Terms and Conditions of Use
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Privacy Policy of ubisys technologies GmbH
As of: January 2018

Your privacy is extremely important to us – so important, that protecting it has always been a primary design goal for all of our products and services. Therefore, all our products and services have been designed, right from the start, to ensure your privacy is protected using state-of-the-art technology in compliance with legal requirements.

This already begins with the fact that we collect data only insofar as absolutely necessary for the provision of a service. We are just as restrictive about the transmission of the data collected. As a result, different product and service categories have to be distinguished.

ubisys technologies GmbH (hereinafter “ubisys”) collects, processes and uses personal data in the spirit of § 3 (1) of the Federal Data Protection Act (BDSG) exclusively within the framework of the BDSG and under §§ 11 to 15a of the German Teleservices Act (TMG) of these regulations. At no time will your information be disclosed to third parties, unless it is absolutely necessary for the provision of the service you ordered.

For particularly sensitive data such as data conveyed in payment transactions, we ensure high security through the use of state-of-the-art encryption procedures, using technology and infrastructure from selected partner companies. However, you should be aware of the general dangers of using the Internet that we have no control over. For example, standard e-mail is generally not secure and may be read by third parties.

I. ubisys Smart Home Platform

1. Smart Home Apps for iOS and Android
The smart home apps for iOS and Android do not collect personally identifiable information. All data is only stored locally on the smartphone or on the gateway G1 and is never transferred to central cloud services. In order to access your Smart Home system while you are on the road, data is encrypted and exchanged directly with the Gateway G1.

1.1. Device Permissions
When installing or operating the app, you may be asked to allow the smart home app to access your smartphone’s camera. The camera is only used to detect machine-readable symbols (barcodes) found on the products, to save you the hassle of typing long strings on the keyboard. The images created during this process are processed exclusively locally and discarded after the barcode has been recognized.

1.2. Quality Assurance
To continuously improve our apps, bug reports will be sent to customer service in the event of a crash. These include information about the app version, Android/iOS version, the device type, as well as an encrypted image of the crashed app. The data does not contain any information that allows an analysis of the usage behavior or conclusions about persons.
For the iOS version, we use the crash reporting feature built into the App Store as provided by Apple Inc. based in Cupertino, USA. For pre-release versions, which we might provide to you for testing and evaluation purposes, we use the TestFlight offering of the same vendor.
For the Android version, we use Firebase Crashlytics as provided by Google Inc., based in Mountain View, USA.
Details regarding the exact operation of these services and related privacy policies are available on the web sites of the respective suppliers mentioned above.

2. Smart Home Gateway G1
The Smart Home Gateway G1 does not collect personal information. All data will only be stored locally on the Gateway G1 and on the smartphones you have authorized and, if possible, never transferred to central cloud services. In particular, neither the usage nor any other activity is recorded in any form. In order to access your smart home system while you are on the road, data is encrypted and exchanged directly with your authorized smartphones – without having to go through cloud services. However, some services, such as sending push notifications, require the exchange of data with cloud services.

2.1. Data on the Gateway G1
The gateway keeps an inventory of all the devices it manages. Here, serial numbers and properties of the devices, rooms and assignment of devices to rooms as well as scenes, groups and associated device settings as well as unique identifiers of controlling devices (smartphones and tablets) are stored. Likewise, time zone and facility location are stored permanently. The current operating states of all devices are available in real time.

2.2. Facility Location
The facility location (geo-position) can be stored via the web interface of the gateway. This information is purely optional and may be given any fuzziness by the user – for example city, district or street and number. The information is used to retrieve and provide location-based services, such as sunrise and sunset times and weather data.

2.3. Remote Maintenance
You might use the web interface of the Gateway G1 to activate a remote maintenance function that allows our customer service to access your Smart Home system for maintenance purposes. This only happens on explicit user action and an explicit request to our support team to assist with a particular question. All data transmission over the Internet is encrypted. Customer service will receive unlimited access to your Smart Home system for the duration you specify. Access by customer service without your active consent by activating the remote maintenance is not technically possible.

2.4. Quality Assurance
You can make a contribution to quality assurance via expressing your consent on the web interface of the Gateway G1 to automatically send us crash reports. The data transfer takes place via the Internet. The customer service receives an encrypted memory image of the crashed service or program, which might contain all the data accessible to the respective process.

3. Remote Access via ubisys P2P
When you use the peer-to-peer service ubisys P2P, data is exchanged between smartphones, the ubisys P2P cloud service and the Gateway G1, supporting the smartphone and the gateway in setting up a direct connection without special configuration of your Internet router.
Serial numbers and device setup codes are transmitted encrypted over the Internet. In most cases, the connection is established directly between the gateway and the smartphone and the ubisys P2P cloud service is no longer involved in the data transfer once the connection is up. In exceptional cases, it may be necessary for the ubisys P2P service to function as a relay station, and also to transmit data packets between smartphones and gateways during operation. Even in this constellation, data transferred between the smartphone and the gateway will not be inspected or evaluated at any time, in any way. Remote access via ubisys P2P is optional. It simplifies setting up remote access compared to other methods like DynDNS, port-forwarding, VPN or similar technologies. These remain usable as alternatives without any restriction, though.

4. Messages sent via ubisys C2D (Push Notifications)
The Gateway G1 and ubisys corporate may send push notifications to your smartphone. To do this, we run the messaging service ubisys C2D, a cloud messaging service that communicates with other third-party cloud services, including Apple Push Notification Service (APNS) and Firebase Cloud Messaging (FCM), in order to deliver such messages. For this purpose, the smartphone app notifies the Gateway G1 of a unique device identifier, which is necessary for addressing the device via APNS or FCM. This device ID is stored on the Gateway G1 and in the central ubisys cloud messaging service and forwarded to the relevant service (APNS or FCM) when sending messages, together with the message text. All data transmitted between Smart Home App and C2D, as well as between the Gateway G1 and C2D, as well as between C2D and APNS, as well as between C2D and FCM via the Internet is encrypted.

5. Apple HomeKit
You have the option to connect the Gateway G1 with the HomeKit smart home platform from Apple Inc. based in Cupertino, USA. In this case, Apple HomeKit will be provided a listing of all devices managed by your Gateway G1 such as switch actuators, lights, motion detectors, thermostats, door and window contacts, which can be linked to HomeKit, and their states in real time. In addition, the Gateway G1 accepts Apple HomeKit control commands, including such originating in the Siri voice assistant running on an iOS, watchOS, tvOS, or macOS device, or an Apple HomePod smart speaker.

6. Amazon Alexa
You may connect the Gateway G1 to the Alexa Smart Home Platform from Amazon.com, Inc., based in Seattle, USA. In this case, Amazon will be provided a list of all devices managed by your Gateway G1, such as switch actuators, lights, motion detectors, thermostats, door and window contacts, which can be linked to Amazon Alexa, and their states in real time. For more information about Amazon’s use of this information, refer to the latest version of the Amazon Privacy Policy. In addition, the Gateway G1 accepts control commands from Amazon Alexa, either via voice orders or via the Amazon Alexa smartphone app or web app. We do not collect or process any personal data. In particular, deducing the e-mail address of the linked Amazon account is technically impossible; The linking of the cloud services of Amazon and ubisys takes place via the industry-standard Open Authorization Protocol (currently OAuth 2.0) by means of a random string (“token”). The ubisys Smart Facility cloud-to-cloud service (ubisys C2F) required for communication between cloud services does not require user registration and does not collect any personal data. All data between the Amazon Alexa Cloud Platform, the ubisys Alexa Smart Home Skill Adapter, the ubisys Smart Facility Cloud-to-Cloud Service, and your ubisys Gateway G1 are always encrypted. In order to find and analyze potential errors in cloud software components, we log inbound and outbound server requests related to our cloud services on our servers and via Amazon Cloud Watch.

II. Website – www.ubisys.de

For the provision of our website, we use a provider in the European Union (One.com A/S based in Copenhagen) who logs access to the data provided by us. The logged data (file name, date, amount of data, browser recognition, operating system identifier, entry point to our site, domain of your Internet service provider) do not allow any conclusion on your person. We occasionally use this information for statistical purposes, to optimize our website, or to decide whether support for a particular legacy browser version can be discontinued. In addition, the provider may be required by law to log data, which in retrospect allow prosecution of illegal actions. Our website currently uses no cookies.

III. Webshop – www.smarthome-store.de

1. Primary Contacts and Orders
In order for us to be able to receive, process, settle and send your order, we must collect personal data or company-related data, store it, process it and forward it to service providers. All data entered in the input fields provided, e.g. last name, first name, company, address with additional information, e-mail address, telephone and telefax numbers, order notes, VAT identification number if applicable, as well as the list of ordered goods (article numbers, quantities, prices) are stored.
If you decide for a permanent user account in our web shop, further data are stored, among other things a password or hash thereof, history of the orders, wish lists you put together, as well as your classification in our B2B partner program. All data is transmitted over an encrypted connection. You can make sure that encryption is enabled by using the features provided in your browser, for example by verifying the protocol prefix in the address line is https://. You also have the option of viewing the associated certificate.

2. Payments
For the processing of payment transactions, we rely on a professional service provider (currently GiroSolution GmbH, based in Meersburg), which ensures the security of payment data. We send a payment request to the servers of this service provider who then collects credit card information, bank details or other account information via a specially secured connection and in return acknowledges the outcome of this transaction to our servers. We do not gain knowledge of any sensitive data – these remain on the specially secured servers of our service provider. You can make sure that encryption is enabled by using the features provided in your browser, for example by verifying the protocol prefix in the address line is https://. You also have the option of viewing the associated certificate.

3. Logistics and Parcel Service Providers
To ship your order and to inform you in advance of associated transport costs, we will send the delivery address as well as the expected number of packages, their size and weight to parcel services such as UPS, DHL, FedEx or TNT. Under certain circumstances, we rely on logistics service providers such as Mail Boxes etc. (Versand-, Büro- und Kommunikationsdienstleistungen Martin Kamrath e.K. based in Düsseldorf and MBE Germany GmbH based in Berlin), who manage customs declarations and parcels in our name and on our behalf or initiate and monitor similar logistical processes.

4. Retention Period
Due to the statutory storage obligation, all invoices, credit notes and delivery notes generated by the web shop are kept at least for the prescribed period of 10 years, currently.

5. Access Logs
Access to the web shop is logged in a similar way as for the web site (see above).

6. Google Analytics
In our web shop we use Google Analytics, a web analytics service provided by Google, Inc., based in Mountain View, USA. This enables us to analyze user behavior in our web shop in order to further improve our offer and to assess the effectiveness of marketing campaigns. The collected information about user activity on our website is usually transmitted to a Google server in the US, where it is stored. Since IP anonymisation is activated on our site to protect your privacy, your IP address will be truncated by Google in the Member States of the European Union and in other states belonging to the European Economic Area prior to the transfer. Only in exceptional cases, the full IP address is transmitted to a Google server in the US and shortened there. We have indicated to Google by means of ‘anonymizeIp’ in the source code of our web shop that we want an anonymous collection of IP addresses.
On our behalf, Google will use the information collected in the manner described to evaluate access to the web shop, to provide reports on user activities on the site and to provide us with other services related to the use of the web shop. According to Google, the Google Analytics IP address provided by your browser will not be aggregated or reconciled with other Google data. However, if you do not wish to use Google Analytics to collect data about your usage behavior in evaluations and statistics, you have the option to stop the data recording by Google Analytics using a browser plug-in that you can download and install at the following address: Browser-Add-on Browser add-on for disabling Google Analytics.
Installing the browser plug-in completely blocks Google Analytics for any websites you visit in a browser. For more information, see: (General information about Google Analytics and privacy).

IV. Query/Revocation/Deletion

On the basis of the Federal Data Protection Act, you can contact us free of charge with questions regarding the collection, processing or use of your personal data and their correction, blocking, deletion or revocation of a given consent.
We point out that you are entitled to request that false data be corrected or personal data be deleted, should this not be precluded by statutory storage requirements.
Please send inquiries or requests in connection with personal data, in particular with regards to queries, blocking, deletion or revocation of consent, to either of the following addresses:

ubisys technologies GmbH
Neumannstraße 10
40235 Düsseldorf
GERMANY

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info@ubisys.de