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Privacy Policy

Cosesy Privacy Policy, version 1.0.1, 14-09-2018

Cosesy Privacy Policy

In this privacy policy it is explained what is personal data, what types of personal data we collect, for what purposes data is collected, how it is processed and what rights you have in this regard. You can rest assured that your personal data is handled with care.

PERSONAL DATA PROCESSING

1. WHAT IS PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person, such as for instance your contact information, your order data or your product data.

2. GENERAL PRINCIPLES FOR DATA PROCESSING BY COSESY

We adhere to the following principles when processing your personal data:

1) we will only collect personal data for specified, explicit and legitimate purposes;

2) we will not collect personal data beyond what is necessary to accomplish those purposes;

3) we will not use personal data for purposes other than that for which the data was collected, except as stated herein, or with prior consent

4) we will not transfer personal data to third parties, except as stated herein, or with prior consent;

5) we will maintain 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 unlawful forms of processing; and

6) except when stated herein, we will not store personal data longer than is necessary to accomplish the purpose for which the data were collected or for which they are further processed, or as is required by law.

3. PERSONAL DATA WE COLLECT AND PROCESS

When you engage with Cosesy A/S via our websites, apps and customer support, we collect and process your personal data. The personal data that we collect and process can be categorized as follows:

1) Your personal details, such as your name, email address, physical address (if provided), phone number (if provided), and  in some cases language.

2) Your purchase information, such as your personal details as specified above,  your delivery information, such as delivery address, if different from physical address, your order information, such as product name, quantity, stock keeping unit no., quantity, date of purchase and distributor information, your payment information, such as credit card or similar payment information.

3) Your use information, such as your personal details as specified above, information regarding your (enrolled) security product(s), including product serial number(s), stock keeping unit no.,  product secret code, product and app usage type, date, log-in credentials, mobile device id, security log, information on other users of same Cosesy app within your household (if applicable), information you choose to attribute in connection with your devices, for instance when customizing name of your devices, mobile device name, video camera credentials(if provided), storage of pictures (if activated and only during potential alarm situations).

4) Requests for customer support and technical assistance, containing your personal details, as specified above, product serial number, secret product code,  place of purchase and other relevant information which Cosesy may inquire in order to proceed with your request.

4. HOW WE USE YOUR PERSONAL DATA

We only collect and process personal data, if at least one of the below mentioned purposes applies:

1) We provide you with services for operation of your security and safety system which includes management of devices, users, notifications, logs for the system and if activated services for video camera, picture storage and voice calls.

2) We handle your purchase orders, complete purchase transactions, ensure delivery of purchased product(s), handle possible returns. Our processing is necessary for the performance of a contract, to which you are a party.

3) We provide you with relevant product software updates and make your future purchases easier by remembering your shipping details. Our processing is necessary for the purposes of the legitimate interests pursued by Cosesy and such processing is not considered to be harmful towards you.

4) We provide you with customer service, handle your requests or complaints and provide you with support. Our processing is necessary for the performance of a contract, to which you are a party.

5) We conduct analytics and statistics on use type, date and frequency of security and safety products to learn how the products are used, to improve the quality of the products and apps and to develop new ones. Our processing is necessary for the purposes of the legitimate interests pursued by Cosesy and such processing is not considered to be harmful towards you.

Accordingly, some of your personal data is collected and processed in order for us to fulfill our contractual obligations to you, for instance, when you purchase our products, contact our customer support or claim warranty. Should you choose not to provide us with the requested and necessary personal data in this regard, we might not be able to fully satisfy your request.

5. WHERE WE STORE AND PROCESS YOUR PERSONAL DATA

As a general principle, your personal data is stored and processed within the European Economic Area (EEA). However, your personal data may be transferred outside EEA for certain types of third parties, as specified in section 6 within the purposes for which your personal data was collected.

In case of transfer of your personal data to any third countries, as defined in General Data Protection Regulation (GDPR), valid law and regulations concerning such transfers are observed and relevant legal and security safeguards are ensured before such transfer.

6. OUR DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

As a general principle, we collect and process data in order to facilitate or improve products, services or offers. We do not sell your personal data or share the said data with third parties, except to the extent stated in this Privacy Policy.

We may disclose your personal data to third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement. In addition, we may share your personal data with the following third parties:

1) Third party vendors carrying out services on our behalf including billing, payment processing, data storage, analytics and  voice-call service operators. Such third-party vendors have access to perform these services but are prohibited from using your personal data for other purposes. 

2) Third parties in order to establish, exercise or defend legal rights of Cosesy A/S.

3) Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Cosesy assets (including without limitation in connection with any bankruptcy or similar proceedings).

4) Other third parties subject to your consent.

When we disclose your personal data to a third party, we take all reasonable steps to ensure that those third parties are bound by confidentiality and privacy obligations with respect to the protection of your personal data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant third parties, to ensure that personal data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.

7. RETENTION OF YOUR PERSONAL DATA

We keep your information for no longer than necessary for the purposes for which it is collected. The length of time for which we retain information depends on the purposes for which we collected and use it.

Personal data related to your purchase and product warranty information is kept and processed for a period of five (5) years from the date of purchase, unless you have obtained extended warranty period or such data is legitimately processed for other purposes, such as pursuing our legal claims, where maintaining such information is considered necessary.

Personal data related to your use of our apps and product software update(s) is kept and processed for a period of five (5) years from the date you last have been active in using any Cosesy apps unless such data is legitimately processed for other purposes, such as pursuing our legal claims, where maintaining such information is considered necessary.

Relevant personal information will be deleted after expiry of the above-mentioned periods, unless such data legitimately can be kept and processed for other processing purposes, which we have legal basis for.

8. COOKIES 

We use cookies and similar technologies to understand how our websites and apps are used. The cookies we use, do not contain any personal information about you and cannot be used to identify an individual user.

A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to:  (1) understand how users interact with the web pages of Cosesy (2)understand how users interact with Cosesy apps (3) assist with security and administrative functions. Some cookies are placed in your browser cache.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information.

Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings on our websites or apps.

9. RESPONSIBLE FOR PROCESSING

Cosesy A/S, Dyssen 1, 8200 Aarhus N, Denmark is data controller and is responsible for the processing of your personal data.

YOUR RIGHTS

10. ACCESS TO YOUR PERSONAL DATA AND DATA PORTABILITY

You have right to access and receive the personal data concerning you, which you have provided to Cosesy A/S, in a structured, commonly used and machine-readable format and have the right to transmit those data to any third party, you should choose to. Most of the personal data can be accessed via Cosesy apps. For access to the complete data set, contact Cosesy, see section 19 for contact details, with your request. We will acknowledge receipt of your request within five (5) business days. We will do our best to resolve it as quickly as possible and within one (1) month from the date of request. In case response would require longer term than one (1) month, we will let you know and inform you of the relevant reason(s).

11. UPDATING AND/OR DELETING YOUR PERSONAL DATA 

We encourage you to update your personal data provided to Cosesy any time there are changes in your personal data. This can be done by logging in and changing the relevant fields via the Cosesy app.

In order to ensure that your personal data processed by us is up-to-date we request you to check and, if relevant, update your personal data at least once a year.

Most of your personal data can be deleted from Cosesy servers, by logging in and deleting the relevant fields via Cosesy’s apps. Data can not be deleted, if Cosesy is entitled or obliged by applicable law and regulations to keep and process such information regardless withdrawal of your consent.

Following deletion your personal data will be deleted from Cosesy servers without undue delay, while it might take a period of one (1) month to ensure complete deletion of any information that might be stored in our back up.

For update/deletion of the complete personal data stored about you, contact Cosesy, see section 19 for contact details, with your request.  Please note that prior to accessing and making changes to your account, we will need to verify your identity properly. We will acknowledge receipt of your request within five (5) business days. We will do our best to resolve it as quickly as possible and within one (1) month from the date of request. In case response would require longer term than one (1) month, we will let you know and inform you of the relevant reason(s).

12. RIGHT TO WITHDRAW YOUR CONSENT

Some of Cosesy's processing activities may be based on your consent. In such case, you will have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of processing conducted prior to the withdrawal.

If you withdraw your consent, Cosesy and third parties involved in personal data processing will cease to process your personal data, unless and to the extent the continued processing or storage is permitted or required according to the applicable personal data legislation or other applicable laws and regulations. Please note that as a consequence of your withdrawal of your consent, Cosesy may not be able to meet your requests or provide you with our services.

13. RIGHT TO RESTRICTION OF PROCESSING AND RIGHT TO OBJECT

You have the right to restriction of processing of your personal data, if the personal data is not correct, if the processing is unlawful, but you oppose erasure of your personal data, if Cosesy no longer needs your personal data for the purposes of processing, but storing such data is requested by you for the establishment, exercise or defence of legal claims, or if you have objected to processing and verification, whether Cosesy still has legitimate interest in the given personal data is pending. Please see section 19 for contact details.

At any time, you have the right to object to processing of your personal data collected and processed for purposes of the legitimate interests pursued by Cosesy, for instance, when we provide you with relevant product software updates, make your future purchases easier by remembering your shipping details, or when we conduct analytics and statistics on your use type, date and frequency of our appss. Please see section 19 for relevant contact details.

14. RIGHT TO COMPLAIN

If you want to complain about a privacy breach, please contact Cosesy, see section 19 below with contact details.

We will acknowledge receipt of your complaint within five (5) business days. We will do our best to resolve it as quickly as possible and within one (1) month from the date of complaint. In case response would require longer term than one (1) month, we will let you know and inform you of the relevant reason(s

If you are not satisfied with outcome of your complaint or with handling of your complaint at Cosesy, you may refer your complaint to the Danish Data Protection Authority:

Datatilsynet, Borgergade 28, 5., DK-1300 Copenhagen, Denmark or by sending e-mail to dt@datatilsynet.dk

MISCELLANEOUS

15. THIRD-PARTY SERVICES

Cosesy may contain links to third party services, for instance voice control functionality provided by Amazon or Google. Regarding your use of voice enabled products, please note that Cosesy does not collect or process any sound recordings on its own behalf, but only makes third-party services available.

If you choose to use these services, you may disclose your information to those third-parties. Cosesy is not responsible for the content or practices of services. The collection, use, and disclosure of your personal data will be subject to the privacy policies of these third parties and not this Privacy Policy. We urge you to read the privacy and security policies of the relevant third-parties.

16. DATA SECURITY

Cosesy is committed to protecting the security of your personal data. We use necessary organizational, technical, and administrative measures to protect your personal data under control of Cosesy, such as control of access, transmission, input and availability and the separation of data.

Access to a number of online services at Cosesy are protected by access restrictions based on user name and password. It is important that you always choose a password which is hard to guess for others, and protect your password against disclosure.

Your personal details, if you have provided such to Cosesy remain in Cosesy’s secure servers. Credit card information is not stored on Cosesy servers, but directed to approved and certified service provider. All external transmissions of personal data facilitated by Cosesy are protected by encryption.

All data storage and processing at computer facilities of Cosesy as well as at business partner facilities are subject to written contracts.

If you have reason to believe that your interaction with Cosesy is no longer secure (for example, if you feel that the security of any account you might have with Cosesy has been compromised), please notify us of the problem immediately by contacting us. Please see section 19 for relevant contact details.

17. USE BY CHILDREN

Cosesy does not target and is not intended to attract children. Accordingly, our online services, including personal accounts on websites and apps provided by Cosesy that collect any personal data are not directed at and should not be accessed by individuals under the age of sixteen (16 years), and we request that such individuals do not provide any personal data to Cosesy. Minors must obtain express consent from parents or legal guardians prior to accessing or providing any personal data. If notified by a parent or guardian or discovered by other means, that a child under age of sixteen has provided his or her personal data to Cosesy, we will cancel the child's account, if any, and delete the child's personal data in our possession.

18. CHANGES TO OUR PRIVACY POLICY

Cosesy may modify or update this Privacy Policy when necessary to reflect changes in Cosesy’s apps and services, changes in applicable legislation, regulations or practice and to address customer feedback. Accordingly, please review it periodically. Date of the latest update is always provided on the top of the document.

If there are material changes to this Privacy Policy, we will notify you either by posting a notice or by sending you a notification.

19. Contact details

If you have questions about this Privacy Policy or Cosesy’s processing of your personal data, please contact us at:

Cosesy A/S, Dyssen 1, 8200 Aarhus N, Denmark, Att.: Legal

or by sending email to dataprotection@cosesy.com

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