Privacy Policy LSC-Smart Connect mobile application
Privacy Policy LSC-Smart Connect mobile application
Version: April 2021
Action Service and Distribution B.V. (“Action”, “we”, “us”, “our”) is committed to protect your privacy. This Privacy Policy describes how we process your personal data when you use the LSC-Smart Connect mobile application (the “LSC Smart Connect App”), by which LSC smart devices (the “Smart Device”) can be controlled remotely. Please find below more information about why we process personal data, how we do it and what rights you have relating to your personal data.
In order to become able to properly provide our services relating to the LSC Smart Connect App (“Services”) to you, we will ask you to register an account. In order to properly carry out the Services, it is necessary to process your personal data. We find it important that the processing of personal data is executed in a manner that is in accordance with the existing safeguards for the protection of privacy. In this, we follow legislation regarding the protection of personal data, such as the General Data Protection Regulation (GDPR).
Action will be the controller of your data. Action is seated inZwaagdijk-Oost, the Netherlands, and is registered at the Dutch Chamber of Commerce under number 50969838. In case of any questions relating to the processing of your personal data, please contact us via the contact details below.
What personal data does the LSC Smart Connect App process?
Personal data are data that can identify you, such as your name, address, e-mail address, IP address, telephone number and age. We process the following personal data:
Personal data
App users – account data and feedback or other messages
·Contact details, such as name, e-mail address and (sometimes) telephone number and/or profile picture;
·Video material (in case your Smart Device involves video);
·Any information you may include in your feedback and/or other messages to us, that can be used to identify you.
SmartDeviceor mobiledeviceinformation
·We automatically collect information about your Smart Device or relating to the mobile device you are using the LSC Smart Connect App with, such as the MAC address of your device, IP address, wireless connection information, operating system type and version (incl. language settings) of the device, application version number, push notification identifier, log files, and mobile network information.
And relating to the Smart Device; the device name, device ID, online status, location, activation time, firmware version, and upgrade information.
How do we obtain your personal data?
We receive your personal data in various ways, but mainly because you provide us with your data when registering an account with us via the LSC Smart Connect App and by using the feedback and suggestion features in the LSC Smart Connect App or otherwise contact us (for example via e-mail), or when you make use of the LSC Smart Connect App to manage your Smart Device. We also collect certain personal data automatically, to the extent this is necessary to properly provide our Services, as indicated above.
On what grounds and for what purposes does LSC process your personal data?
The personal data that we collect are necessary for the provision of our Services and improving these. Without this personal data, we cannot conclude and/or execute the service agreement with you and/or process and answer your messages properly. The purposes of our processing are described in more detail below.
We process personal data in particular for the following purposes and only to the extent necessary for those purposes:
·To became able to enter into a Service Agreement with you and to provide you with the Services as agreed upon in our Service Agreement;
·To create and operate an account to use the LSC Smart Connect App for you;
·To send you relevant information in relation with the Services and to otherwise communicate with you, inter alia, when answering you questions;
·To send you promotional messages relating to our products and/or services, for which we will ask your permission in case we are obliged to do so by law;
·To provide functionality, analyze performance, fix errors, monitor safety and improve usability and effectiveness of our LSC Smart Connect App;
·To comply with laws and regulations.
Children data
Our Services do not address anyone under the age of 18. We do not knowingly collect personal data from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to perform necessary actions (please find our contact details below).
Access to your personal data
Except if otherwise indicated below, only the employees of Action and our service provider who need access to your personal data to perform activities for the aforementioned purposes have direct access to your personal data to perform their work. Employees who have access to personal data are bound by confidentiality. In this way (in combination with the security measures mentioned below) we ensure that the personal data are only accessible to persons who are authorized to do so by virtue of their position and that the personal data is only used for the purposes for which the personal data were obtained.
Exchange of personal data with third parties and/or other countries
In principle, Action and our service provider do not make your personal data available to third parties. However, for the provision of the Services we make use of the third party platform providerTuyaInc. Please be referred to the privacy policy ofTuyafor more information on how your data is processed by this platform provider (TuyaSmart Developer Center).
Action enters into a written agreement with our service provider, by which they are obligated not to disclose or use the information for any other purpose and bound to security and other requirements. We do not transfer your personal data outside the European Economic Area.
In some cases, we are required by law to provide personal data to (other) institutions or authorities. We always look at how we can respect your privacy as much as possible. The sharing of your personal data occurs where reasonably possible in anonymous or otherwise pseudonymized form.
You may choose to use the LSC Smart Connect App in combination with another account provided by a third party, such as your account at Google or Amazon. In case legally required, Action will also conclude agreements with such third parties, as indicated above. However, you will use these applications or functionalities at your own responsibility and for the use of these services your permission will always be asked. Please be referred to the information regarding external links below, which apply accordingly in that case.
Security of personal data
Actions handles your personal data with the utmost care and takes appropriate and commercially acceptable means of organizational and technical security measures to protect the personal data of the users of our LSC Smart Connect App against unauthorized access or changes, disclosure or destruction of personal data. Therefore, we comply with the applicable security standards. In addition, the information that is exchanged, collected and analyzed via the LSC Smart Connect App, is (two-way) encrypted.
Remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. If, despite the security measures we have taken, there is a security incident that is very likely to have an adverse effect on your privacy, we will inform you as soon as possible about the incident. We therefore inform you about the measures we have taken to limit the consequences and to prevent any recurrence in the future.
If you unexpectedly encounter a security breach or you suspect that the security of your personal data is not properly guaranteed, please contact Action immediately. We have procedures in place to handle these reports adequately and carefully in accordance with applicable legislation. Please find ourcontact detailsbelow.
Retention periods
The LSC Smart Connect App only stores personal data as long as necessary for the purpose for which it has been processed or for any longer period we are required for by law. We do not process your personal data longer than during 7 days after the end of our Service Agreement or our last contact (depending on the matter). Retention periods may be longer, for example in case of disputes.
External links
The LSC Smart Connect App may contain links to other websites, applications and/or third party services. Some of these have been explicitly mentioned in this Privacy Policy. We are not responsible for the practices of third-party applications, websites or services that are linked to or from our LSC Smart Connect Appor that you use in relation herewith. Our privacy policy does not apply when you use a link to switch from our LSC Smart Connect App to another application, website or use any third party account or service. Your conduct on a third-party application, website or service, including those who have a link on our LSC Smart Connect App, is subject to their own rules and policies. We are not responsible for the processing activities, privacy policy or the content or other practicing of these other websites and/or services, notwithstanding that LSC may have entered into a written agreement with the third party to safeguard user rights to the extent reasonably possible.
Your rights with regard to the processing of personal data
You have the following rights with regard to the processing of your personal data:
·You can requestinformationabout and/oraccessto the personal data that we process about you. This means that you can request which personal data has been registered and for what purposes that personal data is used;
·You can request us to have your personal datachanged/correctedand/or tolimitthe processing of your personal data;
·You can also ask us toremoveyour personal data from our systems;
·You can also ask us to ensure that your personal data istransferredto another party.
Requests regarding the exercise of the aforementioned rights can be submitted via thecontact detailsbelow. We will update you on the status of your request within one (1) month after receiving your request. We will comply with your request, unless we have a compelling and legitimate interest not to delete data that outweighs your privacy interest or when fulfilling your request is otherwise not required by law and/or in case we could then no longer perform our Service Agreement with you. If we have deleted the data, for technical reasons we cannot immediately remove all copies of the data from our systems and backup systems. We may refuse to comply with the aforementioned requests if they are made unreasonably often, require unreasonable technical efforts, or have unreasonable technical consequences for our systems or endanger the privacy of others. If we have complied with a request to improve, supplement or delete personal data, we will also inform third parties to whom this personal data has been provided of the changes made. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
If you are not satisfied with the way in which we have dealt with your request or objection or otherwise with the processing of your personal data, you can also submit a complaint about the use of your personal data to the competent Data Protection Authority in your country.
Contact details
If you want to exercise your abovementioned rights, or you have any questions that are not answered by this privacy policy, or you have suggestions or comments about the content hereof, or have any complaints about the way we deal with your personal data, you can contact us in writing by using the following contact details:
Privacy Policy changes
Action may adjust or update this privacy policy from time to time. Adjustments to this privacy policy take effect the moment these have been published. We therefore recommend you to regularly consult this privacy policy, so that you are aware of any changes to this privacy policy. If these adjustments are of significant importance to you, we will always inform you about this.