1. Scope
1.1
This privacy policy (the “Privacy Policy”) comprise all Services from:
WelcomeBob Group A/S
CVR no. 38600125
Pilestræde 28A
1112 København K
(“WelcomeBob”, “we”, “our”, “us”, etc.)
to the Customers.
1.2
This Privacy Policy describes the types of Personal Data we collect, how we process such Personal Data, and who you can contact, if you have any questions or comments about this Privacy Policy.
1.3
The Privacy Policy describes our processing of Personal Data as Data Controller of Personal Data. Our processing of Personal Data on behalf of Customers, as Data Processor, is regulated by the Data Processing Agreement. See also clause 4 of this Privacy Policy.
2. Definitions
2.1
Terms and expressions with capital first letters used in this Privacy Policy shall have the meanings set out in this clause 2.
2.2
“Customer”, “you”, “yours” etc. shall mean a customer of Services provided by WelcomeBob.
2.3
“Data Controller” and “Data Processor” shall mean “controller” and “processor” respectively as defined in the GDPR.
3.
“Data Processing Agreement” shall mean the Data Processing Agreement entered into between the Customer and WelcomeBob in connection to the Customer’s use of or subscription to the Services.
3.1
“GDPR” shall mean the General Data Protection Regulation (EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. In Denmark, GDPR is supplemented by the Act on supplementary provisions to the regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (Act No. 502 of 23 May 2018 as amended from time to time) (the “Data Protection Act”).
3.2
“Personal Data” shall mean 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. The Categories of Personal Data processed by WelcomeBob is specified in clause 5.
3.3
“Services” shall mean all services rendered by the WelcomeBob to the Customers related to WelcomeBob’s intercom system, including the actual purchased intercom product, corresponding systems and software, WelcomeBob’s App or other software programs developed by WelcomeBob, support and helpdesk services etc.
4. Data Processing on behalf of Customers
4.1
With respect to all Personal Data entered, transferred or stored on behalf of the Customers in the databases of WelcomeBob or third-party suppliers related to WelcomeBob’s provision of Services, the Customer is the Data Controller, and WelcomeBob is the Data Processor.
4.2
WelcomeBob’s processing of Personal Data on behalf of the Customer in relation to the Services, is regulated by the Data Processing Agreement, which the Parties enter into upon the Customer’s subscription to the Services.
5. Categories of Personal Data
5.1
Personal Data includes information that can be used to identify you as an individual. If you sign up to a use we will ask you to provide us with certain personal identifiable information that can be used to identify you, including:
- Contact information, such as name, phone number, and email and postal address;
- Account information, such as online password and other log-in details used to access WelcomeBob’s Services;
- If you subscribe to our Services, we will ask you for address and company registration no. (CVR no.);
- Product setup information, such as the name and description of your WelcomeBob product (for example, “Company Name – Front Door”) and the location where you install your WelcomeBob product, and adjustments you make to the product setup;
- Product usage information, such as unlocking of door and sharing of keys, to identify users in case of misuse;
- Social media handles, content and other data posted on our official social media pages;
- Information we obtain from third-party social media services (e.g., Facebook, Google) or payment services if you choose to link to, create or log into your WelcomeBob account through these services.
- Information we obtain from third-party business partners if you choose to use our WelcomeBob Service, such as your account ID, account name and email address;
- Information you submit in connection with a career opportunity at WelcomeBob, such as contact details, information in your resume and details about your current employment;
and
- Other personal information contained in content you submit to us, such as through our “Contact Us” feature or customer support tools on our websites or mobile apps
5.2
When you use our website, www.WelcomeBob.com, we collect information about your use of our website through so-called “cookies”. See clause 11 of this Privacy Policy for further information.
6. Our Purposes for Processing of Personal Data
6.1
Our Services are designed to allow you to see, hear and speak to anyone through your WelcomeBob device or mobile device, and collaborate with others in your community. To provide you with the Services, we process and store log files (and related information) that is captured when using our Services, such as live video or audio streams, images, comments, and data our products collect from their surrounding environment to perform their functions. We do not record video or audio streams. Log files are encrypted and stored securely in a separate database. See also clause 10 on “Security Measures”.
6.2
Privacy, data protection and video surveillance laws in your jurisdiction may apply to your use of our products and services and the processing of personal information in connection with such use. You are responsible for ensuring that you comply with applicable law when you use our products or services and process individuals’ personal information in this context. For example, you may need to display a notice that alerts visitors to your home that you are using our products or services. Capturing, recording or sharing video or audio content that involves other people, or capturing other peoples’ facial feature information, may affect their privacy and data protection rights.
6.3
We process the Personal Data we collect to:
- Establish and manage your WelcomeBob account and profile;
- Process and fulfil claims and orders in connection with our products and services and keep you informed about the status of your order;
- Personalize your experience with our products and services;
- Allow you to stream content through our services;
- Identify and authenticate you so you may access certain content or use certain of our services;
- App use to create log for access and user sharing;
- Communicate with you and provide customer support;
- Allow you to interact with certain third-party products or services (for example, to enable you to link to, or view content from, third-party sites within our services, or connect to third-party products and services through the WelcomeBob service);
- Provide functionality, analyse performance, troubleshoot, fix errors, and improve the usability and effectiveness of our products and services;
- Evaluate, develop and improve our business (including analysing and improving our products and services; conducting research and developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
- Comply with and enforce legal requirements to which we are subject;
- Comply with relevant industry standards and policies, including this Privacy Notice and our Terms of Service;
- Increase and maintain the safety and security of our products and services and prevent misuse;
- Perform analytics (including market and consumer research, trend analysis, and financial analysis);
- Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
- Send or display promotional materials, newsletters and other communications about our products and services;
and
- In order to take precontractual steps at your request, information submitted in connection with a career opportunity is processed to manage career opportunities at WelcomeBob, including for recruitment purposes, employee onboarding and other HR-purposes.
7. Transfer of Personal Data
7.1
WelcomeBob is located in Denmark and Personal Data is mainly processed in Denmark or other member states within the EU/EEA. We store Personal Data on servers in the Europe-West data region (currently located in Belgium).
7.2
However, we may, from time to time, employ third-party suppliers located outside the EU/EEA or in the US to facilitate, service or analyze the use of our website or Services or for data hosting and storage. These third-party suppliers and will only have access to your Personal Data if necessary to perform the agreed tasks. We will ensure that third parties with access to Personal Data are obligated not to disclose or use the Personal Data for any other purposes than to perform the agreed tasks.
7.3
Before transferring Personal Data to a third country or an international organization outside the EU/EEA, we will assess whether such transfer of Personal Data ensures an adequate level of protection of the Personal Data. We will ensure that the transfer is in accordance with rules on transfers of personal data to third countries or international organizations in the GDPR and the Danish Data Protection Act, including, where necessary, entering into data processing agreements with our Data Processors (see clause 8) on the basis of the European Commission’s standard contractual clauses for data transfers between EU and non-EU countries or according to the EU-US Privacy Shield Framework.
7.4 Third-party services
7.4.1
Through our WelcomeBob service, you may choose to connect to certain third-party services offered by our business partners. To activate a connection and allow the WelcomeBob products and services to interface with an available third-party service, each WelcomeBob connection requires the exchange of certain information between WelcomeBob and our business partner that is providing the third-party service. For example, to enable you to integrate WelcomeBob’s products and services with those of our business partners, we may share certain account information with those business partners, such as your account ID and email address. In addition, we may share certain data our products collect from their surrounding environment that is necessary to perform their functions. In each case, we will engage with a given third-party service only if you choose to activate such a connection. You may revoke a connection to a third-party service at any time by contacting WelcomeBob at [email protected] or, depending on the particular third-party service, accessing your settings under your account with that service. The privacy statements of our business partners apply to any information practices of those partners and to the information shared with them.
8. Our Use of Data Processors
8.1
If the third-party suppliers act as Data Processors and process Personal Data on our behalf, we will make sure to enter into data processing agreements with the Data Processors before the Data Processors carry out any processing of Personal Data on our behalf.
9. Storage of your Personal Data and Deletion
9.1
In accordance with the general principles of storage limitation set out in the GDPR, we will only keep your Personal Data for as long as necessary. The storage (or retention) period depends on the nature of the information and the background for storage. It is therefore not possible to specify a specific time frame for deletion of Personal Data in each case in this Privacy Policy. However, we have described our general retention rules in clause 9.2 below.
9.2
Generally, we store “key holder” log files and related Personal Data for as long as the key holder in question has an active user account at WelcomeBob and up to 6 months after effective termination thereof. Daily log files and related Personal Data are kept for 3 months from effective termination of the Customer’s use of our Services. However, Personal Data related to payments must be kept for five (5) years + the current calendar year after the end of the accounting year according to Danish rules on bookkeeping. Personal Data may be stored for a longer period if the Personal Data is needed in order to establish, exercise or defend a legal claim.
10. Security Measures
10.1
We have taken technical and organizational measures to prevent your information from being accidentally or illegally deleted, disclosed, lost, impaired, misused or otherwise violated by law.
10.2
All data transferred between intercom and users are encrypted. User profile information is store in a separate database from other information. User passwords are encrypted and cannot be accessed by WelcomeBob. To access your account, you need your personal username and password and must go through our authentication process.
10.3
We host all data on up-to-date servers that are protected against unauthorized access by a firewall. We take a back-up of Personal Data on our servers every 24 h.
10.4
We have internal rules on information security. We have adopted internal rules on information security that contain instructions and measures which protect Personal Data from being destroyed, lost or modified, from unauthorized disclosure, and against unauthorized access or knowledge of them. We will ensure that collected Personal Data are treated with care and protected according to applicable safety standards. We have strict security procedures for collecting, storing and transferring Personal Data to prevent unauthorized access and compliance with applicable laws.
10.5
The security of your data is very important to us, but remember that no online transmissions, or method of electronic storage is 100 % secure. While we strive to use commercially validated means to protect your Personal Data, we cannot guarantee its absolute security.
10.6
We assess the risk of our processing of personal data on an ongoing basis.
11. Cookies
11.1
We use cookies and similar tracking technologies to track the activity on our website and App. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from our website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information.
11.2
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.
11.3
By using our website, you provide your consent to the use of cookies as described in this Privacy Policy. If you no longer wish to consent to the use of cookies, you can deselect and delete the cookies by modifying the settings in your browser (see clause 11.8).
11.4 Types of cookies
11.4.1 Session cookies and Persistent cookies.
There are two types of cookies – session cookies and persistent cookies. Session cookies are bits of information that are erased when you close your web browser. Persistent cookies are bits of information that are stored on your computer until they are erased. Persistent cookies erase themselves after a certain period of time but are renewed each time you visit www.WelcomeBob.com. Our website uses both session cookies and persistent cookies.
11.4.2 “Own” cookies and third-party cookies.
Cookies can be placed on www.WelcomeBob.com by WelcomeBob itself or by third parties such as Google or Facebook (see below for information about the use of Google Analytics).
11.5 Purposes
11.5.1 Session cookies
We use session cookies to operate this website and our App.
11.5.2 Persistent cookies
We use preference cookies to remember your preferences and various settings and security cookies for security purposes.
11.6 Google Analytics
11.6.1
We use Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
11.7 Social Media
We use social media buttons (“plug-ins”) to allow you to connect with your social network. For these to work the social media sites may set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
11.8 Deletion of cookies
11.8.1
Most browsers allow you to erase cookies from your hard drive, block all cookies or receive a warning before a cookie is stored. You must be aware that in such case services and features cannot be used by you because they require cookies to remember choices you make.
11.8.2
You can opt-out of having made your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.
11.9 Links to other websites
11.10
Our website may contain links to other sites that are not operated by WelcomeBob. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.
11.11
We have no control over and assume no responsibility for the contents, privacy policies or practices of any third-party sites or services.
12. Childrens’ Privacy
12.1
Our Service does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
13. Your Rights
13.1
You have certain rights related to our processing of your Personal Data according to the GDPR.
13.2
In short, your rights include:
13.3 Right of access
You are entitled to be informed whether any Personal Data about the subject is being processed and if so, obtain access to the Personal Data.
13.4 Right of data portability
You are entitled to receive Personal Data that you have provided to WelcomeBob (this data must be provided in a structured, commonly used and machine-readable format).
13.5 Right to rectification
You are entitled to obtain rectification of incorrect Personal Data.
13.6 Right of deletion
You are (with certain limitations), entitled to request erasure of Personal Data by us without undue delay.
13.7 Right to object
You are entitled to object to the processing of your personal data, namely if the processing of your personal data includes profiling or if the processing is based on the assessment of our interest in processing your personal data).
13.8 Right to restriction of processing
You are entitled to obtain a restriction of the processing of your personal data, namely if you contest the accuracy of the personal data, or where a request to be deleted cannot be accommodated, e.g. due to WelcomeBob’s need to keep the personal data for the establishment, exercise or defense of legal claims.
13.9
Please note that the above-mentioned rights will only be individually fulfilled by WelcomeBob in relation to the cases where WelcomeBob is considered as the Data Controller. In situations where WelcomeBob is regarded as the data processor, the above-mentioned rights must be fulfilled by the data controller.
13.10
Inquiries related to your rights according to GDPR can be made to: [email protected].
14. Changes to this Privacy Policy
14.1
We may update this Privacy Policy. If you have signed up for a use or subscribed to our Services, we will notify you of any significant changes.
14.2
You are advised to review this Privacy Policy periodically for any changes. The Privacy Policy available on our website (as updated from time to time) applies to our Services and use of our website.
15. Contact Information
15.1
If you have any questions about this privacy policy, please send us an email at [email protected]. We will get back to you asap. If you contact us by email you should not include unnecessary Personal Data, and especially not information containing any confidential or special categories of Personal Data, as the email may not be encrypted. We can only ensure encryption on emails that we send from WelcomeBob.
16. Supervision
16.1
The Danish Data Protection Agency, inter alia, supervises the compliance with the applicable national regulation on Personal Data. The contact information for the Danish Data Protection Agency is:
Datatilsynet
Borgergade 28, 5
DK- 1300 Copenhagen K
T: 3319 3200
Email: [email protected]
Policy Version: 13 September 2019