Data
protection notice for Axdia apps and ODYS ALPHA
e-scooter applications (apps)
Date of
entry into force: June 01, 2024
We at Axdia International GmbH (“Axdia”)
know how important data protection is for our customers. Axdia
is the data controller for the AX Home app and ODYS e-Scooter apps such as the
“ODYS ALPHA X5 PRO SERIES” app, hereinafter collectively referred to as “Axdia Apps”. We have created this Privacy Notice to ensure
that you understand how we collect and use your personal information.
Our privacy
policy on https://www.axdia.com/datenschutz also applies to the use of Axdia Apps. Our privacy policy contains more information
about how we use your data. It also contains information about your rights and
how you can contact us. Please read our Privacy Policy in addition to this
Privacy Notice. However, this Privacy Notice will always take precedence over
the Privacy Policy in relation to how we use your information for Axdia Apps.
WHAT
INFORMATION WE COLLECT?
Through Axdia Apps, Axdia collects and
stores information about you in various ways.
Information
provided directly by you
- Your account information: Axdia Apps will collect such of your account
information as is necessary to initialize and provide the Axdia Apps service to you. This includes information
such as your name, your “Axdia Apps” ID, e-mail
address, postal address, telephone number and your user name. Your account
information includes not only the information you enter in the “Axdia Apps” app to create an Axdia
Apps account, but also the account information in apps from external
service providers that you allow to access Axdia
Apps, as well as on devices registered to your Axdia
Apps account (such as mobile devices).
Information
about your use of Axdia Apps
In addition
to the information you provide, we collect information about your use of Axdia Apps through software on your devices and other
methods. We collect:
- App usage information: We
collect your usage information created when you use the Axdia Apps app, such as app logs, groups, rules,
location identifiers, and your interactions with Axdia
Apps (e.g., the app and websites you visit and the features you use) and other configuration information.
- Information on home IoT devices: Because Axdia
Apps may consist of multiple sets of home appliances, sensors, Axdia Apps hubs, smart products, home security cameras
and other devices connected to Axdia Apps (“Home
IoT Devices”), Axdia Apps also collects usage
information about your Home IoT Devices, such as the model, name, group
name or nickname and location name of the Home IoT Device and other
settings, events and event settings assigned to the device (for example,
if you set up a schedule reminder to be displayed on your home IoT
device), the network connection information (including SSID and password)
and network environment information, the device country code, device
network operator, operating system version, IP address and IMEI, sensor
and configuration data, error and fault logs, device identifier (e.g. ICCID)
and the device and rule name. The main purpose for processing such
information is to provide the service you have requested (although it may
also be used for data analysis and to enable us to provide customized
marketing communications if you have given us your separate consent). Examples
of how we use your information to provide you with the Service are listed
below. For example, if you use a motion sensor, Axdia
Apps collects the information collected by the sensor (e.g. logs
indicating movement in your home, that the lights have been automatically
turned on or off, or if there is unexpected movement in your home) so that
an alert can be sent. Axdia Apps also collects
information relating to the usage settings of household appliances that
are connected to Axdia Apps when you activate
these functions. For example, the time information on the usage time of
your vacuum/mopping robots and other information about the functions you
have selected is collected. This is not only necessary for displaying the
device status in your app, but also to help us understand how you use your
home IoT devices so that we can work on further improving our services. In
addition to the personal data mentioned above, we will collect your
security logs, i.e. files that list the technical errors of your devices.
These security logs will only be used to provide you with the technical
assistance you need and to improve the Axdia
Apps apps or the Home IoT devices.
- Images, video clips and audio
recordings: When
you connect image, video or audio recording devices to Axdia
Apps (including recordings by the Home Monitoring Device), Axdia Apps collects the images, video or audio
recorded by those devices based on your selection (including your sharing
of such media files with other Axdia Apps users
or devices) to provide you with the service in the Axdia
Apps app that you have requested.
- Language information: When you use voice commands
to control Axdia Apps, information about your
conversations, including voice commands, is forwarded via Axdia Apps servers to process your command.
- Location information: If you consent to the
collection and use of location data, your geographic data will be
collected to provide services or features that require location
information. If you do not want your location information to be processed,
you can deactivate this via the Axdia Apps
settings.
- Information in the map view of Axdia Apps: when using the Axdia
Apps map view, information relating to the maps you have created (e.g.
image, address, floor plan, placement of doors, windows and appliances and
room layout)
We do not
knowingly collect any sensitive personal data from you. However, please note
that we cannot guarantee that sensitive information will not be inadvertently
disclosed to us when you use the Axdia Apps app and
other home IoT devices, e.g. the content of your audio or video recordings when
you connect audio or video recording devices to Axdia
Apps. If you submit information to Axdia Apps that is
of a sensitive nature, it will also be collected and processed for the purposes
listed below. However, we will not use this data for marketing purposes, to
provide personalized recommendations or to improve our services.
We may also
collect other information about you, your devices and apps, and your use of Axdia Apps through methods that we disclose to you at the
time of collection or otherwise with your consent.
HOW WE
USE YOUR INFORMATION?
We use the
information collected:
- to identify and authenticate
you;
- to enable you to control your
home IoT devices in the Axdia Apps app;
- to provide you with services or
features that you request in the Axdia Apps app;
- to respond to your requests and
questions and to communicate with you in relation to Axdia
Apps;
- to provide
assistance when you need technical support for the Axdia Apps app or home IoT devices and other
maintenance services;
- to link your account
information with selected apps, devices, functions and services of
external service partners and to enable interaction with them;
- to operate, evaluate and
improve Axdia Apps and our business (including
developing new products and services; enhancing and improving our
products, services and Axdia Apps; analyzing our
products and services by aggregating and anonymizing data and performing
data analytics and accounting, auditing and other internal functions);
- to provide personalized
recommendations related to home IoT devices and other useful services or
features;
- to provide you with easier
access to your personal data generated by the products and services
associated with your Axdia Apps account;
- to comply with laws, regulatory
obligations and legal processes; and
- to protect the rights, property
and/or safety of Axdria or our affiliates,
business partners and/or customers.
Axdia
processes personal information only for the purposes described above. Axdia's legal basis for processing personal information is
set out below:
|
In order
to keep our promise to you
(fulfillment
of the contract)
GDPR
Article 6(1)(b)
|
- To identify and authenticate
you.
- Provision of Axdia Apps and services and functions that you
request in the Axdia Apps app, such as
controlling your home IoT devices in the Axdia
Apps app.
- To provide you with
personalized content, such as the provision of recommendations.
- To allow you to interact with
other Axdia and third-party content.
|
|
To
further our business interests.
(legitimate
interest)
GDPR
Article 6(1)(f)
|
- To operate, evaluate and
improve Axdia Apps and our business.
- To respond to your requests,
instructions and queries.
- To provide technical support
and maintenance service for errors.
- In order to maintain
sufficient safety measures.
- To make it easier for you to
view your personal data associated with your Axdia
Apps account.
- To protect ourselves against
liability, including compliance with industry standards and enforcement
of our policies.
|
|
To comply
with laws, regulatory obligations and legal process.
GDPR Article 6(1)(c)
|
- To comply with applicable
laws and regulatory, administrative or judicial orders.
|
|
With your
consent
GDPR
Article 6(1)(a)
|
- To provide you with Axdia Apps, e.g. if you choose to share audio, video
and image clips.
- To process your location
information to provide location-based features and services.
- To provide you with personalized
content, such as the Personalized Service.
- To enable you to link your Axdia Apps account with third-party content.
|
WHO WE
SHARE YOUR INFORMATION WITH?
We disclose
your information internally within our company and to the following legal entities,
but only for the purposes described above:
- affiliated companies: other
companies of the “Axdia International” group
that we control or own;
- Business partners: partners we
work with to provide you with Axdia Apps, such
as third-party products or services that you can connect to Axdia Apps so that you can control those products or
services. These business partners control and manage your personal information;
- Service providers: carefully
selected companies that provide services to us or on our behalf, such as
cloud platform providers that store data on our behalf. These providers are also obliged to protect your information;
- other parties if required by
law or to protect Axdia Apps:
For example, we may be required to disclose your information by law, legal
process or court order from governmental authorities. We may also be asked
to disclose your information for law enforcement, national security,
counter-terrorism or other public safety related reasons;
- other parties in connection
with corporate transactions: We may share your information with third
parties as part of a merger or transfer, acquisition or sale, or in the
event of bankruptcy; and
- other parties with your consent
or at your direction: In addition to the disclosures described in this Privacy
Notice, we may share information about you with third parties if you
provide separate consent or request such disclosure.
HOW LONG
AND WHERE WE STORE YOUR INFORMATION?
How long
your data is stored depends on the legal basis on which we rely to process your
data. For example, data that we process to fulfill our contract with you must
be retained throughout your use of Axdia Apps. As
long as you are an active user of Axdia Apps, we will
store and process this data. Data such as your account information and device
information and identifiers fall into this category.
Data that
we process to further our business interests, such as your use of Axdia Apps, will only be retained for as long as is
necessary for the purposes for which it was collected. For example, this data
may be collected to perform analytics so that we can develop improvements to Axdia Apps, or we may process data to keep a record of
requests you have made through or via Axdia Apps to
improve your experience with our customer service team.
We may also
process your data on the basis of your consent. If you withdraw your consent,
we will stop processing your data that is dependent on your consent, but this
will not affect the processing of data collected prior to your withdrawal until
the purposes for which such data was collected have been fulfilled.
Please note
that, although our aim is to store your data for the above-mentioned period,
your data may be processed for longer in accordance with applicable law. For
example, if a specific law requires us to retain certain data, we will comply
with these provisions and retain this data until the prescribed retention
period has expired.
As long as
your data is stored by us, your data is subject to appropriate security
measures at all times.
Your use of
Axdia Apps involves the transfer, storage and
processing of your personal information predominantly in Germany, but also to
other country(ies) which include countries in the
European Economic Area. All international data transfers are subject to legal requirements
to ensure that your personal information is processed securely and in
accordance with your expectations.
HOW WE
SECURE YOUR INFORMATION?
We take
data protection very seriously. We have implemented physical and technical
safeguards to protect the information we collect. Please be aware, however,
that while we take reasonable steps to protect your information, no website,
Internet transmission, computer system or wireless connection is completely
secure.
WHAT
RIGHTS DO YOU HAVE?
Your
personal data belongs to you. You can ask us to provide you with details of
what we have collected and you can ask us to delete this data or correct
inaccuracies. You can also ask us to restrict or limit the processing,
disclosure or transfer of your personal data and to provide you with the
personal data we have collected so that you can use it for your own purposes.
However, a request to delete your personal data may also result in a loss of
access to Axdia Apps. We do not delete data that we
are required to retain by law.
To make a
request regarding your rights or to submit a query, please contact us using the
methods described in the “CONTACT US” section below.
CONTACT
You can
contact us if you wish to update your settings, exercise your rights or make a
request or ask us questions.
You can
also contact us at the following address:
Datenschutzbeauftragter
Axdia International GmbH
Hanns-Martin-Schleyer-Straße 36-38,
47877 Willich, Deutschland
The easiest
way to contact our data protection officer directly is by e-mail:
datenschutzbeauftragter(at)axdia.de
You may
lodge a complaint with the competent supervisory authority if you consider that
our processing of your personal data infringes applicable law. Contact details
for all EU supervisory authorities are available at
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
UPDATES
TO THIS PRIVACY NOTICE
This
Privacy Notice may be updated to inform you of changes to the way we collect
and process your information in Axdia Apps and
changes to applicable laws. The date on which the document was last updated is
indicated at the top of this Privacy Notice.
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