1. Our Commitment to Protect Your Privacy
We do not knowingly collect or solicit personal data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 13, we will promptly delete the personal data. If you believe that a child under 13 may have provided us personal data, please contact us at firstname.lastname@example.org.
2. The Data we collect
Personal Data You Provide To Us
It is not mandatory to provide any of the personal data described above to L.C. Industrial, but if you choose not to, you may not be able to receive any of the Services described below, access certain parts of our websites, or receive information from us that you have requested.
Personal Data Collected Automatically
Whenever you interact with our Services (whether via a mobile application, our IoT plug-ins, third party services, App, browser, or other application, connecting a physical device to our services, connecting a third party service to our services, or otherwise), we automatically receive and record information on our servers, logs and databases from your browser, application, services or device(s). In particular, our Services are designed to allow you to connect various physical devices (e.g., the Focal Basic, and associated Focal and third party sensors and other devices) to the Services. While connected to the Services, these devices automatically report information to our servers (including information that you may have provided when setting up or configuring that device), which may include personal data. For example, if you connect a temperature sensor to the Services, the temperature information from that sensor will be transmitted to the Services, along with any identifying information that you have chosen to associate with that sensor (e.g., the device name, Action name, and Room/Location name that you have assigned to the sensor within the Services). The type of information that is collected from each device will vary depending on the device type.
3. Who we share your Personal Data With
In certain circumstances, we will disclose your personal Data to third parties as described below:
Aggregated Personal Information that's no longer personally identifiable
We may anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners or use that information for in marketing or promotional items (“aggregate information”). We may also provide aggregate information to our partners, who may use such information to understand how often and in what ways people use our Services. However, except as described below, we do not disclose aggregate information to a partner in a manner that would identify you personally, as an individual.
We may allow advertisers and/or merchant partners ("Advertisers") to choose the users who will see their advertisements and/or promotional offers. You agree that we may provide any of the aggregate information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers (“Targeted Advertising”). For example, we might use the fact you are located in California to show you ads or offers for California businesses, but we will not tell such businesses who you are. In addition to the foregoing, if you have not opted out of our targeted advertising feature as described below, you agree that we may share your personally identifiable information with Advertisers in order to deliver specific targeted advertising or offers to you ("Targeted Advertising"). For example, we might share with our Advertisers the fact that a moisture sensor that you have connected to our Services has detected a flood in order to show you ads or offers for local plumbing services. If we enable Targeted Advertising for our users by default, you will be able to opt out of Targeted Advertising at any time by changing your personal settings.
Partners, Affiliated Businesses and Third Party Websites We Do Not Control
In certain situations, partners, businesses or third party websites we're affiliated with ("Affiliated Businesses") may sell items or provide services to you through the Services (either alone or jointly with us), including reselling providing third party devices, or delivering unique or custom Apps. You can recognize when an Affiliated Business is associated with such a transaction or service based on the presence of their brand or a transaction you are conducting directly with that Affiliated Business. We will share your Personal Information with that Affiliated Business only to the extent that it is related to such transaction or service, and to the extent that you have explicitly accepted incremental terms with that Affiliated Business whereby you acknowledge and authorize us to share your Personal Information. We have no control over the policies and practices of Affiliated Businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an Affiliated Business, please review all such business' or websites' policies. If you decide you no longer want to share Personal Information with an Affiliated Business, you may no longer be entitled to receive certain benefits from the Affiliated Business or have access to the Services without establishing a new account or relationship with Focal.
User Profiles and Submissions
Certain user profile information, including without limitation a user’s name, location, and any content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for Focal’s Services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by others. Your user name may also be displayed to other users if and when you send messages or comments or upload content through the Services and other users can contact you through messages and comments. Additionally, if you sign into the Services through a third party social networking site or service, your list of "friends" from that site or service may be automatically imported to the Services, and such "friends,"" if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third party site or service.
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.
Protection of Focal and Others
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Focal, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
4. How Secure is your Personal Data
Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or mobile device and browser or application by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We may use Personal Data for marketing and promotional purposes, including (i) for sending or showing you updates on latest news, offers and promotions in connection with our products and services (ii) for sending or showing joint marketing offers, loyalty programs, contests and sweepstakes; or (iii) for tailoring and tracking your interactions with internet banner advertisements and links from third party websites to our website.
We may also use Personal Data to analyze our customers’ preferences and market trends and derive insights, which we may use to tailor the type of products and offers that we present to you. This may involve us combining Personal Data that we hold about your use of our services with information that we have collected about your web usage. We might provide these insights to our third party partners for their marketing and promotional purposes.
We may communicate marketing and promotions to you by post, telephone, or online and, as appropriate and where required.
6. Transmission and storage of your Personal Data
No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.
All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your Personal Data to those persons who need to use it for the purpose for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of.
Exporting your Personal Data
Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.
We will retain your Personal Data for as long as is necessary for the processing purpose for which it was collected and any other permitted linked purpose. Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized.
7. Your rights and contacting us
You have the right to access certain personal Data held about you and correct any inaccuracies. We may charge a reasonable fee for the processing of any data access request in accordance with data protection legislation in your country.
We will take reasonable steps to try and ensure that your Personal Data is accurate. To help us do this, please notify us of any changes to your Personal Data.
Your California Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. You may also ask us to refrain from sharing your personal information with third parties for their marketing purposes If you are a California resident and would like a copy of this notice or wish to make a request that we refrain from sharing your information with third parties for their marketing purposes, please submit a written request to email@example.com with Subject as: CPR Request
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Targeted Advertising. If you do not want to receive Targeted Advertising on other websites or select your preferences about the third party Advertisers and advertising network programs that provide you with Targeted Advertising, you can opt-out by visiting the:
NAI Opt-Out Page: http://www.networkadvertising.org/choices/, and
Ad Choices Opt-Out Page: http://aboutads.info/choices/
Please note that if you opt-out of Targeted Advertising you may still receive advertisements from L.C. Industrial and others; however, these ads will not be displayed due to Targeted Advertising.
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