This Products and Services Privacy Policy ("Policy") describes the information that Lifetronic s.r.l. ("Lifetronic", "we", "our", or "us") collect, use, share, and store about you through the Sweet Home software and services (the "Services"). In doing so, we are committed to protecting and respecting your privacy and personal data, in accordance with applicable data protection and privacy rules. In the interest of clarity, we confirm that we do NOT sell or rent or your personal data to any third party. Data is collected and utilized by Lifetronic solely for the provision of the Services.
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Customers has engaged.
Customers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as "data subjects") with whom our Customers interact. If you are an individual who interacts with a Customer using our Services, then you will be directed to contact our Customer for assistance with any requests or questions relating to your personal information.
This privacy policy was last updated on 20 November, 2018. We may change it from time to time, so please check back regularly to keep informed of any updates.
By using the Services, you are accepting and consenting to the practices described in this policy, now and as amended by us.
Data controller is Lifetronic s.r.l. – VAT number 01886150505 – with headquarter in PISA, Via Meucci, 1/E, Tel. +39.050.877757. For any question about Privacy issues, please do not hesitate to contact us at the following address: privacy@lifetronic.it
We collect the following categories of information:
• Information you give us.
Account and Registration Information:
We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an "Account").
We refer to any information described above as "Account Information" for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
Other Submissions:
We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, requesting customer support, or otherwise communicating with us.
• Information That We Collect From You on our Websites:
We provide additional details about how we collect and use information from our public web sites in our Website Privacy Policy.
• Geo-location data:
We may collect information such as zip code, area code, referrer URL, approximate location, and the time zone where our products and services are installed to provide our services and to assist you in case of troubleshooting.
• Technical information from your network and devices:
We may collect technical and diagnostic information about the devices in your network. For instance, we may collect the MAC address, maker name and model of your devices, up and down status, operating system version, unique device identifiers and the related software. We may also collect real time operating status of your network and its connected devices (i.e. network speed, IP addresses, device event information such as disconnections, system activity, hardware settings, the date and time of your requests) and the related diagnostics information. We may process information from your devices so that we can send you alerts when something happens. We may also use this data as described below; for example, we may use the data in aggregated format for statistical and research purposes to show you how your network performance compares with other users in your area.
• Environmental data:
We may collect data from sensors or devices which may be present in your network, such as data on whether something in the room is moving, temperature data, and the occurrence of smoke or CO alarms in order to deliver such information to you or to security services during the use of our products and services.
• Information we may receive from other sources.
We may receive information about you if you use the Services. We work with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
We may use the information we collect to provide, develop and improve our products and services, such as for:
• Providing you with products, services, or information you request, for example when you contact us for remote support and troubleshooting;
• Making assessments and recommendations about products, services and safety;
• Providing you with information our products and services or the required notices;
• Customizing your experience when using our products and services;
• Improving the products and services that we provide, such as by better tailoring our content to your needs and preferences;
• Internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• Delivering marketing communications about Lifetronic-related and Sweet Home-related services, products or promotions and to measure or understand the effectiveness of marketing. We may use service providers to send these messages on our behalf, but we do not share your email address with any other third parties without your permission;
• Detecting, preventing, and responding to fraud, intellectual property infringement, violations of law, or other misuse of the products and services.
We may also combine or aggregate in anonymized or non-personally identifiable format any of the information collected through the use of the Services or elsewhere for any of these purposes and for research, statistical and business purposes.
Legal Basis for Processing:
Our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) where the processing is in our or a third party's legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or we may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party's) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
The following are the situations where we may share your data:
• Lifetronic partners and third party developers:
We may share deidentified data for research, statistical, and business purposes. Additionally, to improve their software, hardware and services designed for use with our products and services, Lifetronic may provide any such partner or third-party developer with information that is relevant to that partner's or developer's software, hardware and/or services, as long as the diagnostic information is in a form that does not personally identify you.
• Trusted partners working for Lifetronic:
Lifetronic may occasionally use certain third-party service providers to help us provide, improve, protect, and promote our services and to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, providing marketing assistance, processing credit card payments, and providing customer service. These third parties may access your information only to perform tasks on our behalf and in compliance with this Privacy Policy.
• Business Transitions:
If we are involved in a merger, acquisition or sale of all or a portion of our assets, your information may be transferred as part of that deal. We will use reasonable efforts to try to ensure that the purchaser uses your personal information in a manner that is consistent with this Products and Services Privacy Policy.
• Law & Order:
We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Lifetronic or our users; (d) to enforce or apply our Terms of Use and other agreements; or (e) to protect the rights, property, or safety of Lifetronic or others. Your data may be collected, processed and stored by Lifetronic or its service providers where you or our servers reside. As a result, your data may be subject to legal requirements, including lawful requirements to disclose data to government authorities, in those jurisdictions.
The Services may allow you to interact with third party services. Any data that you choose to share with a third party is governed by that third party's privacy policy while in that party's possession. If you select a third party to share your information, we cannot control the collection, storage or sharing of information collected by that party. Always check the privacy policies for any company that collects your data and make sure you are requested to grant/deny permission to access your information.
When you choose to connect third-party products and services through Sweet Home software and services, you are shown details about proposed exchange(s) of data between Sweet Home software and services and the third party that is providing the products or service. In some cases, Sweet Home Services or the third party will instead (or also) ask for permission to control the products that you have connected. Sweet Home software and services may receive and process information from third parties, and some of this information may be associated or stored with your Sweet Home account.
Any data that Sweet Home software and services receives from third-party products and services will be processed and stored by us and will be treated in accordance with this privacy policy. This information may be processed in the same ways as any other data that is a part of your Sweet Home account.
Sweet Home users will have their information sent to Lifetronic Cloud servers that could be located in the United States or in European Union depending of Lifetronic Cloud Servers Policy.
To provide you with the Services when you are on the go, we may need to store, process and transmit information in locations around the world from where you are accessing our services- including those outside your country. Those countries may not provide the same level of protection for your data as your home-country and may be available to the governments or agencies under a lawful order of those countries. Where this is the case, we will use reasonable efforts to try to ensure that your data is protected in accordance with this privacy policy.
Remember that when you visit our Website, we collect data as described in our separate Website Privacy Policy.
Lifetronic generally stores your data on Lifetronic’s cloud servers for as long as you remain a Sweet Home customer in order to provide you with Sweet Home services and products and for legal compliance purposes. You can view and edit your information on the Sweet Home website. You can delete your personal data at any time by terminating your account or by writing to us at privacy@lifetronic.it. We may retain de-identified data indefinitely.
For personal information that we process on behalf of our Customers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.
We take security seriously and care about the integrity of your data. We use administrative, physical, and technical safeguards to protect the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer). However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.
As per the organizational duties introduced by the General Data Protection Regulation ("GDPR"), we commit to report personal data breaches to the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. If the breach is likely to result in a high risk of adversely affecting individuals' rights and freedoms, also those individuals will be informed without undue delay. If you have any questions about the security of your personal information, you can contact us at privacy@lifetronic.it
At Lifetronic we take our users' rights into the highest regard. For this purpose, we align ourselves to the most advanced privacy regulations available. When in it comes to your Personal Data, we recognize, and commit to respect and enforce, the following rights:
The right to be informed: upon request we will provide you with information about whether we hold or process any of your personal information. To request this information please contact us at privacy@lifetronic.it
The right of access: as a user of our Services, you may access your personal data, at any time, by logging into the Sweet Home Website and accessing your profile section.
The right to rectification: as a Customer of our Services, you may access and update or change your Account Information by editing them yourself from your profile area of the Sweet Home Website.
The right to erasure: If you no longer wish to make us of our Services, you can exercise this right by making a request, in accordance with Data Protection Laws, by emailing privacy@lifetronic.it
The right to restrict or object processing: You retain the right to request us to refrain from or restrict our processing of your data for the purposes of marketing. To exercise such right, you may click the "unsubscribe" link in any non-transactional email or marketing email from us or contact us via email at privacy@lifetronic.it.
The right to data portability: You retain at all times the right to exercise your right of having your Personal Data exported and transferred - in a safe way - to another provider of Services similar to ours. You may exercise this right by making a request, in accordance with Data Protection Laws, by emailing privacy@lifetronic.it.
Any request related to your rights above, will be handled within thirty (30) days from the moment we receive such request.
In case you deem your rights to have been violated, or if you are dissatisfied with the way your requests were handled, you can lodge a complaint with the IT data protection regulator.
The Services are not directed to, nor do we knowingly collect information from, children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.
We may revise this privacy policy from time to time and will post the most current version on our website. Please check back frequently to see any updates or changes to this privacy policy. If a revision materially changes your rights, we will notify you and provide you with the opportunity to consent to such changes before applying them to that information.
If you have any questions, please contact us at privacy@lifetronic.it or writing to:
LIFETRONIC s.r.l.
Via Meucci 1/E
56121 PISA
ITALY
Last Updated: 20 November 2018