Welcome to Wisebreeze, a mobile application that, with the use of the accompanying AC controller, allows user to control their AC from the convenience of their mobile device. We, at [Company legal name here]. (“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 data.
It is your decision to provide us with your personal information. You are not legally obligated to provide us with this information, but we need it in order to provide you with the Wisebreeze System’s functionality.
This policy is combined into our User Agreement (the “Terms”), and is a part of them.
- Information we collect. We collect information you provide us in the registration process. We also collect measurements of your room temperature data when you use the AC and it is turned on. These measurements will be sent through the App, to our cloud server every time you control the AC from your appApp.
- Using the information we collect. We use the information we collect to operate the system and provide its features and functionalities.
- Sharing the information we collect. We may share your information with third parties, mainly when you actively choose to share such information, by registering with your personal Wisebreeze user account to third party apps, and with our licensors, contractors and service providers, allowing you to make the most of the Wisebreeze system that help you seamlessly controlling your AC from your mobile device.
- Aggregated information. We may use the information we collect from you to create de-identified (anonymous), statistical or aggregated information, and make it available to others for any purpose.
- Retention. We retain your information for as long as we deem necessary for the purpose it was first obtained. If you withdraw your consent to us processing your data, we will erase your personal data from our systems.
- Security. We implement measures to reduce the risks of damage and unauthorized access or use of information, but these measures, just like any security measure, cannot provide absolute information security.
- Children privacy. We do not knowingly or intentionally collect information about children who are under 13 years of age.
- Changes to the Policy. We may change this Policy, in which case we will seek your consent to those changes if they are material at any time.
Identity and Contact Information of the Data Controller and its Representative
The Data Controller is
[Company legal name]
In any of the above cases, you can also contact our Representative in the EU at __________.
We also have assigned a Data Protection Officer (DPO). Our DPO is Company legal name's CTO/CEO……
INFORMATION WE COLLECT
Registration. Only registered users may use the App. You may register using your email address and your name.
Wisebreeze Device Information. By using the App together with the accompanying AC controlling device (the "Controller"), we collect measurements of room’s set temperature (“Measurements”) when you choose to set or change them from the 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 mobile phone number and other contact information, depending on the nature of your inquiry.
Analytic Information. When you access or use the App as a registered user, we may use third party analytic tools to automatically collect 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.
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.
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 of while we are in possession of or processing your personal data, you have the following rights:
- Right to access – Request information on your personal data processed by us as further detailed below.
- Right to data portability – Gain access to your information by requesting a backup of your data in order to transfer such data to other companies or organizations.
- Right to rectification – Correct your personal data in the App that is inaccurate or incomplete.
- Right to object – Object or withdraw your consent from data processing at any time.
- Right to be forgotten – Request the deletion of your data as further detailed below.
- Right to complain – Lodge a complaint with the relevant supervising data protection authority if you believe we are processing your personal data under violation of applicable data protection regulations.
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 consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.
We use the information we collect for the following purposes:
- Generating reports based on your Measurements, aimed at providing you with a better way to track your temperature patterns or settings;
- Operating the App and providing its features and functionalities;
- Sending you updates and other communications related to the App;
- Generating statistical and aggregated information about users of the App;
- Providing you with support, handling complaints and contacting you when we believe it is necessary.
- Enforcing the Terms and this Policy and preventing misuse of the App.
- Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified.
- Taking any action in any case of dispute involving you, with respect or in relation to the App.
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 use anonymized information for internal research purposes only;
- We may use the information we collect from you to create de-identified (anonymous), statistical or aggregated information, and make it available to others for research purposes;
- We may share your data with our licensors, contractors and service providers [www.zemingo.com/contact-us/], strictly for the purpose of helping us with the internal operation of the system and solely to the extent necessary. When they no longer need your data to fulfil the service or purpose, they will dispose it;
- If we believe that you may have breached the Terms, abused your rights to use the App, or violated any applicable law: Your information may be shared with law enforcement agencies and other competent authorities and with our counsels and any third party as may be required to handle any result of your wrongdoing, if we believe it is necessary or justified;
- We may share your data to the extent required by law, or if we believe that sharing information is necessary to prevent imminent physical damage to body or property.
- We may share your data if the operation of the App is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided however, that those entities agree to be bound by the provisions of this Policy, with respective changes taken into consideration;
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 will never share personal data with third parties for marketing purposes without your prior explicit consent.
RETAINING AND DELETING COLLECTED INFORMATION
We retain the information outlined above, for as long as you are using the App. 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 in it and information sent to Third Party Apps, which may still remain with us and with other Third Party Apps. If you wish to delete all information about you that is 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 you provide 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 immune from information security risks.
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.
You may contact us with any questions or comments, at: [email@example.com]
Effective date of the policy: ___________ 2018