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Cozify Privacy Policy

Last updated: May 24, 2018

Your privacy is important to Cozify. We developed this Privacy Policy to provide you with information on how we process your personal data when you use the Cozify Smart Home Hub, the Cozify app and other smart devices and services provided by Cozify.

“Personal data” is information relating to an identified or identifiable natural person.

Cozify is fully committed to support European Union General Data Protection Regulation (GDPR) and this privacy policy is updated accordingly.

Categories of Personal Data Processed by Cozify

Cozify Account Profile:

When you create a Cozify account, we ask some details about you and your home. This information is primarily gathered to identify your account (e.g. email) and to enable basic features of the Cozify (e.g. app language setting). Optional information is gathered to provide better personalized user experience.

PURPOSES AND LEGAL GROUNDS:

(a) Cozify processes your email address as part of sign up and sign in processes. The legal ground for processing your email address for this purpose is based on Cozify’s legitimate interest in protecting the security of your account.

 (b) Some account profile information is stored to the account for proper use of Cozify. These are for example approximate location based on IP address, time zone and language settings. The legal ground for this processing is our legitimate interest in providing an effortless smart home experience. For example, time zone and approximate geographical location are used for automation based on calculated local sun set and sun rise times.

(c) You can add optional information to your profile, such as your location and type of housing. This information is used to provide you with the best possible user experience as the notifications and instructions provided by the system are accurate for your situation. The legal ground for processing this information for these purposes is your consent. You can withdraw your consent by deleting this information from your account profile.

Event data, logs and application content:

With backend services, we provide the remote control, software upgrades, camera recording service, backups and other features. We also gather usage statistics from Cozify App, Cozify Hub as well as log errors and other diagnostic data. With your consent, the hub may also gather and send information of the events in your house, including data from sensors and devices for additional features and further analysis.

PURPOSES AND LEGAL GROUNDS:

(d) If you provide your opt-in consent for collecting event data from the Cozify Hub, Cozify will process it for the purpose of providing views and analysis to conditions and events in your house and to offer additional capabilities for the home automation based on historical data. The data may be de-identified and aggregated for analysis and research purposes. The legal ground for processing your event data is your consent. You may withdraw your consent at any time by sending a message to support@cozify.fi.

(e) If you activate camera features, Cozify will process (encrypt, convert) and store video clips from your cameras to backend servers. Cozify does not view or analyze the contents of the video clips in any way. The legal ground for processing and storing camera clips is your consent. You can withdraw this consent at any time by disabling camera streaming and/or storage features.

(f) If you activate notification functions within the app, Cozify will process your email address and phone number for the purpose of sending notifications (e.g., when you activate a function that notifies you or other users about possible intrusion to your home, fire or water leakage). The legal ground for processing your email address and phone number for this purpose is your consent. You can withdraw this consent at any time by disabling such notifications.

(g) We log software behaviour, usage data, user behavior (e.g. features used, frequency of use), device state information, mac address, operating system information, crash/diagnostic logs and information from the Hub, websites and our apps. The legal ground for processing this information is Cozify’s legitimate interest in resolving errors, providing quality product support as well as understanding how our customers interact with our products, apps and websites so we can enhance the user experience and improve the product and service.

Communicating with Cozify marketing, sales and support:

When you interact with our sales or customer support via email, telephone, online or in person, we collect personal data, such as your name, mailing and billing information, phone number, email address and contact preferences; and information about the Cozify products you own, such as their serial numbers and dates of purchase.

 PURPOSE AND LEGAL GROUND:

(h) We store information about your direct purchases from Cozify Web Store. This includes purchased products and their serial numbers, your name, shipping information and billing information. Cozify’s legitimate interest in storing purchase information is to provide means for recurring payments and to store legal accounting information. We also use this information to provide you our customer support.

(j) Cozify uses your email address for sending important information about your Cozify products, apps or account, such as important safety information, new features or material changes to this Privacy Policy to you. The messages may also contain information about ongoing promotions. The legal ground for processing your email address and name for these purposes is Cozify’s legitimate interest in providing you important safety or other relevant information about your Cozify products, apps or account or material changes to this Privacy Policy. It is possible to unsubscribe from these messages at any time from a link within the message.

(i) We track all customer support cases in a support system. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys. We use this information to provide you with customer and product support and to monitor the quality of the support we provide to our customers. The legal ground for processing this information for these purposes is Cozify’s legitimate interests in providing quality product support.

(k) With your consent, our customer support representatives may sign in to your Cozify account, if appropriate, to help troubleshoot and resolve your issue. The legal ground for signing in to your Cozify account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

(l) We track the activities associated with our online communication and marketing. We track sales funnels, follow campaign conversion rates, click rates, implement retargeting and so on. Cozify uses this data to analyze the level of engagement with its campaigns.

Categories of Recipients of Personal Data

Other Cozify users:

No-one else has access to your Hub information. Your activities and notifications are not shared with anyone by default. You may allow privileges for other Cozify users to access your Hub. You may also choose to have your alerts sent to other users and / or alert service providers.

3rd party service providers:

From time to time, we may share data in a de-identified and aggregated manner with or to companies that provide Cozify as part of their service portfolio for the purpose of enhancing the quality of features they provide, and with or to other third parties for research or other purposes.

Third-party app, platform or service providers with whom you ask Cozify to share your data:

If you choose to connect device/service that have their own user accounts, we will share the necessary personal data to verify the user identity in both services. This includes services such as Amazon Alexa, Google Home, Apple HomePod and Airpatrol.

We will not do this without your explicit consent. Once you decide to share data with other service provider, you should carefully review the third party’s privacy policy as well. You can choose to stop sharing data with the third-party at any time within your Cozify account by removing the connection between Cozify and the third-party service.

Third-party service providers:

Cozify uses the third-party services who provide technical platforms to implement Cozify’s product and services. Cozify constantly verifies that all these enabling service providers are compatible with Cozify Privacy Policy and follow GDPR regulation.

For example, we use:

  • Shopify is the provider of web shop functionality
  • Stripe and Maksuturva for processing payments
  • Mailchimp and Survey monkey for email campaigns and surveys
  • Amazon for our core infrastructure platform
  • We use Google Analytics for statistics (Find out how to opt-out Google Analytics)

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Cozify’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Transfers of Personal Data

Personal data regarding individuals who reside in a country in the European Economic Area or in Switzerland is controlled by Cozify Oy. The data of Cozify core product functionality resides in servers within the European Economic Area.

Systems that provide support functions for Cozify, such as web store, transfer the data outside EU in compliance with GDPR.

Cookies and Similar Technologies

To help analyze how you and other visitors navigate the Cozify Connect website, compile aggregate statistics about site usage and response rates, help diagnose any problems with Cozify’s servers and administer the Cozify web shop, we, with assistance from third-party analytics service providers, collect certain information when you visit our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click. We may use cookies, pixel tags, web beacons, clear GIFs or other similar tools on our site or in our email messages to assist us in collecting and analyzing such information. We use this information to provide better, more relevant content on our site, to identify and fix problems, and to improve your overall experience on our site.

If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.

If you reside in the European Union or other jurisdiction that requires us to obtain your consent to use cookies on our sites, then you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality, and you cannot choose to disable those cookies.

Children

We request individuals under 13 not to provide personal data to Cozify without their parental approval. If we learn that we have collected the personal data from a child under 13 with no parental approval, we will take steps to delete the information as soon as possible.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Cozify websites and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain your personal data as long as your Cozify account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

If you reside in a country in the European Economic Area or in Switzerland, then your personal data collected by Cozify is controlled by Cozify Oy, which is located at Linnoitustie 4B, 02600 Espoo. Cozify’s EU Data Protection Officer is located at the same address and can also be reached by email at info@cozify.fi.

If you reside outside of the European Economic Area and Switzerland, then the personal data collected by Cozify is controlled by Cozify Oy, Linnoitustie 4B, 02600 Espoo, Finland, which you can also contact by email at info@cozify.fi.

Your Rights

If you reside in the European Union, you have the right under the General Data Protection Regulation to request from Cozify access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws.

To request access to or rectification, portability or erasure of your personal data, or to delete your Cozify account, please contact support@cozify.fi.

If you live in the European Union and you wish to exercise your right to restriction of processing or your right to object to processing, contact Cozify’s EU Data Protection Officer at Cozify Oy at Linnoitustie 4B, 02600 or by email at support@cozify.fi. If you do not live in the European Union but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact Cozify Oy at support@cozify.fi.