Welcome to Wisebreeze, a mobile application that, with the use of the accompanying AC controller, allows users to control their AC from the convenience of their mobile device. We, at Twitoplast Ltd. (an Israeli active company) (“Wisebreeze”, “we”, “us”, “our”) respect your privacy.
We are committed to safeguarding your privacy by achieving the highest standards of privacy and security, as well as being transparent about how we use and process your data.
It is your decision to provide us with your personal information. You are not legally obligated to provide us with this information, but in order to provide you with the Wisebreeze System’s functionality, we shall need access to the specific and rather limited information detailed below.
This policy is combined into our User Agreement [https://wisebreeze.com/wp-content/uploads/2021/06/User- Agreement.pdf] (the “Terms”) and form an integral part of it.
Identity and Contact Information of the Data Controller and its Representative
The Data Controller is –
Twitoplast Ltd. (an Israeli active company No. 511213571), 5 HaHaroshet St. I.Z. Sgulla, Petach Tikva, 4900710, Israel.
EU: EU-REP.Global GmbH, Attn: Twitoplast, Hopfenstr. 1d, 24114 Kiel, Germany
UK: DP Data Protection Services UK Ltd., Attn: Twitoplast, 16 Great Queen Street, Covent Garden,
London, WC2B 5AH, United Kingdom email@example.com
We also have assigned a Data Protection Officer (DPO). Our DPO is Twitoplast LTD. CTO: David Twito
INFORMATION WE COLLECT
Registration. Only registered users may use the App. In order to register to our App, you shall need to provide us with your full name and email address.
Wisebreeze Device Information. Upon using the App together with the accompanying AC controlling device (the “Controller”), we shall collect measurements of your room’s set temperature (“Measurements”) when you choose to set or change them from your mobile device via the App to our cloud server.
Inquiries. If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your name, mobile phone number, e-mail address and other contact information, depending on the nature of your inquiry. We need your name to be able to associate your request with the answer and to address you personally. The phone number or e-mail address is needed for communicating our answer to you.
Analytic Information. When you access or use the App as a registered user, we may use third party analytic tools to automatically collect unidentified information about your use of the App. This information includes your session durations, the content you accessed on the App, your interactions and user-interface clicks, and the frequency and scope of your use of the App.
We specifically use Google Firebase to analyze the use of our System and App. Google Firebase gathers information about the use of the System and App by means of sending events to Google Analytics server. The information gathered relating to our System and App is used to create reports about the use of our System and
Device information. We may collect information about your mobile device, including its model, its operating system, unique device identifiers, browser you use its version and language (i.e., locale) preferences, mobile network information and the Internet Protocol (IP) address through which you accessed the App. This information will be used for statistical, service improvement purpose only.
Cookies. A cookie is a small piece of information that is placed on your device when you visit certain websites.
The data collected in this way will be pseudonymized by technical measures. It is therefore no longer possible to link the data with a specific user. The data will not store together with other personal data of the users.
Most of the cookies we if and when we will use, will be the so-called “session cookies”. They will be automatically deleted at the end of your visit. Other cookies, so called “persistent cookies”, will remain stored on your device until you delete them. These cookies will enable us to recognize your browser the next time you visit our App.
We do not knowingly or intentionally collect information about children who are under 13 years of age.
IF YOU ARE UNDER THE AGE OF 13 YOU MAY NOT USE THE APP IN ANY WAY.
At any point while we are in possession of or processing your personal data, you have the following rights:
If you wish to exercise any of your abovementioned rights, please contact us at: firstname.lastname@example.org.
USING COLLECTED INFORMATION
Your consent serves as the legal basis for processing your information. You may withdraw your consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.
We may use the information we collect from you for the following purposes:
SHARING INFORMATION COLLECTED
We may share the information collected from you, as outlined in this Policy, with others, in any of the following instances:
We may share your data in any case of dispute, or legal proceeding of any kind between you and us, or between you and other users, with respect to the App or your use thereof. In any case other than the above, your information will only be shared with others if you provide your explicit prior consent, and we shall not share your personal data with third parties for marketing purposes without your prior explicit consent.
RETAINING AND DELETING COLLECTED INFORMATION
We may delete your information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.
Please note that merely uninstalling the App won’t delete your account and its details, including all the information maintained on it and information sent to third party apps, which may still remain with us and with other third-party apps. If you wish to actively delete your information stored on our servers, please contact us at: email@example.com. In order to process your request, we may require additional information or corroborative documents from you, to verify your account and confirm your identity.
Once we complete processing your request for deletion, we will delete your information from our systems. However, be advised that following such deletion, some information, though not accessible in the ordinary course of business, may still be retrievable from back-up copies or may still residually reside in our systems. You should also bear in mind that aggregated and analyzed information will not be deleted as it is merged with other information.
TRANSFER OF DATA OUTSIDE YOUR TERRITORY
We may store and process information in the EU and in other countries throughout the world, such as the United States. We may also process information using cloud services. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services, solely to the extent that such countries are observing applicable privacy regulations and ensuring that your privacy rights remain protected.
If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then by using the App you are hereby providing us with your express consent to such cross-border transfer.
ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION AND OBTAINING A COPY OF IT
You may ask to access the personal information about you that is stored in our systems, or have us update, correct or delete such information. You may also be entitled to obtain from us the personal data you provided us (excluding data we obtained from other sources) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact us at: firstname.lastname@example.org.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. We follow industry best practices when transferring and storing your data. We will use all reasonable efforts to prevent any misuse, loss or alternation of your data. However, we cannot ensure or guarantee that the App will be totally immune from information security risks and that any transmission of personal information is at your own risk.
You must also make sure that your information is safe and secure. We are not responsible if you circumvent any privacy settings or security measures on our App. Even if we provide you with (or you have chosen) a password
for access to certain parts of our App, you are responsible for keeping this password confidential. Do not share your password with anyone.
The following disclosure is made pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our App, other parties, such as Google, may collect personally identifiable information about your activities over time and across different websites or online services.
Effective date of the policy: 20/07/2021