B&T Associates Ltd Mobile Privacy Policy
Effective Date: 28/02/2023
Updated: 28/02/2023
B&T Associates Ltd and
subsidiaries (“we”, “us”, “our”, “B&T Associates”) 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”):
truSmart 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:
technical@trusmart.co.uk
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 B&T
Associates 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 truSmart.
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, power consumption, operating hours, device settings,
video recordings.
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 truSmart 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 B&T Associates 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
B&T Associates Ltd 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 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:
Confirm6: please provide at least 2 approaches for
individual user executing their privacy rights, for instance, via the privacy
office email address; technical@trusmart.co.uk, or via the route of Feedback imbedded in the App: Me&rt;Personal
Center&rt;Account and Security&rt;, etc.
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. B&T Associates Ltd provides various security
strategies to effectively ensure data security of user and device. As for
device access, B&T Associates 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 technical@trusmart.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:
B&T Associates Ltd
Postal Mailing Address: David House, Manby
Business Park, Manby, LN11 8UT
Email: technical@trusmart.co.uk