Version:
April 2021
Action
Service and Distribution B.V. (“Action”, “we”, “us”, “our”) is committed to
protect your privacy. This Privacy Policy describes how we process your
personal data when you use the LSC-Smart Connect mobile application (the “LSC
Smart Connect App”), by which LSC smart devices (the “Smart Device”) can be
controlled remotely. Please find below more information about why we process
personal data, how we do it and what rights you have relating to your personal
data.
In order
to become able to properly provide our services relating to the LSC Smart
Connect App (“Services”) to you, we will ask you to register an account. In
order to properly carry out the Services, it is necessary to process your
personal data. We find it important that the processing of personal data is
executed in a manner that is in accordance with the existing safeguards for the
protection of privacy. In this, we follow legislation regarding the protection
of personal data, such as the General Data Protection Regulation (GDPR).
Action
will be the controller of your data. Action is seated inZwaagdijk-Oost, the
Netherlands, and is registered at the Dutch Chamber of Commerce under number
50969838. In case of any questions relating to the processing of your personal
data, please contact us via the contact details below.
What
personal data does the LSC Smart Connect App process?
Personal
data are data that can identify you, such as your name, address, e-mail
address, IP address, telephone number and age. We process the following
personal data:
|
Category |
Personal
data |
|
App users – account
data and feedback or other messages |
·Contact details, such
as name, e-mail address and (sometimes) telephone number and/or profile
picture; ·Video material (in
case your Smart Device involves video); ·Any information you
may include in your feedback and/or other messages to us, that can be used to
identify you. |
|
SmartDeviceor
mobiledeviceinformation |
·We automatically
collect information about your Smart Device or relating to the mobile device
you are using the LSC Smart Connect App with, such as the MAC address of your
device, IP address, wireless connection information, operating system type
and version (incl. language settings) of the device, application version
number, push notification identifier, log files, and mobile network
information. And relating to the
Smart Device; the device name, device ID, online status, location, activation
time, firmware version, and upgrade information. |
How do we
obtain your personal data?
We receive
your personal data in various ways, but mainly because you provide us with your
data when registering an account with us via the LSC Smart Connect App and by
using the feedback and suggestion features in the LSC Smart Connect App or
otherwise contact us (for example via e-mail), or when you make use of the LSC
Smart Connect App to manage your Smart Device. We also collect certain personal
data automatically, to the extent this is necessary to properly provide our
Services, as indicated above.
On what
grounds and for what purposes does LSC process your personal data?
The
personal data that we collect are necessary for the provision of our Services
and improving these. Without this personal data, we cannot conclude and/or
execute the service agreement with you and/or process and answer your messages
properly. The purposes of our processing are described in more detail below.
We process
personal data in particular for the following purposes and only to the extent
necessary for those purposes:
·To became
able to enter into a Service Agreement with you and to provide you with the
Services as agreed upon in our Service Agreement;
·To create
and operate an account to use the LSC Smart Connect App for you;
·To send
you relevant information in relation with the Services and to otherwise
communicate with you, inter alia, when answering you questions;
·To send
you promotional messages relating to our products and/or services, for which we
will ask your permission in case we are obliged to do so by law;
·To
provide functionality, analyze performance, fix errors, monitor safety and
improve usability and effectiveness of our LSC Smart Connect App;
·To comply
with laws and regulations.
Children
data
Our
Services do not address anyone under the age of 18. We do not knowingly collect
personal data from children under 18. In the case we discover that a child
under 18 has provided us with personal information, we immediately delete this
from our servers. If you are a parent or guardian and you are aware that your
child has provided us with personal information, please contact us so that we
will be able to perform necessary actions (please find our contact details
below).
Access to
your personal data
Except if
otherwise indicated below, only the employees of Action and our service
provider who need access to your personal data to perform activities for the
aforementioned purposes have direct access to your personal data to perform
their work. Employees who have access to personal data are bound by
confidentiality. In this way (in combination with the security measures
mentioned below) we ensure that the personal data are only accessible to
persons who are authorized to do so by virtue of their position and that the
personal data is only used for the purposes for which the personal data were
obtained.
Exchange
of personal data with third parties and/or other countries
In
principle, Action and our service provider do not make your personal data
available to third parties. However, for the provision of the Services we make
use of the third party platform providerTuyaInc. Please be referred to the
privacy policy ofTuyafor more information on how your data is processed by this
platform provider (TuyaSmart Developer
Center).
Action
enters into a written agreement with our service provider, by which they are
obligated not to disclose or use the information for any other purpose and
bound to security and other requirements. We do not transfer your personal data
outside the European Economic Area.
In some
cases, we are required by law to provide personal data to (other) institutions
or authorities. We always look at how we can respect your privacy as much as
possible. The sharing of your personal data occurs where reasonably possible in
anonymous or otherwise pseudonymized form.
You may
choose to use the LSC Smart Connect App in combination with another account
provided by a third party, such as your account at Google or Amazon. In case
legally required, Action will also conclude agreements with such third parties,
as indicated above. However, you will use these applications or functionalities
at your own responsibility and for the use of these services your permission
will always be asked. Please be referred to the information regarding external
links below, which apply accordingly in that case.
Security
of personal data
Actions
handles your personal data with the utmost care and takes appropriate and
commercially acceptable means of organizational and technical security measures
to protect the personal data of the users of our LSC Smart Connect App against
unauthorized access or changes, disclosure or destruction of personal data.
Therefore, we comply with the applicable security standards. In addition, the
information that is exchanged, collected and analyzed via the LSC Smart Connect
App, is (two-way) encrypted.
Remember
that no method of transmission over the internet, or method of electronic
storage is 100% secure and reliable, and we cannot guarantee its absolute
security. If, despite the security measures we have taken, there is a security
incident that is very likely to have an adverse effect on your privacy, we will
inform you as soon as possible about the incident. We therefore inform you
about the measures we have taken to limit the consequences and to prevent any
recurrence in the future.
If you
unexpectedly encounter a security breach or you suspect that the security of
your personal data is not properly guaranteed, please contact Action
immediately. We have procedures in place to handle these reports adequately and
carefully in accordance with applicable legislation. Please find ourcontact
detailsbelow.
Retention
periods
The LSC
Smart Connect App only stores personal data as long as necessary for the
purpose for which it has been processed or for any longer period we are
required for by law. We do not process your personal data longer than during 7
days after the end of our Service Agreement or our last contact (depending on
the matter). Retention periods may be longer, for example in case of disputes.
External
links
The LSC
Smart Connect App may contain links to other websites, applications and/or
third party services. Some of these have been explicitly mentioned in this
Privacy Policy. We are not responsible for the practices of third-party
applications, websites or services that are linked to or from our LSC Smart
Connect Appor that you use in relation herewith. Our privacy policy does not
apply when you use a link to switch from our LSC Smart Connect App to another
application, website or use any third party account or service. Your conduct on
a third-party application, website or service, including those who have a link
on our LSC Smart Connect App, is subject to their own rules and policies. We
are not responsible for the processing activities, privacy policy or the
content or other practicing of these other websites and/or services,
notwithstanding that LSC may have entered into a written agreement with the
third party to safeguard user rights to the extent reasonably possible.
Your
rights with regard to the processing of personal data
You have
the following rights with regard to the processing of your personal data:
·You can
requestinformationabout and/oraccessto the personal data that we
process about you. This means that you can request which personal data has been
registered and for what purposes that personal data is used;
·You can
request us to have your personal datachanged/correctedand/or tolimitthe
processing of your personal data;
·You can
also ask us toremoveyour personal data from our systems;
·You can
also ask us to ensure that your personal data istransferredto another
party.
Requests
regarding the exercise of the aforementioned rights can be submitted via thecontact
detailsbelow. We will update you on the status of your request within one
(1) month after receiving your request. We will comply with your request,
unless we have a compelling and legitimate interest not to delete data that
outweighs your privacy interest or when fulfilling your request is otherwise
not required by law and/or in case we could then no longer perform our Service
Agreement with you. If we have deleted the data, for technical reasons we
cannot immediately remove all copies of the data from our systems and backup
systems. We may refuse to comply with the aforementioned requests if they are
made unreasonably often, require unreasonable technical efforts, or have
unreasonable technical consequences for our systems or endanger the privacy of
others. If we have complied with a request to improve, supplement or delete
personal data, we will also inform third parties to whom this personal data has
been provided of the changes made. Please note that we may ask you to verify
your identity before taking further action on your request, for security
purposes.
If you are
not satisfied with the way in which we have dealt with your request or
objection or otherwise with the processing of your personal data, you can also
submit a complaint about the use of your personal data to the competent Data
Protection Authority in your country.
Contact
details
If you
want to exercise your abovementioned rights, or you have any questions that are
not answered by this privacy policy, or you have suggestions or comments about
the content hereof, or have any complaints about the way we deal with your
personal data, you can contact us in writing by using the following contact
details:
E-mail:
klantenservice@action.nl
Privacy
Policy changes
Action may
adjust or update this privacy policy from time to time. Adjustments to this
privacy policy take effect the moment these have been published. We therefore
recommend you to regularly consult this privacy policy, so that you are aware
of any changes to this privacy policy. If these adjustments are of significant
importance to you, we will always inform you about this.