Privacy Policy
Effective Date: 2023-8-31
Updated: 2023-08-28
ProWarmand subsidiaries (“we”, “us”,
“our”, “ProWarm”) 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”):
ProTouch 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: sales@prowarm.com
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 byProWarmthat 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
·Registered Account 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.
However,
if the Services you request or purchase are based on your account, please go to
the registration/login page for guidance.
·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: a) real-time and precise
location, for instance when you choose to use the automation scenarios for
controlling your Smart Devices, or b) 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’s Data Processing and Security Terms
for more details.
You may disable the collection and use of your
location information by changing your mobile device settings ("My - Setting - Privacy Right Setting - Switch
on/off Location Information"), 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.
You may opt-out the using of camera permission: "My - Setting - Privacy Right Setting - Switch
on/off Camera".
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.
You may opt-out the using of photo album permission: "My - Setting - Privacy Right Setting - Switch
on/off Photo Album".
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.
You may opt-out the using of microphone permission: "My - Setting - Privacy Right Setting - Switch
on/off Microphone".
5)Additional
services based on storage permission(Android):
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.
You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switch
on/off Storage".
6)Additional
services based on Notification permission:
The reason why we ask you for the permission is to
send you notifications about using the Smart Devices or Services, especially if
you have purchased security services and you require an alert or message so
that you can capture the real-time status.
You may opt-out the using of App notifications: "My - Message Center - Setting - Switch on/off
Notifications".
7)
Additional services based on Alert Window permission：
You may choose to bind a camera in the App and
require the App to display the real-time image of the camera in a separate
window.
You may opt-out the using of alert window
information: "My - Setting - Privacy
Right Setting - Switch on/off Alert Window".
8) Additional
services based on Bluetooth permission:
You can enable Bluetooth functions after turning on
the permission, including controlling the Smart Devices, acquiring status of,
discovering and configuring Smart Devices. In these functions, we will
communicate with Smart Devices via Bluetooth. Please be aware that even if you
have agreed to enable the Bluetooth permission, we will only use Bluetooth for
communication in these scenarios: display device status on the home page and
Smart Device panel; perform device control on the home page and Smart Device
panel; discovering Smart Devices on the home page and the add device page,
Smart Device distribution network.
You may opt-out the using of Bluetooth via "My - Settings - Privacy Setting -
Disable/Enable Bluetooth permission".
9）Additional services based on
HomeKit permission (iOS):
You can enable related functions after enabling
HomeKit permissions, including discovering Smart Devices, enabling Smart Device
network configuration, controlling Smart Devices, and checking device status.
Among these functions, we will process data with the "Home“ App that comes
with the iOS system through HomeKit. Please be aware that even if you have
agreed to enable the HomeKit permission, we will only use it in these scenarios:
on the home page, to discover HomeKit devices, HomeKit device network
configuration; in "Settings - HomeKit" for discovering HomeKit
devices, HomeKit device network configuration.
You may opt-out the using of HomeKit permission via "My - Settings - Privacy Settings-Turn off/on
HomeKit permission".
10）Additional services based on
HealthKit (iOS):
You can proactively enable related functions after
enabling HealthKit permission, including statistics on weight, height, running,
and swimming. In these functions, we will exchange data with the health-related
functionalities that comes with the iOS system through HealthKit. Please be
aware that even if you have agreed to enable HealthKit permission, we will only
use them in these scenarios: when you use the health-related Smart Device, such
as body fat scales, bracelets, watch and consent to use the HealthKit, the data
reported by the Smart Device will be transferred to HealthKit.
You may opt-out the using of HealthKit permission via
"My - Settings - Privacy Settings - Turn
off/on HealthKit permission".
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
·Mobile
Device Information: When you interact with our
Services, in order to provide and maintain the normal operation of our
Services, to improve and optimize our Services, and to protect your account
security as well, we automatically collect mobile device information, such as
mobile device model number, IP address, wireless connection information, the
type and version of the operating system, application version number, push
notification identifier, log files, and mobile network information. Meanwhile,
we will collect your software version number. In order to ensure the security
of the operating environment or to provide services, we will collect
information about the installed mobile applications and other software you use.
·Usage
Data: During your interaction with our websites and
Services, we automatically collect usage data relating to visits, clicks,
downloads, messages sent/received, and other usage of our websites and
Services.
·Log
Information: When you use the App, in order to improve your user
experience, the system and exception log may be uploaded, including your IP
address, language preference setting, operating system version, date or time of
access, so that we can facilitate and accurately identify problems and help you
solve them in timely manner.
Please note that we 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 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 aggregate
or desensitize such information.
3.Smart Devices Related Information:
·Basic
Information of Smart Devices: When you connect your Smart
Devices with the 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
collected during the process of connecting to a Smart Device:
Based on the type of Smart Device you need to connect, the basic information
collected includes: Wi-Fi information, device MAC address, etc.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information
about you are as follows:
·Provide
You with Our Services: We process your account data,
mobile device information, usage data, location information, and Smart Device
related information to provide you with the Services that you have requested.
The legal basis for this processing is to perform our contract with you
according to user agreement.
·Improve
Our Services: We process your mobile device information, usage
data, location information and Smart Device related information to ensure the
functions and safety of the Services, to develop and improve the 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 user
agreement.
·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 ("Me &rt; Message Center &rt; Setting &rt;
Notification Setting”) 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 user
agreement.
·Data
Analysis: In order to analyze the usage of the products we
provide and improve your user experience, we will analyze the data you provide
us, a) we need to check your problems when you encounter any malfunctions
during the usage of the product, under such circumstance, you may not able to
opt-out because it is highly relate to your functionalities and quality of
using our product and service, and b) analyze data about how you interface with
the product or under particular scenarios so that you can better enjoy the
convenience brought by our Services, under such circumstance, if you do not
agree to data analysis of your data, you can enter the privacy settings of App (“My &rt; Settings &rt; Privacy Settings &rt; Data
Analysis”) to opt-out your selection. The legal basis for such
processing is based on your consent.
·Marketing
Communication and Personalization: We may
process your account 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” (“Me&rt;
Settings &rt; Privacy Settings &rt; Personalization”) in the App. The
legal basis for this processing is your consent.
·Legal
Compliance. We disclose information if we are legally required
to do so, or if we have a good faith belief that such use is reasonably
necessary to:
·comply with a legal obligation,
process or request;
·enforce our User Agreement and
other agreements, policies, and standards, including investigation of any
potential violation thereof;
·protect the rights, property or
safety of us, our users, a third party or the public as required or permitted
by law; or
·detect, prevent or otherwise
address security, fraud or technical issues.
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 ProWarm, 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
websites and Services.
·To subsidiaries or affiliates
within our corporate family for purpose of regular business activities based on
our instructions and in compliance with applicable law, this Policy and other
appropriate confidentiality and security measures.
·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, and
choices you may have regarding your Personal Data.
·As we believe in good faith that
access to, or use, preservation, or disclosure of the information is reasonably
necessary or appropriate to:
(a)Comply
with applicable law, regulation, legal process, or lawful governmental request;
(b)Enforce
our User Agreement and other agreements, policies, and standards, including
investigation of any potential violation thereof;
(c)
Protect our operation and business systems;
(d)Protect
the rights, property or safety of us, our users, a third party or the public as
required or permitted by law; or
(e)Perform
risk management, screening and checks for unlawful, fraudulent, deceptive or
malicious activities.
Except for the third parties mentioned above, we only
disclose your Personal Data to other third parties with your consent.
International Transfer of Information Collected
ProWarmwill
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:
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: "My-Setting-Privacy Settings-Personal Data
Export";
·Request that we correct
inaccurate or incomplete Personal Data about you: 1) Modify your account number
(email address or phone number): "My-Setting-Account
and Security-Change your Account"; 2) Modify the nickname and/or
time zone: "My-Personal Information";
·Request deletion of Personal Data
about you: "My-Setting-Account and
Security-Delete Account", when you confirm the deletion of your
account, your Personal Data will be deleted accordingly.
·Request restrictions, temporarily
or permanently, on our processing of some or all Personal Data about you:
Please send over your request through "My-FAQ
& Feedback", or send over the email request to sales@prowarm.com.
·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: Please send over your
request through "My-FAQ &
Feedback", or send over the email request to sales@prowarm.com .
·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 Confirm the
following details: 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, Bluetooth
settings, notification settings and other related functions;
2)You may opt-out the non-marketing communication
through “Me &rt; Message Center &rt;
Notification Settings” to manage your selection;
3)You may opt-out the data analysis features through “Me &rt; Settings &rt; Privacy Settings”;
4)You may opt-out the Personalization feature through
“Me &rt; Settings &rt; Privacy Settings &rt;
Personalization”;
5)Unbind the Smart Device through the App, and the
information related to the Smart Device will not be collected;
6)By using product with the "Try
Now" mode, and not enable certain location setting for
particular smart scene, we will not collect any Personal Data about you;
7)If you previously agreed to associate App account
with a third-party service, such as a health platform, please unbind it on the
third-party platform.
When you withdraw your consent or authorization, we
may not be able to continue to provide you with certain 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.
About Deletion
of the Account: You can find the Delete function through “Me &rt; Settings &rt; Account and Security &rt;
Delete Account” (Deactivate Account）
Security Measures
We use commercially reasonable physical,
administrative, and technical safeguards to preserve the integrity and security
of your Personal Data. ProWarm provides various security strategies
to effectively ensure data security of user and device. As for device access, ProWarm 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 sales@prowarm.com.
Data Retention
We process your Personal Data for the minimum period
necessary for the purposes set out in this 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.
·For as long as you require us to
fulfill the products and services you request from us as defined in the user agreement.
·Personal Data will no longer be
retained when you request to remove your Personal Data, we will accordingly
complete the task.
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
any child unless we first obtain permission from that child’s parent or legal
guardian. If we become aware that we have collected Personal Data from any
child 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:
The Underfloor Heating
Store
Postal Mailing Address:Unit
12 Carnival Park, Carnival Cl, Basildon, Essex, SS14 3WN
Email: sales@prowarm.com