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LEDVANCE SMART + WiFi App Privacy Policy

As of June 2020

Table of contents

I. Identity and contact details of the data controller

II. Contact details of the data protection officer

III. Permissions

IV. Data processing in the LEDVANCE SMART + WiFi App

V. Provision of the app and creation of log files

VI. Usage of cookies

VII. Usage of corporate presences in professionally oriented networks

VIII. Hosting

IX. Geotargeting

X. Registration

XI. Content Delivery Networks

XII. Telemetry Data

XIII. Usage of SDK

XIV. Data processing by backup service

XV. Rights of the data subject

I. Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other national data protection laws of the Member States as well as other data protection regulations is:

LEDVANCE GmbH
Parkring 29-33
85748 Garching
Germany
+49 89 780673-100
contact@ledvance.com
https://www.ledvance.com

II. Contact details of the data protection officer

The designated data protection officer is:

DataCo GmbH
Dachauer Str. 65
80335 Munich
Germany
+49 89 7400 45840
https://www.dataguard.de

III. Permissions

The following authorizations are required to implement the functions in the app:

  • Photos (iOS)
    Store photos and videos from connected devices
  • Location Services (iOS)
    Access to SSID information during the pairing process, set application location, condition settings (weather, automated rules)
  • Microphone (iOS)
    Enables the two-way voice control
  • Camera (iOS)
    QR Code scanner for pairing process, photo function for profile image creation
  • Bluetooth Sharing (iOS)
    Pairing with and control of devices
  • Media Sharing (iOS)
    Store photos and videos from connected devices
  • Camera (Android)
    QR Code scanner for pairing process, photo function for profile image creation
  • Location (Android)
    Access to SSID information during the pairing process, set application location, condition settings (weather, automated rules)
  • Microphone (Android)
    Two-way voice control
  • Device memory (Android)
    Store photos and videos from connected devices

IV. Data processing in the LEDVANCE SMART + WiFi App

On this page we inform you about the privacy policy of the LEDVANCE SMART + WiFi App for Android and iOS ("App"). The App is offered by LEDVANCE GmbH, Parkring 29 - 33, 85748 Garching near Munich, Germany ("LEDVANCE GmbH", "we" or "us").

1. Scope of processing personal data

The app is used for technical control of SMART+ devices and provides direct technical support for users. Multi-user access is enabled.

The processing of personal data takes the form of creating a user account. The data is also stored for user support. The following personal data may be collected:

  • Username
  • Password
  • E-Mail-address
  • Username
  • Photo
  • Location

The following data is processed when the app is started:

  • Information about the type and version of the app
  • Operating system of the user
  • Date and time of access
  • Language settings
  • Time zone of the device

The servers automatically collect and store information in so-called server log files, which your device automatically transmits when you use the app. The stored information is:

  • Browser type and version
  • Operating system used
  • Referrer-URL
  • Date and time of the server request
  • IP address

Third parties do not have access to server log files. This data is not merged with other data sources.

2. Purpose of the processing

The processing of personal data allows the users of the App to have technical control of SMART+ devices and direct contact for technical support.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data in the context of the creation and use of a user account is the consent of the user in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

The processing of technical data serves to safeguard a legitimate interest of our company in providing a functional application for users and is therefore based on Art. 6 para. 1 sentence 1 letter f GDPR as the legal basis for the processing.

4. Duration of storage

The personal data will be stored until the account is deleted, exclusively for the above-mentioned purpose. With the deletion of the account by the user all data will be removed.

5. Objection and erasure

The user is given the opportunity to object to the processing by e-mail request. By deleting the account all data will be removed.

V. Provision of the app and creation of log files

1. Description and scope of data processing

Each time our app is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

  • Browser type and version used
  • The user's operating system
  • The IP address of the user
  • Date and time of access
  • language settings, time zone, app-version

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the app to the device of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the app. The data is also used to optimise the app and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 para. 1 s. 1 lit. f GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 para. 1 s. 1 lit. f GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the app is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.

5. Objection and erasure

The collection of data for the provision of the app as well as the storage of data in log files are essential for the operation of the app. Therefore, the user may not object to the aforementioned processes.

VI. Usage of cookies

1. Description and scope of data processing

Our app uses cookies. Cookies are text files that are stored in the internet browser or the internet browser on the user’s device. If a user calls up the app, a cookie can be stored on the user’s operation system. These cookies contain a string of characters that allows the browser to be uniquely identified when the app is reopened.

We use cookies to make our app more user-friendly. Some elements of our app require the calling browser to be identified even after a page break.

The following data is stored and transmitted in the cookies:

  • Language settings
  • Log-in information

The user data collected in this manner is pseudonymised by technical measures. It is therefore not possible to assign the data to the user accessing the site. The data is not stored together with other personal data of the users.

2. Purpose of data processing

The purpose of using technical cookies is to simplify the use of app for users. Some functions of our app cannot be offered without the use of cookies. These require that the device is recognised even after a page change.

We need cookies for the following applications:

  • Applying language settings
  • Assignment to nearby server

The user data collected by technical cookies are not used to create user profiles.

3. Legal basis for data processing

The legal basis for the processing of personal data using technical cookies is Art. 6 Para. 1 S. 1 lit. f GDPR.

4. Duration of storage and possibility of objection and erasure

Cookies are stored on the user's device and transmitted to our server by the user. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our app, it is possible that not all functions of the app can be used to their full extent.

VII. Usage of corporate presences in professionally oriented networks

1. Scope of data processing

We use corporate presences on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:

LinkedIn:

LinkedIn, Unlimited Company Wilton Place, Dublin 2, Irleand

On our site we provide information and offer users the possibility of communication.

The corporate presence is used for job applications, information/PR and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate presence. Further information can be found in the privacy policy of LinkedIn:

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

If you carry out an action on our company app (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

2. Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our corporate web presence is Art. 6 Para. 1 S.1 lit. f GDPR.

3. Purpose of the data processing

Our corporate web presence serves to inform users about our services. Every user is free to publish personal data through activities.

4. Duration of storage

We store your activities and personal data published via our corporate web presence until you revoke your consent. In addition, we comply with the statutory retention periods.

5. Objection and erasure

You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web presence and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal Email to the Email address stated in this privacy policy.

LinkedIn has also signed and is certified under the Privacy Shield Agreement between the European Union and the United States. LinkedIn commits itself to comply with the standards and regulations of the European data protection law. Further information can be found in the following linked entry:

https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active

You can find further information on objection and erasure options here:

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

VIII. Hosting

The app is hosted on servers of a service provider commissioned by us.

Our service providers Cloud built on AWS – Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, United States

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you use the app. The stored information is:

  • Browser type and version
  • Used operating system
  • Referrer URL
  • Hostname of the accessing computer
  • Time and date of the server request
  • IP address of the user's device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The apps operator has a legitimate interest in the technically error-free presentation and optimization of his app - for this the server log files must be recorded.

The server of the app is geographically located in Frankfurt, Germany.

IX. Geotargeting

We use the IP address and other information provided by the user (e.g. the postal code used for registration or ordering) to approach regional target groups (so-called "geotargeting").

The regional target group approach is used, for example, to automatically display regional offers or advertisements that often are more relevant to users. The legal basis for the use of the IP address and any other information provided by the user (e.g. postal code) is Art. 6 para. 1 lit. f GDPR, based on our legitimate interest in ensuring a more precise target group approach and thus providing offers and advertising with greater relevance for our users.

Part of the IP address and the additional information provided by the user (e.g. postal code) are merely processed and not stored separately.

You can prevent geotargeting by, for example, using a VPN or proxy server that prevents accurate localization. In addition, depending on the browser you are using, you can also deactivate a location localisation in the corresponding browser settings (as far as this is supported by the respective browser).

We use geotargeting on our app for the following purposes:

  • Weather forecast
  • Control of smart devices according to the weather

X. Registration

1. Description and scope of data processing

We offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:

  • Email address
  • Pseudonym
  • Telephone / mobile phone number
  • IP address of the user's device
  • Date and time of registration

As part of the registration process, the user's consent to the processing of this data is obtained.

2. Purpose of data processing

Registration of the user is required for the provision of certain content and services on our app.

  • Usage of the app
  • Multi-user functionality

3. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 s. 1 lit. a GDPR if the user has given his consent.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.

This is the case for the data collected during the registration process if the registration is cancelled or modified on our app.

5. Objection and erasure

As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time.

The user can request the deletion of his account within his account via a corresponding button.

XI. Content Delivery Networks

Amazon CloudFront

1. Description and scope of data processing

We use functions of the Amazon CloudFront content delivery network of Amazon Web Service Inc, 410 Terry Avenue North, Seattle WA 98109, USA (hereinafter referred to as Amazon CloudFront). A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. Amazon CloudFront provides web optimization and security services that we use to improve the load times of our app and protect it from misuse. When you use our app, a connection will be established to Amazon CloudFront's servers to retrieve content, for example. This allows personal data to be stored and evaluated in server log files, in particular the user's activity (in particular which pages have been visited) and device and browser information (in particular the IP address and the operating system).

This data can be transferred to servers of AWS Cloudfront in the USA. Amazon has submitted to the Privacy Shield Agreement concluded between the European Union and the USA and is certified. Amazon thereby undertakes to comply with the standards and regulations of European data protection law. Further information can be found in the following linked entry:

https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active

For more information on Amazon CloudFront's collection and storage of data, please visit:

https://aws.amazon.com/de/privacy/

2. Purpose of data processing

Amazon CloudFront features are used to deliver and accelerate online applications and content.

3. Legal basis for data processing

The data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The app´s operator has a legitimate interest in the technically error-free presentation and optimization of his app - for this the server log files must be recorded.

4. Duration of storage

Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law.

5. Objection and erasure

Information about objection and erasure options regarding Amazon CloudFront can be found at:

https://aws.amazon.com/de/privacy/

XII. Telemetry Data

1. Description and scope of data processing

We collect telemetry data in our app. In the course of telemetry data processing, the behaviour within the app and device information such as

  • Model
  • and OS version

of the user, but no personal data whatsoever.

2. Purpose of data processing

The data are processed for the following purposes:

  • Infrastructure monitoring
  • Application monitoring
  • Resource optimisation
  • Troubleshooting
  • Functional data analysis of the Smart Device
  • User behaviour
  • Analysis of the app performance:

    • Launch speed of the app
    • Charging times
    • Times for jumps between pages
    • Usage of the buttons

3. Legal basis for the data processing

These data are recorded on the basis of Art. 6 para. 1 lit. f GDPR. The app operator has a legitimate interest in the technically error-free display and optimisation of his app - for this purpose the server log files must be recorded.

4. Duration of storage

Your personal information will be stored for as long as necessary to fulfill the purposes described in this privacy policy or as required by law.

5. Objection and erasure

To make the objection valid, users can write an informal e-mail to contact@ledvance.com , or remove the data by deleting the account and the app.

XIII. Usage of SDK

1. Description of the use of SDKs

We use SDKs to provide functional modules. For this purpose, the used code is embedded into the SDKs.

2. Third party libraries used for iOS

  • AFNetworking
  • CocoaAsyncSocket
  • CocoaLumberjack
  • DACircularProgress
  • FBSDKCoreKit
  • FBSDKLoginKit
  • FBSDKShareKit
  • FLAnimatedImage
  • FMDB
  • IQKeyboardManager
  • Libextobjc
  • lottie-ios
  • Masonry
  • MBProgressHUD
  • MJRefresh
  • MMKV
  • MQTTClient
  • OCMock
  • OpenSSL-Universal
  • Reachability
  • SDWebImage
  • SQLCipher
  • SSZipArchive
  • TPCircularBuffer
  • TZImagePickerController
  • UICKeyChainStore
  • YYModel

3. Third party libraries used for Android

  • Firebase messaging
  • Google map
  • Google speech
  • Google play services location
  • Gson
  • recyclerview-swipe
  • recyclerview-animators
  • SwitchButton
  • Flexbox
  • Openssl
  • Fastjson
  • Eventbus
  • OKHttp
  • RxJava
  • Lottie
  • Systembartint
  • adapterdelegates3
  • MPAndroidChart
  • TextLayoutBuilder
  • android-jsc
  • mqttv3
  • Fresco
  • React-native
  • DSBridge-Android
  • Grpc
  • Libevent
  • Mars
  • MMKV
  • Litho
  • LDNetDiagnoService_Android
  • LoopView
  • grpc-java
  • react-native-svg
  • react-native-image-picker
  • wcdb
  • zxing
  • commons-compress
  • soloader
  • bouncycastle
  • Android-BluetoothKit
  • Android-nRF-Mesh-Library
  • Kotlin
  • Android Support
  • Matrix
  • Mbedtls
  • Libuv
  • Libsrtp
  • Cjson
  • Kcp
  • Curl
  • FFmpeg
  • Rapidjson

The SDK are used on the basis of Art. 6 para. 1 lit. f GDPR.

We have a legitimate interest in the technically error-free display and optimization of our app - for this purpose the SDK must be used.

XIV. Data processing by backup services

You can use backup services to back up settings and data from apps on your device. Backed-up information is transferred to and stored on the server of the backup service you are using and can be restored to the original device or another device. The scope of data collection depends on the backup service used, but in particular, app settings and data, the user name, the email address, the customer number of your account, the time of the backup and the individual device ID can be processed. The processing of this data is carried out exclusively by the provider of the backup service used and is beyond our sphere of influence.

XV. Rights of the data subject

When your personal data is processed, you are subsequently a data subject in the sense of the GDPR and have the following rights:

1. Right to information

You may request from the data controller to confirm whether your personal data is processed by them.

If such processing is the case, you can request the following information from the data controller:

  • The purpose for which the personal data is processed;
  • The categories of personal data being processed;
  • The recipients or categories of recipients to whom the personal data relating to you have been disclosed or are still being disclosed;
  • The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;
  • The existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the data controller or a right to object to such processing;
  • The existence of a right of appeal to a supervisory authority;
  • All available information on the source of the data if the personal data is not collected from the data subject;
  • The existence of automated decision-making including profiling under Article 22 para. 1 and para. 4 GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organisation. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or completion of the data controller, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

  • If you challenge the correctness of your personal data for a period of time that enables the data controller to verify the accuracy of your personal data;
  • The processing is unlawful, and you refuse the erasure of the personal data and instead demand the restriction of the use of the personal data;
  • The representative no longer needs the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
  • If you have objected to the processing pursuant to Art. 21 para. 1 GDPR and it is not yet certain whether the legitimate reasons of the data controller outweigh your reasons.

If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest, interest to the Union, or a Member State.

If the processing has been restricted according to the beforementioned conditions, you will be informed by the data controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase

If you request from the data controller to delete your personal data with immediate effect, they are required to do so immediately given that one of the following applies:

  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
  • You revoke your consent, to which the processing is allowed pursuant to Art. 6 para. 1 s. 1 lit. a oder Art. 9 para. 2 lit. a GDPR and there is no other legal basis for processing the data
  • According to Art. 21 para. 1 GDPR you object to the processing of the data given that the processing of the data is justified by a legitimate interest, or you object pursuant to Art. 21 para. 2 GDPR.
  • Your personal data has been processed unlawfully.
  • The act of deleting your personal data will invoke a legal obligation under the Union law or the law of the Member States to which the data controller is subject.
  • Your personal data was collected in relation to information business services offered pursuant to Art. 8 para. 1 GDPR.

b) Information to third parties

If the data controller has made your personal data public and has to delete the data pursuant to Art. 17 para. 1 GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

c) Exceptions

The right to deletion does not exist if the processing is necessary

  • to exercise the right to freedom of speech and information;
  • to fulfill a legal obligation required by the law of the Union or of the Member States to which the representative is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative;
  • for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
  • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
  • to enforce, exercise or defend legal claims.

5. Right to information

If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You reserve the right to be informed about the recipients of your data by the data controller.

6. Right to data portability

You have the right to receive your personal data given to the data controller in a structured, standard and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, given that

  • 1. the processing is based on a consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract in accordance with Art. 6 para. 1 s. 1 lit. b GDPR and
  • the processing is done by automated means.

In exercising this right, you also have the right to maintain that your personal data relating to you are transmitted directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.

7. Right to object

Subjective to your situation, you have, at any time, the right to object against the processing of your personal data pursuant to Art. 6 para. 1 s. 1 lit. e or f GDPR; this also applies to profiling based on these provisions.

The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling insofar as it is associated with direct mail.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated procedures that use technical specifications.

8. Right to revoke the data protection consent declaration

You have the right to withdraw your consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

9. Automated decision on a case-by-case basis, including profiling

You have the right not to subject to a decision based solely on automated processing – including profiling – that will have legal effect or affect you in a similar manner. This does not apply if the decision

  • is required for the conclusion or execution of a contract between you and the data controller,
  • is permitted by the Union or Member State legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
  • with your expressed consent.

However, these decisions must not be based on special categories of personal data under Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and reasonable measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or their representative, to express your opinion on the matter, and to contest the decision.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of their residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the GDPR.

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

This privacy policy has been created with the assistance of DataGuard .

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