Feilo Sylvania Privacy Policy – SylSmart City
Effective Date: 04/05/2022.
Feilo Sylvania International Group Kft. and subsidiaries (“we”, “us”, “our”, “FSIG”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of our application “SylSmart City Application” or of any other Sylvania SylSmart product and solutions sold worldwide by FSIG and its affiliates.
Feilo Sylvania International Group Kft is a Feilo Sylvania company, based in Hungary (Duna Tower Building “C” 3rd Floor, Népfürdő utca 22, H.1138 Budapest, Hungary, registration number 01 09 304993).
Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways to execute your rights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register with your Personal Data, or if you start to use our Products and does not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any questions regarding this Policy, please do not hesitate to contact us via [email protected].
Definition
Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.
Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including smart home appliances.
Apps refers to those mobile applications sold by FSIG and its affiliates that provide end users remote control to Smart Devices and with the ability to connect to the supplier Cloud, IOS or Android Platform. For SylSmart City, the application is powered by Fonda
Web application refers to a web browser based platform sold by FSIG and its affiliates that provides access, management to the platform to deliver the services. This service may hosted on Microsoft Azure where Microsoft Inc acts as a data processor only. FSIG is the data controller. Where the web application
What Personal Data Do We Collect?
In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.
Information You Voluntarily Provide Us
Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, username, photos and videos if the User opts to upload such, and login credentials. For certain customers we collect business representative such as organizational title, phone number, email address. During your interaction with our products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.
1.2 Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content and ratings to address your problems and solve device failures on a timely basis, or to self-evaluate our performance.
Information We Collect Automatically
2.1 Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information, time online, current state of the device, signal value, dimming value, current (A), Voltage, Power, Power Factor, Electrical Energy, Drain Voltage, Switch Status, number of alerts.
2.2 Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
2.3 Log Information: When you use our app, the system and exception log may be uploaded.
Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.
2.3.1 Location Information: When you enable location-based functions through permission settings on your mobile device, we will collect and process your location information to enable certain functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time precise or non-precise geo-location when you use SylSmart City Application
Based on your consent, when you enable the geo-fence feature on the Products, your location information will be generated and shared with Google Map or Apple Map services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices. You may reject such use of your location information by managing the permission settings in the Products, upon which we will cease to collect and use your location information.
What kinds of personal information about you do we process?
Personal information that we’ll process in connection with all of our products and services, if relevant, includes:
Personal and contact details, such as title, full name, department, job title, line manager, contact details and contact details history, profile picture, password,
Your company details, if relevant for the supply of goods or services
Records of your contact with us such as via the phone number and, if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address and MAC address
Your email and other credentials used to access our service including the website, mobile apps, software and services;
Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
The usage of our products and services, any purchase orders and invoices
Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you.
Information about your use of products or services held with our business partners, such as, financial services and products
Information we obtained from third parties with your consent
Information about your property or site, such as location, remarks, permissions, property type and installation work you have had done, photos of the site if relevant,
Tenant details including tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address;
Financial details about you, such as your payment method(s)
Information we buy or rent from third parties, including demographic information, details of outstanding finance, marketing lists, publicly available information, and information to help improve the relevance of our products and services
Payment information including payment card details and/or online payment services number together with a billing address, financial information (such as bank account number) and tax identification number in circumstances in which you request products or services for which this information is required;
IP address and geographic locations of your terminal and mobile device if you use certain features of our mobile and web applications;
Insights about you and our customers gained from analysis or profiling of customers, cookies, usage data
tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address
your email and other credentials used to access our service including the web, mobile apps, software and services;
your email and other credentials used to access our service including the web, mobile apps, software and services;
individual and business contact information (such as your name and company name);
other personal information that may be provided to us to obtain requested products or services.
We also use and obtain other types of data which do not concern your personal data but are required to operate, analyse, enhance, and improve our service.
What is the source of your personal information?
We’ll collect personal information from the following general sources:
From you directly and from suppliers of products and services
Information generated about you when you use our products and services
From an agent or distributor who we work with to provide products or services or quote to you
Feilo Sylvania Group companies if you already have bought a product with them, have applied for one
Business partners (for example, financial services institutions) or others who are a part of providing your products and services or operating our business
We buy or rent information about you or customers generally from third parties including demographic information, marketing lists, publicly available information and other information to help improve our products and services or our business
What do we use your personal data for?
We use your personal data, including any of the personal data listed in section 3 above, for the following purposes:
Assessing an application for a product or service, including considering whether or not to offer you the product or service, the price, the risk of doing so, availability of payment method and the terms
Managing products and services relating to that the product or service, or application for one
Updating your records, tracing your whereabouts and recovering debt
Managing any aspect of the product or service
To make automated decisions on whether to offer you a product or service, or the price, payment method, risk or terms of it
To perform and/or test the performance of, our products and services
To improve the operation of our business and that of our business partners
For management and auditing of our business operations including accounting
To monitor and to keep records of our communications with you and our staff
For market research and analysis and developing statistics
For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match).
To develop new products and services and to review and improve current products and services
To comply with legal and regulatory obligations, requirements and guidance
To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
To share information, as needed, with business partners (for example, financial services institutions), service providers or as part of providing and administering our products and services or operating our business
To facilitate the sale of one or more parts of our business
To enable other Feilo Sylvania Group companies to perform any of the above purposes
To create your account (Article 6.1 (b) of the GDPR): type of personal data: [email, name, company name
To verify your email and that you have accepted the Terms of Use (Article 6.1 (b), (f) of the GDPR): type of personal data: [email],
To provide technical support (i.a. diagnose technical and service problems) and respond to your requests, questions and comments (Article 6.1 (b) of the GDPR): type of personal data: [email, name, company name],
To perform processing and collecting of payments for services delivered via SylSmart City if applicable (Article 6.1 (f) of the GDPR): type of personal data: [email, name, company name, company address] ],
To perform accounting, auditing, billing, reconciliation and collection activities (Article 6.1 (f) of the GDPR): type of personal data: [email, name, company name, company address] ],
To protect against, identify and prevent fraud and other criminal activity, claims and other liabilities liabilities (Article 6.1 (a), (f) of the GDPR):
type of personal data: [email, name, company name,, IP address, user geolocation, tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address];
To supply, operate, and maintain SylSmart City (in particular, to securely store and process analytics data) (Article 6.1 (a), (f) of the GDPR):
type of personal data: [email, name, company name, IP address, user geolocation, tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address]; To anonymize or perform aggregation of data
To analyze, enhance, and improve the SylSmart City platform (including developing new features and services) (Article 6.1 (a), (f) of the GDPR):
type of personal data: [email, name, company name, IP address, browser information and referring parameters, user geolocation, time zone, tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address];
To provide you with information concerning SylSmart products and services as well as maintenance updates (including newsletter and product information) (Article 6.1 (a), (f) of the GDPR):
type of personal data: [email, name, company name, , IP address, user geolocation, tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address];
To anonymize or perform aggregation of data (Article 6.1 (a), (f) of the GDPR):
type of personal data: [email, name, company name,, IP address, user geolocation, tenant company name, tenant contact name, tenant contact email, tenant contact telephone number, tenant address, building owner company name, building owner contact name, building owner contact email, building owner contact telephone number, building address].
What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data:
Where it is needed to provide you with our products or services, such as:
Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product, the price, the payment methods available and the conditions
Managing products and services you hold with us, or an application for one
Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
Sharing your personal information with business partners and services providers when you apply for a product to help manage your product
All stages and activities relevant to managing the product or service including enquiry, order requests, supply and delivery, claims handling, warranty claims, administration and management of accounts
For some of our profiling and other automated decision making to decide whether to offer you a product and/or service, particular payment method and the price or terms of this
Where it is in our legitimate interests to do so, such as:
Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
Maintaining network and data security
Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product, the price, the payment methods available and the conditions
To perform and/or test the performance of, our products and services
To follow guidance and recommended best practice of government and regulatory bodies
For management and audit of our business operations including accounting
To carry out monitoring and to keep records of our communications with you and our staff (see below)
For market research and analysis and developing statistics
For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and services. We will send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match)
To develop new products and services and to review and improve current products and services
Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses
For some of our profiling and other automated decision making
To facilitate the sale of one or more parts of our business
Where we need to share your personal information with people or organisations in order to run our business
To comply with our legal obligations
To comply with any of our legal and regulatory obligations, requirements and guidance, e.g. tax law, money laundering regulations, etc.
Where we need to share your personal information with people or organisations in order to comply with any legal and/or regulatory obligations
With your consent or explicit consent:
For some direct marketing communications
For some of our profiling and other automated decision making
We do not sell or otherwise share your personal data, except as described in this Privacy Notice.
Who Do We Share Personal Data With?
At FSIG we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:
To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.
As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
To subsidiaries or affiliates within our corporate family, to carry out regular business activities.
Where services are provided on a Microsoft platform (Azure Map), Microsoft Corporation shall be deemed as our data processor. In this case the policies and the connected general terms of the Microsoft Online Services will also be applicable.
We may share information with the following third parties for the purposes listed above:
Business partners (for example, financial services institutions, insurers) or others who are a part of providing your products and services or operating our business
Governmental and regulatory bodies
Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers, suppliers of other back office functions and market research organisations who help us to develop and improve our products and services
International Transfer of Information Collected
We are a global organisation covering mainly Europe, the Middle East and Africa (EMEA), Latin America (LATAM) and South East Asia. Our head office is based in Hungary and our supporting back offices are based in the UK and in Belgium. Your personal information may therefore be transferred outside the European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.
To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. If your data is transferred outside the European Economic Area, adequate protections are put in place to ensure the protection of your Personal Data.
If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.
Do you have to provide your personal information to us?
We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal Data. You may exercise any of the following rights via emailing us at [email protected]
You do not have to pay a fee and we will respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
You may:
Request access to the Personal Data that we process about you.
Request that we correct inaccurate or incomplete Personal Data about you.
Request deletion of Personal Data about you.
Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you.
Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and
Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.
Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:
For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notifications and other related functions.
Unbind the Smart Device through the app, and the information related to the Smart Device will not be collected.
You can delete your account via: Me>Settings>Account>Account and Security>Delete Account .
When you withdraw your consent or authorization, we may not be able to continue to provide you with the products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.
If you feel that your personal data rights have been breached, you can contact and lodge a complaint with the local data protection authority, in the country of your habitual residence, place of work or place of the alleged infringement.
Your right to object
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us via [email protected] to exercise these rights.
Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. We provide various security strategies to effectively ensure data security of user and device. As for device access 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. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing [email protected]
Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.
We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above
Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
Retention periods in line with legal and regulatory requirements or guidance.
for as long as the relevant consent is not withdrawn – in case of processing based on your consent (Article 6.1 (a) of the GDPR;
until the expiration of claims resulting from SylSmart City – in case of processing for the purpose of establishing, exercising and defending claims (Article 6.1 (f) of the GDPR);
Until receiving your objection or fulfillment of the processing purpose – in case of any other processing based on our legal interest (Article 6.1 (f) of the GDPR);
until we stop providing you services – in case of processing for the purpose of performance of the agreement (Article 6.1 (b) of the GDPR);
until the legal obligation expires – in case of any processing based on our obligations resulting from the provisions of law (Article 6.1 (c) of the GDPR).
Cookie Policy
The Feilo Sylvania Group uses Cookies. To learn more and for a detailed cookie notice, we refer to our Cookie Policy.
Children’s Privacy
Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of eighteen (18) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of eighteen (18) without permission from that child’s parent or legal guardian, we will take steps to remove that information.
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 (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Jurisdiction:
To the extent the local applicable data privacy and other laws allow, this Policy shall be governed by Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons about the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) and particularly the laws of Hungary. We undertake to follow the prescriptions of all applicable laws in case the latter laws prevail over the GDPR.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us as follows:
Feilo Sylvania International Group Kft.
Postal Mailing Address: Duna Tower Building C 3rd Floor, Népfürdő u 22., 1138 Budapest, Hungary
Email: [email protected]