Privacy policy

Company Commel-Zagreb Ltd., Samoborska cesta 143, Zagreb, PIN 69638353517 (hereinafter „we“) cares about protection of your privacy. With this Privacy policy we would like to inform you about the way we collect and process your personal data which arises from your individual usage of our services, products and mobile app (hereinafter „the Products“).

“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.

“Apps” refers to those mobile applications we developed, that provide end users remote control to Smart Devices 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 so you can use our Products, 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.

1.Information you voluntarily provide us

Account or Profile Data: When you 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 your nickname, profile picture, country code, language preference or time zone information into your account.

2.Information we collect automatically

Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

Usage Data: During your interaction with our sites and services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our sites and services.

Log Information: When you use our app, the system and exception log may be uploaded.

Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services.

3.Information connected to Smart Devices

Basic Information on Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and 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.

Purpose and legal basis for personal data processing

We collect and process your personal data for following purposes:

Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products 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 your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products 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. 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 Products 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 contest or other promotions, we may use your Personal Data to manage such activities.

Personalization: We may process your account and profile 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 Products. The legal basis for this processing is your consent.

Legal Compliance: We may process your personal data if that is necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to respond to requests from public and government authorities (c) to enforce our terms and conditions; (d) to protect our rights, privacy, safety or property, and/or that of other users, including you.

Who do we share personal data with?

We 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 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. In such an event, you will be notified via email and/or a prominent notice on our website of any change and choices you may have regarding your personal data.

International transfer of collected data

Due to international usage of the app, transfer, storage and processing of your personal data in jurisdictions other than where you live is possible. 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; and

Opt-out or object to our use of personal data about you where our use is based on your consent and in any time withdraw your consent, but that does not influence the validity of processing before the withdrawal.

To achieve cited rights, refer to us through contacts on www.commel.hr and we shall deliver our reply in shortest time period possible. We emphasize that we might ask you to confirm 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. We provide various security strategies to effectively ensure data security of user and device. 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, we apply strict data filtering and validation and complete data audit are applied. All confidential information of users will be safely encrypted for storage.

Data retention

We process your personal data only for the period which is necessary to achieve purposes stipulated in this privacy policy except when there is a legal reason to keep the data for a longer period.

Changes to this privacy policy

We may update this privacy policy to reflect changes. In that case, 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.

If you have any questions about our practices or this Privacy policy, please contact us as follows:

Commel-Zagreb Ltd.

Address: Samoborska cesta 143, 10 000 Zagreb

E-mail: info@commel.hr

You have right to lodge a complaint with the Data protection agency.

This Privacy policy is effective and applies from 20th October 2020 and is valid until amended or recalled.