Feilo Sylvania Group –
SylSmart Connected Privacy Notice
1.
Background
This
privacy notice lets you know what happens to any personal data that you give to
us, or any that we may collect from or about you. This privacy notice applies
to personal information processed by or on behalf of the Feilo Sylvania Group.
It
applies to all products and services, and instances where we collect your
personal data related to the SylSmart Connected Commissioning Tool.
2.
The Feilo Sylvania Group
Feilo
Sylvania International Group Kft. (“FSIG”) with
registered office at Duna Tower, Népfürdő Street
22, Building C, 5th Floor, Budapest, Hungary, H-1138 or Feilo Sylvania Group entities
which provide products or services to you are named at our website. The Feilo
Sylvania entity that collects your data will be regarded as the Data
Controller. You can contact the Data Controller using the details on our
website.
Our
business partner Silvair sp. z o.o. (“Silvair”), a
limited liability company incorporated under the laws of Poland with its
registered office in Kraków at ul. Jasnogórska 44, 31-358 Kraków, Poland, manages the SylSmart
Connected Commissioning Tool and is therefore an independent Data Controller of
Personal Data as indicated in Sec. 3 below and is responsible for the
processing activities necessary to supply, operate and maintain, enhance and improve the Tool, to assess and improve their
business, and to carry out anonymisation of the collected data.
PLEASE
READ ABOUT HOW YOUR PERSONAL AND OTHER DATA IS USED AND PROCESSED BY SILVAIR AS
WELL YOUR DATA SUBJECT RIGHTS AND THE PRIVACY SAFEGUARDS EMPLOYED IN THE
SILVAIR COMMISSIONING PRIVACY NOTICE at https://silvair.com/support/pub/
BEFORE USING THE
TOOL.
3.
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, contact details and contact details history
·
Your date of birth, gender and/or age
·
Your nationality, if needed for the product or service
·
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
commissioning 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,
number of rooms, 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 mobile device
if you use certain features of our mobile apps;
·
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 commissioning service including
the web, mobile apps, software and services;
·
a.
your email and other credentials used to access our commissioning service
including the web, mobile apps, software and services;
·
b.
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 commissioning service.
4.
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
5.
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 lighting devices
commissioning 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 Silvair Commissioning (in particular, to securely
store Bluetooth mesh cryptographic 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
Silvair Commissioning and use of Silvair Commissioning (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 Silvair Commissioning (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].
Your personal data will be stored:
a. 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;
b. until the expiration of claims resulting from the Silvair Commissioning
service – in case of processing for the purpose of establishing, exercising and
defending claims (Article 6.1 (f) of the GDPR);
c. 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);
d. 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);
e. 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).
6.
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:
A.
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
B.
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
C.
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
D.
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.
7.
When do we share your personal information with other organisations?
We
may share information with the following third parties for the purposes listed
above:
·
Feilo
Sylvania Group companies and service providers
·
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 #
·
For
SylSmart Connected products, Silvair Sp. z o.o. (a
technology partner of Feilo Sylvania) is a Controller for Processing of
Personal Data for the purposes indicated the Silvair Commissioning Tool Privacy
Notice at https://silvair.com/support/pub/
8.
How and when can you withdraw your consent?
Where
we’re relying upon your consent to process personal data, you can withdraw this
at any time by contacting us using the details in section19. Please note that
the withdrawal of your consent does not affect the lawfulness of the processing
carried out before such withdrawal.
9.
Is your personal information transferred outside the EEA?
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.
You
may request copies of such safeguards by contacting us using the details below.
10.
What should you do if your personal information changes?
You
should tell us so that we can update our records. We’ll then update your
records if we can.
11.
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.
12.
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.
13.
For how long is your personal information retained by us?
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.
14.
What are your rights under data protection laws?
Here
is a list of the rights that all individuals have under data protection laws.
They don’t apply in all circumstances. If you wish to use any of them, we’ll
explain at that time if they are engaged or not. The right of data portability
is only relevant from 25 May 2018.
·
The
right to be informed about the processing of your personal information
·
The
right to have your personal information corrected if it is inaccurate and
to have incomplete personal information completed
·
The
right to object to processing of your personal information
·
The
right to restrict processing of your personal information
·
The
right to have your personal information erased (the “right to be
forgotten”)
·
The
right to request access to your personal information and to obtain
information about how we process it
·
The
right to move, copy or transfer your personal information (“data
portability”)
·
Rights
in relation to automated decision making which has a legal effect or
otherwise significantly affects you
If
you feel that your personal data rights have been breached, you can also
contact and lodge a complaint with the local data protection authority, in particular in the Member State of your habitual
residence, place of work or place of the alleged infringement. Please visit the
following website for contact details of the Data Protection Authorities of the
member states: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You can contact us using the details below.
15.
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 info@sylvania-lighting.com to exercise these rights.
16.
What are your marketing preferences and what do they mean?
We
may use your home address, phone numbers, email address and social media or
digital channels (for example, Facebook, Google and
message facilities in other platforms) to contact you according to your
marketing preferences. You can stop our marketing at any time by contacting us
using the details below or by following the instructions in the communication.
17.
Cookie Policy
The
Feilo Sylvania Group uses Cookies. To learn more and for a detailed cookie
notice, we refer to our Cookie Policy.
18.
Changes to this privacy notice
We
may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy
practices. We encourage you to check this privacy notice for changes whenever
you visit our website – https://www.connected.sylvania-lighting.com/.
19.
Contact Us
If
you have any questions about this privacy notice, or if you wish to exercise
your rights, you can contact us via info@sylvania-lighting.com or by writing to us
at: Feilo Sylvania International Group Kft, Duna
Tower, Nepfurdo Street 22, Building C, 3rd Floor,
Budapest, Hungary, H-1138