Synergy Smart Box Privacy Policy
Effective Date: 13-08-2024
Updated: 13-08-2024
Synergy Security Solutions and subsidiaries(“we”, “us”, “our”, “Synergy Security Solutions”) are 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 following services, products, and related mobile applications(collectively, the “Products”):
Smart Box Mobile Application
Before you use our Products, please carefully read through this Policy and understand our purposes and practices for collection,and processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy, you will also find ways to execute your rights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register with your Personal Data, or if you start to use our Products and do not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any questions regarding thisPolicy, please do not hesitate to contact us via:
Enterprise house, Mayfield BusinessPark, Old Youghal Road, Cork, T23 CHF6, Ireland
+353 (0)21 4550200 or info@synergy365.ie
Definition
In this Policy, Personal Data means informationgenerated, collected, recorded and/or stored, electronically or otherwise, thatcan be used to identify an individual or reflect the activity of an individual,either from that information alone or from that information and otherinformation we have access to about that individual.
Personal Sensitive Data includes personal biometricinformation, communication records and contents, health information,transaction information, and precise location information. When we collectPersonal Sensitive Data from you, we will generate an explicit notification foryour consent before we collect personal sensitive data about you.
Smart Devices refer to those computing devicesproduced or manufactured by hardware manufacturers, with human-machineinterface and the ability to transmit data that connect wirelessly to anetwork, including smart home appliances, smart wearable devices, smart aircleaning devices, etc.
Apps refers to those mobile applications developed bySynergy Security Solutions that provide end users remote control to SmartDevices and with the ability to connect to the supplier IoT Platform.
What Personal Data do we collect:
In order to provide our services to you, we will askyou to provide the necessary Personal Data that is required to provide thoseservices. If you do not provide your Personal Data, we may not be able toprovide you with our products or services.
1. Information You VoluntarilyProvide Us
· Registered Account Data: Whenyou register an account with us, we may collect your name and contact details,such as your email address, phone number, user name, and login credentials.During your interaction with our Products, we may further collect yournickname, profile picture, country code, language preference or time zoneinformation into your account.
If you authorize login to the Products with a thirdparty account, we will obtain from such third party your account information(such as portrait, nickname, region, gender, etc.) which may be bound with yourSynergy Security Solutions account for quick login. We will ensurecompliance with applicable data protection laws and regulations, as well asagreements, policies or documentation agreed with such third parties regardingsharing personal information, in processing your Personal Data.
However, if the Services you request or purchase arebased on your account, please go to the registration/login page for guidance.
Information based on additionalfunctions:
In order to offer you more convenient andhigher-quality Services with optimised user experiences, we may collect and usecertain information if you consent to use additional functions in the App.Please note, that if you do not provide such information, you may continue touse the basic Services of the App and connected Smart Devices, but certainfeatures based on these additional functions may not be available. Theseadditional functions may include:
1)Additionalfunctions based on location information:
When you enable the location-based functions throughpermission settings on your mobile device, we will collect and process yourlocation information to enable these functions, such as pairing with your SmartDevices. Also, we may collect information about your: a) real-time and preciselocation, for instance when you choose to use the automation scenarios forcontrolling your Smart Devices, or b) non-precise geo-location when you usecertain Smart Devices or the Services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fencefeature, your location information will be generated and shared with GoogleMaps services. Please note that Google has corresponding data protectionmeasures, which you may refer to Google’s Data Processing and Security Termsfor more details.
You may disable the collection and use of yourlocation information by changing your mobile device settings ("My - Setting - Privacy Right Setting - Switchon/off Location Information"), upon which we will cease to collectand use your location information.
2)Additional servicesfor accessing and uploading pictures/videos based on photo albums (picturelibrary/video library):
You can use this function to upload yourphotos/pictures/videos after turning on the photo album permission, so as torealize functions such as changing the avatar, reporting device usage problemsby providing photo proofs, etc. When you use the photos and other functions, wewill not recognize this information; but when you report a device usageproblem, we may use the photos/pictures you upload to locate your problem.
You may opt out of the use of photo album permission:"My - Setting - Privacy Right Setting -Switch on/off Photo Album".
3)Additional servicesrelated to microphone-based service:
You can use the microphone to send voice informationafter turning on the microphone permission, such as shooting videos, waking upthe voice assistant, etc. For these functions, we will collect your voiceinformation to recognize your command. Please be aware that even if you haveagreed to enable the microphone permission, we will only obtain voiceinformation through the microphone when you voluntarily activate the microphonein the App.
You may opt out of the use of microphone permission: "My - Setting - Privacy Right Setting - Switchon/off Microphone".
4)Additional servicesbased on storage permission(Android):
The purpose is to ensure the stable operation of theApp by utilizing the storage permission. After you give or indicate permissionto read/write your mobile device’s storage, we will access pictures, files,crash log information and other necessary information from your mobile device’sstorage to provide you with functions, such as information publications, orrecords the crash log information locally.
You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switchon/off Storage".
5)Additional servicesbased on Notification permission:
The reason why we ask you for permission is to sendyou notifications about using the Smart Devices or Services, especially if youhave purchased security services and you require an alert or message so thatyou can capture the real-time status.
You may opt-out the using of App notifications: "My - Message Center - Setting - Switch on/offNotifications".
6) Additionalservices based on Alert Window permission：
You may choose to bind a camera in the App andrequire the App to display the real-time image of the camera in a separatewindow.
You may opt-out the using of alert windowinformation: "My - Setting - PrivacyRight Setting - Switch on/off Alert Window".
7) Additionalservices based on Bluetooth permission:
You can enable Bluetooth functions after turning onthe permission, including controlling the Smart Devices, acquiring the statusof, discovering and configuring Smart Devices. In these functions, we willcommunicate with Smart Devices via Bluetooth. Please be aware that even if youhave agreed to enable the Bluetooth permission, we will only use Bluetooth forcommunication in these scenarios: display device status on the home page andSmart Device panel; perform device control on the home page and Smart Devicepanel; discovering Smart Devices on the home page and the add device page,Smart Device distribution network.
You may opt out of the use of Bluetooth via "My - Settings - Privacy Setting -Disable/Enable Bluetooth permission".
8）Additional services based on HomeKitpermission (iOS):
You can enable related functions after enablingHomeKit permissions, including discovering Smart Devices, enabling Smart Devicenetwork configuration, controlling Smart Devices, and checking device status.Among these functions, we will process data with the "Home“ App that comeswith the iOS system through HomeKit. Please be aware that even if you haveagreed to enable the HomeKit permission, we will only use it in thesescenarios: on the home page, to discover HomeKit devices, HomeKit device networkconfiguration; in "Settings - HomeKit" for discovering HomeKitdevices, HomeKit device network configuration.
You may opt out of the use of HomeKit permission via "My - Settings - Privacy Settings-Turn off/onHomeKit permission".
Please note that if you turn on any permission, youauthorize us to collect and use relevant personal information to provide youwith corresponding Services. Once you turn off any permission, we will take itas cancelling the authorization, and we will no longer continue to collectPersonal Data based on the corresponding permissions, and the related functionsmay be terminated. However, your decision to turn off the permission will notaffect the previous collection and use of information based on your authorization.
2. Information We CollectAutomatically
· Mobile Device Information: When you interactwith our Services, in order to provide and maintain the normal operation of ourServices, to improve and optimize our Services, and to protect your accountsecurity as well, we automatically collect mobile device information, such as mobiledevice model number, IP address, wireless connection information, the type andversion of the operating system, application version number, push notificationidentifier, log files, and mobile network information. Meanwhile, we willcollect your software version number. In order to ensure the security of theoperating environment or to provide services, we will collect information aboutthe installed mobile applications and other software you use.
· Usage Data: During your interaction withour websites and Services, we automatically collect usage data relating tovisits, clicks, downloads, messages sent/received, and other usage of ourwebsites and Services.
· Log Information: When you use the App, in orderto improve your user experience, the system and exception log may be uploaded,including your IP address, language preference setting, operating systemversion, date or time of access, so that we can facilitate and accuratelyidentify problems and help you solve them in a timely manner.
Please notethat we cannot identify a specific individual by using device information orlog information alone. However, if these types of non-personal information,combined with other information, may be used to identify a specific individual,such information will be treated as Personal Data. Unless we have obtained yourconsent or unless otherwise provided by data protection laws and regulations,we will aggregate or desensitize such information.
3. Smart Devices RelatedInformation:
· Basic Information of Smart Devices: When you connectyour Smart Devices with the Services, we may collect basic information aboutyour Smart Devices such as device name, device ID, online status, activationtime, firmware version, and upgrade information.
· Information collected during the process of connecting to aSmart Device: Based on the type of Smart Device you need toconnect, the basic information collected includes: Wi-Fi information, deviceMAC address, etc.
· Information Reported by Smart Devices: Depending on thedifferent Smart Devices you elect to connect with our Products or Services, wemay collect different information reported by your Smart Devices. For example, smart key box device report.
Purposes and legal basis forprocessing Personal Data
The purposes for which we may process informationabout you are as follows:
· Provide You with Our Services: We process youraccount data, mobile device information, usage data, location information, andSmart Device related information to provide you with the Services that you haverequested. The legal basis for this processing is to perform our contract withyou according to Service Agreement of SynergySecurity Solutions
· Improve Our Services: We process your mobile deviceinformation, usage data, location information and Smart Device relatedinformation to ensure the functions and safety of the Services, to develop andimprove the Services, to analyze the efficiency of our operations and to preventand trace fraudulent or inappropriate usage. The legal basis for thisprocessing is to perform our contract with you according to our Service Agreement of Synergy Security Solutions
· Non-marketing Communication: We process yourPersonal Data to send you important information regarding the Services, changesto our terms, conditions, and policies and/or other administrative information.At the same time, we will also send you notifications related to the services youhave purchased, such as alert services. You can check the “App Notification” inthe App ("Me &rt; Message Center &rt;Setting &rt; Notification Setting”) to manage these communications. Whenyou decide not to enable the Notifications function, we will no longer processyour information for such purpose. The legal basis for this processing is toperform our contract with you according to our ServiceAgreement of Synergy Security Solutions
· Data Analysis: In order to analyze the usageof the products we provide and improve your user experience, we will analyzethe data you provide us, a) we need to check your problems when you encounterany malfunctions during the usage of the product, under such circumstance, youmay not able to opt-out because it is highly relate to your functionalities andquality of using our product and service, and b) analyze data about how youinterface with the product or under particular scenarios so that you can betterenjoy the convenience brought by our Services, under such circumstance, if youdo not agree to data analysis of your data, you can enter the privacy settingsof App (“My &rt; Settings &rt; PrivacySettings &rt; Data Analysis”) to opt-out your selection. The legal basisfor such processing is based on your consent.
· Marketing Communication and Personalization: Wemay process your account data, usage data, and device information topersonalize product design and to provide you with services tailored for you,such as recommending and displaying information and advertisements regardingproducts suited to you, and to invite you to participate in surveys relating toyour use of the Services. If you do not allow us to process your Personal Datafor personalization, you may opt out when you enter the App, or by changingyour preferences in “Privacy Settings”(“Me&rt; Settings &rt; Privacy Settings &rt; Personalization”) in theApp. The legal basis for this processing is your consent.
· Legal Compliance. We disclose information if weare legally required to do so, or if we have a good faith belief that such useis reasonably necessary to:
· comply with a legal obligation,process or request;
· enforce our User Agreement andother agreements, policies, and standards, including investigation of anypotential violation thereof;
· protect the rights, property orsafety of us, our users, a third party or the public as required or permittedby law; or
· detect, prevent or otherwiseaddress security, fraud or technical issues.
If there is any change in the purposes for processingyour personal data, we will inform such change to you via email and/or aprominent notice on our website of such changes of purposes, and choices youmay have regarding your Personal Data.
Who do we Share Personal Data with?
At Synergy Security Solutions, we only sharePersonal Data in ways that we tell you about. We may share your Personal Datawith the following recipients:
· To our third-party serviceproviders who perform certain business-related functions for us, such aswebsite hosting, data analysis, payment and credit card processing,infrastructure provision, IT services, customer support service, e-maildelivery services, and other similar services to enable them to provideservices to us.
· To our customers and otherbusiness partners who provide you, directly or indirectly, with your SmartDevices, and/or networks and systems through which you access and use ourwebsites and Services.
· To subsidiaries or affiliateswithin our corporate family for purpose of regular business activities based onour instructions and in compliance with applicable law, this Policy and otherappropriate confidentiality and security measures.
· To an affiliate or other thirdparty in the event of any reorganization, merger, sale, joint venture,assignment, transfer or other disposition of all or any portion of ourbusiness, assets or stock (including without limitation in connection with anybankruptcy or similar proceedings). In such an event, you will be notified viaemail and/or a prominent notice on our website of any change in ownership, andchoices you may have regarding your Personal Data.
· As we believe in good faith thataccess to, or use, preservation, or disclosure of the information is reasonablynecessary or appropriate to:
(a)Comply with applicable law, regulation, legalprocess, or lawful governmental request;
(b)Enforce our User Agreement and other agreements,policies, and standards, including investigation of any potential violationthereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property or safety of us, ourusers, a third party or the public as required or permitted by law; or
(e)Perform risk management, screening and checks forunlawful, fraudulent, deceptive or malicious activities.
Except for the third parties mentioned above, we onlydisclose your Personal Data to other third parties with your consent.
International Transfer ofInformation Collected
Synergy Security Solutions will comply withapplicable data localization requirements in corresponding jurisdictions withrespect to storage of data. To facilitate our operation, we may transfer, storeand process your Personal Data in jurisdictions other than where you live. Lawsin these countries may differ from the laws applicable to your country ofresidence. When we do so, we will ensure that an adequate level of protectionis provided for the information by using one or more of the followingapproaches:
· Agreement on the basis ofapproved EU standard contractual clauses per GDPR Art. 46. For moreinformation, seehttps://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If you would like further detail on the safeguards wehave in place, you can contact us directly as described in this Privacy Policy.
Your Rights Relating to YourPersonal Data
We respect your rights and control over your PersonalData. You may exercise any of the following rights: info@synergy365.com, or via the phoneat +353 (0)21 4550200
You do not have to pay a fee and we will aim torespond to 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 youwould like to have your Personal Data deleted from our database or otherwiselet us know what limitations you would like to put on our use of your PersonalData. Please note that we may ask you to verify your identity before takingfurther action on your request, for security purposes.
You may:
· Request access to the PersonalData that we process about you: "My-Setting-Privacy Settings-Personal DataExport";
· Request that we correctinaccurate or incomplete Personal Data about you: 1) Modify your account number(email address or phone number): "My-Setting-Accountand Security-Change your Account"; 2) Modify the nickname and/ortime zone: "My-Personal Information";
· Request deletion of PersonalData about you: "My-Setting-Account andSecurity-Delete Account", when you confirm the deletion of youraccount, your Personal Data will be deleted accordingly.
· Request restrictions,temporarily or permanently, on our processing of some or all Personal Dataabout you: Please send over your request through "My-FAQ& Feedback", or send over the email request to info@synergy365.com
· Request transfer of PersonalData to you or a third party where we process the data based on your consent ora contract with you, and where our processing is automated: Please send overyour request through "My-FAQ &Feedback", or send over the email request to info@synergy365.com
· Opt-out or object to our use ofPersonal Data about you where our use is based on your consent or ourlegitimate interests.
Withdrawal of consent Confirm thefollowing details: We will exercise your privacy right to withdrawconsent through the following approaches:
1)For privacy permissions acquired through devicesystem settings, your consent can be withdrawn by changing device permissions,including Confirm: location, photo album(picture library/video library), microphone, Bluetooth settings, notificationsettings and other related functions;
2)You may opt-out the non-marketing communicationthrough “Me &rt; Message Center &rt;Notification Settings” to manage your selection;
3)You may opt out of the data analysis featuresthrough “Me &rt; Settings &rt; PrivacySettings”;
4)You may opt out of the Personalization featurethrough “Me &rt; Settings &rt; PrivacySettings &rt; Personalization”;
5)Unbind the Smart Device through the App, and theinformation related to the Smart Device will not be collected;
6)By using a product with the "Try Now"mode, and not enabling certain location settings for a particular smart scene,we will not collect any Personal Data about you;
7)If you previously agreed to associate an Appaccount with a third-party service, such as a health platform, please unbind iton the third-party platform.
When you withdraw your consent or authorization, wemay not be able to continue to provide you with certain products or servicescorrespondingly. However, your withdrawal of your consent or authorization willnot affect the processing of personal information based on your consent beforethe withdrawal.
About Deletionof the Account: You can find the Delete function through “Me &rt; Settings &rt; Account and Security &rt;Delete Account” (Deactivate Account）
Security Measures
We use commercially reasonable physical,administrative, and technical safeguards to preserve the integrity and securityof your Personal Data. Synergy Security Solutions provides varioussecurity strategies to effectively ensure data security of user and device. Asfor device access, Synergy Security Solutions proprietary algorithms areemployed to ensure data isolation, access authentication, applying forauthorization. As for data communication, communication using securityalgorithms and transmission encryption protocols and commercial-levelinformation encryption transmission based on dynamic keys are supported. As fordata processing, strict data filtering and validation and complete data auditare applied. As for data storage, all confidential information of users will besafely encrypted for storage. If you have reason to believe that yourinteraction with us is no longer secure (for example, if you feel that the securityof any account you might have with us has been compromised), you couldimmediately notify us of the problem by emailing info@synergy365.ie
Data Retention
We process your Personal Data for the minimum periodnecessary for the purposes set out in this Policy unless there is a specificlegal requirement for us to keep the data for a longer retention period. Wedetermine the appropriate retention period based on the amount, nature, andsensitivity of your Personal Data, and after the retention period ends, we willdestroy your Personal Data.
· For as long as you require us tofulfil the products and services you request from us as defined in the Service Agreement of Synergy Security Solutions
· Personal Data will no longer beretained when you request to remove your Personal Data, we will accordinglycomplete the task.
When we are unable to do so for technical reasons, wewill ensure that appropriate measures are put in place to prevent any furthersuch use of your Personal Data.
Children’s Privacy
Protecting the privacy of young children isespecially important to us. The Services are not directed to individuals underthe age of thirteen (13) (or such other age provided by applicable law in yourcountry/region of residence), and we request that these individuals do notprovide any Personal Data to us. We do not knowingly collect Personal Data fromany child unless we first obtain permission from that child’s parent or legalguardian. If we become aware that we have collected Personal Data from any childwithout permission from that child’s parent or legal guardian, we will takesteps to remove that information.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changesto our information practices. If we make any material changes we will notifyyou by email (send to the e-mail address specified in your account) or by meansof a notice in the mobile applications prior to the change becoming effective.We encourage you to periodically review this page for the latest information onour privacy practices.
Contact Us
If you have any questions about our practices or thisPrivacy Policy, please contact us as follows:
Synergy Security Solutions LTD
Postal Mailing Address: Enterprise house, Mayfield Business Park, Old Youghal Road, Cork,
T23 CHF6, Ireland
Email: info@synergy365.ie