Sentio – Data and Privacy Notice
This
Data and Privacy Notice applies to the use of and access to our
services and the provision of access to your data, in relation to the
products marketed under the name “Sentio” (the “System”) sold directly
or indirectly by Wavin B.V. Wavin B.V., located on Schiphol Boulevard
425, 1118BK Schiphol, The Netherlands and registered on the trade
register under number 05014273 (“Wavin”, “we”, “our”, or “us”).
The Sentio App refers to the mobile software application, PC Client
and web portal (the “Apps”) through which the User can access and
remotely control their System, to
obtain direct access (continuously and in real-time) to data generated
by their System, and to allow secure remote access by an installer to
the System
and other services provided in relation to the System (the
“Service”). Data regarding your use of the
System, which may include personal data, will be continuously and
in real-time generated for the duration and under the conditions as set out in the Sentio -
Terms of Use. Such data will be stored by our cloud provider in the
European Union and can be accessed via the Apps provided by Wavin.
This notice will explain how we will use the personal data that we collect from users (“you” and "‘your"’)
via the System
and the Service and which rights you have with respect to your
personal data in accordance with the data privacy legislation which
applies to you, including the General Data Protection Regulation (“GDPR') and the EU Data
Act.
1.
(PERSONAL) DATA
1.1.
Personal
data
is any information that directly or indirectly identifies a natural
person, for example
a name, e-mail address and the IP-address of your computer. However,
we also generate data via the Service that cannot identify you. Below,
we describe the (personal) data we collect and process via your Service
when connected to the internet. For completeness, we also describe the non-personal data generated by use
of the Service.
1.2.
When you register your user account with Wavin on the Apps, we
process your, email
address, password and information regarding the System (such as
registration key, serial number and firmware version) that belongs to
you, for purposes such as identifying you, securing your personal data
in the System and Service against unauthorized access, delivering and
improving the Services etc. We have a legitimate interest for
processing such personal data, because it enables us to secure the
Apps. for unauthorized access to your personal data, and we also have
additional legal basis to process your personal data.
1.3.
You are contractually required to provide such information to us to
be provided with our Service.
1.4.
We process personal data regarding your contract with Wavin, such as
the version of the last accepted terms of use by you. We process such
data for the performance of our contract with you.
1.5.
The installer of your System may provide us with information
regarding the System, your country, time zone and address. Such
information may be necessary to provide customer support in relation
to the use of the System and Service. We have a legitimate interest to
process such data, because we want to provide you with optimal service
and support and the installer is not able to provide customer support
without this data.
1.6.
We collect data via the Service, and, specifically, the Apps, such as
your device type, IP address, and errors related to the Apps, and via
your System, such as the serial number, registration key, access key,
IP address, language, time, personalized names of rooms and widgets,
notification settings, thermostat schedules and settings, and data
generated by the System, which includes the indoor temperature and
humidity history.
1.7.
We process such data to perform our contract with you and to comply
with legal obligations to provide you with access to your data. We
also anonymize data to provide you with suggestions about your habits
and for analytics purposes to improve our products and our services
and to provide services to installers. We have a legitimate interest
for processing such personal data based on article 6 (f) GDPR because
it will help us to optimize (the quality of) our products and
services.
2.
SHARING YOUR DATA
2.1.
We might share your data with:
-
the installer of your System, if you permit them to have access.
-
authorities and courts if we believe that the disclosure is required
by law, or is in response to a legal request;
-
third parties, including affiliates of Wavin, that provide database-,
server-, maintenance-, security-, or other services to us (hereinafter
referred to as ‘data processors’). If we provide access to your data,
we require the third parties to keep your
data confidential and instruct these parties to process this data only on
behalf of us.
2.2.
The System may be used by multiple users, for example by each family
member in a home. In such case information regarding the data
generated by the System is shared with each user. It is your
responsibility to regularly check the user accounts connected to your
System and ensure that no
unauthorized users are registered in
relation their System. This can be verified via the settings on the
Apps.
3.
SECURITY
We implemented appropriate technical and organizational measures to
protect your personal
data against accidental or unlawful destruction or accidental loss,
alteration, unauthorized
disclosure
or access and against all other forms of unlawful processing. Also, we
require our data processors to implement such appropriate technical
and organizational measures.
4.
RETENTION PERIOD
Your data will be stored no longer than is necessary for the purposes
for which the personal data is collected unless otherwise required by
law. We will not retain personal data longer than necessary and will
delete or anonymize your personal data in principle within one year
after our contract with you is terminated.
5.
YOUR RIGHTS
You have the right to request us to comply with any right you may
have under privacy laws applicable to you, including:
-
to know whether or not we process your
data;
-
rectify your personal data;
-
erase your data;
-
restrict
your personal data;
-
cease the sharing with other parties; and/or
-
us to transmit your data to another organization.
You can delete your account or revise your profile via your account
profile on the Apps. Furthermore, you can contact us via the contact
details provided below.
We may request provision of additional information necessary to
confirm your identity. These rights are not absolute. We will assess
your request in accordance with the data privacy laws applicable to
you.
In Europe, You have the right to lodge a
complaint with the supervisory authority about alleged violations of
the
GDPR and/or the Data Act
at any time.
6.
MODIFICATIONS
It is possible
that this notice will be amended in the future. The most recent
version will be available within the Apps. at all times.
7.
CONTACT US
If you have any questions about this Privacy Notice or the processing
of your Personal Information in general, or if you wish to exercise
any of your rights, please email us athttps://www.wavin.com/sentio
dataprivacy@orbia.com
indicating the nature of your query.