Sturlite Electric Pvt Ltd Mobile Privacy Policy

Effective Date 01 JANUARY 2024

Updated: 01 FEBRUARY 2024

Sturlite Electric Pvt Ltd and its subsidiaries (“we,” “us,” “our,” “Sturlite Electric Pvt Ltd”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the Sturlite IHome app and related mobile applications (collectively, the “Products”).

Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share, and transfer Personal Data. In the Policy, you will also find ways to execute your rights of access, update, delete, or protect your Personal Data.

When you accept this Policy during registration or when using our Products and do not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any questions regarding this Policy, please do not hesitate to contact us via:

Postal Mailing Address: #111 Nelson, 3rd floor M. Krishnappa layout, Lal Bagh Main Rd, Bengaluru, Karnataka 560027

Email: care@sturlite.com
Customer Care: 18004199909
Website: www.sturlite.com

Definition:
In this Policy, Personal Data means information generated, collected, recorded, and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone or from that information and other information we have access to about that individual.

Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collect personal sensitive data about you.

Smart Devices refer to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.

Apps refer to those mobile applications developed by Sturlite Electric Pvt Ltd that provide end-users remote control to Smart Devices and with the ability to connect to the supplier IoT Platform.

What Personal Data do we collect:
In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

Information You Voluntarily Provide Us:
Account or Profile Data:
When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference, or time zone information into your account.

If you authorize login to the Products with a third party account, we will obtain from such third party your account information (such as portrait, nickname, region, gender, etc.) which may be bound with your Sturlite Electric Pvt Ltd account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies, or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.

Feedback:
When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number, and your feedback content to address your problems and solve device failures on a timely basis.

Information based on additional functions:
In order to offer you more convenient and higher-quality Services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use the basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:

  • Additional functions based on location information:
    When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time precise or non-precise geo-location when you use certain Smart Devices or the Services, such as a robot cleaner and weather service.
    Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the Services, upon which we will cease to collect and use your location information.
  • Additional services based on camera:
    You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.
  • Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):
    You can use this function to upload your photos/pictures/videos after turning on the photo album permission, so as to realize functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.
  • Additional services related to microphone-based service:
    You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognize your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App.
  • Additional services based on storage permissions:
    The purpose is to ensure the stable operation of the App by utilizing the storage permission. After you give or indicate the permission to read/write your mobile device’s storage, we will access pictures, files, crash log information, and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally. Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect the previous collection and use of information based on your authorization.
  1. Information We Collect Automatically:
    Device Information:
    When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

Usage Data:
During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

Log Information:
When you use our app, the system and exception log may be uploaded. Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.

Location Information:
When you enable location-based functions through permission settings on your mobile device, we will collect and process your location information to enable certain functions, such as pairing with your Smart Devices.
Based on your consent, when you enable the geo-fence feature on the Products, your location information will be generated and shared with Google Map services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the Products, upon which we will cease to collect and use your location information.

  1. Smart Devices Related Information
    Basic Information of Smart Devices:
    When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

Information Reported by Smart Devices:
Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices.

Purposes and legal basis for processing Personal Data:
The purpose for which we may process information about you is as follows:

  • Provide You Services:
    We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
  • Improve Our Services:
    We process your device information, usage data, location information, and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
  • Non-marketing Communication:
    We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, we will also send you notifications related to the services you have purchased, such as alert services. You can check the [App Notification] in the App to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such purpose. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
  • Marketing Communication:
    We may process your Personal Data to provide marketing and promotional materials to you on the Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. If you do not agree to Sturlite Electric Pvt Ltd sending you marketing communications, you may opt out when you enter the App, or by changing your preferences in [Privacy Settings] of the App. The legal basis for this processing is your consent.
  • Personalization:
    We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of the Services. If you do not allow us to process your Personal Data for personalization, you may opt out when you enter the App, or by changing your preferences in [Privacy Settings] in the App. The legal basis for this processing is your consent.
  • Legal Compliance:
    We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
    If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

Who do we Share Personal Data with?
At Sturlite Electric Pvt Ltd, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

-To our third-party service providers:
Who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

-To our customers and other business partners:
Who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.

-To an affiliate or other third party:
In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.

-As we believe to be necessary or appropriate:
(a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

  • To subsidiaries or affiliates:
    Within our corporate family, to carry out regular business activities. Except for the third parties described above, to third parties only with your consent.

International Transfer of Personal Data:
We operate globally and may transfer your Personal Data to individual companies of Sturlite Electric Pvt Ltd, our third-party service providers, business partners, customers, and government authorities around the world. To the extent required by applicable law, when we transfer your Personal Data to recipients in other countries, we will take measures to protect that Personal Data in the manner described in this Policy and in accordance with applicable law.

How Long do we Keep Your Personal Data?
We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

How do we Protect Your Personal Data?
We maintain administrative, technical, and physical safeguards designed to protect the Personal Data you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. When transferring Personal Data, we use SSL encryption to enhance the security of data transmissions. We regularly review our security procedures to consider appropriate new technology and methods.
We have established procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Rights and Choices:
Subject to applicable law, you may have the right to:

  • Request access to your Personal Data;
  • Request correction of your Personal Data;
  • Request deletion of your Personal Data;
  • Object to processing of your Personal Data;
  • Request restriction of processing your Personal Data;
  • Request transfer of your Personal Data;
  • Withdraw your consent.

To exercise any of the above rights, please contact us at care@sturlite.com. We will respond to your request within a reasonable timeframe in accordance with applicable law. We may require additional information from you to allow us to confirm your identity. Please note that we may retain certain information as required by law or for legitimate business purposes.

Cookies and Similar Technologies:
We use cookies and similar technologies to help personalize your use of our Sites and Services. Please refer to our Cookie Policy for more information.

Links to Other Websites:
Our Sites and Services may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Sturlite Electric Pvt Ltd. Linked websites may have their own privacy policies or notices, which we strongly suggest you review. We are not responsible for the content or privacy practices of any website that is not affiliated with Sturlite Electric Pvt Ltd.

Children’s Privacy:
Our Sites and Services are not directed to children under the age of 13, and we do not knowingly collect Personal Data from children under the age of 13. If you are under 13 years of age, then please do not use or access our Sites and Services at any time or in any manner.

Updates to this Privacy Policy:
This Policy may be updated periodically to reflect changes in our information practices. We will indicate at the top of the Policy when it was most recently updated. We encourage you to check this Policy regularly to stay informed of how Sturlite Electric Pvt Ltd is processing your Personal Data.

Contact Us:
If you have any questions or concerns about this Privacy Policy, please contact us at:
Postal Mailing Address: #111 Nelson, 3rd floor M. Krishnappa layout, Lal Bagh Main Rd, Bengaluru, Karnataka 560027

Email: care@sturlite.com
Customer Care: 18004199909
Website: www.sturlite.com