Airam SmartHome App Privacy Policy
Effective
date: 14.11.2022
This
Privacy Policy describes how your personal data is processed when you use the Airam SmartHome Application (“the
App”). The App can be used for managing Airam SmartHome devices. Together the App and the connected Airam SmartHome devices form the Airam SmartHome service.
Before
you start using the App, please read this policy carefully. It describes how we
use, store, share and transfer your personal data. In this policy you will also
find information on the purposes for processing your personal data and how you
can exercise your data protection rights.
Definitions
Personal
data means information, in any format, that can be
directly or indirectly attributed to you or to any other individual.
Smart
devices are devices such as the Airam
SmartHome devices that have a human-machine interface
and the ability to connect wirelessly to a network and to collect and transmit
data.
What personal data is collected, for what purpose and what is the
legal basis of data processing?
The
following types of personal data are collected and processed for the purpose of
providing you the service you requested. More specific purposes for data
processing are explained below. The legal basis for processing your data is the
contract that is formed between you and Airam when you register an account on
the App and accept user terms (GDPR Article 6(1)(b)).
Application
·
Account data:
When you first download the App, you are asked to create an account before you
can start using the App. For this purpose, you are asked to provide a valid
email address. We’ll send a verification code to this email address so you can create
a password and activate your account. Your email address functions as your username,
but you can also set a nickname for the account. You can also set a profile
picture to your account. In addition, the following data is collected from your
mobile device to set up your account: geographical region, time zone.
·
Feedback data: When
using the feedback and suggestion feature of the App, we will collect your contact
details (email address or mobile phone number, based on your choice) and your
feedback content to address your problems and solve the device failures you
report.
·
Mobile device
data: The following data is automatically collected of
your mobile device and used to maintain normal operation of the App, to improve
and optimize the service, and to protect your account security: mobile device
model number, IP address, wireless connection information, the type and version
of the operating system, application version number, push notification
identifier, mobile network information and software version number.
·
Usage data:
When you use the application, usage data is automatically collected of the
functionalities you use. This data is used to provide you the service and to
improve the service.
·
Log data:
When you use the App, the system and exception log may be uploaded for
troubleshooting purposes. The log includes your IP address, language preference
setting, operating system version and date or time of access.
As
far as possible, we will attempt to process device data and log data in
aggregated or pseudonymized form.
Smart
devices
·
Basic data
of smart devices: When you connect your Smart Devices to the App, we
collect basic information about your Smart Devices such as device name, device
ID/MAC address, online status, activation time, firmware version, upgrade
information and Wi-Fi information.
·
Sensor
data: Data detected, recorded and
transmitted by sensors of the smart devices connected to the App, for example
movement, vibrations, time of day, humidity, smoke, other external influence, intrusion
into residential space.
·
Video
footage: if you
have connected a video camera to the application, the collected data can
include real-time video footage from the camera. You are responsible for
ensuring that you are using the video camera and video footage in compliance
with privacy laws. Please ensure that you do not place cameras in places that
infringe other people’s right to privacy and make sure you have informed others
of the existence of recording camera surveillance regardless of where you place
the camera.
You
can remove any smart device from the App at any time to stop the collection and
processing of data from that smart device. This will not affect the processing
of data collected from the removed smart device prior to the removal.
Additional functions in the App:
There
are additional functions in the App that require your permission. If you choose
to use an additional function, you consent to the collection and processing of personal
data for providing you that function.
You
can revoke your permission anytime to stop the collection and processing of
data for the provision of that function. This will not affect the processing of
data collected before you revoked permission.
If
additional functions are disabled, you can continue using the basic functionalities
of the App and connected smart devices, but certain features based on these
additional functions may not be available.
·
Location data:
Location-based functions include pairing smart devices with the App and the use
of the automation scenarios for controlling your smart devices. You can enable/disable
the collection and use of your location information by changing your application
settings.
·
Camera data:
By turning on the camera permission, you can use the camera to scan QR codes to
pair with a Smart Device, take video, etc. We will only obtain information when
you actively use the camera for scanning codes, video recording, etc. You can enable/disable
the using of camera data by changing your application settings.
·
Pictures and videos:
By turning on the photo album permission you can use the photos/pictures/videos
stored on your mobile device for example for changing your profile picture or reporting
usage problems. When you report a device usage problem, we use the photos you
upload to locate and solve your problem. You can enable/disable the photo album
permission by changing your application settings.
·
Voice: To
enable voice control of smart devices, you need to enable the App to collect
data via the microphone. When you have enabled the microphone permission, we
will only obtain voice data through the microphone when you voluntarily
activate the microphone in the App. You can enable/disable the using of
microphone by changing your application settings.
·
Notifications:
Enabling app notifications allows you to receive notifications relating to the
service such as changes to terms and conditions and privacy policy. You can enable/disable
notifications in the App message center.
·
Alerts from smart devices:
Enabling app notifications and alerts allows you to receive alerts from your
smart devices. You can be enable/disable smart device alerts in the App message
center.
·
Bluetooth:
The following functionalities require the use of Bluetooth: display device
status on the home page and smart device panel; perform device control on the
home page and smart device panel; discovering smart devices on the home page
and the add device page, smart device distribution network. You can enable/disable
Bluetooth by changing your application settings.
·
Video footage:
If you have connected a camera to the App, you can require the App to display
the real-time image of the camera in a separate window. This can be
enabled/disabled in the application settings.
·
Additional services based on
storage permission (Android): The purpose of the service is to
ensure the stable operation of the App by utilizing the storage permission.
After you give permission to read/write your mobile device’s storage, we will
access pictures, files, crash log information and other necessary information
from your mobile device’s storage to provide you with functions, such as
information publications, or record the crash log information locally.
You
may enable/disable the using of storage permission by changing your application
settings.
Data analysis and personalized advertising
Based
on your consent, we will collect and analyze data of your use of the App and
the smart devices connected to the App for the purposes of providing more user-friendly
services and products in future.
Based
on your consent, we can use the analyzed usage data to send you personalized recommendations
on our products and services.
You
can enable/disable the collection and analysis of your usage data for development
purposes and for personalized marketing by changing your application settings.
Who do we Share Personal Data with?
We
may share your personal data with third-party service providers who provide
functionalities and services to the Airam SmartHome services. These third-party service providers
include Hangzhou Tuya Technology Co. Ltd who operates the IoT service platform
and have developed the App.
Transfers of data outside the EU/EEA
Airam
uses the following external service providers for developing and operating the
App and the connected IoT platform: Tuya Information Technology Co. Ltd. In
this context international data transfers may occur to China.
The
transfer is made under the Standard Contractual Clauses (SCC) approved by
European Commission.
What are your rights as a data subject?
We
respect your rights and control over your personal data. You have the right to:
-
access your personal data
-
have inaccurate personal data rectified
-
in certain circumstances you have
the right to obtain restriction of processing or object to the processing your
data
You
can choose to delete your account at any time in the application settings. This
will lead to the erasure of your personal data.
If
you wish to exercise your rights, please contact us by email at info@airam.fi.
Please use the same email address you gave when registering for an account, if
possible. Please specify your request as clearly as possible. We will answer
your query within 30 days. Exercising your rights is free.
Security measures
We
use commercially reasonable physical, administrative, and technical safeguards
to preserve the integrity and security of your personal data. Airam provides
various security strategies to effectively ensure data security of user and
device. As for device access, Airam 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.
Data retention
We
process your personal data only for as long as it is needed to provide you the
service or its different functionalities. When the data is no longer needed for
this, it will be permanently erased.
You
can choose to delete your account at any time in the application settings. This
will lead to the erasure of your personal data.
Inactive
accounts will be deleted after one year from the latest log in. This will lead
to the erasure of your personal data.
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 using the e-mail
address specified in your account or the notification function of the App prior
to the change becoming effective. We encourage you to periodically review this
page for the latest information on our privacy practices.
Contact us
If
you have any questions about our practices or this privacy policy, please
contact us:
AIRAM
ELECTRIC OY AB (business id 0733549-5), Sementtitehtaankatu
6, 04260 Kerava, Finland
phone:
+358 207 545 600
email:
info@airam.fi