Privacy

Privacy Policy of SmartphoneKey

Latest update: 01/06/2024

This Policy has been adopted by the company with the name "SMARTPHONEKEY SYSTEMS INC. with the trademark SMARTPHONEKEY. The registered office of our company is located at: 1705-40 High Park Ave., Toronto, Ontario, M6P 2S1, Canada, (hereinafter referred to as SmartphoneKey), which is the controller of the personal data you provide us.

SmartphoneKey takes all the appropriate measures to secure and maintain the confidentiality and privacy of the users’/customers’ Personal Data in compliance with the provisions of no. 2016/679 of the General Data Protection Regulation (GDPR) of the European Parliament and of the Council. 

1. Scope

This Privacy Policy describes how we process and protect your personal information that you provided us when you use or access our services, or that is otherwise obtained or generated by us. 

Your personal data are collected during your use of (a) our website (Smartphonekey.com) and its e-shop and any other platforms that we will make available to the public and (b)any services we provide in connection with one or more of the forementioned. You shall understand that we have no relation to any links to other websites and online services operated and maintained by third parties, in which case we advise you to read the related privacy policies.

Please note that you are under no obligation to provide us with your personal information, however we may not be able to provide you with certain products and/or services if you refuse to provide it.

2.Definitions

“Personal data” is any information that can be used to identify an individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. Personal data that has been de-identified, encrypted or pseudonymised but can be used to re-identify a person remains personal data.1

“User Data” refers to the data submitted by users or collected by SmartphoneKey   in order to provide its services, such as username, contact information, etc., during the use of SmartphoneKey's products and services or any related interaction. User Data include, but not limited, Personal Data. 

“Smart Device” refers to electronic device, such as smart home appliances etc., that have the ability via wireless protocols to connected, interact with and transmit data to other devices, networks or to its users.

“Cookies” are small data files that your browser stores on your device and are used to uniquely identify your browser and help to enhance users’ navigation through the sites.  The information that these files is typically shared with the owner of the site and their other potential partners.

3. How We Collect Your Personal Data

This data can be collected either 

- by telephone (e.g. telephone communication), 

- online (when you register an account on our website/e-shop, or proceed to pay for our services or via electronic mail) 

- physically (e.g. following the provision of services from our technicians at your premises 

- by signing the relevant Services Agreement

Such data includes the following:

a) personal data, such as name, surname, address, contact numbers, TRN number, copy of identity card/ passport, email address, username, password, information about the connection package and full billing information

b) financial and accounting data, such as billing data for SmartphoneKey services, billing data for the equipment purchased, credit or debit card data, data related to disputes, financial debts of the customer 

4. Cookies and Similar Tracking Technologies

During your navigation in our site, we and other service providers on our behalf, use Cookies. Certain cookies are necessary to run our service and those cannot be declined. We also use preference cookies, that help us to present you with a tailored experience, and analytics cookies to measure the total number of visitors to our site, so we can improve our services.  If you do not want cookies to be installed on your device and the as long as the cookie is not strictly necessary, you can decline the use of cookies following a simple procedure and, if you wish, you can change your preferences by reseting your web browser.

We may also HTML-based emails sent to our users to track which emails are opened by recipients and web beacons to record the usage patterns of our users. In any case, however, we respect do-not-track signals or similar technologies that our systems detect and identify.

5. Purpose and Legal Basis for Processing Personal Data

We collect and process your Personal Data with your consent in order to provide you our services and understand how we can improve them. 

We, also, may process your information for the following purposes:

•  To provide you our products and services. We need specific information so you can connect to the platform and control Smart Devices through it and securely store your pictures and videos when purchasing cloud storage services. 

• To improve our products and services, we process your device information to analyze trends and to track your usage of our Services. Such data analysis might be useful to us to identify usage trends and develop new products or services.

• To create and manage accounts when you register with us. 

• To provide you with technical and customer support.

• To communicate with you about our products and services after obtaining your relevant consent, which you always have the right to withdraw and change your preferences again if you wish.

• To inform you regarding modification on our services, changes to our terms and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. 

• Legal Compliance. We disclose information if we are legally required by the provisions of the law, or it was requested by the administrative, judicial, or other competent authorities. Also, in the following cases:

• Enforce our Terms of Use and other special agreements and policies.

• Perform risk management, investigate and prevent security incidents such as breaches, hacks and any other fraudulent or malicious activities.

If there is any change in the purposes for processing your Personal Data, we will inform you via a prominent notice on our website.

6. Who do We Share Personal Data with?

At SmartphoneKey, we value and protect your Personal Data.  We only disclose your Personal Data to third parties in the following cases:

• To our third-party service providers who perform, under contracts with special provision about the data protection, certain business-related functions for us so you can use our site and Services, including but not limited to:

• Providers of infrastructure provision, customer support and enterprise authentication services, 

• Providers of payment and credit card processing services,

• Providers of cloud, network, IT services, server and other virtual services

• Delivery partners so you can receive your orders. 

• To our affiliates in the course of regular business activities and in compliance with applicable law, this Privacy Policy and other special agreements.

• To any subsidiary or other entity in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, its assets or stock (including without limitation bankruptcy or similar proceedings). In such an event, you will be timely notified via email and/or a prominent notice on our website of any change in ownership, and choices you may have regarding your Personal Data.

7. Security

At SmartphoneKey, in order to ensure the integrity and security of your Personal Data, we have taken and constantly updating our organizational safeguards and administrative and technical security measures.

Wherever your Personal Data is involved, we make sure that proprietary algorithms, storage and transmission encryption protocols are used to ensure data isolation and access authentication. Furthermore, we always process your data in accordance with this Agreement and the applicable law, and we follow strict audit and validation of the data. The same obligations apply to any third party who is contracted to process your Personal Data on our behalf.

If you have reason to believe that the data you shared with us is no longer secure, you shall immediately notify us by emailing at info@Smartphonekey.com

8. Data Subject Rights

We respect your rights and control over your Personal Data. You may exercise any of the following rights by emailing us at info@Smartphonekey.com

• • right of access to their personal data as well as the information related to the processing (GDPR Article 15),

  • right to correct inaccuracies and complete any missing data (GDPR Article 16),

  • right to erasure ("right to be forgotten"- GDPR Article 17),

  • right to limit the processing of their data for the cases expressly defined by law (GDPR Article 18),

  • right to portability of their data in a structured, commonly used and machine-readable format (GDPR Article 20),

  • the right to transmit their data to another - other than SmartphoneKey- controller (GDPR Article 20), as well as

  • the right to object to the processing of their personal data in the cases expressly defined by law (GDPR Article 21).

We will respond to your requests free of charge and without culpable delay within one (1) month of receipt of the request. Please note that your request must clearly state what information you would like to be changed, which Personal Data of yours to be deleted from our database, or what restrictions you would like us to place on the use of your Personal Data. In exceptional circumstances, due to large workload and depending on the complexity of your request, this deadline may be extended for two (2) months, after you have been informed beforehand about the reason for the delay. To ensure the security of your personal information, we may, at our discretion, ask you to prove your identity before providing the requested information.

9. Data Retention

SmartphoneKey keeps the data in a physical/electronic file for the entire duration of the cooperation.

The data of inactive contracts is kept for a necessary period of 2 years after the termination of the contract for the provision of services/products, unless according to the law they must be kept until the final liquidation of cases, or if a longer period is defined by other legislation period of time (e.g. tax provisions). They are then permanently deleted without the possibility of recovery.

When you request us to remove your Personal Data, we will timely do so after your request and we will no longer be retained them. If we are unable to do so for technical reasons, we will ensure that appropriate measures are taken to prevent any further such use of your Personal Data.

10. Amendments

We may update this Privacy Policy to comply with the amendments of the relevant legislation and reflect the changes in technology and our practices. When using our services, you will be asked to review and accept this Policy and we may record your acceptance. We encourage you to periodically review this page for any changes, as you will be notified by a notice on this website prior to the change becoming effective. The changes will be applicable, upon their publication to our website.

11. Contact Information 

If you would like to receive further information about this Policy, please contact us:

Postal Mailing Address: SMARTPHONEKEY SYSTEMS INC., 1705-40 High Park Ave., Toronto, Ontario, M6P 2S1, Canada,

Email to SmartphoneKey Privacy Office at: info@Smartphonekey.com.).