Robert Smart Privacy Policy
Robert Smart Privacy Policy
Last updated: 01.02.2022
Robert Smart an official brand owned by Company and operating on behalf of the company is 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 Application and Services.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Policy.
Definitions
For the purposes of this Policy:
·Account means a unique account created for You to access our Application and Service.
·Applicationrefers to those mobile applications developed by Robert Smartthat provide end users remote control to Smart Devices and with the ability to connect to the supplier IoT Platform.
·Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to T.N.Rozalinde SIA, Murmuizas Str 14a, Valmiera, Latvia.
·Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
·Smart Devices refers to those nonstandard 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.
·Personal Datameans information that can be used to identify an individual.
·Service refers to the Application and Smart Devices separate as well as joint operations.
·Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
·Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
·You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
What Personal Data do we collect?
In order to provide our services to you, we will ask you to provide 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.
Information You Voluntarily Provide Us
Account Data:
·Your name and contact details, such as email address and phone number.
·Your user name, login credentials, nickname, profile picture.
·Country code.
·Language preference.
·Time zone information.
Feedback:
·When using feedback features in our Products, we will collect your email address, mobile phone number and your feedback content.
Information We Collect Automatically
Device Information:
·MAC address of your Devices.
·IP address.
·Wireless connectioninformation.
·Operating system type and version.
·Application version number.
·Push notification identifier.
·Log files.
·Mobile network information.
Usage Data:
·Clicks.
·Downloads.
·Messages sent/received.
·and other usage of our Services.
Log Information:
·When you use the Application, the system and exception log may be uploaded.
Location Information:
·geo-location.
Smart Devices Related Information:
Basic Information of Smart Devices:
·Smart device name.
·Smart device ID.
·Online status
·Activation time.
·Firmware version.
·Upgrade information.
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, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or videos captured by it.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you are as follows:
Provide You Services:
We process your Account data, Device information, usage data, location information, and Smart Device related information to provide you with our Application and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,
Improve Our Services:
We process Device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Application, to develop and improve our Application and 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 Terms of Use.
Non-marketing Communication:
We 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 to perform our contract with you according to our Terms of Use.
Marketing Communication:
We may process your Personal Data to provide marketing and promotional materials to you on our Application and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature.The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.
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 our Application and Smart Devices. The legal basis for this processing is your consent.
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.
Who do we share Personal Data with?
At Robert Smart, 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 Sites and Services.
· To 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.
· To 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, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence.
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:
· 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.
· Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.
You do not have to pay a fee 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.
Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Robert Smart provides various security strategies to effectively ensure data security of user and Device. As for Device access, Robert Smart 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. 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 email: support@robertsmart.com . Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy 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. 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.
Governing Laws
Effectiveness, explanation, change, execution and dispute settlement of the Agreement should reference to general EU business practices and (or) industrial practices shall be made.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose Your Personal Data in the good faith belief that such action is necessary to:
·Comply with a legal obligation
·Protect and defend the rights or property of the Company
·Prevent or investigate possible wrongdoing in connection with the Service
·Protect the personal safety of Users of the Service or the public
·Protect against legal liability
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 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.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us as follows: