SEDEA Home Privacy Policy
Effective Date: 09/06/2020
SEDEA Electronique, its affiliates and subsidiaries ("we", "us", "our", "SEDEA") are committed to protecting your privacy. This privacy policy (the "Policy") describes our information privacy practices with respect to the personal data we process in your individual use of the related services, products and mobile applications (collectively the "Products") :
SEDEA Home mobile application, SEDEA Home Amazon Skill, SEDEA Home Google Action
In this Privacy Policy, "Personal Data" means information that can be used to identify an individual, either from that information alone or by combining that information with other information we have access to about that individual. "Smart Devices" means non-standard computing devices produced or manufactured by hardware manufacturers, with a 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. "Applications" means mobile applications developed by SEDEA that provide end users with remote control of smart devices and possess the ability to connect to the IoT Platform.
For mobile applications from other brands relying on SEDEA, our Customers control all Personal Data collected via our Products. We collect information as directed by our Customers and the processing of such data will be limited to the purpose of providing the service for which our Customers have engaged us. If you are a customer of one of our Customers and no longer wish to be contacted by one of our Customers who uses our service, please contact the Customer with whom you interact directly.

What Personal Information do we collect?

In order to provide our services to you, we ask you to provide the necessary personal data that is required to provide those services. If you do not provide us with your Personal Data, we may not be able to provide the products or services to you.

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 information, such as your address, phone number, username and login credentials. During your interaction with our Products, we may collect your nickname, profile picture, country code, language preference or time zone information in your account.
Feedback: When you use the feedback and suggestion features in our Products, we collect your email address, cell phone number and the content of your feedback to address your concerns and resolve device failures without delay.

2. information we collect automatically

Device Information: When you interact with our Product, we automatically collect device information such as your devices MAC address, IP address, wireless connection information, operating system type and version, 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.
Log Information: When you use our application, system and exception logs may be downloaded.
Information about your location: We may collect information about your precise or non-precise real-time geolocation when you use our specific Products or Services, such as weather services.

3. smart device information:

Basic Smart Device Information: When you connect your Smart Devices to our Products or Services, we may collect basic Smart Device information such as device name, device ID, online status, activation time, firmware version and update information.
Information reported by Smart Devices: Depending on the different Smart Devices you choose to connect with our Products or Services, we may collect different information transmitted by your Smart Devices. For example, Smart Cameras may transmit images or videos that they have recorded.

Purposes and legal basis for processing Personal Data

The purposes for which we may process information about you are as follows:
To provide you with 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 lawful basis for this processing is to perform our contract with you under our Terms of Use.
Improving our Services: We process your device information, usage data and Smart Device information to ensure the functionality and security of our Products, to develop and improve our Products and Services, to analyze the effectiveness of our operations and to prevent and trace fraudulent or inappropriate use. The lawful basis for this processing is to perform our contract with you under our Terms of Use.
Non-Marketing Communications: We process your personal data to send you important information about the Services, changes to our terms, conditions and policies and/or administrative information. Because this information may be important, you should not opt out of receiving these communications. The lawful basis for this processing is to perform our contract with you under our terms of use.
Marketing Communications: We may process your personal data to provide you with marketing and promotional materials about our Products and Services. If we do so, each communication we send to you will contain instructions allowing you to unsubscribe from receiving future communications of this nature. The legal basis for this processing is your consent.
Personalization: We may process your account and profile data, usage data, and device information to personalize the product design and to provide you with tailored services, such as recommendations and display of information and advertisements about products that are suitable for you, and to invite you to participate in surveys about your use of our Products. The legal basis for this processing is your consent.
Legal Compliance: We may process your personal data when we believe it is 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 governmental authorities; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, security or property, and/or those of our users, including yourself; and (g) to allow us to pursue available remedies or limit the damages we may suffer.

With whom do we share Personal Information?

At SEDEA, we share Personal Data only in the ways we have informed you. We may share your Personal Data with the following recipients:
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, email services, and other similar services to enable them to provide services to us.
Our customers and other business partners who directly or indirectly provide you with your Smart Devices and/or networks and systems through which you access our Sites and Services.
An affiliate or third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a portion of our business, assets or stock (including, without limitation, in connection with bankruptcy or similar proceedings). In such event, you will be notified by e-mail and/or by prominent notice on our website of any change in ownership, new incompatible uses of your personal data, and choices you have regarding your personal data.
If we believe it is necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from the public and governmental authorities; (d) to enforce our terms and conditions; (e) to protect our operations, business, and systems; (f) to protect our rights, privacy, security, or property, and/or those of our users, including yourself; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Subsidiaries or affiliates within our family of companies, in order to carry out regular business activities.
Except for the above-mentioned third parties, to third parties only 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 where you reside. The laws of these countries may differ from the laws applicable in your country of residence. When we do so, we will ensure that an adequate level of information protection is provided by using one or more of the following approaches:
An agreement based on the approved EU standard contractual clauses in accordance with Article 46 of the GDPR. For more information, see the following link:https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
If you would like more details about the safeguards we have in place, you may contact us directly as described in this Privacy Policy.

Your rights regarding your Personal Information

We respect your rights and control over your personal data. You may exercise any of the following rights:
Via the "Personal Center - Profile" in our Products
By sending us an e-mail to rgpd@sedea.fr
You are not required to pay any fee and we will endeavour to respond to you within 30 days. If you decide to send us an e-mail, please clearly state in your request what information you wish to change, whether you wish to have your personal data removed from our database or otherwise tell us what limitations you wish to place on the use of your personal data. Please note that we may ask you to verify your identity before taking action on your request, for security reasons.
You may:
Request access to the personal data we process about you;
Request that we correct inaccurate or incomplete personal data about you;
Request the deletion of personal data about you;
Request temporary or permanent restrictions on our processing of certain personal data about you;
Request the transfer of personal data to you or to a third party where we process data based on your consent or on a contract 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 legitimate interests.
We undertake with the Customer to comply with the applicable legislative and regulatory provisions and in particular the EU General Data Protection Regulation 2016/679 and the law n°78-17 of 6 January 1978. The personal data that the Customer transmits to us are used by the latter exclusively within the framework of its commercial relationship with the Customer and with the aim of best carrying out its business and associated activities. Any processing of personal data transmitted by the Customer and processed on his behalf by us will be carried out in accordance with his instructions and for no other purpose, in accordance with the applicable legal and regulatory provisions. The owner of the data has rights of access, rectification and opposition to the use of such data, a right to control and formulate instructions on their retention, deletion and communication even after his death. All requests should be sent to the following address: rgpd@sedea.fr. All information on the rights and obligations of the Customer and SEDEA regarding the protection of personal data can be found on our website http://www.sedea.fr/.

Security

We use commercially reasonable physical, administrative and technical safeguards to preserve the integrity and security of your personal data. SEDEA provides various security strategies to effectively ensure the security of user data and devices. With respect to access to devices, SEDEA's proprietary algorithms are employed to ensure data isolation, authentication upon access, and authorization request. For data communication, communications using security algorithms and transmission encryption protocols and dynamic key-based transmission of business-level information encryption are supported. For data processing, strict data filtering, validation and full data auditing are applied. In the case of data storage, all confidential user information is securely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that an account you have with us has been compromised), you can immediately notify us of the problem by sending an e-mail to rgpd@sedea.fr.

Data retention

We process your personal data for the minimum period necessary for the purposes set out in this Privacy Policy, unless we have a specific legal requirement to retain 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 once the retention period ends, we will destroy 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 further use of your personal data.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect any changes in our information practices. If we make material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice in the mobile applications before the change becomes effective. We encourage you to periodically review this page for the most current information about our privacy practices.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us as follows
SEDEA Electronique
Mailing Address: 1011 rue des saules 59810 Lesquin
Email: rgpd@sedea.fr
As a data subject residing within the European Union, you have the right to lodge a complaint with a supervisory authority regarding SEDEA's data processing activities. If you have any questions or wish to exercise your rights as a data subject residing in the EU, please contact our European representative here:
Name: Stéphane OORREEL
Email : rgpd@sedea.fr