Mobile App Privacy Notice

Last update: November 2020

At Hager, we respect your privacy and we want to be transparent about the types of personal information we collect about you and how we use it. This Mobile App Privacy Notice (hereafter the " Notice"), explains how we collect, use and share the information gathered about you through your use of the App and aims to inform you about the rights and freedoms that you can exercise with regard to our use of your personal information. This Notice also describes the measures we implement to protect your data.

By downloading and using the App, you acknowledge that you have read and understood the Notice.

This App that you are using is managed by the Hager affiliate (hereafter "Hager"), who is the data controller for all personal information that is collected via this App. For more information about this App, please see the “About Us” or "Terms and Conditions" section of our App.

If you do not want Hager to process any of your personal information through this App, as set out in this Notice, you should not install and use the App. Please note that some services can only be provided via the App and therefore, the subscription to the services implies the use of the App.

1. Quick links

We recommend that you read this Notice in full to ensure you are fully informed.  However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.

2. Definitions
3. What personal data we collect and why
4. For what purposes we use your personal information
5. Who we share your personal information with
6. On what legal basis we process your personal information
7. Transfers of personal information outside the EU/EEA
8. How long we store your personal information
9. Profiling
10. How we protect your personal information
11. Minors
12. How to opt-out of direct marketing
13. Your rights and choices
14. External links
15. Updates to this Notice
16. How to contact us

2.Definitions

The Smart Home Service, hereinafter also referred to as the service, is the server-based service to your Smart Home device.

The Smart Home device is the controller to be activated which performs the networking of the peripheral devices connected to it and which communicates with your mobile device.

The Smart Home system is the system composed of the Smart Home device, the peripheral devices connected to it and the App for the Smart Home device to manage and/or control building installations and/or not stationary products.

Hager is the Hager affiliate who managed the App that you are using and is the data controller for all personal information that is collected by this App. For more information about this App, please see the “About Us” or "Terms and Conditions" section of our App.

Mobile device is Smartphone, PC or PC tablet.

The Reference user is the member of the family responsible for the use of the Smart Home system and its services.

The terms and conditions of service are the terms and conditions of service specified in Sections A and B.

The software products are the computer programs on which this service is based.

The system is the Smart Home system set up at the home of the reference user.

App is  the Hager solution you are using with your Mobile device and which is available in your country

General information on how data transmission functions in the Smart Home system:

If the peripheral devices connected to the Smart Home device communicates information to the Smart home device (temperature, blinds open/closed, someone is on the door, portraits, etc.), these information are stored in an encrypted form at your home in the Smart Home device. If you log into the system via the App for your Smart Home device inside or outside your home, the App creates a direct https://secured link to your device (bank level encryption: https. SSL 2048 bits).

Https (hypertext transfer protocol secure) is a hypertext transfer protocol. It is possible to make data inaudible and unreadable in the transfer process. This is achieved through encryption and authentication. Authentication serves to verify the identity of the connecting partner when establishing the communication.

This means that you alone see the information on your home. When logging in outside your home, the Hager server connects you with your Smart home device. Your Smart home device and your mobile device can communicate with each other and your Smart home device can receive commands. At no time will information on your home be collected by us or stored on the Hager server.

3.What personal data we collect and why

We collect various types of personal information via your use of this App and this information will be processed in accordance with the purposes described below.

• Information that you provide voluntarily

In order to use the App and to benefit from our services, you must provide us with certain personal information, including:

• Identification information : such as first and last name, date of birth, address, phone number, e-mail address, gender;
• Professional life information : business contact details and business affiliation.
• Private life information : details about the products/services you are using or interested in, different personal choices in your settings (i.e. Security alarm scheduling), daily operations made via our app (i.e. temperature settings);

• If you choose to register via social media (Facebook, Google +), we will obtain and process, for the needs of the App, only your surname, first name and email address.

We do not collect and store any credit card details via our App. If you wish to make an online purchase via this App, you will be redirected to our website and the online transaction will take place entirely on the website. Please read our Web Privacy Notice for further details about the collection of your personal information on our website.

• Information that we collect automatically

We collect and process to a limited extent and in anonymous and aggregate form, personal data concerning users of the App. The data collected includes your IP address or your device identifier (e.g. IMEI number), operating system version, the dates on which you access and use the App, user behavior (such as your interactions with the App), etc.

Collecting this information enables us to better understand the visitors who use our App, where they come from, and what content on our App is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our App.

Some of this information may be collected using tracking technology, as explained further under the heading “Use of tracking technologies” below. We may also use the location data on your device as explained in the section "Location-based data" below".

For our applications we collect the following information in addition to the below mentioned data (if applicable):

• application version (client & server)
• Application settings (like language)
• Local or remote access
• Number of users
• Events (here)
• device events (like switch on/off the lights) if applicable
• User properties (here)
• Orientation (portrait / landscape)
• Use of tracking technologies

With your consent, we may use different types of tracking technology across our Apps (collectively, “Tracking technology”) to collect and use personal information about you including to serve interest-based advertising and location-based services. Please find further information on these technologies in Section 9 of this Notice.

• Location-based data

If you authorise us to access the location data on your device, we will use this information to send you location-based information and to deliver services at your request.

Also, if you no longer wish to receive push notifications for location-based services you can disable this service by changing your phone settings, or by altering the settings in the App by unchecking the relevant box in the “My Account” section of the App.

On Android devices, simply: go to Settings → General → App Manager then find the App → uncheck the “Show notifications” option (More details on Google Website : https://support.google.com/android/answer/9079661?hl=en)

On Apple devices, simply go to: Settings -> Notifications -> Hager -> uncheck “Allow Notifications” (More details on Apple website : https://support.apple.com/fr-fr/guide/)

4.For what purposes we use your personal information

We use your personal information :

 With your prior consent :

• to send you information or promotions on our products and proposed services;
• to understand your preferences and improve your experience and customer satisfaction when you use the App and our services;
• to carry out statistical analyses on use of the App and visit frequency;

• to serve interest-based, location based advertising.

To perform our contract with you :

• to create your account in the App. If you choose to register via social media (Facebook, Google +, etc.), we  will collect and process, for the needs of the App, only your surname, first name and email address;
• to provide installation services for our devices and to provide a usage interface;
• to administer and monitor the stability and performance of the App in order to improve it;
• to ensure that content from the App is presented in the most effective manner for you and your devices;
• to allow access to the installer to the system on the command of the reference user;
• to serve you location-based services;
• to notify you when updates for the App are available and of changes to any products or services we offer or provide through it;
• to communicate efficiently with you and to answer any questions or queries you may have;

For the purposes of our legitimate interests 

• as part of our effort to keep our App safe and secure;
• for administrative purposes

• to correspond in the case of a complaint;
• to correspond in the case of a complaint;
• to communicate efficiently with you and to answer any questions or queries you may have;
• to administer and monitor the stability and performance of the App in order to improve it;
• to ensure that content from the App is presented in the most effective manner for you and your devices;
• to allow access to the installer to the system on the command of the reference user;
• as part of our effort to keep our App safe and secure;
• to send you information or promotions on our products and proposed services;
• to notify you when updates for the App are available and of changes to any products or services we offer or provide through it;
• to understand your preferences and improve your experience and customer satisfaction when you use the App and our services;
• to carry out statistical analyses on use of the App and visit frequency;
• for administrative purposes.

The Hager solution is provided to you through different ways:

• There is a do-it-yourself process in order to use the solution in which you create your personal account and install your devices by yourself.
• There is an installation process with collaboration of a professional who will set up your account and your devices with your authorization.

For a detailed description please refer to the specific description in the terms of use of the solution you have subscribed to.

We will use the personal information we collect from you only for the purposes described in this Notice.

5.Who we share your personal information with

We may disclose your personal information to the following categories of recipients:

• to Hager affiliates, third party service providers and partners who provide data processing services to us. It may be product delivery services, database hosting services, marketing solutions providers (advertising, IT safety companies, call centers, payment (non exhaustive list)  to support the delivery of, provide functionality on, or help to enhance the security of our App);
• For our application solution, we share your data with Google Firebase, a Google subsidiary that is based in San Francisco (CA), USA. You can find further information on third country data transfers in section 9 of this Notice;

• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe such disclosure is necessary (i) as a matter of complying with applicable laws or regulations, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Notice;

• to any other person with your consent to the disclosure.

6.On what legal basis we process your personal information

We will process the personal information collected via this App based on the necessity to manage our relationship with you, based on our legitimate interests which will depend on the personal information concerned and the specific context in which we collect it, or based on your consent.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact 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 legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are. You may question us for more details regarding the invoked legitimate interest.

7.Transfers of personal information outside the EU/EEA

We operate at a global level and, as a result, your personal information may be transferred to, and processed in, countries other than the country in which you are resident. In some cases, these countries may be located outside the European Union / European Economic Area (EU/EEA) and therefore may have data protection laws that are different to the laws of your country of residence.

Specifically, our servers are located in the EU/EEA but we may share or give access to your personal information to group entities, third party service providers and partners who may be operating from outside the EU/EEA (for example, we may use web hosting providers or cloud computing service providers who store or access your personal information outside the EU/EEA).

Where that is the case, we make sure that your personal information is transferred to third countries outside the EU/EEA that are deemed "adequate" by the European Commission (a list of adequate countries is available here [link]), or alternatively, where your personal information is not sent to a country that provides adequate protection, we will put in place appropriate safeguards to ensure that your personal information remains protected while it is being processed outside the EU/EEA in accordance with applicable privacy laws. These appropriate safeguards may include signing the European Commission’s Standard Contractual Clauses with the Hager affiliate, third party service provider or partner outside the EU/EEA with whom we share your personal information. For further information about transfers of personal information outside the EU/EEA, please refer to the "How to contact us" section below.

8.How long we store your personal information

We will retain your personal information for as long as necessary to enable us to fulfil our legal, pre-contractual and contractual obligations or our herein indicated legitimate interest. We also will retain your personal information unless you request us to erase them if the purpose of their use requires your consent.

Once the purpose for processing your personal information no longer exists, or the period of retention has expired, or if you ask us to delete your personal information, please be aware that we may continue to store your personal information for a limited period of time if necessary to comply with applicable legal, tax or accounting requirements.

When we no longer have a purpose to process your personal information, we will make sure your personal information is either deleted or anonymized.

9.Profiling

In some instances, we may use your personal information in order to better understand your preferences and to provide customized products or services to you. We do not make any decisions based solely on automated processing of such data, which either produce legal effects that concern you or similarly significantly affect you. 

Google Analytics for Firebase

(https://firebase.google.com/)

The collected data helps us to better understand how the app is used and to improve the service. All IP addresses are only stored in anonymous form. Therefore, the data collected cannot be used to personally identify users.

Further information about Google Firebase and data protection can be found here: https://www.google.com/policies/privacy/

10.How we protect your personal information

We are committed to ensuring the security of your personal information. We utilize robust precautions to protect the confidentiality and security of the personal information within our App, by employing technological, physical and administrative security safeguards, such as firewalls and carefully developed security procedures, for example, when you enter confidential information (such as login credentials or information submitted from within the App). We encrypt the transmission of that information using secure socket layer technology (SSL). These technologies, procedures and other measures are used in an effort to ensure that your personal information remains safe, secure, and only available to you and to those you authorized to access your personal information. However, no internet, e-mail or other electronic transmission is ever fully secure or error free, so you should take care in deciding what information you send to us in this way.

11.Minors

The services we provide on this App are not intended for individuals below the age of 16. If you are under 16, please do not download this App.

12.How to opt-out of direct marketing

We use the information you provide us (including your email address) for direct marketing purposes. Particularly, when you use the App, if you accept push notifications, we may send you promotional offers about our products and services via push notifications. If you no longer wish to receive push notifications about promotional offers from Hager, you can disable this service by changing your mobile device settings or by altering the settings in the App by unchecking the relevant box for the Hager Mobile app – i.e. “My profile > My settings ” section of the Hager mobile App.

On Android devices, simply go to: -> On Android devices, simply go to: Settings → General/Personal → App Manager → then find your Hager mobile app → uncheck the “Show notifications” option.

On Apple devices, simply go to: Settings -> Notifications -> your Hager mobile app -> uncheck “Allow Notifications”.

13.Your rights and choices

You have the following data protection rights:

• You may request access to and obtain a copy of your personal information.

• You may also request that any personal information that is inaccurate or incomplete be rectified or completed.

• You may request that your personal information be erased under certain legal conditions (for example, where the personal information is no longer needed to achieve the purposes for which the information was initially collected). 

• In addition, you may object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information under certain legal conditions.

• You have the right to opt-out of electronic marketing communications we send you at any time and free of charge.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.

• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact the data protection authority of your home or your usual workplace by clicking here. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.

You can also request to close your account at any time by contacting us as described below or by clicking on "Delete my profile" in the preferences of the App. You should be aware that once the App is uninstalled, you will not be able to use certain functionalities of the App.

You may exercise any of the rights above at any time by contacting us as described under the “How to contact us” section below. We will respond to your request in accordance with applicable data protection laws.

14.External links

If any part of this App provides links you to third party websites, such websites do not operate under this Notice. We recommend you examine the privacy notices posted on those websites to understand their procedures for collecting, using and disclosing personal data.

15.Updates to this Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last update” date displayed at the top of this Privacy Notice. 

16.How to contact us

If you have any questions, concerns or complaints about this Notice or the way we process your personal information, or if you want to exercise your rights as described above, please contact us by filling out this request form .