Orange Smart Home ES Privacy Policy
ORANGE ESPAGNE, S.A.U(now on, “Orange”) a company registered in Paseo del Club Deportivo 1, Parque
Empresarial La Finca, Edificio 8, 28223 Pozuelo de Alarcón (Madrid) will
process your personal data acting as the Data Controller and committed to
protecting your privacy. This Privacy Policy (now on “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”):
·Orange Smart Home ES Mobile Application
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.
The reference “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. The
reference “Apps” refers to those mobile applications developed by Orange 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 and suggestions: 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 without delay.
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 connectioninformation, 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: 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.
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.
·Information collected by the Smart Device to provide the video
monitoring service: image, voice, facial recognition, etc.
Purposes
and legal basis for processing Personal Data
The purpose for which we may process
information about your personal data 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 relevant 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 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 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 activity is your
consent.
Moreover, we can invite you to participate in surveys; in that case, the
legal basis for this processing activity is the contract.
- 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.
Who do we
Share Personal Data with?
The User's data
may be communicated where appropriate to:
•Public Administrations in the cases provided by Law.
•Banks and Financial Entities for the collection of
the services offered.
•Other companies of the business group for internal
administrative purposes and the management of the products and services
contracted.
•The entities responsible for the Credit Information
Files to which the data relating to non-payments and incidents in the payment
of products or services contracted to ORANGE or to third parties may be
communicated.
•Recovery entities for the total or partial assignment
of the loan portfolio derived from the provision of telecommunications services
that are unpaid.
•Suppliers and distributors that perform necessary
functions for the correct provision of the service, in the name and / or on
behalf of ORANGE.
International
Transfer of Information Collected
ORANGE will 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 the
following approach:[ODPO11]
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 the use you manage over your Personal Data. You may exercise any of the
following rights through the section “Profile-Personal Center”. For that
matter, 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.
·Right
to not be subject to decisions based solely on automated decisions made by
Orange. You have the right to have an agent intervention to explain the
decision made through this automated processing, also collect your comments and
dispute such decision where appropriate.
·File
a claim regarding the protection of your personal data through the mediation
system of the Association for the Self-regulation of Commercial Communication
(AUTOCONTROL) at the following link: www.autocontrol.es/servicios/mediacion or through
the Spanish Data Protection Authority through its web www.aepd.es, or by postal
address at C / Jorge Juan, 6, 28001-Madrid.
Security
We use commercially
reasonable physical, administrative, and technical safeguards to preserve the
integrity and security of your Personal Data. Orange
provides 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, 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.
Data
Retention
ORANGE will process the
user's personal data in compliance with the principle of limitation and the retention
period, for the time necessary to fulfill the purposes for which they were
collected and will be kept for the time necessary to provide the services
requested and in response to the retention periods provided for in current
legislation for the exercise or defense of possible administrative or judicial
claims. In these cases, the information will be kept blocked with restricted
access to certain profiles, with the necessary technical and organizational
measures that guarantee the security of the information avoiding its
alteration, loss, treatment or unauthorized access, taking into account the
state of technology, the nature of the stored data and the risks to which they
are exposed. After these periods, the data will be deleted or anonymized, as applicable,
and in accordance with the applicable regulations.
Regarding the period of
conservation of the data processed for profiling activities, they will respond
to the current situation of the client and in any case, it will not exceed 12
months.
Changes
to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information
practices. 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:
ORANGE
ESPAGNE SAU
Postal Mailing Address: Paseo del Club Deportivo 1, Parque Empresarial
La Finca, Edificio 8, 28223 - Pozuelo de Alarcón (Madrid)
Email: orangeproteccion.datos@orange.com.