PRIVACY POLICY

COMPLIANCE WITH DATA PROTECTION LEGISLATION

IDENTITY OF THE DATA CONTROLLER

ACCOUNT CREATION

• On the basis of the contract, We will process such data in order to create and manage your personal client account.
• We may also process your e-mail address for communications and direct marketing purposes. For more information on this processing activity, please consult the COMMUNICATIONS AND DIRECT MARKETING ACTIVITIES section.

CONTACTING OUR CUSTOMER SERVICE

• When contacting Our Helpdesk Support, We will collect the reason for contact and your message. Note that both data are mandatory and essential for providing the Services that you requested. Failure to fill in one of those field will compromise the proper handling of your request. Also note that you may attach and send Us a file to support your query. On the basis of the contract, We will process such data for the exclusive purposes of directing your request to the relevant internal department and giving an answer to your query.
• On the legal basis of the contract, we may where applicable and subject to your prior authorization, access your installation data (user account and associated Products data) for after-sales services purposes in order to diagnose and resolve a potential issue.
• On the basis of Our legitimate interest in improving Our client relations, we inform you that we will retain your Helpdesk customer history.

WEBSITE

• Navigating On Our Website And Using Our Web-Applications

• Facebook / Instagram. You will find a list and an overview of Facebook social plugins at the following address: https://developers.facebook.com/docs/plugins. For more information on Facebook's policy with regard personal data protection, please refer to: https://www.facebook.com/policy.php
• Twitter. For more information on Twitter's policy concerning personal data protection, please refer to: https://twitter.com/privacy
• LinkedIn. For more information on LinkedIn’s policy concerning personal data protection, please refer to: https://www.linkedin.com/legal/privacy-policy.
• Youtube. You will find a list and an overview of YouTube social plugins at the following address: https://www.youtube.com/yt/dev/. For more information on YouTube’s policy with regard to personal data protection, please refer to: https://support.google.com/youtube/answer/2801895

• Making A Purchase On Our E-shop

• On the basis of the contract, We will process all compulsory data in order to create and manage your store account and to manage your order and its delivery.
• Should you provide Us with this information, we will process your birth date for birthday offer proposition management purposes on the basis of Our legitimate interest in direct marketing, For more information on this processing activity, please consult the COMMUNICATIONS AND DIRECT MARKETING ACTIVITIES section below.
• We inform you that, on the basis of the contract, We will also retain your Purchase history and make it accessible to you on your account. We may also process such data for analytical profiling purposes. For more information on analytical profiling please refer to the Analytical Profiling for Direct Marketing Purposes section below.

COMMUNICATIONS AND DIRECT MARKETING ACTIVITIES

• Direct Marketing by E-mail

• In-App Communications and Push Notifications
  • In-App Communications

• Push Notifications

• Analytical Profiling for Direct Marketing Purposes (through e-mail and in-app communications)

• Surveys, Quizzes and Contests
  • Surveys and Quizzes

• Contests

MOBILE APPLICATIONS AND ASSOCIATED PRODUCTS

• Processing Activities Common To All Our Mobile Applications
  • Cookies And Similar Technologies Used On Our Mobile Applications

• Third-Party Applications

• Uninstalling Our Mobile Applications

• WEATHER Mobile Application

• Your Weather station location (GPS) will be processed on the contract basis for Product registration, Identification of available WIFI networks and display of more precise information purposes.
  Subject to your explicit consent, collected at the time of registration, this data will also be used to place you on the NETATMO’s WeatherMap. .
  The location of your Weather Station will be retained until you change its location: should you move your Weather Station after installation, you can geolocate it again at any time in order to obtain more relevant information and proper placement on the WeatherMap. On this occasion, a system pop-up will ask for your explicit consent. In the alternative, you can decide to enter a new address manually.
  Note that contribution to the NETATMO WeatherMap is disabled by default. By choosing to contribute to the NETATMO WeatherMap, only your outdoor data will be shared. The indoor data will remain private. If you do not wish to contribute, we will not share any information of yours whatsoever, only you will see your Station on the map. Should you consent to contributing, We inform you that you can withdraw your consent from the Weather Station’s settings menu at any time (Settings > Station name > Advanced).
• The language of your device, your city and country (inferred from your IP address) will be processed on the contract basis for adapting the language used on your Application and to adapt zone information.
• We will also collect measurement data relative to each product (temperature, wind, rain, altitude inferred from localization of Product, pressure, sound level, humidity, Co2) on the contract basis and communicate it to you on your Application to render the Service. On the basis of Our legitimate interest in improving Our Products and Services, We will also process measurement data for R&D analysis in order to improve the content and functionality of Our Products and Services. If consented, the external measurement data could be shared with third party partners to improve the weather forecast or make statistical studies for a given time
• The Product and Home name(s) will be processed on the contract basis in order to personalize your user’s interface.
• The Date and time of setup of each Product and the Last time and date of seen for each Product will be processed on the contract basis for Helpdesk support purposes and to delete inactive user accounts.
• The following technical data: MAC addresses of each Product, Network IP address, Network Transport, WIFI status, Mobile IP address, Mobile type and Mobile version will be processed on the contract basis for Product registration, Usage of the solution and distribution of Weather Feed alerts purposes.

• ENERGY Mobile Application

• The Product Location (GPS) will be processed on the contract basis for product registration, identification of available WIFI networks and obtention of external temperature purposes.
• The language of your device, your city and country (inferred from your IP address) will be processed on the contract basis for adapting the language used on your Application.
• We will also collect measurement data relative to each product (temperature) on the contract basis and communicate it to you on your Application to render the Service. On the basis of Our legitimate interest in improving Our Products and Services, We will also process measurement data for R&D analysis in order to improve the content and functionality of Our Products and Services.
• Heating schedule (per user and per device) will be collected and processed on the contract basis and communicated to you on your Application. This data also serves the purpose of operating the solution.
• Should you provide Us with the following data: Energy sources, type of house, surface of house m², We will process it on the contract basis in order to give you more precise and personalized information.
• The Product and Home name(s), room name and type will be processed on the contract basis in order to personalize your interface.
• The Date and time of setup of each Product and the Last time and date of seen for each Product will be processed on the contract basis for Helpdesk support purposes and to delete inactive user accounts.
• The following technical data: MAC addresses of each Product, Network IP address, Network Transport, WIFI status, Mobile IP address, Mobile type and Mobile version will be processed on the contract basis for product registration, execution of the Service and maintenance of Thermostat and associated accessories.

• AIR CARE Mobile Application

• The Healthy Home Coach Location (GPS) will be processed on the contract basis for product registration, identification of available WIFI networks and obtention of external temperature purposes.
• The language of your device, your city and country (inferred from your IP address) will be processed on the contract basis for adapting the language used on your Application.
• The Healthy Home Coach name, the Home and room names will be processed on the contract basis in order to personalize your user’s interface.
• We will also collect measurement data relative to each product (Temperature, Humidity, CO2, Noise Level) on the contract basis and communicate it to you on your Application to render the Service. On the basis of Our legitimate interest in improving Our Products and Services, We will also process measurement data for R&D analysis in order to improve the content and functionality of Our Products and Services.
• The Date and time of setup of each Product and the Last time and date of seen for each Product will be processed on the contract basis for Helpdesk support purposes and to delete inactive user accounts.
• The following technical data: MAC addresses of each Product, Network IP address, Network Transport, WIFI status, Mobile IP address, Mobile type and Mobile version will be processed on the contract basis for product registration, execution of the Service and maintenance of the Product.

• SECURITY Mobile Application

• The Security Cameras and accessories GPS location (Smart Door & Window Sensors) will be processed on the contract basis for product registration and identification of available WIFI networks purposes.
• The type and number of Security accessories linked to the Camera (Tags – Siren - Smart Door & Window Sensors) will be processed on the contract basis for product registration and rendering of the Service purposes.
• The location of your Mobile device will be processed, subject to your explicit consent, for geofencing purposes in order to determine when you leave your home, in the background (even when the app is closed or not in use).
• The language of your device, your city and country (inferred from your IP address) will be processed on the contract basis for adapting the language used on your Application.
• The Security Cameras and accessories name, Home and room names will be processed on the contract basis in order to personalize your user’s interface.
• The Metrics used for the Products (Event logs, home occupancy) will be processed on the contract basis in order to personalize the Service to your needs.
• We will also collect measurement data relative to each product (Events from Cameras, Tags, Sirens, Smart Door & Window Sensors, end user reports) on the contract basis and communicate it to you on your Application to render the Service.
• The Date and time of setup of each Product and the Last time and date of seen for each Product will be processed on the contract basis for Helpdesk support purposes and to delete inactive user accounts.
• The following technical data: MAC addresses of each Product, Network IP address, Network Transport, WIFI status, Mobile IP address, Mobile type and Mobile version will be processed on the contract basis for product registration, execution of the Service and maintenance of the Cameras and associated accessories.

• The Smart Smoke Alarm / Smart Carbon Monoxide Alarm location (GPS) will be processed on the contract basis for product registration and identification of available WIFI networks purposes.
• The language of your device, your city and country (inferred from your IP address) will be processed on the contract basis for adapting the language used on your Application.
• The Smart Smoke Alarm / Smart Carbon Monoxide Alarm name, Home and room names will be processed on the contract basis in order to personalize your user’s interface.
• We will also collect measurement data relative to each product (Smart Smoke Alarm / Smart Carbon Monoxide Alarm status, last detected time, start time, end time, tamper status, date of last sound test) on the contract basis and communicate it to you on your Application to render the Service. On the basis of Our legitimate interest in improving Our Products and Services, We will also process measurement data for R&D analysis in order to improve the content and functionality of Our Products and Services.
• The Date and time of setup of each Product and the Last time and date of seen for each Product will be processed on the contract basis for Helpdesk support purposes and to delete inactive user accounts.
• The following technical data: MAC addresses of each Product, Network IP address, Network Transport, WIFI status, Mobile IP address, Mobile type and Mobile version will be processed on the contract basis for product registration, execution of the Service and maintenance of the Smart Smoke Alarm / Smart Carbon Monoxide Alarm.

NETATMO PRO

• On the basis of the contract, We will process such data in order to create and manage your NETATMO PRO account.
• On the basis of Our legitimate interest in improving Our clients’ relations, We will process such data in order to create of your personal file on Our CRM tool provided by Mailchimp.
• We may also process your e-mail address for communications and direct marketing purposes. For more information on this processing activity, please consult the COMMUNICATIONS AND DIRECT MARKETING ACTIVITIES section above.
• During the use of Our Services, We will collect your Test results (per product) on the basis of the contract and process such data for the purpose of giving you your professional certification.

ACCESS TO DATA

• The relevant internal departments of NETATMO, established in France:
  • The Research and Development (R&D) teams in charge of our intelligent solutions have, in order to achieve their missions, access: to customer account data (email address only) (see section ACCOUNT CREATION), the information collected by the technical cookies necessary for the proper functioning of the Services (see sections Browsing Our Website And Using Our Internet Applications and Cookies And Similar Technologies Used On Our Mobile Applications ), data processed in connection with the use of the Products (see sections WEATHER Mobile Application, ENERGY Mobile Application, AIR CARE Mobile Application, SECURITY Mobile Application except for biometric data that remains locally on the Product)
  • The teams of our customer support have, for the purpose of achieving their mission, access: to customer account data (see section ACCOUNT CREATION), data collected during your contacts with Technical Support (see section CONTACTING OUR CUSTOMER SERVICE), the data collected as part of the purchase on the Online Store (see section Making A Purchase On Our E-shop), Account Data for NETATMO PRO (refer to section NETATMO PRO), to the data processed in connection with the use of the Products(see sections WEATHER Mobile Application, ENERGY Mobile Application, AIR CARE Mobile Application, SECURITY Mobile Application except for biometric data that remains locally on the Product)
  • Our marketing teams have, for the purpose of achieving their mission, access to: customer account data (email address) (see section ACCOUNT CREATION), information collected by advertising cookies and measures (see section Browsing Our Website And Using Our Internet Applications), the history of your purchases (see section Making A Purchase On Our E-shop), other possible data while purchasing online (eg anniversary date see Direct Marketing by E-mail), data collected as part of analytic profiling (refer to section In-App Communications and Push Notifications), data collected by our advertising identifiers (see section Cookies and Similar Technologies Used On Our Mobile Applications)
  • Our online sales teams have access, for the purpose of carrying out their missions, to data transmitted by third-party cookies aimed at improving navigation, functionalities and user experience of the Website (consult section Browsing Our Website And Using Our Internet Applications)
  • Our sales administration teams have access, for the purpose of carrying out their missions, to the data collected during online purchases (see section Making A Purchase On Our E-shop)
  • Our sales teams have access to NETATMO PRO account data for the purposes of carrying out their assignments (see section NETATMO PRO)

• The service provider MICROSOFT AZURE, whose data centers are located in the Netherlands, responsible for hosting the NETATMO’s cloud architecture hosting all the data related to the Products and associated Services;
• The service provider CROC, whose data centers are located in Russia, responsible for hosting Russian user emails to be compliant with Russian Regulation;
• The service provider ONLINE, established in France, responsible for hosting historical product data;
• The service provider OVH, established in France, responsible for hosting NETATMO’s backups;
• The service provider Mailchimp, established in the United States of America, hosting the data related to NETATMO PRO accounts. We also inform you that Mailchimp benefits from a “Privacy Shield” certificate and that any transfer of your data towards the United States of America will take place under security and privacy conditions which are considered adequate according to European legislation.
• When making a purchase on Our E-shop, the service provider STRIPE, established in Ireland, is in charge of payment execution;
• AMAZON WEB SERVICE, established in Ireland, and in charge of hosting web applications;
• The service provider ADOBE SYSTEMS SOFTWARE IRELAND LIMITED, established in Ireland, for the purpose of sending you direct marketing communications where applicable.;
• The service provider ZENDESK, whose data centers are located in Germany, for Customer Support Service purposes. We also inform you that Zendesk benefits from a “Privacy Shield” certificate and that We have put the Standard Contractual Clauses of the European Commission in place to organize the transfer of your data towards the United States of America under security and privacy conditions which are considered adequate according to European legislation;
• The platforms and social media: Facebook, Instagram, Twitter, LinkedIn and YouTube insofar as they have access to your browsing history on Our Website and Mobile Applications should you consent to such access. We also inform you that such platforms and social media benefit from a “Privacy Shield” certificate and as such, any potential transfer of your data for hosting and further processing purposes in the United States of America will take place under security and privacy conditions which are considered adequate according to European legislation. To learn more, please consult Our Cookies and Similar Technologies Used On Our Mobile Applications sections.
  Subject to your express consent, you may also decide to share your Personal Data or Measurements on other platforms such as social networking websites for example. In this case, you recognize that We do not own and have no control over these Third-party Partner Service Providers and that We are not responsible for data processing performed by these Third-party Service Providers. To learn more about the manner in which these Third-party Partner Service Providers process your Personal Data, We advise you to consult their applicable privacy policies.
• GOOGLE insofar as they have access to data relating to your browsing history when you confirm your agreement upon arrival on Our Website and Mobile Applications. We inform you that Google benefits from a “Privacy Shield” certificate and as such, any potential transfer of your data for hosting purposes in the United States will take place under security and privacy conditions which are considered adequate according to European legislation. For further information, please consult Our Cookies and Similar Technologies used on Our Mobile Applications sections.

• You may decide to make your Personal Data or Measurements publicly available to other users and third parties on the Website.
• You may also decide to invite other user(s) to control the Products that have been installed in your Home. To do so, your guests will be required to create their own personal account. For more information on such invitations, please consult Our Help center on Our Website.
• NETATMO may also be required to share your Personal Data if and when it is necessary in order to protect the vital interests of the data subject or of another natural person, if it is necessary for compliance with a legal obligation to which It is subject or for the establishment, exercise or defense of legal claims.

DATA SECURITY

UNDER EIGHTEEN

EXERCISE OF USERS' RIGHTS

AMENDMENT TO THIS DOCUMENT

ADDITIONAL CONDITIONS

DEFINITIONS

PRIVACY POLICY FORUM NETATMO

IDENTITY OF THE DATA CONTROLLER

DATA COLLECTED AND PURPOSE OF PROCESSING

RECIPIENTS WITH ACCESS TO THE DATA

• NETATMO's internal services, based in France;

• NETATMO's service providers, who are responsible in particular for hosting the Forum.

DATA SECURITY

USER RIGHTS

• Right of access: you are entitled to request a copy of your Personal Data and obtain information about the processing of your Personal Data (such as the categories of Personal Data processed, the purposes of the processing, the categories of recipient to whom the Personal Data is disclosed, the period for which the Personal Data will be stored);

• Right to rectification: you are entitled to request us to rectify, complete or update Personal Data which is inaccurate, incomplete, ambiguous, and/or out of date;

• Right to erasure (“right to be forgotten”): you are entitled to request us to erase your Personal Data in certain circumstances as set out in Article 17 of the GDPR (for example, if your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; or if you have withdrawn your consent to the Personal Data processing, provided that prior consent was the legal basis for its collection and processing and there is no other legal basis for it);

• Right to restriction of processing: you are entitled to request us to restrict the processing of your Personal Data in certain circumstances set out in Article 18 of the GDPR (for example, when you contest the accuracy of the Personal Data, while we verify this point);

• Right not to be subject to certain processing (as set out in Article 22 of the GDPR): you are entitled to request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;

• Right to object: you are entitled to request to object to the processing of Personal Data on grounds relating to your particular situation, as specified in Article 21 of the GDPR (for example, you can object at any time to processing of your Personal Data for marketing purposes and profiling related to such marketing);

• Right to data portability: you are entitled to request to receive your Personal Data (where it is processed on the legal basis of your consent or its necessity for the execution of an agreement) in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller (for example, another service provider);

• Right to withdraw consent: you are entitled to withdraw your consent at any time, without having to justify this, for all the processing activities outlined in the Privacy Policy which are based on your consent;

• Right in the event of death: you are entitled to request us to define directives relating to the storage, deletion and disclosure of your Personal Data after your death (in accordance with Article 85 of the French Data Protection Act). These directives may be general or specific. The general directives relate to all your Personal Data and may be stored with a trusted digital third party certified by the Commission Nationale de l'Informatique et des Libertés (French Information Commissioner's Office). The specific directives relate to the processing of Personal Data set out in this Privacy Policy, and which are stored with us;

• Right to submit a claim: you may lodge a claim with a supervisory authority, in particular in the EEA country in which you reside or work, or in the EEA country where the alleged breach occurred, if you believe that one or more of our Personal Data processing operations violates the GDPR. In France, the supervisory authority is the Commission Nationale de l'Informatique et des Libertés (CNIL or French Information Commissioner's Office).

UNDER FIFTEEN

CHANGES TO THE PERSONAL DATA POLICY

CONTACT US & CONTACT OUR DPO