B2B Privacy Policy – OWNER

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 FireAngel 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.

 

1. WHO WE ARE

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 data protection laws including the Data Protection Act 2018 and 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:

Contract Service Provider	means the entity that installed the Product in your premises.
Product	means the FireAngel Wi-Safe Gateway product.
Product Software	means the software that is embedded in the Product, which enables it to function.
Service	means the FireAngel Wi-Safe Connect service.
“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“)	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 and/or the Service, information about problems/defects you are experiencing with the Product, the Product Software and/or the Service and/or details relating to why you are corresponding with/contacting us.   We may collect this personal data: ·      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 and 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, 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 it 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).
Information we receive from other sources (“Third Party Information”)	We work closely with other parties (including, for example, Contract Service Providers, technical services providers and distributors of the Product) to enable us to monitor the quality of our products and their operation and we may receive information from those other parties about you, about the Product, the Product Software and/or the Service.   The personal data provided to us may include: your first and last names, your email address and/or your correspondence address, your Product serial number and information about correspondence/contact you have had with them concerning the Product, the Product Software and/or the Service and/or its/their operation.   This personal data will be provided to us by third parties, including the entity who installed the Product in the premises where it is located.

We need to collect the above personal data, so that the Product can perform its 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 and Product Software from operating correctly and it may delay or prevent us from providing the Service.

 

3. HOW AND WHY WE USE YOUR PERSONAL DATA

Under the data protection law, we can only use your personal data if we have a legal basis for doing so. The legal basis on which we use your personal data (as 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 forms a contract between you and us, under which we are legally bound to provide the Service (subject to the terms and conditions set out in the End User Licence Agreement)).

We use the information we collect about you (i.e Submitted Information, Product Information, Operational Information and Third Party 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 register your Product on our FireAngel Wi-Safe network; ·      so that the Product can (i.e. via the Internet) connect to our network and perform its function; and ·      in order for the Service to operate or to notify you that we are ending the Service in accordance with the End User Licence Agreement.
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 a mobile software application (if you have downloaded and installed the same on a mobile device) and/or to a third party email address (nominated by you); ·      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.
Submitted Information Third Party Information	Used by us, so that we can: ·      provide you with customer service and support in relation to the Product, the Product Software and/or the Service, if and when you contact us and ask us to do so; ·      monitor the quality of our products, their operation and/or our products’ compliance with applicable laws and regulations; ·      contact you or the installer of the Product about issues/faults with/the performance of the Product, the Product Software and/or the Service

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 about you to the following third parties:

Category of data	Recipient
Submitted Information Product Information Operational Information	Contract Service Provider: We will disclose this data to the Contract Service Provider via our FireAngel Connected software, which will allow the Contract Service Provider to access, process, analyse and/or store the data for the purposes of enabling them to perform any contract they enter into with you and to: ·      monitor the operational status and usage of the Product; ·      receive alerts about faults that have arisen with the Product; ·      receive alerts about the dates and times at which the alarm in the Product has been triggered; ·      monitor the dates and times at which the “test” button on the Product has been tested. This is so that the Contract Service Provider can: ·      notify you if the Product is not connected to our network, ·      notify you if the Product has developed a fault; ·      send you email notifications about the dates and times at which the alarm in the Product has been triggered; ·      (if you have registered the FireAngel Wi-Safe Connect App) send push notifications to the FireAngel Wi-Safe App about the dates and times at which the alarm in the Product has been triggered; and/or ·      notify you to remind you to test your Product.
Submitted Information Product Information Operational Information Third Party Information	The entity from whom the Contract Service Provider purchased your Product (“Distributor“): we will disclose this data to the Distributor so that they can: ·      provide you with customer service and support in relation to the Product, the Product Software and/or the Service, if and when you contact us/them and ask us/them to do so; ·      communicate/correspond with us about customer service and support issues, faults and/or maintenance issues you are experiencing / have experienced in respect of the Product, the Product Software and/or the Service.
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. 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.

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:
• 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;
• 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;
• 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:
• 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”).

 

6. HOW LONG WE WILL KEEP YOUR PERSONAL DATA

Unless otherwise required by law or a regulatory authority, 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;
• Product Information: For as long as your subscription to the FireAngel connect system (i.e. the Service) remains live, plus 3 years;
• Operational Information: For as long as your subscription to the FireAngel connect system (i.e. the Service) remains live, plus 3 years;
• Third Party 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 you can exercise free of charge (unless your request is manifestly unfounded or excessive, in which case we may charge you 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 July 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.fireangel.co.uk) 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: connectedsupport@fireangeltech.com

Telephone: 0330 094 5830