Privacy Policy

1     Introduction

The owner of this mobile application as more fully defined below (the “App”) is Automated Technical Controls Limited (variously referred to as “ATC”, the “Company”, “we” or “us”). ATC is a Company registered in Ireland under the provisions of the Companies Act 2014. Our Company registration number is 166907 and our registered office is at ATC House, Broomhill Drive, Tallaght, Dublin 24, Ireland.

We are committed to protecting the privacy, and the privacy of the Personal Data, of all who use the App and our Services (referred to as “you” or “your” as the context so requires). This policy explains how we do this and gives you details of our privacy practices, including a) what information we collect about you and in what circumstances as you use the App and our Services; b) how that information is used or disclosed; and c) your rights with respect to our collection, use and retention of your Personal Data.

This Privacy Policy refers solely and exclusively to the App and the Services and does not refer or apply to any other activities of ATC or its affiliates.

2     Definitions and legal references

The following terms are used in this Privacy Policy. Wherever they appear they have the following meaning:

“App” means the mobile software application known as ATC CALA which enables you to control the Product from your mobile device remotely via the internet and which is available for download to your mobile device under license from Google Play of Google LLC or App Store of Apple Inc.

“Data Processor” or “Data Supervisor” refers to the natural or legal person, public authority, agency or other body which processes your Personal Data on our behalf as described in this privacy policy.

“European Union” or “EU” refers to all current member states of the European Union and the European Economic Area unless otherwise specified.

“Personal Data” refers to any information that directly, indirectly, or in connection with other information — including a personal identification number — allows you to be identified as a natural person.

Product” refers to the iLifestyle intelligent radiator purchased from ATC which may be controlled remotely via the App.

Registration Data” refers to information collected by the App to register you as an owner of a Product and to enable you to access the services. This includes your email address, a password created by you and the ATC product identification number associated with each of your Product(s).

Services” refers to the services provided by ATC to allow you to control the Product remotely via the App. The Services make use of third-party services and products including mobile networks and the internet.

“Usage Data” refers to information collected automatically by the App (or third-party services employed in the provision of the Services), including but not limited to the IP addresses, MAC addresses and other identifiers of the mobile devices utilized by you when using the App, the ATC product identification number, IP addresses, MAC addresses and other identifiers of the Product(s) being controlled by the App, the times of sending and receiving of messages between the App and the Product(s), measurement data collected by the App from the Product(s) (including but not limited to on/off status, temperature and power consumption) and control data provided by the App to the Product(s).

3     Types of Personal Data collected

The types of Personal Data that this App collects, by itself or through third parties, includes Registration Data and Usage Data.

 

Personal Data may be freely provided by you in the case of Registration Data or, in case of Usage Data, collected automatically when using the App and the Services.

 

Unless specified otherwise, all Personal Data requested by this App is mandatory and failure to provide this Personal Data may make it impossible for us to provide the Services. In cases where the App specifically states that certain Personal Data is not mandatory, you are free not to communicate this Personal Data without consequences to the availability or the functioning of the Services.

 

If you are uncertain about which Personal Data is mandatory you are welcome to contact us.

 

Note that additional Personal Data may be collected by the distributors of the App, in particular, Apple Store and Google Play. This Privacy Policy does not cover Personal Data collected by such distributors and you should consult the respective privacy policies of these distributors available via their respective websites.

4     Mode and Place of processing the Data

4.1    Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your Personal Data.

 

However, it is your responsibility to maintain the secrecy of any passwords you create when registering with us to access the Services. ATC accepts no responsibility whatsoever for any unauthorised access to or disclosure of your Personal Data as a result of a disclosure of your password whether accidental or otherwise.

 

Personal Data is processed using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the provision of the Services. In addition to us, in some cases, Personal Data may be accessible to certain types of persons in charge, involved with the operation of the App and the provision of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communication network providers) appointed, if necessary, by us. You may request an updated list of these parties from us at any time.

 

You hereby agree to the disclosure of your Personal Data to such third parties as necessary to perform the Services.

4.2    Legal basis of processing

By installing the App and registering for the Services you consent to the collection and processing of your Personal Data for the purposes of us providing the Services to you.

 

The App does not require you to accept or agree to accept advertising messages from us or third parties in order for you to install and use it. Such messages will only be received if you expressly consent to receive them by ticking the box "I accept the sending of electronic commercial communications, including from third parties, according to the Privacy Policy".

 

You understand and agree that we may also be required to process your Personal Data:

·         for compliance with a legal obligation to which we are subject;

·         where the processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; or

·         where the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

4.3    Place

The Personal Data is processed at our operating offices and in any other places where the parties involved in the processing are located.

 

Depending on your location, data transfers may involve transferring your Personal Data to a country other than your own.

 

All Personal Data will be held on servers within the European Union. We will not transfer your Personal Data from within the European Union to outside of the European Union.

 

If you are resident outside the European Union and you wish to use the Services you hereby consent to the transfer to and storing of your Personal Data within the European Union.

4.4    Retention of your Personal Data

We process and retain your Personal Data only for as long as required by the purpose for which they have been collected.

 

Therefore:

 

 

We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

 

Once the retention period expires, we will delete your Personal Data. Therefore, your rights in respect of access to, erasure of, rectification of and portability of your Personal Data cannot be enforced after expiration of the retention period.

5     The Purposes of Processing

We collect and process your Personal Data to allow us provide the Services, comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or the rights and interests of you or third parties), detect any malicious or fraudulent activity, as well as the following: analytics, tag management, infrastructure monitoring, displaying content from external platforms, hosting and backend infrastructure, location-based interactions, managing contacts and sending messages, remarketing and behavioural targeting, contacting you, heat mapping, user database management, interaction with support and feedback platforms, managing support and contact requests, registration and authentication provided directly by the App and SPAM protection.

6     Your rights in respect of your Personal Data

You have certain rights regarding your Personal Data as processed by us which you may exercise at any time while we hold your Personal Data.

 

In particular, you have the right to do the following:

 

 

Any requests to exercise your rights can be sent to us through the contact details provided at the end of this Privacy Policy. These requests can be made free of charge and will be addressed by us as early as possible and always within one month.

7     Additional information about Personal Data collection and processing

7.1    Legal action

Your Personal Data may be used for legal purposes by us in court or in the stages leading to possible legal action arising from improper use of the App or the Services.

 

You declare that you are aware that we may be required to reveal your Personal Data upon request of public authorities.

7.2    System logs and maintenance

For operation and maintenance purposes, the App and any third-party services used by or accessed via the App may collect files that record interaction with the App (System logs) or use other Personal Data (such as your IP Address) for this purpose.

7.3    Information not contained in this policy

You may request further details concerning the collection or processing of your Personal Data from us at any time. Please see the contact information at the end of this Privacy Policy.

8     Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time by notifying you on this page. We strongly recommend that you check this page often, referring to the date of the most recent modification listed at the bottom.

 

Should the changes affect processing activities performed on the basis of your consent, we will collect new consent from you, where required.

 

This Privacy Policy relates solely to this Site, if not stated otherwise within this document.

9     Legal information

This Privacy Policy is subject to the laws of Ireland and has been prepared based on the Data Protection Act 1988 as amended by the Data Protection Act 2018 and in accordance with Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

10   Contacting us

You may contact us in relation to this Privacy Policy or any matter relating to your Personal Data by writing to us at our office address and marking the envelope “Privacy Policy” or by emailing us at GDPR@ATC.com and including the text “Privacy Policy” in the subject line of your email.