Introduction
[MOTAN Cloud](Here in after referred to as “we”, “us”) has made great efforts to protect your personal data. We collect and process your personal data fully complying with the requirements of EU General Data Protection Regulation and within the scope stated in the Privacy Policy (hereinafter referred to as “this Policy”) when providing you with [MOTAN Cloud Smart System](hereinafter referred to as “this system”).
Please read and understand this Policy before submitting your personal data to us. Please note that this Policy applies only and exclusively to this application. Please refer to other privacy policies if you use our other products and services.
This Policy will help you understand the following content:
Questa politica ti aiuta a comprendere quanto segue:
1.Who we are
2.What personal data we collect
3.What is our legal basis for processing your personal data
4.How we manage your personal data
5.How we entrust a third party to process, share, transfer and disclose your personal data
6.How your personal data is transferred outside EU/EEA
7.What rights you have
8.How we protect children’s personal data
9.How to update this Policy
10.How to contact us
1.Who we are
Our company [Köber SRL Dumbrava Roșie Sucursala Vaduri], is registered at [Neamț, România]. As the controller determining the personal data processing activity, we have full rights to this system and will be responsible for all matters related to this system.
2.What personal data we collect
To provide you with better service and realize the basic functions of this application, we collect the following personal data for each function:
(1) In order for you to successfully register and verify your account, we need to collect your user name, password, e-mail address and mobile phone number; according to your wishes, selectively collect your detailed address, telephone number, boiler brand, boiler model , Boiler item number, boiler serial number;
(2) In order to enable you to operate the related equipment smoothly and ensure the normal operation of the equipment, we need to collect your IP address, city, time zone, equipment information (including but not limited to WIFI box number, WIFI box mac address, SSDI, temperature Controller number, boiler model, boiler identification code, etc.) and equipment real-time data (including but not limited to software version, time, temperature, fault code, etc.);
(3) In order for you to smoothly feedback on equipment failures and push failure information to you when necessary, we need to collect your email address, mobile phone identification code, and App version information.
3.What is our legal basis for processing your personal data
We collect and process your personal data within the scope necessary for realizing the above functions. We conduct such personal data processing activities in order to fulfill our obligations under the wall-mounted furnace purchase agreement and to provide you with the product and related services (including this application). Therefore we rely on the necessity of performing the contract as the legal basis for such data processing activities.
Cookies
To enable you to log in normally, we will collect a small data file called cookie. Cookies are plain text files stored on computers as a network server, usually containing identifiers, site names, numbers and characters, etc. We will not use cookies for any purpose other than the above and will take appropriate technical measures to fully safeguard their security.
4.How we manage your personal data
4.1 Storage of your personal data
Your personal data will be stored properly on [AliCloud] in [Frankfurt, Germany] ，[Email reminders will be sent to users who have not logged in for 1 year. If the user does not respond, the corresponding data will be destroyed after one month]
4.2 Security of your personal data
The server we use has the industry-leading security capacities to protect your personal data. In addition, by strengthening the administrative and technical safeguards (such as the access control system, encryption and security training on employees) of personal data, we will endeavor to protect your personal data from unauthorized access, use, disclosure, modification, damage, loss and any other forms of unlawful processing.
The network environment is not absolutely secure. In the event of a personal data security incident, we will fulfill our notification obligations, which may include informing you of the basic circumstances and possible impact of the security incident, the actions we have taken or will take, and recommendations that you can take precautions and reduce risk on your own initiative. We will endeavor to inform you in a timely manner by telephone, email, notification, etc., and we may make an announcement on this website under certain circumstances.
If you know or have reason to believe that your personal data has been lost, stolen, misappropriated or otherwise infringed, or if there is any actual or suspected embezzlement of your personal data, please contact us.
5.How we entrust a third party to process, share, transfer and disclose your personal data
In principle, we transfer your personal data to third parties only with the notification and your authorization. In order to ensure the security of your personal data, we will follow the principle of minimization and comply with applicable legal requirements when sharing, transferring or disclosing your personal data with the following third-parties:
(1) Service providers: such as companies that support our IT, help us process we hold and provide us with underlying cloud service，such as AliCloud. We have signed data processing agreements with related service providers to ensure the lawful and secure personal data processing.
SDK provider: In order to enable you to use the functions and services of this application normally, we will embed the SDK of authorized partners or other similar applications in this application.
When pushing notifications to your mobile phone, Alibaba Cloud Push SDK or Push SDK needs to collect your device information, application list information, network information, and location-related information; Push SDK needs to collect your device information, application list information, and network Information and location-related information.
Purpose: Used to push device change information and some user operation information.
When you use the App to close unexpectedly or make an error, the Bugly SDK will collect the crash information of the App;
Purpose: Used for App function optimization and troubleshooting
when you use the App to add a device, the EasyLink SDK will collect the wifi information of your current location.
Purpose: Used to configure device network information to ensure that the device is normally connected to the Internet
We will use the API for authorized partners to obtain personal information(API), Software Work Development Kit (SDK) conduct strict security testing, and agree strict data protection measures with authorized partners to ensure that they collect and process your personal data in accordance with our agreement and the provisions of this privacy policy.
(3) Government or regulators: on the basis of ensuring the security and legality of the disclosure, we may also disclose your minimal and necessary personal data to the law enforcement agencies/governmental authorities, if we believe that such disclosure of your personal data complies with any applicable law or responds to related legal process, after checking with specific law enforcement authorities on the basis of the disclosure.
(4) Business transfer: for the transfer of your personal data during merger, acquisition, bankruptcy liquidation, asset transfer, or other similar transactions, we will require the new company or organization possessing your personal data to be bound continuously by the requirements, commitments and safeguards described in this Policy. For instance, the new company or organization should not use your personal data beyond the said purposes. Otherwise, we will require the new company or organization to reapply for corresponding authorization from you.
6.How your personal data is transferred outside EU/EEA
In order to normally operate and maintain this application, the service providers we entrusted needs to access your personal data remotely from countries or territories outside EU/EEA (including China) where the data protection laws in effect are not as stringent as those in EU/EEA. To fully secure your personal data, we have signed the cross-border data transfer Standard Contractual Clauses (SCC) as the transfer mechanism. You can contact us to obtain the corresponding data transfer agreement text.
7.What rights you have
You are entitled by law to the following rights in respect of your personal data:
（1）INFORMATION AND ACCESS: You have the right to be provided with certain information about our processing of your personal data and access to that data.
（2）RECTIFICATION: If your personal data changes, we encourage you to inform us of the change. You have the right to require inaccurate or incomplete personal data to be updated or corrected.
（3）ERASURE: You have the right to require that your data be erased in certain circumstances where it is no longer necessary for us to process this data in relation to the purposes for which we collected or processed the data.
（4）DATA PORTABILITY: You may have the right to have the data transferred to you or another controller in a structured, commonly used and machine-readable format, where this is technically feasible.
（5）RIGHT TO RESTRICTION OF PROCESSING: You have the right to restrict our processing of your personal data while your request for data rectification or objection to personal data processing is being considered, if we no longer need to process your data but you need that data in connection with a legal claim, or if our processing is unlawful but you do not want us to erase the data. If this right applies, we will continue to store your data but will only further process it with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another person, or for reasons of important public interest.
（6）RIGHT TO COMPLAINTS: If you have any objection to our data processing activities and this Policy, you have the right to lodge a complaint with the regulatory authorities in your country or region.
We guarantee that you may lawfully exercise the relevant rights described in this section by contacting us or by changing settings. Please note that we may ask you to verify your identity and request before taking further action on your request. In general, we will not charge you any fees unless such requests exceed the usual requirements. If you have any questions, you can contact us.
8.How we protect children’s personal data
Our products and service are primarily aimed at adults. We do not knowingly collect personal data of children under 13 without the parents or guardian’s consent. Where the parents or guardian consent to collect and process children’s data, we will only use or disclose these data within the scope of parents or guardian’s explicit consent and strictly complying with GDPR. If we find that we have collected a child’s personal data without prior verifiable consent of his/her parents or guardian, we will take measures to delete related personal data as soon as possible.
9.How to update this Policy
We may update this Policy from time to time. If this Policy is revised, we will promptly release the latest revised version of this Policy in prominent positions of this website for your awareness. If there is any major change to this Policy, we will notify you of such change in a more prominent way by means of email, text message or website pop-ups.
10.How to contact us
If you have any opinion, suggestion or question about this Policy, or have any request or query for your personal data, please contact us in the following manner. In principle we will reply within 30 days.
Contact Information: office.vaduri@kober.ro
Address: Alexandru cel Bun, loc. Vaduri, Strada Zorelelor, Nr 25, Județ Neamț