Mobile
Application Privacy Statement for Collingwood Lighting Limited
Introduction and Scope of application
We care about your privacy.
Our Privacy Policy will take effect on 24 April 2019. This Privacy Statement for Collingwood Lighting Limited (“Privacy Statement” or “Statement”) describes information that Collingwood Lighting Limited, and its subsidiaries, associates and affiliates (collectively, “CLL”) may collect, use, share, and store, including personal information (i.e. information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).
This Statement focuses on information related to the operation of CLL services. In this Statement, the expression “CLL Services” or “Services” includes the Collingwood Smart Home, and Subscription Services as defined in our Terms of Service. The Services are for use in connection with CLL hardware products (“CLL Products” or “Products”).
Our commitment to you
At CLL, we take your privacy seriously. Except as provided in this Privacy Statement, we will not disclose your personal information to any third party.
By using or otherwise accessing the Services, you agree to allow CLL to collect and process information as described in this Statement. If you disagree, please stop using or otherwise accessing the Services.
By using or otherwise accessing the Services, you agree that CLL may record your personal information on CLL’s internal systems. You acknowledge and understand that the privacy protections and legal requirements, including the rights of authorities to access your personal information, will be governed by English law..
Information CLL receives or collects
The Services collects the following information (collectively “Your Information”)
· Information about you and your account. When you create an account, CLL receives and stores the information about you that you provide, including your name, email, and contact information. When you use or otherwise access the Services, CLL receives and stores the information associated with your account. Such information includes, but is not limited to, password, email address, account ID, avatar, account creation date and time, and the date and time of each login.
· Information about your own device. When you use or otherwise access the Services through your own device (e.g., a desktop computer, a laptop, a tablet, or a smartphone), CLL receives and stores information associated with your own device, including but not limited to the device number, IP address, operation system information, software version information, firmware version information, hardware information, access date and time, SIM information, and IMSI/IMEI information.
· Information about the Products. When you use the Products, CLL receives and stores information associated with the Products, including but not limited to product icon, product name, model number, serial number, MAC address, product UUID, device status (e.g., battery charge level, online/offline status, operation indicators), device properties (e.g., functional name, functional code, read/write status, manufacturer identification, product name, network status), software version information, firmware version information, hardware information, and product location.
· Information about the configurations, settings, and data you create and edit through the Mobile Apps, including but not limited to the scene setup, scene configurations, scene properties, room setup, room configurations, room properties, security setup, security configurations, security properties, and IFTTT (“if this then that”) rules.
· Information about your account activities, including logs of account logins, device logs, scene use logs, IFTTT logs, security system logs.
· Information you submit. When you submit or publish information through the Services, CLL receives and stores the information you submit or publish and other data associated with the information you submit or publish, including but not limited to the activities you participate in, the date and time associated with your submission or publication.
Additionally, when you submit comments through the Mobile Apps, CLL receives and collects the comments, and information associated with your account. When you contact CLL’s customer services, CLL collects and records your personal information, such as your name, account ID, phone number, email address and other contact information.
During processing and collecting Your Information, if CLL identifies activities against the law, rules by government agencies, or CLL’s Terms of Service, CLL may take action, including reporting to relevant government authorities.
Use of Your Information
CLL uses Your Information to provide our services and
products. Below are examples of how CLL
uses Your Information:
· Creating your account: When you create an account, Your Information will be used to create your account and account profile.
· Verifying your identity: Your Information will be used to verify your identity.
· Accessing and using the Services: Your Information will be used to activate your access to the Services, and maintain the operations of the Services.
· Locating and diagnosing the Products: Your Information will be used to locating the Products and, diagnose the Products if they are not functioning properly.
· Adding metadata to Your Information: Your Information will be used to create tags and metadata (e.g., geographic locations and time stamps) that will be added to Your Information (such as still images, videos, and audio signals).
· Improving user experience: Your Information will be used to improve the user experience of the Services and Products.
· Sending notifications: CLL may use Your Information to send your important notices, promotional information, and marketing materials.
CLL may also use Your Information in an aggregated, non-identified form for research and marketing purposes and to help CLL make sales, marketing, and business decisions.
Disclosure to Third Parties
CLL does not disclose Your Information to a third party, except in limited situations:
· Required by the normal operation of the Services. The Services may rely on or interoperate with third party products and services. These third-party products and services may have to access Your Information. By using or otherwise accessing the Services, you consent to disclose Your Information to the third parties that provides functions or facilities required by the normal operation of the Services.
· When required by local laws and regulations, or ordered by courts or government agencies, CLL will transfer or disclose Your Information to comply with such laws, regulations, and orders.
· Upon the sale or transfer of the company and/or all or part of its assets, Your Information may be among the items sold or transferred. CLL will request a purchaser to treat the information under the privacy statement in place at the time of its collection confidentially.
At your request or with your consent, CLL may disclose Your Information. CLL prohibits any third party from collecting, editing, selling, disseminating Your Information in any manner. If a user of the Services engages in such activities, CLL will immediate suspend or terminate that user’s account and rights.
Access, update, correct,
erase or restrict processing your personal information
· You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.
· A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
· If you would like to request access to your personal data held by us or if you believe any information that we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at this email address: [ ]
· For details relating to the personal information in your account, you may also access and change them at account setting by logging into your account on your mobile device or our website.
· If you are a European Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
· If you are a European Union user under GDPR, you have the right to obtain from us a restriction on processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
· If you are a European Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
· If you are a European Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.
Withdrawal of consent
· You may withdraw your consent for the collection, use and/or disclosure of your personal information in our possession or control by submitting a request by contact with customer.service@collingwoodgroup.com. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.
· Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy CLL’s products and services.
Deletion of Information
CLL generally stores Your Information on CLL’s servers for as long as needed by the normal operations of the Services (for example, as short as a couple seconds for motion detection processing).
· You can delete the information on the Products by resetting it to factory defaults.
· You can access, edit, or delete Your Information stored on CLL’s servers through the controls in your account.
· Upon termination of your account (either at your request or by CLL), your Information will be deleted immediately or in a predetermined period. Please refer to the Terms of Services for further information.
· After Your Information is deleted, backup copies may continue to exist for some time before they are deleted. CLL may retain certain data for a longer period of time if CLL is required to do so for legal reasons.
Security measures
CLL takes the security of your personal information very seriously. We will use all reasonable efforts to safeguard your personal information. CLL promises to use its security advisers and its own professional experience to provide security operation and maintenance for CLL products, protect its operation security, and guarantee the security of customer’s privacy and data. This commitment includes but is not limited to:
· Physical security: CLL makes efforts to provide each customer with secure, stable, sustainable and reliable physical infrastructure. We are establishing an all-round security management system according to the national standards and supervision requirements related to data center to cover the process from system and policy to process management and follows strict supervision and audit to ensure physical and environmental security of the data center.
· Network isolation and access control management: CLL has established strict internal network isolation rules to realize access control and boundary protection for internal office network, development network, test network and production network through physical and logic isolation.
· Communication security: We use OAuth authentication to avoid the hijack risk, keep whole chain channel TLS encryption Or AES encryption. We ensure the contents of transmitted data and key fields are encrypted.
· Data security: The data security system of CLL is developed for comprehensive and systematic construction by management and technical means. Every link of the lifecycle of data (data production, data storage, data use, data transmission, data spread, and data elimination) is under the data security management and control to realize the data security objective.
·
Compliance: CLL
follows international information security standards and industrial
requirements by integrating and fulfilling compliance requirements and
standards in our products, and fully embrace the requirements of GDPR.
·
Security
organization and staff: We are building a complete in-house security technology
team to support the security operations and maintenance of our products to
ensure that each layer of the system is protected. Our employees understand
their role in protecting the confidentiality, integrity, and availability of
Information Resources.
· Security operation and maintenance: Unified management is carried out through our security operation & management platform, and strict access control and monitoring audit are implemented to ensure security.
We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet. We will act upon any personal data breach, notifying the breach to the relevant supervisory authority as appropriate, and notifying the personal data breach to the data subjects by complying with the applicable laws.
Integrity and Retention of Personal Information
CLL makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. When assessing these periods, we carefully examine our need to collect personal information at all and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.
How we deal with children's
personal information
We understand the importance of taking extra precautions to protect the privacy and safety of children using CLL products and services. Children under the age of 16, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own accounts.
If we learn that we have collected the personal information
of a child under 16, or equivalent minimum age depending on jurisdiction,
outside the above circumstances we will take steps to delete the information as
soon as possible.
Transfer of personal information outside of your
jurisdiction
Whenever CLL shares
personal data originating in the EEA with a third party which may or may not be
a CLL entity outside the EEA, we will do so on the basis of EU standard
contractual clauses or any other safeguards provided for in the GDPR.
Change of the
Privacy Statement
This Privacy Statement may change from time to time. CLL will provide notice of any changes by publishing such notice on a website or by contacting you.
Contact us
If you have any comments or questions about this Privacy Policy or any questions relating to your personal data processing, please contact our Data Protection Officer at the address below.
Collingwood Lighting Limited, Brooklands House, Sywell Aerodrome, Sywell, Northamptionshire NN6 0BT, United Kingdom.
Telephone: +44 (0)1604 495151
Email: customer.service@collingwoodgroup.com
Thank you for
taking the time to understand our Privacy Policy!