FIREANGEL 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 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.
- 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:
|App||means the FireAngel Wi-Safe mobile application software (version 1.6.2 for IOS and 1.07 for Android 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 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, made available to you and accessed via the App.|
|“we” “us” and “our”||means FireAngel Safety Technology Limited.|
- 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.
- HOW AND WHY WE USE PERSONAL DATA
Under the data protection law, 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 (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, 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) 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).
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
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|
|Used by us:
· so that we can 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;
· in order for the Service to operate in accordance with the End User Licence Agreement;
· 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;
· 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.
|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).
|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.
- 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 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.
|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.
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.
- 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”).
- 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;
- 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.
- 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):
|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.
- 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.
- 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.
- 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 https://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.
- 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
Telephone: 0330 094 5830