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Last updated: 10th May 2018

 

1 – OVERVIEW

At Gooee, we provide a platform for the management, control and analysis of lighting and sensing based devices. Data generated by these devices can be used for the purposes of automated device control and/or processed within our analytics engine and visualised in real-time or historically within our Dashboard or our SpaceViewTM tool.

Gooee is committed to protecting and respecting your privacy. The following policy outlines what information Gooee Limited and its related entities (“Gooee”) collect about you when you visit our website gooee.com, when you use our products and services (our “Services”), or when you otherwise do business or make contact with us, what we do with that information, how we share it, and how we handle the content you place in our products and services. It also explains the choices available to you regarding our use of your personal information and how you can access and update this information.

 

2 – WHAT INFORMATION DO WE COLLECT?

2.1 – Information you provide to us

We collect personal information when you provide us with such information in the course of using our website or Services. For example, when you register to use our Services, we will collect your:

  • Name
  • Email address
  • Password
  • Phone Number
  • Address

We may also log your IP address when using our Services in order to allow us to monitor for suspicious activity and harmful attacks against our Network.

We also collect personal information from you when you subscribe to our newsletter. If you make an enquiry through our website, or contact us in any other way, we will keep a copy of your communications with us.

2.1.1 – Sensitive Data

We do not collect Sensitive Data (as classified in the GDPR Art. (9)) and it is forbidden under our Terms of Service for users of our platform to store this type of information.

2.1.2 – Our policy toward Children

Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected personal of a child under 13 we will take steps to delete such information from our files as soon as possible.

2.2 – Information we collect from your use of our Services

We may process your personal information when you do business with us – for example, as a customer or prospective customer, or as a vendor, supplier, consultant, or other third party. For example, we may hold your business contact information and financial account information (if any) and other communications you have with us for the purposes of maintaining our business relations with you.

At certain times, another individual (such as an IT Administrator) may create an account for you and may provide your information, including Personal Information (most commonly when your company requests that you use our platform). We collect Information at the request of our customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our customers and would no longer like us to process your information, please contact your employer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.

2.3 – Information we automatically collect

We may also collect certain technical information by automatic means when you visit our website, such as IP address, browser type and operating system, referring URLs, your use of our website, and other clickstream data. We collect this information automatically through the use of various technologies, such as cookies.

2.4 – Personal information where we act as a data processor

We also process personal information on behalf of our customers in the context of supporting our products and services. Where a customer subscribes to our Services to sell lighting and sensing applications (whether this is using a Gooee developed frontend or a proprietary interface), they will be the ones who are responsible for what event data is collected and stored on our systems.

You will need to refer to the privacy policies of our customers to find out more about how such information is handled by them.

 

3 – HOW WE USE THE INFORMATION WE COLLECT

The information we collect is used for the following purposes:

  • Operate, maintain and iterate our Services.
  • To create and administer records about any online account that you register with us
  • Provide a secure access mechanism to our Services, either through a web application, mobile application or directly through our API.
  • To provide you with technical support
  • To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you), including to improve the navigation and content of our sites
  • To provide you with information and access to resources that you have requested from us.
  • For recruitment purposes, where you apply for a job with us
  • Send promotional communications, such as providing you with information about services, upcoming events, new features and news updates.

 

4 – USE OF COOKIES

Gooee and our third party partners may cookies to save site preferences for future visits; improve and customize Services and your experience and to count visits and understand which areas and features of the websites and Gooee Portal are most popular. Cookies are small files that a website, web application or its service provider transfers to your computers hard drive through your browser (if you permit) that allows the website, web application  or service providers systems to identify your browser, store and remember certain information.

You may refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies.

 

5 – SECURITY MEASURES

Gooee implements a variety of security measures to ensure your data is secure and protected, these include but are not limited to:

  • Forcing all APIs (REST and Pub/Sub) to operate over encrypted ports (HTTPS and TLS).
  • Data encryption between services within the Gooee cloud.
  • File encryption on all database servers.
  • Highly restricted access to Production Environments.
  • Full enablement of 2FA and MFA across all services.

 

6 – INFORMATION SHARING

We may, under certain circumstances, share your information with third parties:

  • We work with trusted third party service providers to provide website, application development, hosting, maintenance, backup, storage, virtual infrastructure, analytics and other services for us. These service providers may have access to or process your Information for the purpose of providing those services for us. Any sharing of information will be in accordance with the purposes set out in this Privacy Policy and applicable laws.
  • We may also disclose your information (including personal information) to third parties where we believe it necessary or appropriate under law, for example: (1) to protect or defend our rights, interests, or property or that of third parties; (2) to comply with legal process, judicial orders, or subpoenas; (3) to respond to requests from public or government authorities, including for national security and law enforcement purposes; (4) to prevent or investigate possible wrongdoing in connection with the Services or to enforce our Terms of Service; (5) to protect the vital interests of our users, customers, and other third parties.
  • We may use and share aggregated non-personal information with third parties for marketing, advertising, and analytics purposes.

6.1 – Third Party Services used by our Services

We do not sell or trade your personal information or data to third parties. However our services do utilise the following Third Party Services, and Gooee may share certain information with them:

6.1.1 – Amazon Web Services

Our website and Services are hosted on Amazon Web Services, LLC (AWS) infrastructure. The Personal Data outlined in section 2.1 that collected by Gooee for use in our Services is stored in database services offered by AWS that are encrypted and continually backed up. All information is stored within the European Economic Area (EEA). By using our website and Services, you consent to the processing of data about you by AWS in the manner and for the purposes set out above.

You can find more information about AWS’s security practices at:

http://aws.amazon.com/security/

6.1.2 – MongoDB

Our Services utilise MongoDB, a database service provided by MongoDB, Inc. (Mongo). Our services use Mongo to typically store device and sensor data, however it is possible that some Personal Data (outlined in Section 2.1) could also be stored. All information is stored within the European Economic Area (EEA). By using our website and Services, you consent to the processing of data about you by Mongo in the manner and for the purposes set out above

You can find more information about Mongo’s security practises at:

https://www.mongodb.com/security

6.1.3 – Sentry.io

Our Services utilise Sentry.io (Sentry) for error and issue alerting that enable us to identify and react to any issues that may occur within our Services, and allow us to improve the quality and reliability. The Personal Data outlined in section 2.1 that is collected by Gooee for use in our Services may be transferred to Sentry as part of our use of their platform, by using our Services, you consent to the processing of data about you by Sentry in the manner and for the purposes set out above.

You can find more information about Sentry’s security practises at:

https://sentry.io/security/

6.1.4 – New Relic

Our Services use New Relic, an application performance monitoring tool provided by New Relic, Inc. (New relic). This service helps Gooee monitor for performance of our services and analyse various metrics that help us improve the quality and performance. We do not transfer Personal Data to this service, since the data collected is application and server performance information, however if you wish to find out more about New Relic’s security practises please visit:

https://newrelic.com/security

6.2 – Third Party Services used by our Website

6.2.1 – Google Analytics

Our website and Services uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If you wish to find out more about Google’s security practises in relation to Google Analytics, please visit:

https://support.google.com/analytics/answer/6004245

6.2.2 – Hotjar

Our website and Services uses Hotjar, a web analytics service provided by Hotjar Limited (“Hotjar”). Hotjar uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Hotjar on servers in the European Union. Hotjar will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Hotjar may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Hotjar’s behalf. Hotjar will not associate your IP address with any other data held by Hotjar. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Hotjar in the manner and for the purposes set out above.

If you wish to find out more about Hotjar’s security practises, please visit:

https://help.hotjar.com/hc/en-us/sections/115003180467-Privacy-Security-and-Operations

6.3 – Liability of Onward Transfers

Please be aware that other websites that can be accessed through our website or Services may collect personally identifiable information about you. The information practices of those third-party websites linked to the website and/or our Services are not covered by this Privacy Policy.

 

7 – DATA STORAGE AND HOSTING

Gooee hosts its Services and data within the European Union. The servers and infrastructure upon which Gooee stores your Personal Information are within a highly controlled environment and where data is transferred across the internet it is done so securely using industry standards such as HTTPS and TLS.

Whilst Gooee takes considerable efforts to protect your Personal Information, no security system is impenetrable and due to the nature of the Internet, we cannot provide a complete guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by unauthorised third parties, such as hackers.

 

8 – PRIVACY SHIELD

Gooee complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Gooee has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Under certain limited conditions, EU and Swiss individuals may invoke binding arbitration as a last resort before the Privacy Shield Panel.

  • With respect to onward transfers of data subject to the EU-US and Swiss-US Privacy Shield, we remain liable for processing such transfers in accordance with the EU-US and Swiss-US Privacy Shield Principles.
  • With respect to our compliance with applicable privacy laws and regulations Gooee may be subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

 

9 – DISPUTE RESOLUTION

Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Gooee’s internal processes, Gooee has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure accessed here:

https://www.verasafe.com/privacy-services/dispute-resolution/privacy-shield-dispute-procedure/

Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here:

https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

 

10 – YOUR RIGHTS – ACCESSING YOUR INFORMATION

If you are from the European Union, you may have the right to access a copy of the Personal Information we store about you, or to request an amendment, or deletion of such information where it is inaccurate or processed in violation of the Privacy Shield Principles. To make such a request, please contact us at the contact details below in section (11).

 

11 – CONTACT US

To contact our Data Privacy Officer, please use the following information:

Gooee Limited

2 Eastbourne Terrace

Paddington, London

W2 6LG, UK

Email: privacy@gooee.com