Privacy Policy

1 Who we are

1.1. We are Perenio IoT spol s r.o. Na Dlouhem 79, Ricany – Jazlovice 251 01, Czeh Republic.
1.2. This Privacy Policy sets out how we collect and use your personal information when you visit perenio.com (including our iPhone, Android apps) (hereinafter the Site) and the choices available to you in connection with our use of your personal information (the Privacy Policy). This Privacy Policy should be read alongside, and in addition to, our Site terms and conditions (accessible online at Terms and Conditions (Terms) and our Cookie Policy (accessible online at Cookie Policy). In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

 

2 This Privacy Policy

2.1. By making available the Site and App (hereinafter the Site and Apps) we, acting reasonably and in good faith, believe that you:

• have all necessary rights to register on and use this Site and Apps;
• provide true information about yourself to the extent necessary for use of the Site Services and Apps;
• understand that by the posting your personal information you have manifestly made this information public, and this information may become available to Administration; 
• understand that some types of information transferred by you to other Site users cannot be deleted by you or us; 
• are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
2.3. This Privacy Policy shall be applicable to EU Citizens only. If you are not a EU Citizen, please refer to the Privacy Policy applicable in your jurisdiction.

 

3 Information we collect about you

3.1. In order to implement the agreement between you and us and provide you with access to the use of the Site functionality, we will improve the Site Services, develop and implement new Site and App Services, and enhance available Site and App functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organize, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we collect when you use our Site and App Services, why we collect and process it and the legal bases below.

	Information Collected	Purpose	Legal Basis
1	Location Data	We use your location data in order to generate recommendations and tailor and improve the adverts that are presented on the Sites partners. We also use this information in order to provide you with recommendations, we feel you may be interested in, updates and information on our and selected third parties' products and services we think you may be interested in	Consent Legitimate Interests
2	Data you provide for registering on the Site including your name, surname, mobile phone number and/or email	We also use this information in order to provide you with recommendations, partners Sites we feel you may be interested in, updates and information on our and selected third parties' products and services we think you may be interested in. We use this information in order to generate recommendations and tailor and improve the Services that are presented on the Site and App	Legitimate interests Performance of our contract with you
3	Where necessary, a copy of your identity or another document containing your name, surname, photography and number of the principal identity document of you or your representative. We may take additional verification steps where we consider reasonable in order to verify your account	We use this data in order to verify your account and prevent abuse and infringements of your or other persons' rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us	Legitimate Interests Performance of our contract with you
4	Additional data you provide when you edit your page via Profile including your family status, native city, current city,home address etc. Additional data you provide when you edit your settings	We use this information in order to manage and administer the Site including providing our Site and App Services to you. We also use this information in order to provide you with recommendations we feel you may be interested in, updates and information on our and selected third parties' products and services we think you may be interested in. We use this information in order to tailor and improve the adverts that are presented on the Site partners and measure the effectiveness of these advertisements	Legitimate interests Performance of our contract with you
5	Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP-address, your operating system, type of a browser, geographic position, your installed apps, the Internet provider, contacts from your phonebook, data obtained accessing the camera, microphone and similar devices) and your browsing behavior and further actions on the Site and App	We use your data for internal review in order to constantly improve the content of our web page, to understand any errors you may encounter when using the Site and App, to notify you of changes to the Site and App and to personalize the use of our Site and App. Information containing the Site activity history is available in the "Settings / Security" section of your page. We use this information in order to tailor and improve the adverts that are presented on the Site and App and measure the effectiveness of these advertisements	Legitimate Interests
6	Information that is automatically received at the time of access to the Site or the third parties’ websites with the use of cookies and such a technology as Google Analytics and Yandex Metriks	Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for. We use this information in order to tailor and improve the adverts that are presented on the Sites partners and measure the effectiveness of these advertisements and to provide you with the possibility of use the part of Site’s functionality on the third parties’ websites	Consent
7	Information that is created by you on your page outside the page edit section Profile and the Site and App ((including profile name, rooms, alerts, pictures, audio recordings, video recordings)	We use this information in order to manage and administer the Site and App including providing our services to you	Legitimate interests, which inter alia, include the processing of manifestly made public by you data Performance of our contract with you
8	Information that is created by you while placing requests to our Services support	We use this information in order to verify your identity and to fullfil your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service	Legitimate Interests Performance of our contract with you
9	Information that is received as the result of your behavioral actions on the Site (joining / leaving an App, posting pictures, your activity history and watch video)	We use this information in order to manage and administer the Site and App including providing our Site and App Services to you. We use this information in order to quality of services, display of information on the site and in the application. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service	Legitimate Interests
10	Information that is received about you as the result of other users’ actions on the Site (Motion sensor, leakage, etc.)	We use this information in order to manage and administer the Site including providing our Site Services to you. We also may use this data in order to tailor your use of the Site and your interaction with our Site Services	Legitimate Interests
11	Information that is received as the result of your using payment functionality on the Site (e.g. first and last four digits of your card number that are needed for the option of matching these details with user’s id number)	We use this information in order to manage and administer the Site including providing our Site Services to you. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service	Legitimate Interests Performance of our contract with you
12	Data collected via third parties including your friends' information from Facebook, VK, Instagram	We import this information into a web analytics system for the subsequent preparation of promotional offers about our services and services to your friends	Legitimate Interests Performance of our contract with you

 

3.3. Our legitimate interests include (1) maintaining and administrating the Site and App; (2) providing the Site Services to you; (3) improving the content of the Site; (4) processing of the data that was manifestly made public by you (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.4. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
3.5. You may withdraw your consent the collection of location data and your apps by amending your privacy settings on the mobile app/the privacy settings of your mobile device. You may withdraw your Start of active services, Startup after device is switched on Reading notifications in popups Network connection, viewing Sleep mode disabling, Wi-Fi Connection viewing, retrieving data from the Internet Vibration signal control Google Play Payment System, Wi-Fi Connection/Disconnection, Unlimited Internet Access Network setting changing, Play Install Referrer API in your phone settings. An option to unsubscribe will also be included in every email (as direct marketing) sent to you by us or our selected third-party partners if such direct marketing is realized in fact by us or our selected third-party partners with our permission.
3.6. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Site. Once you have provided this data it will be accessible by Administration and third-party partners, and it becomes difficult for us to remove this data.
3.7. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Site and App, you may not be able to access or register with the Site and App.
3.8. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

 

4 Data sharing

4.1. Using VPN services, "Private Tab" mode, Tor Browser, etc. tools you can determine your confidentiality mode and conditions of access to the information mentioned at purposes 2,3,4 and 7 in the table above. But in this case, we can not guarantee the quality of the services provided. We take technical and organizational measures to ensure that the appropriate Site and App tools are functional. Please note that when you post your personal information this may become available to internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.
4.2. We may share your data with Luxembourg-based AWS entity, Amazon Web Services EMEA SARL, ("AWS Europe") because some of our services are serviced there; for more details, see their data collection and storage policy at the following address: aws.amazon.com. Sometimes we may also need to share your data with a third party in order to provide our services to you or to administer the Site and App, for example if you choose to share your data across other social media platforms.
4.3. We may also share your data with our third-party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by the Site and your use of the applications they offer. Data will only be shared with these developers with your consent. You can authorize developers to access your information via the Site and/or App.
4.4. The following services are used as an advertising management system: Yandex Merika and Google Analytics and Facebook Ads Systems is designed so that your information will not be shared directly with third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type, e.g. cars or fashion. If you fall within one of the target groups, you will receive an advert or recommendation.
4.5. An advertiser or maker of recommendations may also choose to upload a list of emails, phone numbers and PERENIO Site and/or App identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.
4.6. Luxembourg-based AWS entity, Amazon Web Services EMEA SARL, ("AWS Europe") and other companies in the AMAZON, using their own ad services, can show advertisements to you.

 

5 Privacy Settings

5.1. The Site contains links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.
5.2. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Site Services, obtain access to your information in accordance with the confidentiality level internet (4.1) selected by you.
5.3. We are not responsible for the consequences of using information that, due to the nature of the Site in the Application, may be available to any Internet user, if you grant access rights to your personal account Profile and/or the Application. We ask you to responsibly approach the integrity of information about the username and password and remind you that it is forbidden to share such information in accordance with the rules described in the user agreement.

 

6 International Transfers

6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Ukraine, the Russian Federation and the Republic of Belarus. 
6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

 

7 Retention Periods

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7.2. You may delete your personal data by removing the data from your personal page; alternatively, you can remove your page using the Remove My Profile functionality available in the My Settings section. You have the right to restore your personal profile within 90 days after the personal page is removed.
7.3. We may remove your Profile, or the information you post in App if there are grounds provided for by applicable law or as provided by the Terms.

 

8 Your Rights

8.1. You have the following rights, in certain circumstances, in relation to your personal information:

1. Right to access your personal information.
2. Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
3. Right to restrict the use of your personal information.
4. Right to request that your personal information is erased.
5. Right to object to processing of your personal information.
6. Right to data portability (in certain specific circumstances).
7. Right not to be subject to an automated decision.
8. Right to lodge a complaint with a relevant supervisory authority.

8.2. You also have a right to independently remove your Profile, information on your Profile and make changes and corrections to your personal Profile on the Site and App, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you via the Site.
8.3. If you would like to exercise these rights, please send your request to us in our Support Service Support , or in writing to Perenio IoT spol s r.o. Na Dlouhem 79, Ricany – Jazlovice 251 01, Czeh Republic We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

 

9 Security Measures

9.1.  We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9.2. Access to the Site is authorized using your login (e-mail address) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
9.3. If you forget your login details, and we hold your mobile phone number, you can ask us to send you an E-mail which will contain a restoration code using special tool available here perenio.com.
9.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual server (in particular, from a server located in a foreign country), we will block entry to your personal page. You will then receive a message asking you to provide certain digits indicated in E-mail sent to your mobile phone number. After three unsuccessful attempts to enter these digits, we will block access from that server for 4 hours.
9.5. You can access information concerning the time and device from which your account was accessed using the Show activity history link in the My Settings.

 

10 Changes to this Policy

10.1.  From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such. At the moment, we collect only the data necessary for the correct operation of the Site and the Application in accordance with Articles 15-18 of the Regulation (GDPR). Your right to delete personal information in accordance with Article 5 of the Regulation (GDPR) has been realized. A system for transferring data to other Countries in the framework of Holdings was developed and set up based on Article 45 of the Regulation (GDPR). We also use a payment system with pre-bank payment processing in which we are guided by the Payment Policy and Cookie Policy. As part of our company, Personal Data Protection Policy has been developed and implemented in accordance with article 24 of the regulation. Inventory of Processing Activities in accordance with Article 30 of the Regulation and Security incident response policy, as well as a system has been developed and introduced to notify personal data subjects and the supervisory authority of cases of hacking and leakage in accordance with Article 33 of the regulation (GDPR).

 

11 Contact Us

11.1. If you have any questions, please send your inquiries to us, in writing to: Perenio IoT spol s r.o. Na Dlouhem 79, Ricany – Jazlovice 251 01, Czeh Republic, or to Support. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.
11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
11.3. The e-mail address of our DPO is dpo@perenio.com. Date of Last Revision: 28th of February.