PRIVACY POLICY
Neo Smart Blinds is part of Neo Materials and Consulting inc. located in the country of Canada and subject to Canadian privacy laws. This privacy policy will explain how our organization uses the personal data we collect from you when you use our Website, the Neo Smart Blinds Controller Application and the Neo Smart Blinds Blue Application.
Table of Contents
Definitions
Here is a list of the defined terms that is used throughout the document.
Neo Smart Blinds Controller
The Neo Smart Blinds Controller is a device used in conjunction with the Neo Smart Blinds Controller Application This device is identified by the names “Neo Smart Blinds Controller”, “Power Shade Smart Controller”, “Louvolite One Touch” with the Model number WC100, C-R200. This device allows for wireless and remote control of a wide variety of blind motors. The term Controller is used liberally as an alias for the term Neo Smart Blinds Controller.
Neo Smart Blinds Controller Application
The Neo Smart Blinds Controller Application is the application most appropriate to interact with a Neo Smart Blinds Controller. The Neo Smart Blinds Controller Application is found on Android as com.neosmartblinds.app and as id104691217 on iOS.
It is possible to find the application on .apk format at the following URL on the Play Store:
https://play.google.com/store/apps/details?id=com.neosmartblinds.appIt is possible to find the application on .ipa format at the following URL on the Itunes Store:
https://itunes.apple.com/ca/app/neo-smart-blinds/id1046912127Also the Neo Smart Blinds Controller Application is available in a web format at the two following urls:
Neo Smart Blinds BlueLink
The Neo Smart Blinds BlueLink is a device used in conjunction with the Neo Smart Blinds Blue Application. This device is identified as the Blue Link model L-B200. This device allows for bluetooth control of some specified blind motor categories.
Neo Smart Blinds Blue Application
The Neo Smart Blinds Blue Application is the application most appropriate to interact with a Neo Smart Blinds BlueLink. The Neo Smart Blinds Blue Application is found on Android as com.neosmartblinds.bleapp and as id1182557086 iOS.
It is possible to find the application on .apk format at the following URL on the Play Store:
https://play.google.com/store/apps/details?id=com.neosmartblinds.bleappIt is possible to find the application on .ipa format at the following URL on the Itunes Store:
https://itunes.apple.com/ca/app/neo-smart-blinds/id1182557086Personal Data
In order to function properly, Neo Smart Blinds various applications exposed to EU customers must process Personal Data. Personal Data means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Personal Data is required for multiple reasons as described in the following section of this document. The Personal Data required for each of the 3 applications is different since the need for each application is different. Hereinafter, will list which Personal Data does Neo Smart Blinds process and control.
Data Subject
Neo Smart Blinds Data Subject refers to users of its applications and Website. The term itself is a reference to the fact that those are users which we are processing Personal Data
Data categories
Data collection in the Neo Smart Blinds system is split into four different categories which will be referred to later on.
Error Report
Personal Data in the Error Report category are located in error reports sent automatically when errors happen in an application.
Access Log
Personal Data in the Access Log category are located in web server access logs when Data Subjects are interacting with an application.
User Account
Personal Data in the User Account category is linked to a Data Subject user account (ie. Personal information)
Controller Information
Personal Data in the Controller Information category are stored and processed in the Neo Smart Blinds Controller.
What data do we collect?
Neo Smart Blinds Controller Application
Email Address
In the Neo Smart Blinds Controller Application, a record of the email address of a Data Subject is kept. This constitutes Personal Data in the User Account category.
Email address is defined as what is normally considered to be an email address (name@example.com).
Geolocation Data
In the Neo Smart Blinds Controller Application, the geolocation of the Data Subject is optionally processed. This constitutes Personal Data in the User Account category as well as in the Controller Information category.
Geolocation is defined as the latitude and longitude of the Controller product that is usually located in the Data Subject’s home.
This Personal Data is optional and always used at the behest of our customers, but when it is provided, it allows the Neo Smart Blinds Controller Application to give a richer user experience to the Data Subject by unlocking the relative scheduling functionality (scheduling blinds relative to sunset/sunrise).
In order to protect the Data Subject’s Personal Data, the Geolocation Data is pseudonymized by rounding the location to around 1km of the actual Data Subject’s home. The specific location of a Data Subject’s home is thus never processed.
Timezone Data
In the Neo Smart Blinds Controller Application, the time zone of the Data Subject is stored. This constitutes Personal Data in the User Account category.
Time zone is the one for Data Subject’s home where the Neo Smart Blinds Controller is located.
This is considered as some Personal Data, because it is related to the Data Subject’s location.
IP Address
In the Neo Smart Blinds Controller Application, IP Addresses are stored in logs and in error reports. This constitutes Personal Data in the Error Report category as well as in the Access Log category.
IP Address means an IPV4 IP address (0.0.0.0 - 255.255.255.255) linked to the device that runs the Neo Smart Blinds Controller Application or the IP Address of the Neo Smart Blinds Controller.
Network Information
In the Neo Smart Blinds Controller, Network information is processed in order to allow the Neo Smart Blinds Controller to connect to the network. This information is collected and processed in the Neo Smart Blinds Controller itself. The password of the network itself is never exposed or even accessible.
Neo Smart Blinds Blue Application
IP Address
In the Neo Smart Blinds Blue Application, some IP addresses are stored in error reports. There is no access logs in the Neo Smart Blinds Blue Application. Thus, IP addresses are Personal Data of the Error Report category.
IP Address means an IPV4 IP address (0.0.0.0 - 255.255.255.255) linked to the device that runs the Neo Smart Blinds Blue Application.
Data we do not keep
Since there is no account being created on the Neo Smart Blinds Blue Application, Neo Smart Blinds do not process any other data besides the IP address which is used for error reporting.
All the data the application needs, resides on the phone and is never transferred to a server or any other device.
Website
The Neo Smart Blinds Website does not process Personal Data directly, but process Personal Data through Google Analytics. While Google Analytics doesn't disclose exactly how it builds its profile, it does state that it processes those types of data:
- Online identifiers including cookie identifiers
- internet protocol addresses and device identifiers
- Client identifiers
How do we collect your data?
Personal Data is collected and processed data when a Data Subject:
- Registers or update his personal information in the Neo Smart Blinds Controller Application
- Interacts with the Neo Smart Blinds Controller Application or the Neo Smart Blinds Blue Application
- Connects a Neo Smart Blinds Controller to a personal network
- Browses Neo Smart Blinds website
How will we use your data?
Email communications (Neo Smart Blinds Controller Application)
Neo Smart Blinds processes email addresses within the context of its applications in order to have a way of communicating with its users. Email addresses are processed to allow Data Subjects to reset their password in the case that they have forgotten it. The email address can also be used to send warnings about usage safety. It can also be used when an update would be necessary for the application to keep on working or finally when the Data Subject seems to be experiencing issues with the application as reported by the Neo Smart Blinds error reporting tool.
Identification (Neo Smart Blinds Controller Application)
Email addresses are also processed for authenticating the user. While this personal data could be pseudonymized, it is already being processed for the reasons above. As follows, it is used as an identifier without pseudonymization.
Scheduling (Neo Smart Blinds Controller Application)
Geolocation data is used solely to provide schedules that are relative to sunset/sunrise which is directly linked with the location of the device. Indeed the time for sunset/sunrise is different depending on the location on earth.
If the Data Subject does not wish to use the relative scheduling feature, the geolocation data is not processed.
Time zone data is also used for scheduling, since schedules normally need to be in sync with the local time.
Marketing research (Neo Smart Blinds Website)
On the Neo Smart Blinds Website, Personal Data is processed through Google Analytics to do research on potential market development as well as on user's behaviour on the website.
By having potential customers visits tied to a rough geographical data, it allows Neo Smart Blinds to reach to regional distributors in order for these potential customers to have Neo Smart Blinds products available to them in the future.
By monitoring Data Subject’s behaviour on the website, it allows Neo Smart Blinds to improve its website by making sure that users find the information they were looking for more rapidly.
Error reporting and monitoring
In the Neo Smart Blinds Controller Application and in the Neo Smart Blinds Blue Application, an error reporting tool called Sentry is used to report errors and bugs occurring in the applications. Within these error reports, some Personal Data is being processed (namely the email address and/or the IP address) of the Data Subject experiencing those errors.
This information allows for better debugging and for helping users experiencing these errors to resolve their issues. The IP address allows us to determine the geographical region of the occurrence of the bug which is then used to track the server where resides the bug, greatly improving the capability of resolving the issue without disturbance.
How do we store your data?
Amazon Web Services
Most of the Personal Data stored and processed by Neo Smart Blinds is done through the Amazon Web Services platform. The design of the different applications move those data seamlessly through the Amazon Web Services regions that are used.
EU-WEST (Ireland)
Most of the EU zone Personal Data will be processed through the EU-West-1 zone which is in Ireland. Ireland is subject to EU laws.
US-EAST and US-WEST
Most of the international data will be processed through the US-East-1 and US-West-2 zones which are both in the United States.
GDPR provisions
The United States is not subject to EU laws. But the United States (as well as Canada) is a Third Country expressly permitted by the GDPR to have Personal Data transferred to it without special authorization as long as it is a member of Privacy Shield. The list of Third Countries is listed here: https://gdpr-info.eu/issues/third-countries/ and the list of companies member of Privacy Shield is listed here: https://www.privacyshield.gov/list
No special treatments for data transfers between regions are thus required.
Access Logs and Error reports
All Personal Data in the Error Report category or the Access Log category is only kept for a period of 30 days, after which it is erased.
Since Personal Data in those two categories is only processed for debugging purposes and issue fixing purpose, the period of 30 days is deemed sufficient to accomplish the purpose of debugging and issue fixing.
Personal data in Controller
Personal Data in the Controller is stored within the Neo Smart Blinds Controller itself. All external communications to the Internet from and to the Neo Smart Blinds Controller is done in an encrypted tunnel. Personal Data is deleted either through a full hardware reset or through external commands sent to the Neo Smart Blinds Controller.
Security
All Neo Smart Blinds systems are built upon stable and secure infrastructure. Communications within the different systems is encrypted. Personal Data is pseudonymized as much as possible to limit damages in case of a data leak.
Regular safety measures are imposed to protect the sensitive information. If you have any issues about security or require more precision, feel free to contact us.
Personal Data Retention
Once a Data Subject states his desire to be removed from the application through email communication or through the application itself, all Personal Data from the Controller Information category and all Personal Data from the User Account category will be deleted within 1 month.
In the context of the Neo Smart Blinds Website, the Data Subject will have to submit additional information in order to identify the concerning data, as these applications do not store sufficient Personal Data for identification. Namely, those Data Subject will have to submit their IP as well as proof that their IP is associated with them in order to delete those Personal Data.
Account inactivity
After a reasonable delay of (365) days and an email notification to the Data Subject, Personal Data from the User Account category for inactive accounts are erased. An account is deemed inactive if there is no Neo Smart Blinds Controller linked to the user account.
Only some archived pseudonymized data for growth reporting is kept once this erasure is completed; No Personal Data remains.
No User Account Personal Data is ever created for the Neo Smart Blinds Website, nor for the Neo Smart Blinds Blue Application. The paragraph above is solely within the context of the Neo Smart Blinds Controller Application.
What are your data protection rights?
Neo Smart Blinds would like to make sure that his Data Subject are fully aware of all of their data protection rights. Every user is entitled to the following:
The right to access – Data Subjects have the right to request Neo Smart Blinds for copies of their Personal Data.
The right to rectification – Data Subjects have the right to request that Neo Smart Blinds correct any information they believe is inaccurate. They also have the right to request Neo Smart Blinds to complete the information that they believe is incomplete.
The right to erasure – Data Subjects have the right to request that Neo Smart Blinds erase their Personal Data.
The right to restrict processing – Data Subjects have the right to request that Neo Smart Blinds restrict the processing of their Personal Data.
The right to object to processing – Data Subjects have the right to object to Neo Smart Blinds’s processing of their Personal Data.
The right to data portability – Data Subjects have the right to request that Neo Smart Blinds transfer the data that they have collected to another organization, or directly to the Data Subject.
For any such request, Neo Smart Blinds have one month to respond to the Data Subject query. To exercise any of these rights, please contact Neo Smart Blinds
- Email us at: tech@neosmartblinds.com
- Call us at: +1 514-291-9430
- Or write to us: 9386, Boulevard Viau Saint Leonard, QC, H1R 3B5, Canada
Privacy policies of other websites
The Neo Smart Blinds website contains links to other websites. This privacy policy applies only to the Neo Smart Blinds website.
Changes to our privacy policy
Neo Smart Blinds keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 16th of October 2019.
How to contact us
If you have any questions about Neo Smart Blinds’s privacy policy, the data it holds on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
- Email us at: tech@neosmartblinds.com
- Call us at: +1 514-291-9430
- Or write to us: 9386, Boulevard Viau Saint Leonard, QC, H1R 3B5, Canada
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Neo Smart Blinds has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.
- Email: general@oic-ci.gc.ca
- Address: 30 Victoria Street Gatineau, QC K1A 1H3, Canada
Previous Policy and Terms versions
- March 15, 2022: Privacy Policy
- October 16, 2019: Privacy Policy Terms of Service
TERMS OF SERVICE
These Terms apply in full force and effect to your use of this app and by using this app you accept all terms and conditions in full. You must not use Neo Smart Blinds applications, if you have any objection to any of these Terms of Service.
Intellectual Property Rights
Other than content you own, which you may have chosen to include in one of Neo Smart Blinds Applications, Neo Smart Blinds and/or its licensors own all rights to the intellectual property and material contained in this app. You are granted a limited license only, subject to the restrictions provided in these Terms, for purposes of viewing the material contained on this app.
Restrictions
You are expressly and emphatically restricted from all of the following: Publishing any app material in any media, Selling, sublicensing and/or commercializing in any way, any app material, Publicly performing or displaying any app material, Using this app in a way that is damaging, or that could be damaging to this app, Using this app contrary to applicable laws and regulations, or in a manner that results in, or that could result in harm to the app, or to any person or business entity, Engaging in any data mining, data harvesting, data extracting or any other similar type activity related to this app, or while using this app Using this app to engage in any type of advertising or marketing activity. Certain areas of this app are restricted from access by you and Neo Smart Blinds may further restrict access to other areas of this app by you, at any time, at its sole discretion.
No warranties
Neo Smart Blinds makes no express or implied warranties or representations of any kind with regards to this app or the materials contained on this app. In addition no content contained on this app shall be considered as providing advice to you.
Limitation of liability
Under no circumstances shall Neo Smart Blinds, or any of its officers, directors and employees, be liable to you for anything resulting from or connected to your use of this app. Neo Smart Blinds, including its officers, directors and employees shall not be liable for any indirect, consequential or special liability resulting from or in any way related to your use of this app.
Severability
Should any provision of these Terms be found to be unenforceable or invalid under any applicable law, the unenforceability or invalidity shall not render these Terms unenforceable or invalid as a whole. Any such provisions shall be deleted without affecting the remaining provisions contained herein.
Variation of Terms
These Terms may be revised at any time Neo Smart Blinds sees fit, and you are expected to review such terms on a regular basis to ensure your understanding of all terms and conditions governing use of this app revise the updated date at the bottom of this page. By using this app you are acknowledging your responsibility to do so.
Entire Agreement
These Terms, including any legal notices and disclaimers contained on this app, constitute the entire agreement between Neo Smart Blinds and you with regards to your use of this app, and replace all prior agreements and understandings with respect to the same.
Governing Law and Jurisdiction
These Terms will be governed by and construed in accordance with the laws of Canada, and you submit to the nonexclusive jurisdiction of the courts located in Canada for the resolution of any disputes.
Previous Policy and Terms versions
- March 15, 2022: Privacy Policy
- October 16, 2019: Privacy Policy Terms of Service