Living Reinvented Mobile Privacy Policy
Effective Date 28/03/2022
Updated: 28/03/2022
Living Reinvented Ltd and it's subsidiaries 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”).
iHelios Living Reinvented Mobile Application
Before you use our Products, please carefully read through
this Policy and understand our purposes and practices of collection, 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 does 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 question r regarding
this Policy, please do not hesitate to contact us via:
Postal Mailing Address: The Old Brass Foundry, Marlborough
Terrace, Hull, HU2 9AE, UK.
Email: hello@living-reinvented.co.uk.
For other branded mobile applications powered by Living
Reinvented Ltd, our clients control all the Personal Data collected through our
Products. We collect the information under the direction of our Clients and the
processing of such information shall be limited to the purpose of providing the
service for which our Clients has engaged us. If you are a customer of one of
our clients and would no longer like to be contacted by one of our Clients that
use our service, please contact the Client that you interact with directly.
Definition
In this Policy, Personal Data means information generated,
collected, recorded and/or stored, electronically or otherwise, that can be
used to identify an individual or reflect the activity of an individual, either
from that information alone, or from that information and other information we
have access to about that individual.
Personal Sensitive Data includes personal biometric
information, communication records and contents, health information,
transaction information, and precise location information. When we collect
Personal Sensitive Data from you, we will generate an explicit notification for
your consent before we collection personal sensitive data about you.
Smart Devices refers to those 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 developed by Living
Reinvented Ltd 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, 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.
Feedback: When using feedback and suggestion features in our
Products, we will collect your email address, mobile phone number and your
feedback content to address your problems and solve device failures on a timely
basis.
Information based on additional functions:
In order to offer you with more convenient and
higher-quality Services with optimized user experiences, we may collect and use
certain information if you consent to use additional functions in the App.
Please note, if you do not provide such information, you may continue to use
basic Services of the App and connected Smart Devices, but certain features
based on these additional functions may not be available. These additional
functions may include:
1)Additional functions based on location information:
When you enable the location-based functions through
permission settings on your mobile device, we will collect and process your
location information to enable these functions, such as pairing with your Smart
Devices. Also, we may collect information about your real-time precise or
non-precise geo-location when you use certain Smart Devices or the Services,
such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fence
feature, your location information will be generated and shared with Google
Maps services. Please note that Google has corresponding data protection
measures, which you may refer to Google Data Protection Terms for more details:
https://privacy.google.com/businesses/gdprservices/. You may reject such use of
your location information by managing the permission settings in the Services,
upon which we will cease to collect and use your location information.
2)Additional services based on camera:
You may use the camera to scan the code by turning on the
camera permission to pair with a Smart Device, take video, etc. Please be aware
that even if you have agreed to enable the camera permission, we will only
obtain information when you actively use the camera for scanning codes, video
recording, etc.
3)Additional services for accessing and uploading
pictures/videos based on photo albums (picture library/video library):
You can use this function to upload your
photos/pictures/videos after turning on the photo album permission, so as to
realize functions such as changing the avatar, reporting device usage problems by
providing photo proofs, etc.. When you use the photos and other functions, we
will not recognize this information; but when you report a device usage
problem, we may use the photos/pictures you upload to locate your problem.
4)Additional services related to microphone-based service:
You can use the microphone to send voice information after
turning on the microphone permission, such as shooting videos, waking up the
voice assistant, etc. For these functions, we will collect your voice information
to recognize your command. Please be aware that even if you have agreed to
enable the microphone permission, we will only obtain voice information through
the microphone when you voluntarily activate the microphone in the App.
5)Additional services based on storage permissions:
The purpose is to ensure the stable operation of the App by
utilizing the storage permission. After you give or indicate the permission to
read/write your mobile device’s storage, we will access pictures, files, crash
log information and other necessary information from your mobile device’s
storage to provide you with functions, such as information publications, or
record the crash log information locally.
Please note that if you turn on any permission, you
authorize us to collect and use relevant personal information to provide you
with corresponding Services. Once you turn off any permission, we will take it
as canceling the authorization, and we will no longer continue to collect
Personal Data based on the corresponding permissions, and the related functions
may be terminated. However, your decision to turn off the permission will not
affect the previous collection and use of information based on your
authorization.
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.
Please note that one cannot identify a specific individual
by using Device Information or Log Information alone. However, if these types
of non-personal information, combined with other information, may be used to
identify a specific individual, such non-personal information will be treated
as Personal Data. Unless we have obtained your consent or unless otherwise
provided by data protection laws and regulations, we will anonymize and
desensitize such non-personal information.
Location Information: When you enable location-based
functions through permission settings on your mobile device, we will collect
and process your location information to enable certain functions, such as
pairing with your Smart Devices. Also, we may collect information about your
real-time precise or non-precise geo-location when you use our specific
Products or Services, such as Please enter the product name.
Based on your consent, when you enable the geo-fence feature
on the Products, your location information will be generated and shared with
Google Map services. Please note that Google has corresponding data protection
measures, which you may refer to Google Data Protection Terms for more details:
https://privacy.google.com/businesses/gdprservices/. You may reject such use of
your location information by managing the permission settings in the Products,
upon which we will cease to collect and use your location information.
3.Smart Devices Related Information:
Basic Information of 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. For example,
please enter information about the smart device report.
Please note that when you actively agree to enter the App
name and the application is connected to the Apple Health app, we will share
your measurement data with Apple Health (including only your BMI, height, weight
and body fat% data). The purpose of sharing data is only to measure and analyze
health-related indicators related to you, and it will never be disclosed to
other third parties. You can close at any time by managing the HealthKit
settings page. Please enter the App name. The application is authorized to
connect with Apple Health.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you
are as follows:
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. At the same
time, we will also send you notifications related to the services you have
purchased, such as alert services. You can check the [App Notification] in the
App to manage these communications. When you decide not to enable the
Notifications function, we will no longer process your information for such
purpose. 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 the 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. If you do not agree
to Living Reinvented Ltd sending you marketing communications, you may opt out
when you enter the App, or by changing your preferences in [Privacy Settings]
of the App. The legal basis for this processing is your consent.
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 the Services. If you do
not allow us to process your Personal Data for personalization, you may opt out
when you enter the App, or by changing your preferences in [Privacy Settings]
in the App. The legal basis for this processing is your consent.
Legal Compliance: We may process your Personal Data as we
believe to be 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 government authorities (d) to enforce our terms and conditions; (e)
to protect our operations, business and systems; (f) to protect our rights,
privacy, safety or property, and/or that of other users, including you; and (g)
to allow us to pursue available remedies or limit the damages that we may
sustain.
If there is any change in the purposes for processing your
personal data, we will inform such change to you via email and/or a prominent
notice on our website of such changes of purposes, and choices you may have
regarding your Personal Data.
Who do we Share Personal Data with?
At Living Reinvented Ltd, we only share Personal Data in
ways that we tell you about. We may 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 our customers and other business partners who provide
you, directly or indirectly, with your Smart Devices, and/or networks and
systems through which you access and use our Sites and Services.
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, assets or stock (including without
limitation in connection with any bankruptcy or similar proceedings). In such
an event, you will be notified via email and/or a prominent notice on our
website of any change in ownership, incompatible new uses of your Personal
Data, and choices you may have regarding your Personal Data.
As we believe to be 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 government authorities, including public and
government authorities outside your country of residence; (d) to enforce our
terms and conditions; (e) to protect our operations, business and systems; (f)
to protect our rights, privacy, safety or property, and/or that of other users,
including you; and (g) to allow us to pursue available remedies or limit the
damages that we may sustain.
To subsidiaries or affiliates within our corporate family,
to carry out regular business activities.
Except for the third parties described above, to third
parties only with your consent.
International Transfer of Information Collected
Living Reinvented Ltdwill comply with applicable data
localization requirements in corresponding jurisdictions with respect to
storage of data. To facilitate our operation, we may transfer, store and
process your Personal Data in jurisdictions other than where you live. Laws in
these countries may differ from the laws applicable to your country of
residence. When we do so, we will ensure that an adequate level of protection
is provided for the information by using one or more of the following
approaches:
Agreement on the basis of approved EU standard contractual
clauses per GDPR Art. 46. For more information, see https://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 we have
in place, you can contact us directly as described in this Privacy Policy.
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:
Via the privacy office email address at info@ihelios.co.uk.
You do not have to pay a fee and we will aim to respond 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 you would like to have
your Personal Data deleted from our database or otherwise let us know what
limitations you would like to put on our use of your Personal Data. Please note
that we may ask you to verify your identity before taking further action on
your request, for security purposes.
You may:
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 or our legitimate interests.
Withdrawal of consent: We will exercise your privacy right
to withdraw consent through the following approaches:
1) For privacy permissions acquired through device system
settings, your consent can be withdrawn by changing device permissions,
including location, camera, photo album (picture library/video library),
microphone, Bluetooth settings, notifications and other related functions.
2) In the marketing communications that you agree to, the
information we send to you contains instructions that allow you to withdraw
your consent in accordance with the “unsubscribe” method described in the
information.
3) Unbind the Smart Device through the app, and the
information related to the Smart Device will not be collected.
4) By using product with the visitor mode, we will not
collect any personal data about you.
When you withdraw your consent or authorization, we may not
be able to continue to provide you with the products or services
correspondingly. However, your withdrawal of your consent or authorization will
not affect the processing of personal information based on your consent before
the withdrawal.
Confirm7: if the App enables the account
deletion/termination, please fill out the route in the App to delete/terminate
the account.
Security
We use commercially reasonable physical, administrative, and
technical safeguards to preserve the integrity and security of your Personal
Data. Living Reinvented Ltd provides various security strategies to effectively
ensure data security of user and device. As for device access, Living
Reinvented Ltd 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, strict data filtering and validation and
complete data audit are applied. As for data storage, all confidential
information of users will be safely encrypted for storage. If you have reason
to believe that your interaction with us is no longer secure (for example, if
you feel that the security of any account you might have with us has been
compromised), you could immediately notify us of the problem by emailing
info@ihelios.co.uk.
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 for us to keep 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 after the retention period
ends, we will destruct your Personal Data. When we are unable to do so for
technical reasons, we will ensure that appropriate measures are put in place to
prevent any further such use of your Personal Data.
Children’s Privacy
Protecting the privacy of young children is especially
important to us. The Services are not directed to individuals under the age of
thirteen (13)(or such other age provided by applicable law in your
country/region of residence), and we request that these individuals do not
provide any Personal Data to us. We do not knowingly collect Personal Data from
anyone under the age of thirteen (13) unless we first obtain permission from
that child’s parent or legal guardian. If we become aware that we have
collected Personal Data from anyone under the age of thirteen (13) without
permission from that child’s parent or legal guardian, we will take steps to
remove that information.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our
information practices. If we make any material changes 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.
Contact Us
If you have any questions about our practices or this
Privacy Policy, please contact us as follows:
Living Reinvented Ltd
Postal Mailing Address: The Old Brass Foundry, Marlborough
Terrace, Hull, HU2 9AE, UK
Email:hello@living-reinvented.co.uk