This Privacy Notice sets out how SALUS Controls Limited and its subsidiaries ,including, in particular, Salus Controls plc (collectively, "SALUS Controls", "we", "us" and "our"; when we use these terms we are referring to the company in the group that is responsible for processing your data), will process your personal data, to allow customers or end users to control various Internet connected and smart home products, devices and equipment (collectively, "Device" or "Product") remotely through our SALUS branded technology and mobile software applications, whether accessed through the application itself or our website (collectively, "App" or "Apps").
This Privacy Notice covers users in the United Kingdom ("UK") and countries in the European Economic Areas ("EEA") of the following Internet connected Devices and Apps:
Any other Devices and/or Apps provided by us Any reference to "you" or "your" shall mean the user of the App and Device and includes any individual or commercial users. Customers and users in the US and other countries outside of the UK and EEA are served by our sister company, SALUS North America Inc.
Personal data or personal information refers to information in any form that can identify an individual. This includes any data, attributes or activities associated with an identifiable person or can be combined to identify a person. Any personal data you supply to us via our Apps or Devices will be treated in accordance with applicable data protection laws.
When you provide us with personal data about others, you must ensure you notify the relevant individual(s) before sharing their information and present this Privacy Notice (or your own legally compliant privacy notice), explaining that their personal information will be processed in accordance with the relevant Privacy Notice. By accepting our Privacy Notice you are confirming you have met this requirement and will comply with all applicable laws relating to the personal data of the relevant third party.
In order to register an account with us you must be 18 years old. Our Devices and Apps are not intended for or directed at persons under 18 years of age.
By connecting our Devices to the Internet and using our Apps you are accepting the terms of this Privacy Notice. If you do not agree with this Privacy Notice, then please refrain from downloading and using our Apps, or connecting our Devices to the Internet.
SALUS Controls Plc is the headquarters for the SALUS Controls Group and is a company located in Rotherham registered in the United Kingdom (company number: 05057362; registered address as Units 8-10 Northfield Forge Way, Parkgate, Rotherham, South Yorkshire, S60 1SD). For the purposes of the European Union ("EU") General Data Protection Regulation ("GDPR"), SALUS Controls Plc acts as the data controller responsible for determining the purposes and means of any processing of your personal data.
SALUS Controls has appointed a Group Data Protection Officer ("DPO") for you to contact if you have any questions or concerns about our personal data policies or practices. The DPO can be contacted via email at: dataprotection@salus-tech.com, or by post at:
Other affiliate companies in the EU that form the SALUS Controls Group include:
SALUS Controls Plc and its affiliate companies above are subsidiaries of SALUS Controls Limited. SALUS Controls Limited is a holding company incorporated in the British Virgin Isles (BVI) and is wholly owned by the Computime Group Limited, which is registered in Hong Kong.
QL Controls Sp. Z o.o. Sp.K. ("Agent") is a company registered in Poland and is an exclusive and sole Agent appointed to sell SALUS Controls Limited Devices in select markets.
SALUS Controls will collect and process your information when we have one or more of these reasons:
Generally, we do not rely on consent as a legal basis for processing your personal data.
We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature within the App. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
The table below describes the personal data SALUS Controls collects from users of our Apps and Devices, how we may use such personal data, and the reasons or purposes we rely on to do so.
| TYPE OF PERSONAL DATA | REASON / PURPOSE DETAILS |
|---|---|
|
Account Registration or Profile Information This is the personal data you enter and submit to register details on our App and includes:
A Device Identifier is a number that is automatically assigned to your Device when you access our servers. Our computers identify your Device by its Device Identifier. |
Basis for Processing: CONTRACT This information is used to meet our contractual obligations and provide our services to you as described when you purchase our Devices, and in the Terms and Conditions you accept when you download and use our Apps. For example, we use this information to:
|
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Basis for Processing: LEGITIMATE INTEREST We have a legitimate interest to use this data to:
Refer to "Your Communications Choices" below for details on how to update your choices. |
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|
SALUS Device and App Information This is the personal data passively, automatically or voluntarily sent to us when you install and use our Devices and Apps, and includes:
We also receive Device and App properties and information that will be treated as personal data when combined with Account or Profile Information for as long as it remains combined:
The IP address associated with a smart device, phone or computer may provide an approximate location when you connect to our App, but this will be no more precise than the city, state or country. |
Basis for Processing: LEGITIMATE INTEREST We have a legitimate interest to use this data to:
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SALUS Controls uses cookies to enable functionality of our Apps and improve the user's experience. Cookies are small text files which are stored in the memory of your computer or other device such as mobile phones or tablet devices. Cookies are created when you visit a website or load an App that uses cookies.
We use cookies to save information about registered users on our Apps such as your username and password, provide secure log in, assess how our Apps are used, and personalize your experience.
It may be possible to disable some cookies through your computer, tablet or mobile device browser settings. Please note, however, that certain features of our services may not be available if cookies are disabled or deleted. For more details about cookies and details of how to disable and delete cookies, please visit www.youronlinechoices.eu.
The list below details the cookies that are used by our Apps:
| App | Cookie Name | Description - What does this cookie do? | Retention / Expiry |
|---|---|---|---|
| SALUS iT500 | PHPSESSID | Identify the client and save the login status | Browsing session |
| SALUS-iT500.com (Web) | PHPSESSID | Identify the client and save the login status | Browsing session |
| SALUS-iT500.com (Web) | LG[one] | Remember username / email when 'Keep me logged in' is selected by user. | 1 month |
| SALUS-iT500.com (Web) | LG[two] | Remember encrypted password when 'Keep me logged in' is selected by user. | 1 month |
| SALUS Smart Home | _device_service_session | Identify the client and save the login status | Browsing session |
| SALUS Smart Home | _session_id | Identify the client and save the login status | Browsing session |
To fulfil our contractual obligations we require our users to provide certain categories of personal data as described above. Although failure to provide information will not generally prevent users of SALUS Controls products from operating their Devices manually, in some cases those users will not benefit from the full user experience and not be able to connect or control our Devices remotely through our Apps. Please refer to the user guide of the SALUS branded Device you own for instructions on how to use the relevant Device manually.
Some of our Apps offer the functionality to switch off "Data Collection" within the App Settings. Please refer to settings within the App you use. Where Data Collection is switched off this means the App will be automatically disabled and your mobile device or computer cannot be used to manage your equipment or service, and you will also not receive important alerts or notifications.
SALUS Controls will only share personal data with others when we are legally permitted to do so.
SALUS Controls is a global group of companies with subsidiaries and affiliates across Asia, North America and Europe supporting us to develop, engineer and sell our Devices and Apps, and provide technical support to users. We may share your personal data with these group companies, acting as joint controllers or processors of personal data, for the purposes set out in the table above. We also use third party data processors to process personal data on our behalf who help provide and support our products and services. Some third party data processors are based outside of the UK or are part of an international group of companies. Further details of these providers are set out below.
As a result of the above, personal data may be transferred, stored and accessed outside the countries where we and our data processors are located. This includes countries outside the European Economic Area ("EEA"). The laws in some countries may not provide as much legal protection for your personal data as in the EEA.
SALUS Controls take steps to ensure all personal data is provided with adequate protection and that transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an appropriate framework that protects the fundamental rights of anyone in the EU for such international data transfers, such as the EU-US Privacy Shield or a European Commission approved standard contractual clauses. If you would like more information on our international data transfer mechanisms please contact us via the details in section "Data Controller and Data Protection Officer"
Personal data held by us may be transferred to the following categories of third party (whether as data processor or joint controller):
SALUS Controls is committed to keeping personal data secure. We endeavour to apply suitable safeguards including technical, administrative and physical measures designed to protect the privacy and security of your personal data.
SALUS Controls also minimizes the risk to your rights and freedoms by limiting access to personal data to only those who have a business need and not collecting or storing special categories of information about you through our Apps or Devices. We require third party data processors to safeguard personal data and only use your personal data for the purposes we specify.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to and from our Apps or Devices. Once we receive your information, we will use strict measures and security features to try to prevent unauthorised access.
SALUS Controls will keep your personal data for as long as is reasonably necessary for the purposes we have described. These periods vary depending on the nature of the information and your interactions with us, our legal basis for processing the information and the requirements imposed on us by law and regulations. The retention period may also be affected by our litigation, accounting or reporting requirements. When we no longer need (or are obliged) to process your personal data, we will take reasonable steps to securely destroy your information or permanently de-identify it.
The GDPR and other countries' privacy laws provide certain rights over your personal data. If you have any questions about how we process your personal data or wish to exercise any of your rights, please contact us via the details in section "Data Controller and Data Protection Officer".
In certain instances, you have the right to:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing. SALUS Controls will nevertheless give users a choice to receive marketing and promotional communications. If you wish to stop receiving such communications, you can update your preference at any time by the following methods:
Note - Opting out of promotional emails will not end transmission of important service-related emails that are necessary to the on-going use of our services.
SALUS Controls hopes that you won't ever need to, but if you do want to complain about our use of personal data, please contact our Data Protection Officer using the contact details in section "Data Controller and Data Protection Officer".
If you do not feel we have been able to resolve your complaint satisfactorily you can lodge a complaint with the data protection regulator in the United Kingdom - the Information Commissioner's Office ("ICO"). For further information on how to complain to the ICO, please refer to the ICO website: https://ico.org.uk/global/contact-us/.
This Privacy Notice was last updated on [9 March 2020].
We recognise that transparency is a continual responsibility, so we will keep this Privacy Notice under regular review and updated. Any changes to this notice will be posted on this page, so please check back frequently.