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

Retention Period

We retain the personal data that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services you requested or to comply with an applicable legal requirement).

Information Protection

Smartzone has security measures in place to protect against the loss, misuse, and alteration of your personal data. For example, we protect your information through a unique username and password, and we protect certain sensitive communications with our website through server authentication and secure connections.

Third Party Websites

For your convenience, some hyperlinks may be posted on the Smartzone website that link to other websites not under Smartzone’s control. Smartzone is not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that Smartzone does not own or control. Smartzone does not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. Smartzone encourages you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website linked to the Smartzone website, even if you reached that site through the Smartzone User Interfaces, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal data that is collected about you is used and protected.

Changes to Our Privacy Notice

We may modify our Privacy Notice from time to time, and we will post the revised statement here, with an updated revision date. If we revise our Privacy Notice in a material way, we will provide a conspicuous notice on our website before any changes take effect.

Contact Information

You can contact our data protection officer (DPO) at privacy@Smartzone.ie
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