Privacy Policy Calex Smart Mobile APP
Last updated Nov 15, 2023, Rotterdam, The Netherlands
This privacy notice for Electro-Cirkel RETAIL B.V. (doing business as Calex) ('Calex', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information
when you use our services ('Services'), such as when you:
• Download and use our mobile application (Calex Smart), or any other application of ours that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.
Your privacy is important to us. It is Electro-Cirkel RETAIL B.V.'s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Calex Smart, and its associated services.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service.
In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at help@calex.eu.
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Calex and the Services, the choices you make, and the products and features you use.
• We may collect personal information from you when you do any of the following on our website: Register for an account using our online support solution
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or on any similar technologies
• When you mention us on social media
Children’s Privacy
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information about children under 13. In case your child has registered for the app and you want to terminate the account, you should submit a ticket using our support system support.calex.eu and request the termination of the account, always provide an username or e-mail.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties.
How do we keep your information safe?
We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights?
The easiest way to exercise your rights is by filling out our data subject request form available here: http://www.calex.eu/calexmobile/forms/datarequest/, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what Calex does with any information we collect?
IP-Camera Cloud and Subscription Services:
Payment and transaction information. Information such as the model of camera purchased, subscription plans purchased, date and time of your transaction, and payment information, such as your credit card or bank account details.
Images stored and processed. When you capture images and videos using a Calex IP-camera or other type of camera (e.g. pet feeder equipped with a camera), we may temporary collect personal information which is depicted within the imagery you submit to for e.g. to analyse motion detection.
Payment and transaction information. We use this information to facilitate transactions, detect and prevent fraud and keep a record of your purchases so we can provide you Customer Support and warranty services, and for financial purposes as required by law. We do not process your credit card information directly, but rather this information is processed by one or more 3rd-party payment processors such as PayPal and or Stripe.You can find more information about the terms and conditions on the respective pages of these providers.
Snapshots, Video Clips, and Other video and audio signals and data.
When you use the recording or streaming features of your Calex Cameras, we will record and process video and/or audio recordings received from your device, subject to your configuration and settings. If you have enabled motion sensing or sound detection, we will record and process video and/or audio recordings upon sensing motion or detecting sound and may send notifications to you regarding the sensed motion or sound. In addition, if you have the recording feature enabled, we will capture, process and retain video, photo, and audio data recordings received from your device depending on your subscription plan( for example 7, 15, or 30 days) and you will be able to access, download, and delete those recordings using Calex Smart App during that time. After the subscription period, you will not be able to access the recordings beyond the time frame allotted for your subscription.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO WE MAKE UPDATES TO THIS NOTICE?
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:We collect personal information that you provide to us.We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
• Names
• Email addresses
• Phone numbers
• Usernames
• Contact or authentication data
• Contact preferences
Sensitive Information.
We do not process sensitive information.
Payment Data.
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number, bank-account), and the security code associated with your payment instrument. All payment data is stored by Apple Pay, Google Pay and Stripe. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/data/en/apple-pay/, https://support.google.com/pay/answer/7020860?hl=en and https://stripe.com/en-gb-nl/privacy.
Performance of a Contract or Transaction:
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, we need technical information about your device in order to provide the essential features of our app.
Application Data:
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
• Geolocation Information: We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, camera, microphone, storage, sensors, wi-fi, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data: We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.Like many businesses, we also collect information through cookies and similar technologies.
You can find out more about this in our Cookie Notice:
https://www.calex.eu/
The information we collect includes:
• Log and Usage Data.Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
• Device Data.We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data.We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short:We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
• Consent.We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Legitimate Interests.We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Diagnose problems and/or prevent fraudulent activities.
• Legal Obligations.We may process your information where we believe it is necessary forcompliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests.We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short:We may share information in specific situations described in this section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:
• Cloud Computing Services
• Amazon Web Services (AWS), Microsoft Azure
• Functionality and Infrastructure Optimisation
• Amazon Web Services, Microsoft Azure
• Invoice and Billing
• Stripe, Android Pay and Apple Pay
• Web and Mobile Analytics
• Provider Data Analysis
• Geolocation and Maps
• Google Maps API
We also may need to share your personal information in the following situations:
• Business Transfers.We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs.We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: We store the geolocation of the device in order to be able to provide smart home related services (e.g. sunset/sunrise); and other similar information. A full list of what we use information for can be found in this section and in the previous section titled 'HOW DO WE PROCESS YOUR INFORMATION?'. We obtain and store on your device ('cache') your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice, which can be found at this link: https://www.calex.eu/
• Business Partners.We may share your information with our business partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.calex.eu/
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
International Transfers Outside of the European Economic Area (EEA)
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Objecting to processing:You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Data Breaches: Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Limits of Our Policy: Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
• Log in to your account settings and update your user account.
• Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO WE MAKE UPDATES TO THIS NOTICE?
In Short:
Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), ElectroCirkel Data Protection Officer, by email at dpo@calex.nl, by phone at +31851302214, or by post to:
Electro-Cirkel RETAIL B.V.
ElectroCirkel Data Protection Officer
Lyonstraat 29, 3047 AJ
Rotterdam. Netherlands
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information,
please visit: https://help.calex.eu