‘personal data’ means any information relating to an identified or identifiable natural person. It adds that:
an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
You may provide us with information about your personal data through our website or other social media accounts registered to Climeon. You may also provide such information when in contact with Climeon employees officially representing Climeon through e-mail, telephone or other contact.
Such data (“Customer-provided personal data”) may include:
- Your contact information (name, address, telephone number, email address, etc.);
- Location data generated by your activities (search queries, location sharing, etc.); and
- Data pertaining to your order and use of our products, system and services (customer preferences and settings, purchase history, etc.).
Climeon is also offering a cloud-based subscription software, Climeon Live TM, which is the control system for the Climeon Heat power system, and which also includes a range of add-on cloud-based applications. Each separate module in a Climeon Heat Power system has multiple sensors providing the software with precision measurements and large amounts of data.
In order to access all functionalities of Climeon Live TM you need to set up a profile comprising information about your personal data. Your personal data will be saved on the cloud provided by us or a third party supplier and will also be stored locally on each separate module. Our system will also automatically collect data relating to the system and its surroundings, primarily of a technical nature and not directly related to you as a person.
Such data (“System-recorded data”) is typically connected to the identification number of each module and may therefore be traceable to you. System-recorded data may include:
- Safety and access information;
- System functionality status;
- Location data; and
- Surroundings data.
PURPOSE OF DATA USE
The personal data which you have provided to Climeon is mainly used to fulfil your requests and to respond to your enquiry.
However, we might also use your personal data for other purposes, as stated below, and for any additional purposes stated at the time of collection:
- Enable good customer service, like correcting incorrect information or sending information you requested e.g. newsletter;
- Information on ordering a service is stored and analyzed, as well as the basis for offers and discounts as well as promotion of both general and targeted nature;
- In order to manage customer profiles, conduct analyses and market research;
- For system administration and for obtaining statistical data about the behavior and patterns of our users, this does not identify any individual but occurs at aggregated level;
- To develop, deliver and improve our products and services through analysis of your behavior on our websites and app;
- Personal data is also used for analysis to perform segmentation/profiling, in order to develop targeted offers and services;
- To send you information and promotion via SMS, email, app, push or other digital contact routes such as social media since you have an active customer relationship with us;
- To contact you via app, SMS, email or post about other offers, promotions or services that we believe may be of interest to you, please note that you may decline this promotion at any time;
- To provide you with relevant recommendations, offers, and custom services based on what other people with similar behaviors have been interested in, what you have chosen for service, looked at and shown interest in;
- To help us develop our site and app to be more useful and to enhance your user experience of the platforms offered through the Climeon by customizing the display of the services to the device being used;
- To provide system support and services (warranty service, recall information, etc.);
- For product development purposes, for example to improve system performance, quality and safety done by ourselves and our chosen third-party recipients or suppliers.
Sometimes collecting and using personal data is necessary for the purposes of legal obligations or is necessary to protect the interests of Climeon. Your personal data may therefore be used:
- To comply with legal requirements or lawful authority requests;
- To protect our legal rights, for example to investigate potential violations of our terms and conditions or to detect, prevent or disclose fraud or other security issues.
LEGAL BASIS OF PERSONAL DATA COLLECTION
By submitting data to Climeon, you provide your permission for us to register and store information about which service you requested and processing the specified personal data for the specified purposes. As a legal basis for treatment, Climeon will refer to the fulfilment of agreements, legitimate interest or consent. If Climeon uses legitimate interest as a basis, it will only be done for the purposes 13 and 14 stated above.
For most processing acts, you are able to terminate our use of your personal data by updating your preferences or terminating a particular service. You have the right to revoke your consent at any time. Please direct a request for withdrawal of consent to firstname.lastname@example.org.
Where reasonably practical or as required by applicable law, we will, in collecting or registering your personal data, provide you with (i) specific information as to the purposes of the processing of your personal data, (ii) the identity of the data controller, (iii) the identities of any third parties to whom the data may be disclosed and (iv) other information which may be necessary to ensure that you are able to safeguard your rights.
RECIPIENTS OF YOUR PERSONAL DATA
We restrict access to your personal data to Climeon employees and suppliers who need to use the information in order to process it on our behalf partners for the above purposes, and who are contractually required to keep your personal data secure and confidential. We aim to choose the option for data processing services that best safeguards the integrity of your personal data towards any third party.
We will only retain your personal data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. This means that once you have consented to our processing of your personal data, we will retain your data in accordance with the consent given and/or until you revoke your consent. If you have revoked your consent, we may nevertheless retain certain personal data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not obtained your consent to the processing, the data will only be retained for as long as such a period of time as permitted by law.
“System-recorded data” will be save locally for one year on each module and on the server provided by us or our third party supplier for as long as it is necessary.
DISCLOSURES TO THIRD PARTIES
No data is sold to or shared with third parties for other purposes than the above.
Climeon will, as a general rule, only disclose your personal data to a third party if we have received your consent to do so. You will be informed of the third parties involve before giving your consent. If you have provided such consent, but wish to revoke it, please contact the third party directly.
However, we may share your personal data without your consent, unless we consider your consent necessary in the individual case or your consent is required by law, in the following situations:
- Situations in which disclosure is required by law; and
- Situations in which disclosure is necessary for the purpose of a legitimate interest pursued by Climeon (for example in order to protect our legal rights, as described above).
Climeon strives to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.
INFORMATION AND ACCESS
As stated in the “Notice” section above, we may provide you with specific information concerning our processing of your personal data when collecting or registering such data. You have the right to request, and receive free of charge, information on (i) what personal data relating to you we process, (ii) where the personal data is collected, (iii) the purpose of the processing, and (iv) with which recipients or categories of recipients the personal data is shared. Requests for such information must be made in writing and be personally signed by you, and include information on name, address and, preferably, your e-mail address. You also have the right to request that we correct, block or delete any incorrect data relating to you. Requests should be sent to the legal entity stipulated in the end of this document. Your requests will be dealt with in a prompt and proper manner. Requests to delete personal data will be subject to any applicable legal requirements. Where the applicable law provides for an administrative fee for complying with such a request, such a fee may be charged by Climeon.
Climeon reserves the right to amend this policy from time to time. The date of the last modification is stated in the end of this document.
In order to exercise your right to have information or access to your data, please use the following contact details. Climeon AB, email@example.com.
This policy was published 21/05/2018