This privacy policy was updated on June 18, 2018
Privacy Policy
iotGizmo Corporation ("iotGizmo") respects your privacy and is committed to comply with applicable data protection and privacy laws. This privacy policy ("Policy") describes how we collect and use personal data where iotGizmo is the data controller or where we refer to the applicability of this Policy. Personal data means information relating to you or another identifiable individual.
iotGizmo does not share your personal information with third parties and does not sell any information that we may gather about you. iotGizmo is committed to making smart energy simple to use for all consumers and information that we gather is used for product improvements, troubleshooting for the purposes of customer service or marketing additional products and/or services that we believe are relevant to your interests in smart energy. Our products or services may contain links to, or may be embedded within, other companies' websites and services that have privacy policies of their own.
If you do not agree with this Policy, do not use our products and services or provide iotGizmo with your personal data.
What information do we collect?
We collect your personal data and other information when you make a purchase, use or register for our products and services, take part in campaigns or research or otherwise interact with us. This includes following categories:
Product and service activations
iotGizmo products and services may require electronic activation, where your device and application type, as well as unique device, application, network and subscription identifiers are used by iotGizmo.
Use of products and services
When you access our services online, our servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information.
Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information may be collected subject to your consent.
Information you provide us with
When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such payment information.
Your transactions with us
We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and iotGizmo, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, for quality assurance and continuous improvement purposes, record your communication with our customer care or with other such contact points.
Positioning and Location data
Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy ("BLE") or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network related identifiers with iotGizmo. Our products may operate on multiple device platforms, applications and services which may also collect your location data. We do not use this information to identify you personally without your consent and we never share with or sell this data to third parties.
When you use our location based services and features, for example location based smart thermostat controls, your location data is sent to iotGizmo.
Why do we process personal data?
iotGizmo may process your personal data for the following purposes. One or more purposes may apply simultaneously.
Providing products and services
We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to fulfill the Terms of Service between you and iotGizmo, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.
Developing and managing products and services
We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular iotGizmo product and/or service with other personal data we may have about you. For example, information about the location where you use iotGizmo products may be used towards evolving product features and the general improvement of our products and/or services.
Communicating with you
We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.
Marketing, advertising and making recommendations
We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying iotGizmo and third party content.
What is our legal basis for processing your personal data?
Our legal basis for processing your personal data is dependent on the purpose for processing as to the product or service you are using. In general, we process your personal data under the following legal basis:
Performance of a contract with you
We process your personal data to fulfill our obligations under the Terms of Service applicable to the product or service you are using, provided by us or our customers.
Your consent
We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available based on consent.
Legal obligations
We process your personal data as needed to comply with laws and regulations.
Legitimate interests
We process your personal data to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal data, and in any event will be subject to the restrictions provided in this Policy.
How long do we retain personal data?
We endeavor to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was provided. For example, your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period for customer service purposes before being anonymized or pseudonymized. You may contact the iotGizmo Privacy Office at
privacy@iotGizmo.com to obtain additional information about retention of your personal data.
Do we share personal data?
We do not sell, lease, or rent your personal data to third parties. Further, we do not share or otherwise disclose your personal data to third parties unless otherwise stated below.
Your consent and social sharing services
We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.
iotGizmo companies and authorized third parties
We may share your personal data with other iotGizmo companies or authorized third parties who process personal data for iotGizmo for the purposes described in this Policy. This may include for example billing and/or delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting research and managing marketing and other such campaigns. When you purchase an iotGizmoproduct and/or service from us with a network service provider plan, we may need to exchange information with your network service provider to provide you with such service.
We may conduct joint marketing and other communications with our partners, for example your mobile operator. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that iotGizmo has collected with information that the partner has collected where this is permitted by law.
These authorized third parties are not permitted to use your personal data for any other purposes. We bind them contractually, require them to act consistently with this Policy, and to use appropriate security measures to protect your personal data.
International transfers of personal data
Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by requiring the use of appropriate technical and organizational information security measures and by using standard contractual clauses approved by the European Commission or relevant authorities (where necessary). You may contact the iotGizmo Privacy Office at
privacy@iotGizmo.com to obtain additional information about the safeguards we take in connection with these transfers. A copy of the unchangeable Standard Contractual Clauses can be accessed at
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en for iotGizmo customers using our products and/or services who are within the European Union.
Mandatory disclosures
We may be obligated by law or regulation to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend iotGizmo’s legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings.
Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisors. We will require a similar level of protection of your private information as a condition of any such transaction should one occur.
How do we address the privacy of children?
iotGizmo products and services are not designed for children and are typically intended for general audiences. iotGizmo does not knowingly collect information of children without the consent of their parents or guardians.
How do we address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We encourage you to access your personal data through your account from time to time to ensure that it is up to date.
What steps are taken to safeguard Personal Data?
Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. All data gathered from our website, our mobile application and smart devices use encrypted communications and all such data is stored in encrypted form. All appropriate data is de-identified or pseudonymized after a period of time. Also, we limit access to our databases containing personal data to authorized persons having a justified need to access such information.
How do we use Cookies and Web Beacons?
iotGizmo uses cookies, web beacons and other similar technologies to operate and improve our websites and offerings. We may use cookies for personalization and to display ads. Some iotGizmo websites may use third party advertising technologies to serve ads.
Our domains may include third party elements that set cookies on behalf of a third party, for example relating to third party social network.
What are your rights?
You have a right to know what personal data we hold about you, and to access it. You have a right to have incomplete, incorrect, unnecessary or outdated personal data updated. You have the right to request that your personal data be erased, and to obtain a copy of your data in a machine-readable format. You have the right to object to or restrict processing in certain circumstances, such as where you believe the data is inaccurate or the processing activity is unlawful. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from iotGizmo, critical alerts related to your continued use of our products and/or services may still be sent to you. If you are located in a European Union member state or within the European Economic Area, you have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned.
You may exercise your rights by
contacting us or by managing your account and choices through available profile management tools on your device and our services. In some cases, especially if you wish us to delete or stop processing your personal data, this may also mean that we may not be able to continue to provide the services to you. Applicable data protection law may provide certain restrictions on the extent to which these rights may be exercised. If a restriction applies, we will respond to your request with an explanation of what action will be taken, to the extent required under applicable data protection law.
Changes to this Privacy Policy
iotGizmo may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material adverse way, iotGizmo will post a notice advising of a change at the beginning of this Policy and on this site's
home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy
