Moxiam Privacy Policy

This Privacy Policy was updated on: December 16, 2020.

SmartHome4U Sweden AB with org. No. 559111-3195 (“SH4U”,”we”, “us” and “our”) is the data controller for the processing of your personal data.

The integrity and security of your personal information is, and will remain, very important to us. Therefore, we want to describe in a transparent way how we process your personal data (“Privacy Policy”). This Privacy Policy is aimed at:

1. Customer
2. Resident
3. App User

This Privacy Policy along with our General Terms have been provided to the Resident in a printed format within the packaging sent together with the Service Hardware as part of the information packet intended to be read by the Resident prior to installation.

This Privacy Policy is also available:

1. as a downloadable version from moxiam.com(“the Website”);
2. upon request, emailed to by contacting: support@moxiam.com;
3. upon request, posted to you by contacting: support@moxiam.com.

Contents Of The Privacy Policy

1. Introduction
2. The scope of the Privacy Policy
3. Where do we collect your personal information from?
4. What categories of personal data do we process, for what purpose and on what legal basis do we base our processing of personal data?
5. With whom do we share your personal information?
6. Will we transfer your personal data outside the EU / EEA?
7. What rights do you have?
8. How can you contact us?

1 Introduction

SH4U provides a web-based and application-based service (“Moxiam “) to consumers. Moxiam aims to improve the everyday life of its users by offering an opportunity for them to stay at home for as long as possible as the get older while offering peace of mind to their relatives as users of the Service. Moxiam offers a solution which collects information about how its user moves in their home and which notifies the relative of any incidents considered not normal. The Customer and the Resident choose who they wishes to be able to access the information through the Application. In this way, the App user should in turn be able to communicate better and be there for the Resident without always having to be physically present.

Moxiam uses its own hardware in the form of, among other things, sensors and a network lock (“Service Tools”) that are installed at the Resident´s home to collect information to enable the Service. The Service uses a mobile application to display information accessible to the App user (“Application”) and or the Website. Collectively the use and the installation of the Service Tools with the Application and/or Website create the service (the “Service”).

2. The Scope Of The Personal Data Policy
This Privacy Policy covers our processing of your personal data such as the Resident, the Customer and/or the App User. We have adapted the content of this Privacy Policy so that, depending on whether you are the Resident, the Customer and/or the App User, you get a better overview of how we process your personal data. This Privacy Policy contains, among other things, information about the purposes for which we process personal data, with whom we share your data and what rights you have in relation to your personal data.

4. What Categories Of Personal Data Do We Process, For What Purpose And On What Legal Basis Do We Base Our Processing Of Personal Data?
We process personal data in the manner and for the purposes described herein. For each purpose, we base provide a legal basis for the processing of your personal data. A legal basis can be: (i) the processing is necessary to fulfill the performance of the agreement where you are a party to the agreement or (ii) by legitimate interest where SH4U or a third party has a legitimate interest that outweighs your interest in your personal data not being processed.

The tables below show the legal basis on which SH4U bases its processing for each purpose and for how long we will retain your personal data.

If you are the Customer

Purposes:
• Create and administer a Customer Account

Processes performed:
• Use the personal data collected to create and administer your Customer Account that enables you to access the Service;
• The creation of a login function and verification of users including you as the Customer at login
• Identification
• Management of user and customer settings
• Storage
• Reading

Categories of personal data:
• Name
• Registered and delivery address
• Telephone number
• Information about your type of subscription
• E-mail address
• Your password for the Service
• Acceptance of the General Terms (incl. Version)

Legal basis: performance of agreement.

Retention period: For this purpose, we will process your personal data during the term of the service contract and for a period of two (2) years thereafter to be able to handle any complaints and for the time necessary to establish, assert or defend legal claims.

Purpose:
• To be able to handle ordering / purchasing the Service

Processes performed:
• Storage
• Reading
• Registered and delivery address verified against SPAR
• Identification
• Delivery of the Service’s tools (including notification and contacts regarding the delivery).

Categories of personal data:
• Name
• Registered and delivery address
• Amount

• Payment confirmation
  and associated subscription
  Legal basis: performance of agreement.

Storage period: For this purpose, we will process your personal data until the purchase has been completed (including delivery and payment) and for a period of three (3) years thereafter to be able to handle any complaints and or warranty matters and for the time necessary to establish, assert or defend legal claims.

Purposes:
• Handle Customer Service and Support matters.

Treatments performed:
• Storage
• Reading
• Identification
• Communication and answering any questions concerning the Customer Service and Support (by phone or digital channels, including social media)
• Investigations of and support for complaints and complaints related to the use of the Service, for example when we help you solve a problem that has arisen in connection with you installing the Service’s Tools.

Categories of personal information
• Name
• Contact information (e-mail address, mobile number, address)
• Information provided by the Customer during the complaint case
• Information about time of purchase, place of purchase, possible errors/complaints
• Verification of customer identity by e-mail

Legal basis: Legitimate interests. The processing is necessary to satisfy our and your legitimate interest in handling complaints and customer service matters.

Storage period: For this purpose, we will process your personal data until the customer service case is closed and during the time necessary to establish, assert or defend legal claims.

If you are the Resident

Purposes:
• To be able to provide the Service for the Resident

Treatments performed:
• Storage
• Reading
• Profiling in the form of monitoring and analysis of movement patterns
• Conversion to statistics for establishing general behavioral patterns
• Comparison with historical general behavioral patterns.

Categories of personal data:
• Movement patterns
• Direction-generating patterns
• Individual behavior patterns
• Date and time
• Your sensor location
• Number of people living in your home
• Your home’s ‘name’ in the Service

Legal basis: Balancing of interests. The processing is necessary to satisfy our legitimate interest in providing the Service. Alternatively if you are also the Customer, performance of the agreement.

Storage period: For this purpose, we will process your personal data during the service agreement’s contract period with the Customer and for a period of two (2) years thereafter to be able to handle any complaint matters and for the time necessary to establish, assert or defend legal claims.

Purpose
• To be able to provide the Service to the App User

Treatments performed:
• Storage
• Reading
• Profiling in the form of monitoring and analysis of movement patterns
• Transformation into statistics for establishing general behavioral patterns
• Comparison with general behavioral patterns
• Transmission of the information to the App user

Categories of personal data:
• Movement patterns
• Directional patterns
• Individual behavior patterns
• Dates and times
• Notice of deviant behavior

Legal basis: Balancing of interests. The processing is necessary to satisfy our legitimate interest in providing the Service. Alternatively if you are also the Customer; performance of agreement.

Storage period: For this purpose, we will process your personal data during the service agreement’s period with the Customer and for a period of (2) years thereafter to be able to handle any complaint matters and for the time necessary to establish, assert or defend legal claims.

If you are the App user

Purpose:
• To be able to provide the Service to the App user

Treatments performed:
• Storage
• Reading
• Logging of received information

Categories of personal data:
• Date and time
• Name
• E-mail address
• Telephone number
• Your password for the Service

Legal basis: Balancing of interests. The processing is necessary to satisfy our legitimate interest in providing the Service. Alternatively if you are also the Customer, performance of contracts.

Storage period: For this purpose, we will process your personal data during the service agreement’s contract period with the Customer and for a period of [2 years] thereafter to be able to handle any complaint matters and for the time necessary to establish, assert or defend legal claims.

If you are the Customer, the Accommodation and/or App User

Purpose:
• To fulfill legal obligations

Processing performed:
• Storage
• Reading
• Accounting of financial transactions
• Necessary handling for fulfillment of legal obligations according to legal requirements, judgments or government decisions (eg. the Accounting Act)
• Management of the data subjects’ rights

Categories of personal data:
• Name
• The customer and the App user’s contact information ( eg delivery address and e-mail)
• The customer’s payment history and information
• Your correspondence
• Communication history

Legal basis: Legal obligation. This collection of your personal information is required by law. If the information is not provided, our legal obligation cannot be fulfilled.

Storage period: For accounting purposes, we will process your personal data for 7 years and otherwise the storage period required by law or otherwise during the time necessary to establish, assert or defend legal claims.

Purposes:
• Marketing

Treatments performed:
• Storage
• Reading
• Create targeted offers and discounts and inspirational
mailings

• Analysing the information we collect for the purpose to categorise you into a suitable target group that is the basis for targeted offers and discounts and other customised communication.

Categories of personal data: 
• Name
• The customer and the App user’s contact information (eg. e-mail address and delivery address)
• Type of registered (the Customer, App user or the Resident)

Legal basis: Balancing of interests. The processing is necessary to satisfy our legitimate interest in providing our services.

Storage period: For this purpose, we will process your personal data for 1 year after the service agreement’s contract period with the Customer / App user has expired.

Purposes:
• Evaluate, develop and improve our Service and Service Tools for the customer group as a whole.

Treatments performed:
• Storage
• Reading
• Adapting services to be more user-friendly (eg. changing the user interface to simplify the flow of information or to highlight features that are often used by customers in our digital channels)
• Development of data to develop and improve our range of Services
• Development of data to improve IT systems in order to generally increase the security of our Customers
• Analyze the information we collect for the purpose. Based on the information we collect ( eg purchase history, age and gender), you are sorted into a customer group (so-called customer segment) for which analyzes are then performed on an aggregate level, without any connection to you as an individual. The insights from the analysis form the basis for improving our services.

Categories of personal data:
• Age
• Postal code
• Correspondence and feedback regarding our services
• Purchase and user-generated data
• Technical data concerning devices used and their settings (eg. language setting , IP address, browser settings, time zone, operating system, screen resolution and platform). Information about how you have interacted with us, e.g.how you have used the Service, login method, where and for how long different pages have been visited, response times, download errors, how to reach and leave the service, etc.

Legal basis: Legitimate Interest. The treatment is necessary to satisfy our and our customers’ legitimate interest in evaluating, developing and improving our services, products and systems.

Storage period: For this purpose, we will process your personal data for three (3) years after collection.

Which Who Do We Share Your Personal Information?
In order to fulfill the purposes set out above, SH4U will share your personal information with the following recipients:

(a) Users of the Service:

The App User and the Customer for you as the Resident,
The Customer for you who are an App user,
(B) Third Parties for the performance of the Service:

 

6. Will We Transfer Your Personal Data Outside The EU / EEA?
We may transfer your personal data to countries outside the EU/EEA. If the European Commission has not decided that a country to which your personal data is transferred has an adequate level of protection for your personal data, we will provide a description of the protection measures taken or the legal basis on which we base the transfer to ensure that your personal data is transferred. in accordance with European data protection law. For information on whether we have transferred your personal data to a country outside the EU/EEA, which countries we have transferred your personal data to and what security measures have been taken for the transfer, please contact us by sending a written request to the contact details stated at the end of this Privacy Policy .

7. Cookies
We use cookies and other similar technologies to enhance the user experience and make the most effective use of the service. A cookie is a piece of data sent from an online site that is visited and stored locally on the user’s browser. The purpose for using cookies is to maintain data related to device identity, device-level preferences, user accounts, account settings, user preferences as well as to evaluate and compile statistics about user activity. Please see our cookie policy for more information: https://moxiam.com/cookie-policy.

8. What Rights Do You Have?
Below is a summary of the rights you have under European data protection law. It does not cost you to exercise these rights and you can exercise them by contacting us. Do not hesitate to contact us if you have any questions regarding your rights.

Please note that we will always make an assessment of a request to exercise a right to determine if the request is justified. Not all rights listed below are absolute and exceptions may be made. In addition to the rights set out below, you always have the right to lodge a complaint with a supervisory authority regarding our processing of your personal data.

(a) Right of access. Upon request, you are entitled to receive a copy of your personal data that we process and also to receive additional information regarding our processing of your personal data.

(b) Right to rectification. You have the right to have your personal information corrected and / or supplemented if it is incorrect and / or incomplete.

(c) Right to erasure. You have the right to request that we delete your personal data without undue delay in the following situations:

– the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

– you make a legitimate objection to the processing of your personal data;

– the personal data has been processed illegally; or

– deletion is required to fulfill a legal obligation.

(d) Right to limitation of treatment. You have the right to request a restriction on the processing of your personal data in the following situations:

– the accuracy of the personal data is under investigation;

– the processing is illegal or no longer necessary for the purposes of the processing, but you oppose the deletion of personal data and instead request a restriction of the processing;

– we no longer need the personal data but you need the personal data to establish, exercise or defend legal claims; or

– you have objected to the processing of your personal data and such objection is under investigation.

(e) Right to data portability. In certain circumstances, you have the right to receive the personal data that concerns you and that you have provided to us to transfer this to another service provider if the processing of the personal data is based on the performance of an agreement.

(f) General right to object. You have a general right to, at any time, object to the processing of your personal data based on our legitimate interest. If you object, we must show that we have compelling justification for such processing or that we need the personal data to establish, exercise or defend legal claims.

(g) Right to object to direct marketing. You have the right to object at any time to such processing of your personal data that takes place for direct marketing purposes. If you do this, we will not continue to process your personal data for such purposes.

How Can You Contact Us?
You can get in touch with us as follows:

SmartHome4U Sweden AB
Data Protection Officer Jonas Valkonen

Postal address: Kvarnbergsgatan 2, 411 05 Gothenburg, Sweden. Phone number: 010-888 73 66

Email: support@moxiam.com