Privacy policy for Paulmann smik
This privacy policy governs the processing of your personal data in the context of using the Paulmann smik app in combination with a Paulmann smik gateway, as well as compatible Zigbee products connected to this gateway and services of Paulmann or third-party providers.
Protecting the security and confidentiality of your personal data is an important concern for us. For this reason, we operate our business in compliance with the applicable laws concerning data protection and data security. In the policy below, we want to help you understand which data we collect and how we use, save, protect, forward and store these data.
Controller
The controller pursuant to Art. 4 (7) of the European General Data Protection Regulation, hereinafter referred to as "GDPR", is
Paulmann Licht GmbH
Quezinger Feld 2
31832 Springe-Völksen
Germany
Email: info@paulmann.de
(hereinafter referred to as Paulmann).
Data protection officer
Paulmann has appointed a data protection officer, who you can contact at Datenschutz@paulmann.de or at
Thosa-Datenschutz UG (limited liability)
Hans-Böckler-Allee 26
30173 Hannover, Germany.
Collection and processing of personal data
We obtain your personal data when you use the Paulmann smik app.
When you download the Paulmann smik app from an app store, certain required information, in particular your user name, email address and customer number, time of download, payment information and individual device ID number, will be transferred to the app store. The data is not processed by us, but by the provider of the respective app store within the scope of the terms and conditions of use. We do not have any influence over this data processing. More detailed information can be found in the data protection policy of the respective app store (Google Play Store, Apple App Store).
If you have a Paulmann smik gateway, a Paulmann user account is technically required in order to use particular services such as remote control or voice assistants. During account creation, we ask you for your email address, username and optionally for your gender and age (not specifically, but in age ranges). For account verification, an email will be sent to you including an email code to enter in the registration screen. The Paulmann user account is processed via a Microsoft Azure platform hosted in Germany. You can find more information about Microsoft Azure in Microsoft's privacy policy (Microsoft Azure Datenschutzhinweise, Microsoft Azure Compliance).
We collect and store all the abovementioned information that you intentionally share with us in the process of creating your Paulmann user account. We use your email address to identify your user account. The legal basis for the processing of your personal data in this respect is Art. 6 (1)(b) GDPR. To this extent, you are contractually obligated to provide us with the corresponding information. Otherwise, we are unable to provide you with all the services of our app in connection with the smik gateway.
If you connect your products using third-party applications such as Amazon Alexa, Google Assistant etc., these third-party providers may collect personal data and may return personal data via the interface. We do not have any influence over this data processing. If you use third-party applications, we will only pass on your data to these third-party providers with your consent. More detailed information can be found in the privacy policy of your respective third-party provider (Amazon Alexa, Google Assistant). Please read this carefully and make sure that you agree to the use of your personal data by these third-party providers.
In case of malfunctions, you have the option of actively providing the Paulmann Service Team with locally created and maintained log files. These log files could contain personal data of your user account. You provide these data voluntarily and only for the purpose of fault analysis. The legal basis for this data processing is Art. 6 (1) letter (a) GDPR. If you have given your consent for your personal data to be processed, you can revoke this consent at any time with effect for the future.
Transfer of your personal data
Neither we nor third parties will sell or trade your personal data.
We only transfer your personal data in compliance with applicable law and exclusively to third parties who we have engaged as IT service providers to provide the platform and cloud services, administration as well as system upkeep. The corresponding third party only uses the data for the provision of services and according to contractual agreements regarding the confidentiality of the data. Regardless of where this third party is based, we also demand them to ensure compliance with the GDPR and the applicable data protection laws.
In general, third parties could process your personal data outside of the European Economic Area insofar as you use third-party services such as Amazon Alexa or Google Assistant . If the protection level is not considered appropriate as resolved by the European Commission, we have prepared suitable guarantees in order to protect your personal data at a level corresponding to the level of data protection in the European Union. In particular, we use the standard contractual clauses published by the European Union.
Protection of your data
The protection of your personal data is very important to us. Here are some examples of preventive measures that we take in order to protect your personal data:
• Hosting in Germany
• Encryption of communication paths and critical data
• Use of passwords and (if necessary) additional tokens
• Use of Microsoft Azure security architecture
• Maintenance access to data only for a minimum number of administrators
• Regular review of the smik system for security gaps
Erasure of your data
We erase your personal data as soon as the intended purpose is no longer relevant and no further processing or storage of your personal data is required in order to comply with a corresponding legal obligation.
In particular, the Paulmann user account enables you to use specific services such as remote control or voice assistants. We regularly review whether you have accessed specific cloud-based functions using your account in the past 24 months. If this has not occurred, the intended purpose is no longer relevant and we automatically delete your account without informing you further. Alternatively, we will inform you at our due discretion using the email address you indicated when registering for a Paulmann user account.
As required, of course, you can create a new Paulmann user account.
If you would like to delete your account with the personal data, send an email to app-support@paulmann.de.
Your rights
You have the following rights regarding your personal data (in accordance with Art. 15 to 20 of GPDR)
• Right to information / a copy of the processed data
You can request information about whether your personal data is processed and, in particular, about the purpose of processing, the categories of processed personal data, who receives your personal data, as well as the storage duration.
You can request a copy of your personal data, which, if requested by email, must be provided to you in a conventional electronic format, provided that this does not impinge on the rights or freedoms of other individuals. To request a copy of your data, please specify exactly which data you require.
• Right to correction and completion
You can request the immediate correction or completion of incorrect or incomplete personal data.
• Right to deletion
You have the right to request that your personal data is deleted, particularly if the data is no longer needed for the purpose for which it was processed. Your data will be deleted immediately, provided that there is no legal exception allowing the retention of your data.
• Right to limitation of processing
You can request that the processing of your personal data be limited, particularly if you dispute the correctness of the data and the data is being reviewed, if the processing of the data is unlawful and you decline its deletion, if you require the data in order to assert, exercise or defend your legal rights, or if you have raised an objection to the processing of your data.
• Data portability
You can request the personal data you have provided in a structured, conventional and machine-readable format, so that you can transfer it to another controller. You also have the right to request that data is transferred directly to another controller. The prerequisite to this right is that the processing of your data is based on consent, the implementation of pre-contractual measures, or the fulfilment of a contract.
• Right to object
If the processing of your data is based on a legitimate interest of the controller, you can object to it.
• Right to revoke
If you have given your consent for your personal data to be processed, you can revoke this consent at any time with effect for the future.
Right to complain
You have the right to make a complaint to the supervisory authority, if you feel that the processing of your personal data violates the legal regulations.
Supervisory authority: Landesbeauftragte für den Datenschutz in Niedersachsen (State Representatives for Data Protection in Lower Saxony), Prinzenstr. 5, 30159 Hanover, Germany. Phone +49 511 120 – 4500, Fax +49 511 120 – 4599, Email: poststelle@lfd.niedersachsen.de.
Automated decision-making
No automated decision-making or profiling takes place via the Paulmann app.
Contact details
If you have questions about this policy or our data protection measures in general, you can contact us at any time:
Paulmann Licht GmbH
Quezinger Feld 2
31832 Springe-Völksen
Email: app-support@paulmann.de
State: February 2022