CONALUX WIFI UPDATE 1.0.4
Privacy policy of ILUMINACION NACO S.L
Effectivedate: 18-08-2019
Updated: 09-12-2021
ILUMINACION NACO
S.L, and its affiliates and subsidiaries("CONALUX WIFI") are
committed to protecting your privacy. This Privacy Policy ("Policy")
describes our practices regarding the privacy of information about the personal
data we process through your individual use of the following related services,
products and mobile applications (collectively, the "Products"):
· CONALUX WIFI Smart mobile app
Before using our Products, please read this Policy carefully and understand our purposes and practices of collecting, processing your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways
to enforce your access rights, update, delete or protect your Personal Data.
When you accept this Policy when you register with your Personal Data, or if you wish to use our Products and do not expressly object to the content of this Policy, we will consider that you understand and fully agree with this Policy. If you have any questions regarding this Policy, please do not hesitate to contact us through:
CONALUX WIFI
Lighting Naco S.L
C/ Ronda Norte
s/nPol. Indus. Virgen de la Salud - Xirivella46.950 - Xirivella -ValenciaTel.: 96 313 72 90 - Fax: 96 399 02
10
· CONALUX WIFI Smart mobile app
In this Privacy Policy, "Personal Data" refers to information that can be used to
identify an individual, either from the information itself alone, or from such
information added to other information that we can access about the
corresponding person. "Smart Devices" means non-standard computing
devices produced or manufactured by hardwaremanufacturers,including
human-machine interface and the ability to transmit data over a wireless
connection to a network. These devices include: smart appliances, smart
wearable devices, smart air purification devices, etc. "Applications"
refers to the mobile applications developed by CONALUX WIFI that provide end
users with remote control of smart devices and the ability to connect with
theCONALUX WIFI IoT platform.
In the case of mobile applications of other brands that work with technology developed by CONALUX WIFI, our Customers control all personal data collected through our Products. We collect the information under the direction of our Clients, and
the processing of such information will be limited to the purpose of providing
the service for which our Clients have engaged us. If you are an end customer
of one of our Customers and do not wish to receive communications from one of
our Customers using our service, please contact the Customer with whom you
interact directly.
What personal data we collect
For the purpose of providing our services, we ask the user to provide the personal data necessary to provide these services. If you do not provide your personal data,
it may be unfeasible for us to provide you with our products or services.
1.Information you voluntarily provide to 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, telephone number, username and login credentials. During interaction with our Products, we may collect
additional information about your nickname, profile picture, country code,
language preference or time zone that you have entered into your account.
· Feedback:When you use the feedback and suggestions features in our Products, we will collect your email address, mobile phone number, and the content of your feedback to address your issues and troubleshoot device failures in time.
2.Information We Collect Automatically
· Device Information:
When you interact with our Product, we automatically collect
information from your device, such as: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 related to visits, clicks, downloads, messages sent/received, and other
uses of our Sites and Services.
· Registration Information:
When you use our application, the system and exception logging
may be loaded.
· Location Information:
We may collect information about your geographic location, in real time, accurately or inaccurately, when you use our specific Products or Services, such as the
cleaning robot and weather service.
3.Information related to Smart Devices:
· Smart Device Basic Information:
When you connect your Smart Devices to our Products or
Services, we may collect basic information about your Smart Devices, such
as:device name, device ID, connection status, activation time,firmware version, and update information.
· Information Communicated by Smart Devices:
Depending on the different smart devices you choose to connect to our Products or Services, we may collect various information communicated directly by your smart devices. For example, smart devices that track weight or fitness can communicate your height, weight, body fat mass (BFM), body mass index, and bone and muscle mass (SMM). Smart cameras can communicate images or videos that they
capture.
Purpose and legal basis for the processing of personal data
The followingdescribes the purposes that justify that we can process information about the user:
· Provide services to the user:
We process your account and profile data, device information, usage data, location information, and smart device-related information to provide you with the Products and Services you have requested or purchased from us. The legal basis for this
processing consists in compliance with our contract with the user under the Terms of Use.
· Improve our services:
We process device information, usage data, location information, and information related to Smart Devices for the purpose of ensuring the features and security of our Products, developing and improving our Products and Services, analyzing the effectiveness of our operations, and preventing and tracking any fraudulent or improper use. The legal basis for this processing consists in the fulfillment of our contractwith the user in under the Terms of Use.
Communication not related to marketingactivities:
We process your personal data to send you important information in connection with the Services, changes to our terms, conditions and policies and/or other
administrative information. You may not opt out of receiving these
communications, as such information may be important. The legal basis for this
processing consists in the performance of our contractwith the user under the
Terms of Use.
· Marketing Communication:
We may process your personal data to provide you with marketing and promotional material about our Products and Services. In such a case, each communication we send you will include instructions that allow you to opt out of receiving future
communications of that nature. Thelegal basis for this processing consists of your
consent.
Additionally, if you agree to participate in our lottery, contest or other
promotions, we may use your personal data to manage those activities.
· Customization:
We may process your account and profile data, usage data and device information to personalize the design of the product and provide you with services tailored to your needs, such as recommending and displaying information and advertisements about products suitable for your needs and inviting you to participate in surveys related to your use of our products. The legal basis for this processing consists of
yourconsent.
· Legal compliance:
We may process your personal data as we deem necessary or appropriate to: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public and governmental authorities; (d) enforce our terms and
conditions; (e) protect our operations, businesses and systems; (f) protect our
rights, privacy, safety or property and/or those of other users, including you;
and (g) allow us to apply available remedy measures or limit the damages we may
suffer.
Who do we share personal data with?
At CONALUX WIFI, we only share personal data as described to the user. We mayshare your personal data with the following recipients:
· Our third-party
service providers who perform specific business-related functions for us, such
as website hosting, data analysis, payment and credit card processing,
infrastructure provision, IT services, customer service, email delivery
services, and other similar services that enable them to provide services to
us.
· Our customers
and other business partners who provide you, directly and indirectly, with
their smart devices, and/or networks and systems through which you access and
use our Sites and Services. · An affiliate or other third party in the event of
any reorganization, merger, sale, joint venture, assignment, transfer or other
disposition of all or part of our business, assets or shares (including,
without limitation, everything related to any bankruptcy or other similar
proceedings). In such a case, you will receive an email notification and/or a
prominent notice will be posted on our website about any changes in ownership,
new incompatible uses of your personal data and decisions you may make in
relation to your personal data.
· As we deem
necessary or appropriate to: (a) comply with applicable laws and regulations;
(b) comply with legal process; (c) respond to requests from public and
governmental authorities, including public and governmental authorities outside
your country of residence; (d) enforce our terms and conditions; (e) protect
our operations, businesses and systems; (f) protect our rights, privacy, safety
or property and/or those of other users, including you; and (g) allow us to
apply available remedy measures or limit the damages we may suffer.
· Affiliates or
subsidiaries within our corporate family, for the purpose of conducting
ordinary business activities.
With the
exception of the third parties described above, to other third parties
exclusively with your consent.
International transfer of collected information
To facilitate our operations, we may transfer, store and process your personal data in jurisdictions other than the one you inhabit. The laws in these countries may
be different from the laws applicable in your country of residence. When we do,
we will ensure that we provide an adequate level of protection for information
using one or more of the following approaches:
If you would like more information about the protection we apply, you can contact us directly as described in this Privacy Policy.
Your rights in relation to your personal data
We respect your rights and control over your personal data. You can exercise any of the following rights:
· Through
the"Profile – Personal Center" section in our Products (for Product
versions 3.2 and later)
· By sending an
email conaluxwifi@iluminaco.com (for Product version earlier than 3.2)
No fee is required and we aim to respond within 30 days. If you decide to send us an email, in your request please clarify what information you want to be modified,
whether you want your personal data removed from our database, or inform us
about the limitations you wish to impose on our use of your personal data.
Please note thatfor security reasons, we may ask you to verify your identity before taking any action you request.
You can:
· Request access to the personal data we process about you,
· Request that we correct incorrect or incomplete personal data about
you
· Request the deletion of personal data about you,
· Request restrictions, temporarily or permanently, on the processing we make of some or all of your personal data,
· Request the transfer of your personal data to you or to a third party where we process the data on the basis of your consent or a contract entered into with you, and where our processing is automated, and
· Opt out of or object to our use of personal data about you where our use is based on your consent or our legitimate interests.
Safety
We use commercially reasonable physical, administrative and technical protections to protect the integrity and security of your personal data. CONALUX WIFI applies
various security strategies to effectively guarantee the security of user and
device data. With regard to device access, proprietary CONALUX WIFI algorithms
are used to ensure data isolation, access authentication and the request for
authorization.
With regard to data communication, communication is used that applies security
algorithms and encryption protocols of transmissions, and transmission with
encryption of information with commercial quality based on dynamic keys. As far
as data processing is concerned, strict filtering and validation of the data
and complete auditing of the data are applied. As far as data storage is
concerned, all sensitive user information will be securely encrypted for
storage. If you have any reason to believe that your interaction with us is no
longer secure (for example, if you feel that the security of any account you
may maintain with us has been compromised), you must immediately notify us of
the problem via the email address conaluxwifi@iluminaco.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 that requires us to keep the data for a longer retention period. We determine the corresponding retention period based on the amount, nature and sensitivity of your personal
data, and when the retention period ends, we will delete your personal data.
Where we are unable to do so for technical reasons, we will ensure that
appropriate measures are in place to prevent any future use of your personal
data.
Conflict resolution
If you have any unresolved data use or privacy disputes that we have not satisfactorily addressed, please contact our third-party dispute resolution provider located
in the U.S. (free of charge) at
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes we implement in our information-related practices. If we make any material changes, we will inform you by sending an email notification (to the email address specified in your account) or through a notice in the mobile applications prior to the entry into force of the
change. It is recommended to periodically check this page for the most
up-to-date information about our privacy practices.
Contact Us
If you have any questions about our practices or about this Privacy Policy, please contact us at:
CONALUX WIFI
Lighting Naco S.L
C/ Ronda Norte
s/nPol. Indus. Virgen de la Salud - Xirivella46.950 - Xirivella -ValenciaTel.: 96 313 72 90 - Fax: 96 399 02
10
If you are a data subject in the European Union, you have the right to lodge a complaint with a supervisory authority regarding the data processing activities of
CONALUX WIFI.
For inquiries or to exercise your rights as a data subject in the EU, please
contact our EU Representative here:
Name: Data Protection Representative
Email: conaluxwifi@iluminaco.com