The following document (hereinafter: “Document”) sets out the Privacy Policy specific to Salus Controls Limited and its Subsidiaries' (hereinafter: ‘Salus’, ’SALUS Controls’ ‘we’, ‘us’ or ‘our’) Products, Devices and Services (hereinafter: ‘Products’), that are operated by the Salus apps (hereinafter ‘App’ or ‘Application’) whether accessed directly through the App or where the App is accessed through our website (https://eu.premium.salusconnect.io/ ).

 

This Document covers users in the European Economic Area (‘EEA’) and in the United Kingdom (‘UK’) of the following Products operated through the Salus apps:

 

 

Any reference to ‘you’, ‘your’ or ‘User’ shall mean the user of the Application and includes any individual or commercial users. Customers and users in the US and other countries outside of the UK and EEA are served by our sister company, SALUS North America Inc.

 

You must be at least 18 years of age to register an account on the Application. Our Products and Apps are not intended or directed to persons under the age of 18.

 

SALUS Controls Limited is a holding company incorporated in the British Virgin Isles (BVI) and is wholly owned by the Computime Group Limited, which is registered in Hong Kong.

 

Other affiliate companies in the EU that form the SALUS Controls Group include:

 

 

All Companies indicated above are subsidiaries of SALUS Controls Limited.

 

”Salus Premium Lite” is the commercial name of the app owned by Salus Controls Limited (further named Salus Controls).

Also, Salus Premium Lite operates the feature Salus Installer Mode, where you may or may not subscribe/register, but if you do, the herein Policy should also apply to you.

If you are a user of the SALUS apps mentioned above and you have any questions or if you need any additional information concerning your data and how we process it, we encourage you to reach our Data Protection Officer at the following e-mail address: dataprotection@salus-tech.com or send us your concerns to:

Data Protection Officer SALUS Controls PLC

Units 8-10, Northfield Business Park

Forge Way

Rotherham

South Yorkshire

S601SD

United Kingdom

PRIVACY POLICY OF THE APPLICATION SALUS APPS

 

 

 

 

Data Protection Officer

SALUS Controls Plc

Units 8-10, Northfield Business Park

Forge Way

Rotherham

South Yorkshire

S601SD

United Kingdom

 

 

 

TYPE OF PERSONAL DATA

REASON / PURPOSE DETAILS

Account Registration or Profile Information

This is the personal data you enter and submit to register details on our App and includes:

  • First and Last Name;
  • Email Address;
  • Password;
  • Address;
  • Postal Code;
  • Telephone Number;
  • Language;
  • Unique Device Reference or Identifier;
  • IP Address.

A Device Identifier is a number that is automatically assigned to your Device when you access our servers. Our computers identify your Device by its Device Identifier.

 

Basis for Processing: PERFORMANCE OF A CONTRACT

This information is used to meet our contractual obligations and provide our services to you as described when you purchase our Products, and / or in the Terms and Conditions you accept when you download and use our App.

For example, we use this information to:

  • register and link Products to an account or profile.
  • authenticate a Device owner and manage your account.
  • provide technical support, customer services, and assist you with the installation, use or configuration of your Products and App.
  • manage an account and provide services to support the operation of your Products.
  • administer your Device or App remotely.
  • provide guidance or fixes for you to implement.
  • log, diagnose and resolve issues or faults;
  • deal with complaints and claims, and process refunds or a product replacement.
  • send you specifications, manuals or installation guides; and
  • transition you between different versions of Apps and replacement Apps.


Basis for Processing: LEGITIMATE INTEREST

We have a legitimate interest to use this data to:

  • support our audits and help meet our service standards, or for training purposes;
  • send you servicing communications by email - such as important notices, alerts, scheduled maintenance, updates or changes to our services;
  • send you information on new features or functionality of existing products you may own, and information to help improve the safety, security and way you use our Products and Apps;
  • provide useful information to you on how to better utilise your heating, ventilation and cooling systems, and enhance the use of connected Products and App you already own;
  • request feedback about the services we are currently providing to you through a survey for research purposes (although you do not need to respond to them);

and

  • send you communications containing promotional information on SALUS' products, offers, and services and to make suggestions and recommendations to you about goods or services that may be of interest to you. It is in our legitimate interests to promote and develop our products/services and grow our business.

Basis for Processing: LEGITIMATE INTEREST


We have a legitimate interest to use this data to:

  • investigate any suspected breach of our terms.


Refer to "Your Communications Choices" below for details on how to update your choices.

SALUS Device and App Information

This is the personal data passively, automatically or voluntarily sent to us when you install and use our Products and Apps, and includes:

  • First and Last Name;
  • Email Address;
  • Unique Device Reference (Device ID) and Device Type;
  • IP Address;
  • Device Mac Address;
  • Device location (if Geo-location is activated and enabled through your smart Device or phone, or if an App or Device uses the location in the background, i.e. uses the location also when the App is not in use);
  • Names you give to your locations or Products;
  • Images you decide to upload where they are of a personal nature;
  • Distance alerts or geo-fencing set up;
  • Account type (consumer user or Installer user);
  • Order history.

We also receive Device and App properties and information that will be treated as personal data when combined with Account or Profile Information for as long as it remains combined:

  • How you use Products in your home: For example,
    • user behaviour when logging on or using our Products or Apps;
    • usage history, including household energy and electricity, patterns and use;
    • Device configuration, settings, and schedules including temperature and if Device is set to holiday mode;
    • Device status - whether active or disabled (on/off).
  • Device Type, Browser Type, Operating System and Application Version

The IP address associated with a smart device, phone or computer may provide an approximate location when you connect to our App, but this will be no more precise than the city, state or country.

Basis for Processing:  PERFORMANCE OF A CONTRACT

This information is used to meet our contractual obligations and provide our services to you as described when you purchase our Products, and / or in the Terms and Conditions you accept when you download and use our Apps.

For example, we use this information to:

  • add or remove Products to your account;
  • enable you to view real-time Device settings, status and monitor energy usage;
  • enable you to control your Products remotely through the Apps;
  • enable you to control Products owned by people who have authorised you to control their Products through the Apps;
  • enables you to set the Products to activate or deactivate automatically according to your recognised location (background location use).
  • enable us to perform analytics to diagnose and resolve problems which we may detect in your heating system or which you as the user may experience;
  • enable us to monitor the stability of your Products and connections between Device, gateway and Internet; and
  • monitor compliance with these terms or other applicable terms and conditions.


Basis for Processing: CONSENT 

Separately, we may also rely on consent to analyse the data we hold about you for other purposes, namely to improve our products and services and to enable us to deliver content to you which takes account of your likes and dislikes. For these purposes, we obtain your consent through the cookie consent notice. You can opt out of such analytics through the cookie consent notice. Where you given your consent for us to do so, we may use your personal data to:

  • personalise the content you see, based on the details given by you and /or your activity on the App;
  • identify, develop and deliver improvements to our products and services for example device battery life, stability of Apps, or identify issues with heating system or smart home Device and connections; and
  • provide useful information on how to better utilise your heating, ventilation and cooling systems, and enhance the use of connected Products and Apps you already own.


Basis for Processing: LEGITIMATE INTEREST

We have a legitimate interest to use this data to:

  • investigate any suspected breach of our terms;
  • identify, develop and deliver improvements to our products and services in order to assess and enhance safety use or process of your personal data. 

We will monitor our network and your use of it. It is a legitimate interest of ours to make sure that your use of our App does not compromise our network and systems security.

Payment data

This includes your name, and any card payment details and bank account details which you provide to us/our payment processing provider  within the App, for the purpose of making payment for subscriptions purchased through the App.

Basis for Processing: PERFORMANCE OF A CONTRACT 

The use of your payment information is necessary for us to collect payments due to us in accordance with your contract with us. 

Subscription data

Where you have purchased a subscription via the App, we will collect and process information about your subscription type, subscription plan, and billing preferences. 

Where you have purchased the "Installer Pro" subscription specifically, this will include:

  • gateway information:
    • your connection status (with historical record), MAC, version, EUID, firmware version, Zigbee Channel);
    • network - LAN/WiFi settings, wifi SSID and wifi password)
    • your address and timezone.
  • connected user data (including the "SALUS Device and App Information" listed above);
  • your device information (connection status, MAC/EUID, version, firmware version), historical record (usage data including energy consumption, on/off, open/close, room temperature, humidity, heating/cooling, motion detected) 
  • calendar and scheduling data (appointment title, time, and scheduling options);
  • any other notes, messages, photos or information inputted by you into the Installer Dashboard.

Basis for Processing: PERFORMANCE OF A CONTRACT

The use of your personal data is necessary for the management and administration of your contract with us and our responsibilities to you to provide you with the subscription you have purchased.

 


 

 

App

Cookie Name

Description – What does this cookie do?

Type of cookie

Retention / Expiry

SALUS iT500

PHPSESSID

Identify the client and save the login status

Strictly necessary (session / authentication)

Browsing session

SALUS-iT500.com (Web)

PHPSESSID

Identify the client and save the login status

Strictly necessary (session / authentication)

Browsing session

SALUS-iT500.com (Web)

LG[one]

Remember username / email when “Keep me logged in” is selected by user

Functional (persistent login)

1 month

SALUS-iT500.com (Web)

LG[two]

Remember encrypted password when “Keep me logged in” is selected by user

Functional (persistent login)

1 month

SALUS iT600

PHPSESSID

Identify the client and save the login status

Strictly necessary (session / authentication)

Browsing session

SALUS Premium Lite

_device_service_session

Minimize webpage response times and provide personalisation (such as language preferences)

Functional (performance / personalisation)

Browsing session

SALUS Premium Lite

_session_id

Identify the client and save the login status

Strictly necessary (session / authentication)

Browsing session

  


 

 

Some third-party data processors are based outside of the UK or are part of an international group of companies. Further details of these providers are set out below. We have a legal agreement or contract with all third parties with whom we share your personal data.

 

 

 

 


Salus Controls will keep your personal data for as long as you have an active account on one of our Apps, as listed above. This retention period may also be affected by certain litigation procedures, accounting or reporting requirements. When this period ends or we are no longer required by certain authorities to process your personal data, we will take reasonable steps to securely destroy your information or permanently de-identify it.

 

 

– you object the accuracy of your personal data

-you consider the processing to be illegal

- you consider we no longer need your data to be processed, but you also consider you need the personal data for exercising your rights in court

– you objected the processing of your data considering your personal status or situation, and you ask us to restrict the access to your personal data during the evaluation of your personal interest compared to our lawful rights;  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances, except for the request to delete your personal data that can be requested at all times. Please consider that in the event you request your personal data to be deleted, Section 5, What Happens If You Don't Give Us Your Information, shall further apply.


 

 

 

 

Please note that if you are based in the UK, the relevant National Supervisory Authority to whom you should direct your complaints, is the Information Commissioner's Office. Details about the Information Commissioner's Office (including contact information) can be found on their website which is available here: http://www.ico.org.uk/ 

If you are located outside of Romania or the UK, you may be able to direct your complaint to your local National Supervisory Authority.

Although you have an unlimited right to contact the National Supervisory Authority for Personal Data Processing, we encourage you to firstly contact us, since our concern to solve any matter regarding the safety of your personal data is constant and we promise to engage all our efforts in solving you issue with in time and effectively.