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Data Processor Agreement

 

1 BACKGROUND AND PURPOSE

  1. IOT4ALL ApS, company reg.no.  39085666 (“the Processor”) provides various IT service to the customer (the “Controller”) as describes in the parties’ underlying agreement(s) concerning the Services (the “Services”).
  2. The Processor processes personal data on behalf of the Controller as part of the performance of the Services. Accordingly, the parties have concluded this agreement (the “Data Processor Agreement”) which constitutes an integrated part of the parties’ agreement(s) concerning the Services. In case of conflict between any agreement between the Parties and this Data Processor Agreement, this Data Processor Agreement shall take precedence.
  3. To the extent that the applicable data protection regulation entails a need to adjust the Data Processor Agreement, the parties agree that the content of this Data Processor Agreement shall be renegotiated between the Parties.

2 SCOPE

  1. The Processor is authorized to process personal data on behalf of the Controller as part of the performance of the Services on the terms and conditions set out in this Data Processor Agreement.
  2. The Processer is only allowed to process personal data pursuant to this Data Processor Agreement on behalf of the Controller and only to the extent the processing is necessary for delivering the Services.
  3. The Processor is not allowed to process the personal data for its own purposes.
  4. The Processor will process ordinary categories of personal data. This includes all personal data the Controller provides to the Processor, e.g. personal data uploaded to the Processor’s by the Customer when using the Services including GPS-data, data on electrical or gas consumption, price data concerning electrical or gas consumption, utility used and data on the Controllers buildings, addresses, ID number, contact information etc. No special or sensitive categories of personal data is processed.
  5. To the extent the Processor becomes aware that special/sensitive categories of personal data has been provided to the Processor, such personal data will be deleted instantly and without prior notice to the Controller, unless the Processer receives instructions from the Controller allowing the Processer to process such categories of personal data.
  6. The Processor will process personal data pertaining to all categories of data subjects on behalf of the Controller incl. citizens, and any other stakeholders, which may also include children, to extent such data is provided by the Controller.
  7. The Processor may only process the personal data on the terms and conditions of the Controller’s instructions unless processing is otherwise required under EU law or national law applicable to the Processor. In this event, the Processor shall notify the Controller of the legal requirement before processing is carried out unless such notification would be in contravention to the law in question.
  8. The Processor may anonymize data. Such anonymized data, may be used, without the instructions of the Controller and for the Processors own purposes.

3 DURATION

  1. This Data Processor Agreement shall be effective for the duration of the provision of the Services and shall terminate automatically when the Processor no longer processes personal data on be-half of the Controller as part of the Services.
  2. Upon termination of the Data Processor Agreement, the Processor shall return to the Controller all personal data (if the Controller does not already have such data) and shall delete any existing copies unless EU law or national law requires the Processor to store the personal data.
  3. Processor may keep any data which is not classified as personal data.

4 CONTROLLER’S OBLIGATIONS

  1. The Controller is responsible for com-plying with applicable data protection law in relation to the personal data processed by the Processor on behalf of the Controller.
  2. The Controller’s responsibility includes in particular the following, the compliance with which is warranted by the Controller:

  • The Controller has the necessary legal basis to process, and to permit the Processor to process, the personal data processed as part of the performance of the Services.
  • The specification of personal data in clause 2 of this Data Processor Agreement is exhaustive and no other personal data is being processed as part of the performance of the Services.
  • The instructions given are legal and sufficient for the Processor to fulfill its obligations.

5 PROCESSOR’S OBLIGATIONS

  1. Security measures
    1. The Processor shall initiate and implement appropriate technical and organizational measures to achieve a security level that matches the risks involved in the processing activities carried out by the Processor for the Controller.
    2. The technical and organizational measures shall be determined, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risk of varying likelihood and severity to the rights and freedoms of natural persons.
    3. The Processor shall ensure that persons authorized to process the Controller’s personal data have committed them-selves to confidentiality or are subject to an appropriate statutory obligation of confidentiality.  
  2. Documentation for compliance with the processor’s obligations
    1. The Processor shall make available to the Controller all information required to demonstrate compliance with the requirements of the Data Processor Agreement. The Processor shall give access and contribute to audits, including inspections, conducted by the Controller or another auditor authorized by the Controller. This clause can also be fulfilled by the Processors submission of an audit report.
    2. The Processor shall notify the Controller immediately if, in the Processor’s view, an instruction to make information available or give access to audits or inspections is contrary to applicable Danish law or data protection provisions in other EU law or national law.  
  3. Notification of personal data breaches

  • The Processor shall notify the Controller without undue delay after becoming aware of a personal data breach.  

  1. Assistance to the Controller
    1. At the Controller’s request and taking into account the nature of the processing, the Processor shall assist the Controller by appropriate technical and organizational measures, with the fulfilment of the Controller’s obligation to respond to requests for exercising the data subjects’ rights as set out in the applicable legislation on the processing of personal data.
    2. At the Controller’s request and taking into account the nature of the processing and the information available to the Processor, the Processor shall also assist the Controller with ensuring compliance with the Controller’s obligations to: a) implement appropriate technical and organizational measures; b) notify the supervisory authorities of personal data breaches; c) communicate a personal data breach to data subjects; d) carry out data protection impact assessments; and e) perform prior consultations of the supervisory authority.

6 COMPENSATION

  1. The Processor is entitled to receive payment for time spent as well as other direct costs incurred by the Processor relating to assistance and services provided by the Processor at the request of the Controller. Such assistance and services may include but is not limited to assistance with reporting a security breach, provision of data to data subjects, audits, cooperation with supervisory authorities and assistance for compliance with request from data subjects.
  2. The Processor is entitled to receive payment for time spent as well as other direct costs incurred by the Processor relating to changes in the Controller’s circumstances or the instructions. The costs may include but is not limited to changes as a result of new risk assessments and impact assessments as well as changes necessitated due to the Controller is being subject to law or than Danish law.
  3. The compensation is calculated in accordance with the agreed hourly rate in the agreement(s) regarding delivery of the Service. Where no agreement regarding hourly rate has been made, the compensation is calculated in accordance with the Processor’s generally applied hourly rates.
  4. Notwithstanding anything to the contrary in this clause 6, a party does not have the right to claim compensation for assistance or implementation of changes to the extend where such assistance or changes are a direct consequence of the party’s own breach of this Data Processor Agreement.

7 USE OF ANOTHER PROCESSOR

  1. The Processor may use another processor (a sub-processor) without the Controller’s prior approval.
  2. An updated list of sub-processors can be found either on the Processor’s website or made available through the IT solution provided by the Processor. Such list can also be provided by request to the e-mail address fm@iot4all.co. Further, any updates to the sub-processors will be notified to the Controller, e.g. via e-mail, newsletters, system notification etc. The Controller may object against the addition or substitution of a sub-processor to the extent the Controller has a reasonable basis for such objection.
  3. Where the Processor engages a sub-processor, the same data protection obligations as set out in this Data Processor Agreement shall be imposed on that other sub-processor by way of a contract, in particular providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of the general data protection regulation. Notwithstanding the foregoing, the Controller accepts that the processing of data by the sub-processor may be subject to the standard terms and conditions that applies to such sub-processor, provided that the Controller is informed hereof. Such information regarding the sub-processors can be found on the Processor’s website, the IT solution provided by the Processor or otherwise provided to the Controller.
  4. The Processor is fully liable to the Controller for the performance of the sub-processor’s obligations.

8 DATA EXPORT

  1. The Processor will seek to keep all personal data within the European Union or EEA; it is not the intention of the Processor to export data. However, the Controller accepts that the Processor may transfer personal data to a country outside the European Union or EEA – provided that the Processor, prior to the transfer, has secured the necessary lawful basis for such transfer - or that the Controller has instructed the Processor to do so (e.g. by using the services provided by the Processor to send information to recipients outside of the EU or EEA), in which case the Controller is responsible for securing the necessary lawful basis.
  2. If the Controller under the employed transfer basis is required to be a direct contractual party to an agreement, e.g. the EU Commission’s model con-tracts for the transfer of personal data to third countries, the Processor shall be authorized to conclude such agreement on behalf of the Controller. The content of this Data Processor Agreement shall not be deemed to change the content of such transfer basis, incl. the EU Commission’s model contracts.

9 AMENDMENTS

  1. The Processor may amend this Data Processor Agreement by giving 90 days prior written notice, such notice to include the amendment(s). If the Controller does not wish to be bound by the amended Data Processor Agreement, the Controller shall terminate the affected part(s) of the parties’ agreement(s) concerning the Services for convenience, by giving written notice hereof prior to the end of the Processor’s notice period with effect at the expiry of such notice period.

10 LIMITATIONS OF LIABILITY

  1. The limitation of liability in the under-lying agreement(s) concerning the Services applies to the Processor’s processing of the personal data under this Data Processor Agreement, incl. with regard to art. 82(5) of the general data protection regulation.

11 DISPUTES AND CHOICE OF LAW

  1. This Data Processor Agreement is subject to the laws of Denmark, except for (a) Danish International Private Law principles leading to the application of law other than Danish law and (b) the United Nations Convention on Contracts for the International Sale of Goods (CISG).
  2. Any dispute arising out of or in connection with this Data Processor Agreement which is not resolved by negotiation shall be settled by a competent court at the Processor’s venue.

Privacy Policy

 

 

GENERAL INFORMATION

We attach great importance to the protection and handling of your personal data in accordance with the applicable law, in particular in accordance with the General Data Protection Regulation of 27 April 2016 ("GDPR"). Our goal is to provide you with full information and control regarding the processing of your data and the availability of tools that allow you to take advantage of the rights arising from the law.

Below we present information on which personal data we process about you, how we process your personal data and the legal basis under which we process your personal data. You can also read about your rights as a data subject, how we care for the security of your data and who we share it with. If you have additional questions about how we use your personal data, write to us at the following email address: fm@iot4all.co.

WHO IS THE CONTROLLER FOR THE PROCESSING OF YOUR DATA?

IOT4ALL ApS, company reg.no.  39085666 , Aabenraa 4, 1124 Copenhagen K, Denmark CVR ("Easy Home","we", "us" or "our"), is the controller for the processing of your personal data.

HOW CAN YOU CONTACT US?

You can send an email to: fm@iot4all.co  or by regular mail to:  Easy Home Smart Systems ApS, Hyskenstræde 12, 1207 Copenhagen K, Denmark

WHEN DO WE PROCESS YOUR DATA?

We process personal data about you in the following situations:

  • You have set up an account on one or more of our platforms: Connected Home Hub, HomeManager ("Platform"). The platform operates based on the Terms and Conditions, which you can read here.
  • You have sent us a support request ("Ticket").
  • You have sent us a message via the Contact form.
  • You have applied for a job with us.
  • You are our contact-person with our suppliers, customers or any other third party. 
  • You have requested a demo of our system.
  • You have agreed to receive commercial information.
  • You have decided to make purchases.

We focus on the transparency of processing your personal data. If you have any question about the process or rules of processing, please contact us.

We process your data in accordance with applicable law, ensuring that it remains current and correct. Therefore, from time to time we will remind you about the need to update the data by sending a message to the e-mail address provided by you.

Your personal data will not be processed for automated decision making without your consent.

WHICH PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES DO WE PROCESS THE DATA?

You have set up an account on the Platform

When you set up an account on the Platform, whether directly via a Easy Home app, the Easy Home home page or via an administrator or other third party, we will process personal data about your e-mail, telephone number, house nickname, activity logs, data generated by the data, data collected by the installed devices (e.g. data from electronic door locks og on electrical consumption), list of installed devices, push notification devices enabled, geo-location of the house based on the gateway location (IP).

We will process your personal data for the following purposes:

  1. Service availability - setting up the Platform account, from which you will have access to the services,
  2. Identification of you as a user on the platform,
  3. Service & billing related communication with you,
  4. Normal operation of the system, including data received from installed devices,
  5. Sending you notifications from the installed devices (e.g. temperature low or the like),
  6. Quality of service and reliability,
  7. Identification of your resources and providing budget information to you.

The legal basis for processing your data will be to fulfil the contract concluded with you (GDPR article 6(1)(b)); to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our legitimate interest (GDPR article 6(1)(f)). 

It is up to you to decide whether and what data you provide us with on the Platform, but remember that when setting up an account on the Platform, providing certain data will be mandatory to provide you the service, because without them you will not be able to login to your secure account, have access to the functionalities of the Platform, manage and control your integrated devices and/or receive notifications from the devices.

You have sent us a Ticket

When you set sent us a Ticket we will process personal data about your name, address, e-mail, phone number, data collected by your devices installed on the Platform.

We will process your personal data for the following purposes:

  1. Contact you and reply to the Ticket you placed.
  2. Investigate and provide support if needed.
  3. Send a replacement of the faulty device, if, after an investigation process, the Technician’s Report recommends so.

We use Zoho Desk (https://desk.zoho.eu/) and Zoho CRM (https://crm.zoho.eu/) to process the Ticket and the data associated with it.

The legal basis for processing your data will be to fulfil the contract concluded with you (GDPR article 6(1)(b)); to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our legitimate interest (GDPR article 6(1)(f)). 

You have applied for a job with us

When you apply for a job with us we will process personal data about your name, address, e-mail, telephone, information included in your CV, application and LinkedIn profile.

We will process your personal data for the following purposes:

  1. To perform a recruitment process in the best possible way.
  2. To contact you with the recruitment process results.

We use BambooHR (https://www.bamboohr.com) for holding this data.

The legal basis for processing your data will be to enter into a contract with you (GDPR article 6(1)(b)); to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our legitimate interest (GDPR article 6(1)(f)). 

You are our contact person with our suppliers, customers or any other third party 

When you are our contact person with our suppliers, customers or any other third party we will process personal data about your name, e-mail, telephone number(s), title, company you work for. In this context, we use Zoho CRM (https://zoho.com/crm/) for data storage, Zoho Projects (https://projects.zoho.eu/) for project management and Zoho Sign (https://sign.zoho.eu/) for signing legal documents.

We will process your personal data for the following purposes:

  1. We process data in order to contact you and correspond with you as a contact person at a company.

The legal basis for processing your data will be to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our legitimate interest (GDPR article 6(1)(f)). 

You have requested a demo

When you request an Easy Home demo,  we will process personal data about your name, address, region, e-mail, telephone, company, company size and your title.

We will process your personal data for the following purposes:

  1. To provide you with a link to the demo page

We use Zoho tools (https://www.zoho.com/gdpr.html) such as Zoho Forms, Zoho CRM for handling this data.

The legal basis for processing your data will be to enter into a contract with you (GDPR article 6(1)(b)); to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our legitimate interest (GDPR article 6(1)(f)). 

You have agreed to receive commercial information

When you agree to receive commercial information, we will process personal data about your name and e-mail address.

We will process your personal data for the following purposes:

  1. If you give your consent, we will send (to the e-mail address provided by you) commercial information regarding the goods offered for sale in the Store, including promotional offers. 
  2. If you give your consent, we will send (on the mobile phone number provided by you) commercial information regarding the goods offered for sale in the store, including promotional offers.
  3. For statistical purposes for internal needs.
  4. In order to confirm the performance of our obligations and assert claims or defend against claims that may be directed against us, and in order to prevent or detect fraud.

The legal basis for processing your data will be to your consent (GDPR article 6(1)(a)); to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our or our partners legitimate interest (GDPR article 6(1)(f)). 

You are not required to give your consent to receive commercial information. If you give your consent, you will be able to withdraw it at any time by contacting the above data or clicking on the link that we send in each e-mail containing commercial information. Withdrawal of consent does not affect the correctness of data processing in the period before its withdrawal.

You have decided to make purchases in our Store

When you make a purchase in our Store, we will process personal data about your name, billing address, delivery address, email, phone number.

We will process your personal data for the following purposes:

  1. In order to carry out the sales contract concluded with you from the Store. 
  2. In order to conduct complaint processes.
  3. For statistical purposes for internal needs.
  4. In order to confirm the performance of our obligations and assert claims or defend against claims that may be directed against us, and in order to prevent or detect fraud.

The legal basis for processing your data will be to fulfil the contract concluded with you (GDPR article 6(1)(b)); to comply with a legal obligation (GDPR article 6(1)(c)); or to fulfil our or our partner’s legitimate interest (GDPR article 6(1)(f)). 

We will process data from you only to the extent necessary to fulfil the purposes described above. It is up to you to decide whether and what data you provide us with, but remember that when making purchases in the Store, providing certain data will be mandatory to perform the contract of sale, because without them we will not be able to process your order. Failure to provide the data we require results in failure to place an order.

WHO WILL WE DISCLOSE OR SHARE YOUR PERSONAL DATA WITH?

Depending on the personal data involved and the purpose of the processing and the context in which personal data is included, we may disclose your personal data to third parties (as independent data controllers). We may also share personal data with our suppliers when necessary for the purpose of the cooperation (as data processors).

You have set up an account on the Platform

Our Platform and Apps are using: Amazon Web Services (AWS), Push notification services (Firebase Cloud Messaging), Google Play Store, Apple App Store, Google Analytics and Firebase Crashlytics.

You have sent us a Ticket

We use Zoho Forms (https://forms.zoho.eu/) and Zoho Desk (https://desk.zoho.eu/) for support to our customers via NorthQ’s website. The information that you provide us while placing the ticket is processed in Zoho Desk by our Support Team. Please see Zoho’s Privacy Policy here: https://www.zoho.com/privacy.html.

You have applied for a job with us

We use BambooHR (Privacy Policy: https://www.bamboohr.com/privacy.php) to collect the job applications. If you applied directly or via a career portal such as Graduateland, we will save your application on the company’s Google Drive for relevant parties to have access to it.

You have sent us a message via Contact Form on the website

We use Zoho CRM as the Customer Relationship Management System (Privacy Policy: https://www.zoho.com/privacy.html), so that the information provided via the contact form on www.easy-home.app is sent to us via Zoho Desk, using Zoho Forms.

You are our contact person with our suppliers, customers or any other third party

We use Zoho CRM (https://crm.zoho.eu/) as our Customer Relationship Management system. Please see the Zoho Privacy Policy here: https://www.zoho.com/privacy.html.  

You have agreed to receive commercial information

We will share your information with the entities providing on our request with the service of sending commercial information, such as:

  1. Zoho (Zoho’s Privacy Policy: https://www.zoho.com/privacy and https://www.zoho.com/gdpr)
  2. We may also share your personal data with other entities from the above categories with which we will establish cooperation.

You have decided to make purchases in our Store

We will pass your data to entities that cooperate with us in the performance of the contract for the sale of goods purchased by you.

We will share your data necessary for the delivery of goods to LEMAN International System Transport A/S (Leman’s Privacy and Cookie Policy: http://leman.dk/cookies) who will share your data with one of the following entities, depending on your choosing how to deliver the goods:

  1. GLS (General Logistics Systems),
  2. Other entities that will provide delivery services for goods purchased by you in the Store in the future.
  3. UPS
  4. FedEx,
  5. DHL Express,

Depending on your choice of payment method for purchased goods, we will share your data necessary for collection or payment for purchased goods to the following entities:

  1. PAYPAL - if you have chosen the PayPal.com payment system as the payment method (PayPal’s Privacy Policy: https://www.paypal.com/en/webapps/mpp/ua/privacy-full),
  2. Stripe - if you have chosen the embedded credit card payment solution as the payment method (Stripe’s Privacy Policy: https://stripe.com/en-dk/privacy).

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Wix’s Terms of Service (https://www.wix.com/about/terms-of-use), Privacy Statement (https://www.wix.com/about/privacy) and Wix’s Billing Services and PCI Compliance (https://support.wix.com/en/article/security-of-wixs-billing-services-and-pci-compliance).

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

We will seek to keep all personal data within the European Union or EEA; it is not our intention to export data.

HOW LONG WILL WE PROCESS YOUR PERSONAL DATA?

The personal data provided by you will be processed for the time necessary to fulfil the purposes described in this privacy policy. e.g.:

  • Your data may be retained for the period necessary for the fulfilment of the contract of sale, and for the period for defending us against claims that may be directed against us. This will be no longer than 10 years from the date you provided us with your data,
  • Your data in the Platform will be retained for as long as necessary for providing you access to the Platform. Therefore we will be processing your data as long as the service is required.
  • Personal data processed when you apply for a job with us, will usually be retained for the time required for the recruitment process. If you are not offered the job, we will either delete your information or request your consent to store your personal information for a longer time in order to include them in a future recruitment process. Information, we receive for unsolicited applications, are stored by us for six months. Information may also be stored for a longer time if you have been offered a job with us.

HOW ARE WE PROTECTING YOUR DATA?

We will ensure the confidentiality, integrity and availability of the personal data that we process through technical and organisational security measures.

We use a range of IT and organizational security measures aimed at minimizing the risk of data leakage, their destruction and disintegration, such as: firewall system, cyber security good practices, internal access procedures, data processing and emergency recovery, as well as a multi-level backup system.

All third party services are trusted platforms with big communities. NorthQ is using latest security standards in order to use, build on top off and/or integrate with those services.

Our Store operates on a platform with a very high level of security and we use a high level of encryption HTTPS/SSL connection in accordance with accepted best practices.

Remember that using the internet always brings with it the risk of certain security incidents, but we assure you that thanks to the implemented regular procedures, reviews of information systems and their updates, and active monitoring of critical points of the system, we want to reduce this risk as much as possible.

WHAT RIGHTS DO YOU HAVE IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA BY US?

According to the GDPR, you have a number of rights in connection with providing your personal data to us, such as:

  1. The right to know how your personal data is processed - if you have questions about whether and how we process your data, please contact us by sending information to fm@iot4all.co. We will be happy to answer them,
  2. The right to access and update data - you always have access to your personal data on your account in the Store and on the Platform (or via App). If you have not created an account in the Store or on the Platform, please contact us by writing to our Data Protection Officer requesting access to your data - we will inform you about your data and update it at your request,
  3. Under the terms of the GDPR, you also have the rights to:
    1. Data rectification - You can edit the data provided to us and update it.
    2. Data deletion - if you want us to stop processing your data, you can delete your account in the Store or on the Platform or report such a request to us. Remember, however, that this is not an absolute right and we may refuse to delete those of your data which we have a basis for still processing (e.g. the fulfilment of a legal obligation or pursuing claims or defending against claims that may be directed against us),
    3. Request to limit the processing of your data,
    4. Object to the processing of your data if the basis for processing is our or our partners legitimate interest or performance of tasks in the public interest,
    5. Object to the processing of your data, where personal data are processed for direct marketing purposes.
    6. Withdrawal of consent, if the data is processed on the basis of your consent,
    7. Data transfer, if the processing is based on a contract or your consent.

If you would like to exercise any of your rights please contact us on our email: fm@iot4all.co.

HOW LONG TIME WILL IT TAKE FOR YOU TO GET THE ANSWER FROM US?

We try to complete your requests as quickly as possible and answer your questions about your data. In any case, you should receive a message from us not later than within 30 days of receiving your request. During this period we will give you an answer or inform you about the extension of the deadline and explain the reasons. If we have doubts as to whether you are making a specific request, we may ask a few more questions to verify your identity.

INFORMATION ON THE COMPETENT AUTHORITY

If you feel that we are processing your personal data unlawfully, you can also file a complaint with Data Protection Agency in Denmark (https://www.datatilsynet.dk/).

If you have any questions related to the processing of your personal data by us or you want to use the rights resulting from the GDPR, please use the contact form or write directly to our Data Protection Officer: fm@iot4all.co.

UPDATES TO THIS PRIVACY POLICY

From time to time, we may need to update this privacy policy. We regularly review our privacy policy to ensure that it is updated, accurate and in accordance with applicable laws and principles for processing of personal data.

INFORMATION ON THE USE OF "COOKIES"

DEFINITIONS

  1. Administrator - means Easy Home Smart Systems ApS, Hyskenstræde 12, 1207 Copenhagen K, Denmark CVR 41278226, which provides electronic services and stores and gains access to information on User devices,
  2. Website - means a website or application under which the Administrator runs a website that operates in the following domains: http://easy-home.app
    Applications operate under the name Easy Home.
  3. Cookies - means IT data, in particular small text files, saved and stored on devices through which the User uses the Website pages,
  4. Administrator's Cookies - means Cookies placed by the Administrator related to the provision of electronic services by the Administrator via the Website.
  5. External Cookies - means Cookies placed by the Administrator's partners via the Website,
  6. Device - means an electronic device through which the User gains access to the Website,
  7. User - means an entity for which services may be provided electronically or with which an Agreement for the provision of electronic services may be concluded in accordance with the Regulations and legal regulations.

TYPES OF COOKIES USED

  1. Cookies used by the Administrator are safe for the User's Device. Under normal circumstances, it is not possible for viruses or other unwanted software or malicious software to enter User Devices via our cookies. These files allow identification of the software used by the User and adjusting of the operation of the Website individually to each User. Cookies usually contain the name of the domain from which they originate, their storage time on the Device and the assigned value.
  2. The administrator uses two types of cookies:

a) SESSION COOKIES: they are stored on the User's Device and remain there until the session of the given browser ends. The saved information is then permanently removed from the Device's memory. The mechanism of session cookies does not allow the collection of any personal data or any confidential information from the User's Device,

b) PERMANENT COOKIES: they are stored on the User's Device and remain there until they are deleted. Ending the session of a given browser or turning off the Device does not delete them from the User's Device. The mechanism of persistent cookies does not allow the collection of any personal data or any confidential information from the User's Device.

The User has the ability to limit or disable the access of cookies to his Device. If you use this option, the use of the Website will be possible, in addition to functions that, by their nature, require cookies.

THE PURPOSES FOR WHICH COOKIES ARE USED

  1. THE ADMINISTRATOR USES OWN COOKIES IN FOLLOWING PURPOSES:
    1. SERVICE CONFIGURATION
      1. adjusting the content of the Website pages to the User's preferences and optimizing the use of the Website pages,
      2. recognize the Website User's device and its location and properly display the website, adapted to his individual needs.
    2. AUTHENTICATION OF THE USER ON THE WEBSITE AND PROVIDING THE USER'S SESSION ON THE SERVICE
      1. maintaining the Website User's session (after logging in), thanks to which the User does not have to re-enter their login and password on every subpage of the Website;
      2. correct configuration of selected Website functions, allowing in particular verification of the authenticity of the browser session,
      3. optimizing and increasing the efficiency of services provided by the Administrator.
    3. IMPLEMENTATION OF PROCESSES NECESSARY FOR FULL FUNCTIONALITY OF WEBSITES
      1. adjusting the content of the Website pages to the User's preferences and optimizing the use of the Website pages. In particular, these files allow to recognize the basic parameters of the User's Device and properly display the website, tailored to his individual needs;
      2. proper operation of the affiliate program, allowing in particular verification of sources of Users' redirects to the Website's websites,
      3. enabling the use of the "Clipboard" and "Cart" functions on the Website.
    4. ANALYSIS AND TESTS AND WATCH AUDIT
      1. creating anonymous statistics that help us understand how the Website Users use Website pages, which allows improving their structure and content.
    5. ENSURING SAFETY AND RELIABILITY OF THE SERVICE
  2. THE SERVICE ADMINISTRATOR USES EXTERNAL COOKIES FOR THE FOLLOWING PURPOSES:
    1. presenting multimedia content on the Website, which is downloaded from an external website, e.g. youtube,
    2. collecting general and anonymous static data via analytical tools, e.g. Google analytics tools, such as Google Analytics (https://analytics.google.com/analytics/web/), Google Search Console (https://search.google.com/search-console/about), Google My Business (https://www.google.com/business/), but also Bing Webmaster (https://www.bing.com/webmasters), Evolution360 (https://evolution360.com/faq), Leadfeeder (https://www.leadfeeder.com/leadfeeder-and-gdpr/) and Zoho, such as Zoho Pagesense (https://www.zoho.com/pagesense/), Zoho Campaign (https://campaigns.zoho.eu/) and Zoho Marketing Hub (https://www.zoho.com/marketinghub/).
    3. logging in to the website using a social website, e.g. Facebook.com,
    4. use interactive functions to popularize the Website using social networking sites, including such as Facebook.com, Twitter.com,
    5. using the functions to facilitate communication via the Website, which are downloaded from an external internet service such as Zoho SalesIQ.

THE POSSIBILITY OF DETERMINING THE CONDITIONS FOR STORING OR ACCESSING COOKIES

  1. The User may independently and at any time change the settings for Cookies, specifying the conditions for their storage and access to the User's Device via Cookies. Changes to the settings referred to in the previous sentence, the User can make using the web browser settings. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the web browser settings or to inform them whenever Cookies are placed on the User's device. Detailed information about the possibilities and ways of handling cookies are available in the software (web browser) settings.
  2. The User may at any time delete cookies using the functions available in the web browser he uses.
  3. Limiting the use of cookies may affect some of the functionalities available on the websites of the Services.

Last revision on 27.02.2022

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