FIRE
ANGEL WI-SAFE GATEWAY - PRODUCT PRIVACY NOTICE
We take your privacy very
seriously. We ask that you read this privacy notice carefully. It sets out
important information about the operation of your Fire Angel Wi-Safe Gateway
product and about:
·
who we are;
·
how
and why we collect, store, use and share information about you
(known as "personal data");
·
how
long we will keep your personal data;
·
your rights in relation to
your personal data;
·
how to contact us (and
supervisory authorities) if you have a complaint.
Fireangel Safety Technology
Limited is a private limited company, registered under the laws of England and
Wales, with company number 3641019 and whose registered address is Bridge
House, 4 Borough Street, London Bridge, London, SE1 9QR.
We are the "controller"
of personal data we collect from you or you provide to us. This means that when
we collect and use your personal data, we are responsible for ensuring that
your personal data is lawfully and properly processed and our conduct is
regulated by the General Data Protection Regulation (Regulation (EU) 2016/679)
("GDPR"). Our registration number under the Data Protection Public
Register is ZA059289.
When the following words
with capital letters are used in this Privacy Notice, this is what they mean:
|
App |
means the Fire Angel Wi-Safe mobile application software (version [1.0] and any updates, future version or supplements). |
|
Nominee |
the individual (if any) nominated during the App setup process (via the App) to receive email notifications about the Product via the Service. |
|
Product |
means the Fire Angel Wi-Safe Gateway product. |
|
Product Software |
means the software that is embedded in the Product, which enables it to function. |
|
Service |
means the Fire Angel Wi-Safe Connect service, made available to you and accessed via the App. |
|
"we" "us" and "our" |
means Fireangel Safety Technology Limited. |
2. PERSONAL DATA WE MAY COLLECT FROM YOU
The
following table explains what personal data we will or may collect about you
and how it will be collected.
|
Category
of personal data |
What the personal data is and how it is collected |
|
Information
you give us ("Submitted Information" and "Nominee Information") |
The personal data you give us may include: your first and last names, address, e-mail
address, telephone number, country of residence, enquiries you submit to us
about the Product, the Product Software, the App and/or the Service,
information about problems/defects you are experiencing with the Product, the
Product Software, the App and/or the Service and/or details relating to why
you are corresponding with/contacting us ("Submitted Information") You may also (if you choose to) provide us with
the email address of a Nominee ("Nominee
Information"). We may collect this personal data: ·
when
you fill in and submit (via the App) forms we ask you to complete in relation
to the Product, the Product Software and/or the Service during the in-App
set-up process for the Product; ·
when
you fill in and submit (i.e. via the Internet) forms we ask you to complete
in relation to the Product, the Product Software and/or the Service; ·
by
corresponding or communicating with us, including by telephone, by letter or
by email. |
|
Information
we collect via the Product, Product Software, the App and/or the Service ("Product
Information" and "Operational Information") |
The personal data we collect may include: ·
technical
information, comprising the type of Product you use, a unique product
identifier (for example, the serial number and/or model number of the
Product) the MAC address of the Product's network interface, IP address,
network information, carrier information, cellular network provider, device
screen size, time zone setting, Product Software version number ("Product Information"); ·
details
about the operation of the Product and/or the Product Software, comprising
the activation state of the Product (i.e. whether the Product is turned on,
connected to our network and operating within normal parameters (which is
determined solely by us)), the dates and times at which the alarm in the
Product has been triggered (e.g. by smoke or carbon monoxide) and if and when
the alarm in the Product has been silenced subsequently, the dates and times
at which the "test" button on the Product has been pressed, battery
charge level and other diagnostic information about the Product and its
performance ("Operational
Information"). This personal data will be collected
automatically during the
normal operation of the Product (via the Product Software and the Service). |
We need to collect the above
personal data, so that the Product and the App can perform their function and
so that we can provide the Service. If you do not provide the above personal
data to us, it may prevent the Product, the Product Software and/or the App
from operating correctly and it may delay or prevent us from providing the
Service.
Under the GDPR, we can only
use personal data if we have a legal basis for doing so.
The legal basis on which we
use your personal data is that the use of your personal data described in the
table below is necessary for the
performance of that contract with you or to take steps, at your request, before
entering into that contract (i.e. your agreement to the End User Licence Agreement shown in the
mobile app which forms a contract between you and us, under which we are
legally bound to provide the Service and under which we allow you to use the
App and the Product Software (subject to the terms and conditions set out in
the End User Licence Agreement)
The legal basis on which we
use personal data of third parties (i.e. the Nominee and/or Operational Information
generated by people other than you who interact with the Product and/or the
App) is that the use of that personal data is
necessary for the purposes of our legitimate interests (i.e. for the success,
growth and protection of our business in complying with our obligations under
the EULA shown in the mobile app) and
for the purposes of the legitimate
interests of the owner of the premises in which the Product is installed (i.e.
for the operation of the Product and the safety of those premises and any persons
living in those premises).
We use the information we collect
about you (i.e Submitted Information, Nominee
Information, Product Information and Operational Information) in the following
ways:
|
Category
of personal data |
How and why we use your personal data |
|
Submitted
Information |
Used by us: ·
so
that we can we can register your Product on our Fire Angel Wi-Safe network; ·
so
that the Product can (i.e. via the Internet) connect to our network and
perform its function; ·
in
order for the Service to operate in accordance with the End User Licence Agreement shown in the mobile app;
·
to
notify the Nominee that they have been nominated by you as a Nominee in
respect of the Service; ·
to
notify you that we are ending the Service in accordance with the End User Licence Agreement shown in
the mobile app; ·
provide
you with customer service and support in relation to the Product, the Product
Software, the App and/or the Service, if and when
you contact us and ask us to do so; and ·
monitor
the quality of our products, their operation and/or our products' compliance
with applicable laws and regulations. |
|
Nominee
Information |
Used by us: ·
to
notify the Nominee that they have been nominated by you to receive email
notifications (described in the box below) in respect of the Service; ·
in
the event that the alarm in the Product is triggered, send automated email
notifications to the Nominee (if you ask us to, by providing us with their
email address) as described below in "Disclosure of your
information" (i.e. in accordance with the preferences selected by the
Nominee); ·
to monitor
the quality of our products, their operation and/or our products' compliance
with applicable laws and regulations (for example, to check the dates/times
at which Product notifications (as described below) were sent to the
Nominee). |
|
Submitted
Information Product
Information Operational
Information |
Used by us, so that we can: ·
identify
your Product on our network (and distinguish it from other products on our
network); ·
monitor
the Product and its operation and use in connection with the Service. We will
use the information gathered on an aggregated and anonymised basis to
ascertain behaviour patterns in respect of the use made of and/or interaction
with the Product from time to time (i.e. when our “Predict” service is in
use). For example, the Product Software will tell us the number of times the
alarm in the Product is triggered and subsequently silenced over a period of
time and we will use the information we gather to understand the frequency of
risk patterns where fire/temperature/CO risk is identified; ·
in
the event that the alarm in the Product is triggered, send automated
notifications to you (including "push" notifications, where you
have indicated you would like to receive them (i.e. by ticking the push
notification's check box in your device settings)) via the App; ·
in
the event that the alarm in the Product is triggered, send automated
notifications to your Nominee (if you ask us to, by providing us with their
email address) by email as described below in "Disclosure of your
information" (i.e. in accordance with the preferences selected by the
Nominee); ·
analyse
faults with the Product that are reported to us via the Service and to
provide customer assistance in respect of such faults in accordance with any
applicable warranty in respect of the Product; ·
develop
and/or improve the technical operation and/or quality of our
products/services and/or any software used in connection with our
products/services. |
We may also use the information you provide to us in an aggregated
and anonymous form for research purposes and to help us make development,
marketing, sales and/or other business decisions.
We may associate/combine
any category of information with any other category of information (for
example, we may associate/combine Submitted Information with Third party
Information) and will treat the combined information as personal data in
accordance with this Privacy Notice for as long as it is combined.
4. DISCLOSURE
OF YOUR INFORMATION
At any time during which
the Product, the Product Software and/or the Service are in use, we may
disclose some or all of the data we collect from you
to the following third parties:
|
Category of data |
Recipient |
|
Submitted Information Operational Information |
The Nominee(s): Where
(and only where) during the in-App set-up process and/or during your use of
the App you provide us with an email address to which you would like us to
send email notifications about the Product, we will send automated notifications
to that email address comprising: ·
alerts about faults that have
arisen with the Product; ·
alerts about the dates and times
at which the alarm in the Product has been triggered; ·
alerts about the dates and times at which the
"test" button on the Product has been tested. |
|
Submitted Information Operational Information |
Amazon: If (and only if)
you link the Service with Amazon’s Alexa service, so that you can submit
questions to the Service via Alexa about the status of your Product, your
data may be disclosed to Amazon. The data sent to Amazon will depend on what
name you give to your Product on the Service (e.g. “John Smith’s kitchen
alarm” or “221b Baker St kitchen alarm”), as part of the Submitted Information. When you submit questions
to the Service via Alexa about the status of the Product, the Service (and
not Amazon) will automatically review the data held on our cloud servers to
find the answer to the question. The Service will create a text instruction
(i.e. the answer to the question, which may contain Submitted Information
and/or Operational Information) and send it to Amazon for Alexa to read out
(e.g. “John Smith’s kitchen fire alarm is faulty” or “221b Baker St alarm was
last activated on 6 January 2018”). Other than the text instructions that are
created when questions are submitted to the Service via Alexa, we will not
send any other data to Amazon. Amazon will control,
store, process and transfer the data it receives from us in accordance with
their Privacy Policy https://www.alexa.com/help/privacy
. For information about the data controllers who form part of Amazon
and about how those data controllers will store, process and transfer your
data, please read Amazon’s Privacy Policy https://www.alexa.com/help/privacy
|
We may need to
share your personal data with other third parties:
·
where disclosure of the
information is in our legitimate interests (i.e. for the success, growth and
protection of our business), including:
o
with prospective sellers or buyers of businesses or assets,
if we plan to sell or buy any business or assets, but we will only do so after
the prospective seller or buyer has entered into an agreement with us to
protect the confidentiality and security of your personal data;
o
if Fireangel Safety Technology Limited or substantially all
of its assets are acquired by a third party, in which case personal data held
by it about users of the Product/Product Software/Service will be one of the
transferred assets;
o
in order to enforce or apply the EULA and/or any other
agreements or to investigate potential breaches and/or to protect the rights,
property or safety of Fireangel Safety Technology Limited, our customers, or
others.
·
where disclosure of the
information is necessary for compliance with a legal obligation to which we are
subject, including:
o
if we are under a duty to disclose or share your personal
data in order to comply with any legal or regulatory obligation or request, in
which case we may have to disclose your personal data to law enforcement
agencies and regulatory authorities.
We may allow other IT
service providers to handle your personal data if we are satisfied that we have
a legal basis to share the same with them and they take appropriate measures to
protect your personal data.
5. WHERE
WE STORE YOUR PERSONAL DATA
Personal data you provide
to us by corresponding with us by telephone, email or otherwise howsoever will
be filed and stored at our offices (at Fireangel Safety Technology Limited,
Vanguard Centre, Coventry, CV4 7EZ).
Information which we
collect from and about you (including Submitted Information, Product
Information and Operational Information) will also be stored using the Amazon
Cloud service, via an account which we control and administer. The information
stored using the Amazon Cloud service is a distributed cloud platform, and
therefore the information we collect is not stored at one specific address.
Nevertheless, all the information you provide to us and which we collect will
be stored at a destination within the European Economic Area ("EEA").
We will hold your personal
data for the following duration:
·
Submitted Information: For as long
as your subscription to the FireAngel connect system (i.e. the Service) remains
live, plus 3 years;
·
Nominee Information: For as long
as the Nominee's email address is designated by you as a Nominee on the
FireAngel connect system (i.e. the Service) remains live, plus 3 years;
·
Product Information: For as long
as your subscription to the FireAngel connect system (i.e. the Service) remains
live, plus 3 years; and
·
Operational Information: For as
long as your subscription to the FireAngel connect system (i.e. the Service)
remains live, plus 3 years;
We
will not retain and process your personal data other than for the purposes set
out in this Privacy Notice.
When
it is no longer necessary to retain your personal data, we will delete or
anonymise it.
7. YOUR RIGHTS
You have the following rights in respect of your personal data,
which may be exercised free of charge (unless the request is manifestly
unfounded or excessive, in which case we may charge a reasonable fee or refuse
to act on the request):
|
Right |
Description |
|
Access |
The right to be provided with a copy of your personal data. |
|
Rectification |
The right to require us to correct any mistakes in your
personal data. |
|
To be forgotten |
The right to require us to delete your personal data - in
certain situations. |
|
Restriction of processing |
The right to require us to restrict processing of your
personal data — in certain circumstances (e.g. if you contest the accuracy of
the personal data). |
|
Data portability |
The right to receive the personal data you provided to us,
in a structured, commonly used and machine-readable format and/or transmit
that data to a third party
— in certain situations. |
|
To object |
The right to object: ·
at any time to your personal data
being processed for direct marketing (including profiling); ·
in certain other situations to
our continued processing of your personal data (e.g. processing carried out
for the purpose of our legitimate interests). |
|
Not to be subject to automated individual decision-making |
The right not to be subject to a decision based solely on
automated processing (including profiling) that produces legal effects
concerning you or similarly significantly affects you. |
For further information
on each of those rights, including the circumstances in which they apply, please contact us or consult the guidance issued by the UK Information Commissioner’s Office
(ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
·
email, or write to us (see below: ‘How to
contact us’);
·
let us have enough information to identify you (e.g. your full name,
address and client or matter reference number);
·
let us have proof of your identity and address (a
copy of your driving licence or passport and a recent utility or credit card
bill); and
·
let us know what right you want to exercise and the
information to which your request relates.
8. KEEPING
YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent your personal data from being accidentally lost, or used or accessed unlawfully. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
9. HOW TO COMPLAIN
We hope we can resolve any query or concern you may raise about our use of your personal data (see below ‘How to contact us’).
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioners Office, who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
10. CHANGES
TO THIS PRIVACY NOTICE
This Privacy Notice was published in March 2020.
We may change this Privacy Notice
from time to time. Any changes we may make to our Privacy Notice in
the future will be posted on our website (at www.fireangeltech.com)
and, where appropriate, notified to you by e-mail. Please check our website
frequently to see any updates or changes to this Privacy Notice.
11. HOW TO CONTACT US
Please contact us by post, email or telephone if you have any questions about this privacy notice or the personal data we hold about you. Our contact details are as follows:
Post: Fireangel Safety Technology Limited, Vanguard Centre, Coventry, CV4 7EZ
Email: technicalsupport@fireangeltech.com
Telephone: 02477
717570