Privacy Statement.
Effective Date: 13-May-2022
Last Updated: 13-May-2022
Infoo takes your privacy and right to control your personal data very seriously and strives handle your privacy in accordance with applicable laws. We are guided in this regard by the following principles:
● We use data to serve our users;
● We aim to provide meaningful choices that are easy to understand;
● We collect only what we need to serve our users effectively; and
● We protect the data of our users in the way we would expect our own data to be protected.
The primary purpose of collecting your data is to enhance your experience when engaging with Infoo’s Products and Services. For example, we need to know certain things about you and the products that you use so that we can provide a meaningful service to you that correlates with the products that you own and have added to Infoo using the My Stuff section of the Infoo App. To that end, we only collect your data for clearly defined purposes. We do not and will not sell your personal data to third parties.
This Privacy Statement (the 'Statement') explains the personal information we collect from you, either directly or indirectly, and how we will use it. Personal information is any information that can be used to identify you or that we can link to you. The Statement also elaborates on the available choices that you can make about the data we collect and how you can control it. It applies to all products we offer (‘Infoo Product(s)'), including our iOS and Android apps ('Infoo app' or 'app') or services, for example the Infoo website (collectively referred to as 'Services').
Please read this Statement carefully to understand how Infoo may collect, use, and share your personal information.
The terms 'we', 'us', or 'Infoo' are each intended as reference to Infoo Limited.
This Statement describes:
● The Types of personal information we collect
● Customer interactions with Infoo
● How we use personal information
● How we may share personal information
● The legal bases for using personal information
● Security, storage, and retention of personal information we collect
● Your rights and choices
● Our use of cookies and other similar technologies
● How to contact us
● Changes to Our Privacy Statement
THE TYPES OF PERSONAL INFORMATION WE COLLECT
Information you provide to us
We collect information which you voluntarily provide to us. This includes the following:
Personal identifiers, contacts and characteristics (for example, name and contact details);
Email addresses, your profile picture/image/avatar (if applicable);
Information about your appliances which you enter on our website or via our app(s) including manufacturer details, appliance model and serial numbers; where you choose to record these items as located (for example by choosing rooms in your home to which you allocate them), any nicknames you give to appliances and their dates of purchase;
Electronic photographic images of appliance product labels and the data extracted from those images (including text and meta data) or any other image data you choose to share with us via our website(s), app(s) or services;
The nature of appliance troubleshooting problems that you are experiencing or any other information or queries exchanged with us using our support services.
Information we collect automatically
We automatically collect information about you, related to your use of Infoo Products and Services or information collected by using cookies and similar technologies when you use, access, or interact with us via our websites or app.
We may, for example, collect information about the type of device you use to access our app or websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.
Information obtained from other sources
We may receive information about you from other sources, including third parties, such as repairers, suppliers of parts or accessories, insurance or warranty providers or manufacturers of products with whom we offer co-branded services or engage in joint-marketing activities.
We may also receive information about you from technology or social media platforms, for instance, when you interact with us on social media or when you use a trusted provider to log into our systems (such as Google, Apple or Facebook). We protect data obtained from third parties according to the practices described in this Statement and we also apply any additional restrictions imposed by the source of data, for example according to Google’s requirements for the use of their APIs.
Some specific examples are as follows:
Google OAuth APIs
Used to sign into Infoo’s apps and to provide basic profile information about you as detailed below, using your Google User Account with your consent.
We collect: Your email address, your name, your language preferences and your profile picture.
Why: We use your name to address and identify you. We use your email address to contact you regarding the administration of your Infoo account, for alerts and to contact you regarding our products and services. We use your profile picture to display it as part of your Infoo user profile and your language preferences to communicate with you effectively. It is our legitimate interest to process your data for these purposes.
Information of children
Infoo does not target and is not intended to attract children to use its Products or Services. Although visitors of all ages may navigate through our website or use our app, we do not knowingly collect or request personal information from those under the age of eighteen without parental consent. If, following a notification from a parent or guardian or discovery by other means, a child under eighteen has been improperly registered on our site by using false information, we will cancel the child's account and delete the child's personal information from our records.
CUSTOMER INTERACTIONS WITH INFOO
To make the information in this Statement easy to understand, we have highlighted different occasions when Infoo could potentially collect personal information from its customers.
The customer interactions with Infoo are broken down into the following categories:
Learning about Infoo
As you gather more information about Infoo, you may virtually visit a site that we own. Examples include one browsing our website, registering for our mailing list, app or contacting our in-house support representatives. To learn more about Infoo Products, you may voluntarily provide personal information, such as your name and email address, during these interactions. We may also collect information about you online via cookies or similar technologies when you visit our websites.
We collect: Name, email address, telephone numbers, IP address and information provided by cookies or similar technology.
Why: We use this information to share news about event, products and services offered by Infoo. Additionally, the IP address helps us to understand geographic information about our website’s visitors better, so that we can improve our website for everyone. It is our legitimate interest to process your personal data for these purposes.
Using the Infoo App or Website to Manage your appliances
When you register or add items/appliances to the Infoo App, we give you the opportunity to associate those items with rooms in your home or premises. We also provide you with the opportunity to upload to Infoo, information assets relating to those items/appliances such as product receipts, photographs or to provide data in relation to the items/appliances, such as purchase dates, retailer information and warranty data. Some of this information allows us to provide an enhanced interaction with our technologies (such as product safety recall related information services, warranty or service reminders where it is necessary for us to know certain information about your appliances and/or purchase dates, for example).
Other information upload capability is provided to give you a place to conveniently store your information or documents related to your purchases or items/appliances, such as receipts of purchase or your own appliance photographs.
We collect: Your name, telephone number, email address, location data, your password, and IP address, product data including manufacturer and model number details, receipts of purchase, warranty data, photographs, retailer information and location of purchase data.
Your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including Infoo. Other data is encrypted and stored on our behalf by data centre partners in accordance with local legislation.
Why: We collect this information to help get the most from your Infoo Product and/or Service and help prevent unauthorised access to your Infoo account, Services, or home network) and to make sure that we enable you to select the right product and service options based on your geographic location (e.g. repairers available in your region). This processing is necessary for the performance of the contract we have with you.
We also use your email to send you Infoo-related notifications, such as promotional messages, updates, information about Infoo Products and/or Services and to share Infoo news and Product offerings. It is our legitimate interest to process your personal data for these purposes.
Buying Infoo Products and Services
Once you have decided to buy an Infoo Product and/or Service, you may use our systems to buy parts, accessories or to procure repairs or servicing from within our app or via our website.
When you buy from us, you may be asked to provide information so that we can complete your purchase.
We collect: Your name, phone number, email address, delivery/shipping address, and payment information.
Why: We use this information to complete your transaction, follow up with you about your purchase(s), help with any delivery issues or appointment, handle returns, and other issues related to the purchase of your Infoo Products and/or Services. Processing your personal data for this purpose is necessary for the performance of the agreement we have with you. We only use payment information in connection with the purchase of Infoo or associated third party Products and Services.
Getting Help from Infoo
From time to time, you may decide to contact our Customer Support team for assistance with Infoo Products and/or Services. To be able to offer you the best service possible, we may collect certain data from you or your Infoo Products.
We collect: Contact information, such as your name, email address, phone number, social media identifiers (if you contact us using a social media channel), and the content of your chats and other communications with the Infoo Support Team (including, in some cases, voice recordings if you call us).
Why: We collect this information to give you the best and most efficient customer support possible. For instance, for customer support enquiries and technical questions, we use the contact information to respond to the customer in their preferred channel (phone, email, social). Using these types of data is necessary to fulfil the agreement we have with you.
HOW WE USE PERSONAL INFORMATION
Infoo uses your personal information which we collect to provide you with the Infoo Products and Services we offer, which includes using data to improve and personalise your experiences. We also use your personal information to communicate with you, for example, informing you about your account, new Infoo Products or Services available, security, and other types of updates.
Additionally, as described below, we may use other data related to your interactions with Infoo Products and Services in order to provide certain Infoo Services and for advertising purposes.
Infoo uses the data for the following purposes:
Purchase and Delivery of Infoo Products and Services
We use your personal information to take and handle orders, deliver Products and Services, process payments and communicate with you about orders, Products and Services, and promotional offers. This processing is necessary for the performance of the agreement we have with you.
Product Experience, Recommendations, and Personalisation
We use data to provide, operate, support, and improve the Infoo Products and Services we offer to ensure our customers can experience Infoo Products and Services as effectively as possible. We use your personal information to recommend features, Products, and Services that might be of interest to you, identify your preferences and personalise your experience with Products and Services. This processing is necessary for the performance of the agreement we have with you, as well as to serve our legitimate interest.
Customer Support
We use data to respond to customer enquiries, diagnose app and other technical problems, handle or assist with repairs and provide other customer care and support services. This processing is necessary for the performance of the agreement we have with you, as well as to serve our legitimate interest.
Product Improvement
We continually use data for research purposes and to develop and improve Infoo Products and Services, including maintaining and improving the performance of Infoo Products and Services, developing and adding new features or capabilities, such as using error reports to improve security features, using search queries and clicks to improve the relevance of search results, and using usage data to determine what new features to prioritise. We use your personal information to provide functionality, analyse performance, fix errors, and improve usability and effectiveness of Infoo Products and Services. This processing is necessary to serve our legitimate interest.
HOW WE MAY SHARE PERSONAL INFORMATION
Infoo does not and will not sell personal information about our customers. We want you to understand that information about our customers is an important part of our business. We only disclose your data as described in this Statement.
We may share information with the following types of third parties.
Third-Party Vendors of Products or Services associated with the Infoo Offering
Infoo uses a variety of third-party vendors to carry out services like repairs management, provision of parts and accessories and product data, as well as services necessary for the technical provision of Infoo Products and Services such as hosting, cloud-related technology services, online Product purchases and delivery (including fulfilling orders for Products or Services, delivering packages, sending postal mail and email), credit cards and other alternative payment processing, email communications, analysing data, providing marketing assistance, transmitting content, if applicable scoring credit risk, and providing customer service.
We only share your personal information as necessary, such as to complete a transaction or to provide a Product or Service you have requested or authorised and only with vendors or agents working on our behalf for the purposes described in this Statement. In this case, your personal information will be shared with these agents or contractors but only for the purpose of performing services on behalf and under the instructions of Infoo and in accordance with this Statement. It is our legitimate interest to share information with these parties for these purposes. For questions about third-party vendors, please send an email to privacy@infoo.com.
Transactions involving Third Parties
Infoo may make available to you products, services and features provided by third parties for use on or through Infoo Products. We may also offer services and/or sell product lines jointly with third-party business, such as co-branded repair, insurance, warranty or servicing products.
Depending on your use of the third-party products, features, and/or services, we may share certain personal information we have about you with these third parties to enable functionality and/or provide customer support. Please note that functionally of these third-party products, features, skills, and/or services is subject to these third-party terms of use or service and their respective privacy notices.
We encourage you to read these third-party terms carefully before you use them via your Infoo Products.
THE LEGAL BASES FOR USING PERSONAL INFORMATION
There are different legal bases that we rely on to use your personal information, namely:
Performance of a Contract
The use of your personal information may be necessary to perform an agreement you have with us. For example, to complete your purchase of your Infoo Product, to register and maintain your account, to help with delivery issues, to handle returns or to register for the Infoo app.
Consent
Where legally required, we may rely on your consent to use your personal information. When this is the case, we will provide you with more specific information when we actually request your consent. You may withdraw your consent at any time by sending us an email to privacy@infoo.com.
Your withdrawal will not affect the lawfulness of processing based on your consent before your withdrawal.
Compliance with Legal Obligation
We may use your relevant personal information to ensure compliance with applicable laws; for example, to comply with lawful requests from law enforcement authorities and for regulatory investigations and compliance.
Legitimate Interests
We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyse and improve our Infoo Products and Services, and the content on our websites and app, to send you notifications about updates or information about Infoo Products and Services, and to use your relevant personal data for administrative purposes and for fraud detection and prevention.
Furthermore, except where consent is required under applicable local law, we rely on our legitimate interest to send you relevant marketing communications. When using personal data to serve our legitimate interests, we will always balance your rights and interests in the protection of your personal data against our rights and interests.
Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you (e.g. within the Infoo app settings), you may exercise your right to object by sending an email to privacy@infoo.com.
SECURITY, STORAGE, AND RETENTION OF PERSONAL INFORMATION WE COLLECT
Security
Infoo is committed to protecting the security of your personal information. However, whilst we take reasonable precautions to guard the personal information we collect, no security system is impenetrable. We use a range of appropriate technical and organisational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse, and unauthorised access, disclosure, alteration, and destruction. For example, we store the personal data you provide on computer systems that have limited access and that are in controlled facilities. We also ensure that our third-party data centre vendors provide adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transition over the Internet. Please note, your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including Infoo. It can only be reset.
You can only access your Infoo account information and our service through the use of an individual user login and password or via authentication services using OAUTH with trusted identity providers. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please notify us immediately if you believe your password has been misused. You should always log out and close your browser when you finish your session. Please note, we will never ask you to disclose your password. If you have any questions about the security of your personal information, you can contact us at privacy@infoo.com.
Storage
Personal data collected by Infoo may be stored and processed in your region, in the United Kingdom (for example, in our major partner data centres), or in any other country where Infoo or its affiliates, subsidiaries, or service providers are located or maintain facilities.
Should it be necessary to transfer data internationally Infoo will have put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission. Your use of our Products and Services is also deemed to give us your explicit consent to store, process and transfer your data in this way.
Retention
Infoo will retain your personal information:
for as long as we have a customer relationship with you and/or as necessary to enable you to use the website, your Infoo account, and/or your Infoo Product(s);
for the period required to provide services that you request from us;
for the period required to provide marketing or other promotional materials that you request from us;
to comply with our legal obligations, including requirements of regulators and governmental agencies that have authority over us, such as tax and/or accounting obligations, which usually require retaining certain transaction data for periods between seven and 10 years after a transaction has occurred;
for the period required to resolve disputes with any parties and/or to investigate or defend against potential legal claims; and
otherwise as necessary to allow us to conduct our business in compliance with applicable laws and regulations.
All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. Infoo will delete your personal data when it is no longer required for the above-mentioned purposes. If there is any personal data that, for technical reasons, we are unable to delete entirely from our systems, Infoo will implement appropriate measures to prevent any further processing or use of such data. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to privacy@infoo.com.
YOUR RIGHTS AND CHOICES
Your Rights
We want you to be in control of how your personal information is used by us. Subject to local law, including the UK General Data Protection Regulation (UK GDPR) you can do this in the following ways:
you can ask us for a copy of the personal information we hold about you;
you can inform us of any changes to your personal information, or if you want us to correct any of the personal information, we hold about you;
in certain situations, you can ask us to erase, block, or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
in certain situations, you can also ask us to send the personal information you have given us to a third party.
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information. We rely on you to ensure that your personal information is complete, accurate, and up to date. Please inform us promptly of any changes to or inaccuracies of your personal information by contacting privacy@infoo.com. We will respond to your request as soon as possible but certainly within 30 days.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to file a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.
Your Choices
Infoo Account and Infoo App
If you wish to access, edit, or remove profile information, change your password, close your account, or request deletion of your personal data, you can do it by logging in to your Infoo account or Infoo app or by sending an email to privacy@infoo.com.
If you cannot access certain personal information collected by Infoo via the Infoo account, the Infoo app, or directly via the Infoo Product that you use, you can always contact us by sending an email to privacy@infoo.com. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days.
Your Communication, Marketing and Advertising Preferences
You can opt out of receiving direct marketing communications from Infoo by following the instructions included in every email sent to you, via the “Unsubscribe” tab. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.
Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, Infoo Product software updates, routine customer service messages such as information about important product recalls, current or past purchases, delivery of products, service interruptions, data breaches, or other significant information about a Product you own.
Advertising and Modern Marketing Tools
To help more people get effective use and benefit from Infoo, we may use several modern marketing tools in support of our advertising efforts. Infoo may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about Infoo Products and Services on our websites and across the Internet. To provide this “interest-based advertising,” the parties combine non-personal data about your online activities, acquired over time, which data help cater advertising that we deliver to you. Examples of this may include a Infoo advertisement on a Facebook page, or a Google-owned page such as a search results page or YouTube, or on a site within Google’s advertising network. We do not share your personal information as part of this process.
Where necessary, we obtain your consent for this process. At all times, you can opt out of these personalised ads from third-party advertisers and ad networks that are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioural Advertising by visiting the optout pages on the NAI websites and DAA websites. Opting out may make the ads you see across the internet less relevant to you. Users that enjoy rights under EU data protection laws can visit www.youronlinechoices.com to learn how to opt out of having their data used for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) member companies. If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.
OUR USE OF COOKIES AND OTHER SIMILAR TECHNOLOGIES
We use cookies and similar technologies like pixels, tags, web beacons, and other identifiers to help us personalise our website for you, remember your preferences, understand how users are using our website or app, and help customise our marketing offerings. In addition to this Privacy Statement, you are also referred to our Cookie Policy and features implemented on our website to help you manage your cookie preferences.
Cookies
A cookie is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognise your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. Infoo uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.
We may use the following types of cookies on our website:
Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, services like shopping baskets cannot be provided.
Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimise our website and make it easier for you to navigate.
Functional cookies. These cookies allow our websites to remember choices you make whilst browsing and personalise your experience. We may store your geographic location in a cookie for instance, to ensure that we show you the website relevant to your area.
Third Party cookies/advertising cookies. Third party cookies/advertising cookies are those placed by websites and/or parties other than Infoo. These cookies may be used on our website to improve our products or services or to help us provide more relevant advertising. These cookies are subject to their respective privacy policies for these external services, for example, the Facebook Data Use Policy.
Analytics cookies. We may use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our website, what pages they find most useful, and how they arrived at Infoo.com. To learn more about Google Analytics and your data, visit this Google webpage.
How to Control Cookie Settings
Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impact your overall user experience. Some browsers offer a “Do Not Track” (“DNT”) signal whereby you can indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognises DNT signals, we will only process your personal data in accordance with this Statement.
In addition to cookies, we may sometimes use small graphic images known as 'pixels' (also known as web beacons, clear GIFs, or pixel tags). We use pixels in our email communications to you (if you have selected to receive such communications) to help us to understand whether our email communication has been viewed. We may also use third-party pixels (such as those from Google, Facebook, and other advertising networks) to help us provide advertising that is relevant to your interests. Learn more about our advertising and marketing activities below.
Other Identifiers
When you use our app, we may collect a unique ad-tracking identifier from your device (the Advertising Identifier or “IDFA” on iOS devices and the Google Ad ID or “AID” on Android devices) so that we can learn more about users of our app and provide the most relevant messaging and marketing. Although these identifiers are unique to your device, they do not contain any of your personal information such as your name or email address.
How to control Identifier Settings
You can control how these identifiers are used, including the ability to reset them, through your device settings.
HOW TO CONTACT US
If you have any questions about the use of your personal information, please send an email to privacy@infoo.com. Unless otherwise stated, Infoo Limited is a data controller for personal data we collect through the Infoo Products and Services subject to this Privacy Statement.
Our postal address is Infoo Limited, 264 Banbury Road, Oxford, Oxfordshire, England, OX2 7DY.
Paul Livett is our data protection representative for the European Economic Area.
You can contact us via email at privacy@infoo.com.
CHANGES TO OUR PRIVACY STATEMENT
Infoo may modify or update this Statement when necessary, to reflect customer feedback and changes in our Infoo Products and Service. Please review it regularly.
When we update this Statement, we will revise the 'Last Update' date at the top of the Statement. If there are material changes to this Statement or in how Infoo uses your personal data, we will notify you either by posting a notice of such changes before they take effect or by directly sending you a notification.
We encourage you to regularly review this Statement to learn more about how Infoo is using and protecting your information.