Feilo Sylvania Privacy Policy – SylSmart Standalone
Effective Date: 19/05/2022.
Feilo Sylvania International Group Kft. and subsidiaries (“we”, “us”, “our”, “FSIG”) 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 our application “SylSmart Standalone Application” or of any other Sylvania SylSmart product and solutions sold worldwide by FSIG and its affiliates.
Feilo Sylvania International Group Kft is a Feilo Sylvania company, based in Hungary (Duna Tower, Népfürdő utca 22, H.1138 Budapest, Hungary, registration number 01 09 304993).
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 questions regarding this Policy, please do not hesitate to contact us via compliancemanager@sylvania-lighting.com.
We inform you that the Products are powered by Casambi software services The SylSmart Standalone Mobile application is powered by Casambi Technologies Oy (Bertel Jungin Aukio 1 E, 02600 Espoo, Finland, email: info@casambi.com, web: casambi.com). When you register with your Personal Data, you also accept the Casambi Privacy Policy available at https://casambi.com/privacy-policy/. For any data processing serving the analytic or marketing purposes of Casambi, the mentioned Casambi Privacy Policy will apply, in which activities Casambi shall qualify as data controller.
Definition
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.
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.
Apps refers to those mobile applications sold by FSIG and its affiliates that provide end users remote control to Smart Devices and with the ability to connect to the supplier IoT or Android Platform. For SylSmart Standalone, the application is powered by Casambi Technologies Oy.
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.
- 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, username, photos if the User opts to upload such, and login credentials. For certain customers we collect business representative such as organizational title, phone number, email address. 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.
1.2 Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content and ratings to address your problems and solve device failures on a timely basis, or to self-evaluate our performance.
- Information We Collect Automatically
2.1 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.
2.2 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.
2.3 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.
2.3.1 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 SylSmart Standalone Application
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 or Apple Map services. Please note that Google and Apple have corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices, while Apple’s terms are available at https://www.apple.com/legal/privacy/data/en/apple-maps/. 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.
- Smart Devices Related Information:
3.1 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.
3.2 Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our SylSmart Standalone Application, we may collect different information reported by your Smart Devices. For example, product code, product ID, status, access type, local key, software version, protocol version.
4. Any Other Analytic Information Collected by the Application (Casambi) according to the Casambi Privacy Policy https://casambi.com/privacy-policy/.
Purposes and Legal Basis for Processing Personal Data
The purpose for which we may process information about you are as follows:
1. 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.,
2. 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. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
3. 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 FSIG we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:
1. 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.
2. 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.
3. 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.
4. To subsidiaries or affiliates within our corporate family, to carry out regular business activities.
5. Where services are provided on a Microsoft platform (Azure Map), Microsoft Corporation shall be deemed as our data processor. In this case the policies and the connected general terms of the Microsoft Online Services will also be applicable.
International Transfer of Information Collected
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. If your data is transferred outside the European Economic Area, adequate protections are put in place to ensure the protection of your Personal Data.
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 via emailing us at compliancemanager@sylvania-lighting.com, or via the route of Feedback embedded in the App: More > App Settings > Send feedback.
You do not have to pay a fee and we will 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:
1. Request access to the Personal Data that we process about you.
2. Request that we correct inaccurate or incomplete Personal Data about you.
3. Request deletion of Personal Data about you.
4. Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you.
5. 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
6. 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:
- 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.
- Unbind the Smart Device through the app, and the information related to the Smart Device will not be collected.
- Me>Settings>Account>Account and Security>Delete Account .
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.
Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. We provide various security strategies to effectively ensure data security of user and device. As for device access 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 compliancemanager@sylvania-lighting.com
Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.
We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
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 eighteen (18), 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 eighteen (18) 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 eighteen (18) without permission from that child’s parent or legal guardian, we will take steps to remove that information.
Cookie Policy
The Feilo Sylvania Group uses Cookies. To learn more and for a detailed cookie notice, we refer to our Cookie Policy.
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.
To the extent the local applicable data privacy and other laws allow, this Policy shall be governed by Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons about the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) and particularly the laws of Hungary. We undertake to follow the prescriptions of all applicable laws in case the latter laws prevail over the GDPR.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us as follows:
Feilo Sylvania International Group Kft.
Postal Mailing Address: Duna Tower, Népfürdő u 22., 1138 Budapest, Hungary
Email: compliancemanager@sylvania-lighting.com