Effective Date: 4 June 2018
Which Personal Data we Collect
Personal Data is information that identifies you or can be used to identify or contact you (“Personal Data”). Such Personal Data may include your name, address, email address, telephone number, birth date (primarily for eligibility purposes), billing and credit card information.
How we Collect and Use Your Personal Data
The types of information that you provide actively and that we collect automatically depend on your level of engagement with our Services. The higher the level of your engagement, the more information we need to serve you.
We collect Information, some of which contains Personal Data that you provide directly to us through responses to special Services such as surveys, questionnaires and the like. We use this data to personalise our Services and to optimize your customer experience when using our Website.
Moreover, we automatically collect information including Personal Data when you browse our Website, such as your IP address, browser type, operating system, error logs, and other similar information. Such aggregated information does not allow us to identify you and is used by us to analyse trends, to administer the Website, to monitor our Website’s use, and to gather general information about the use of our Website.
The legal basis for such processing of your Personal Data are our legitimate interests (Art. 6(1)(f) GDPR) in customizing the content of our Services in line with user preferences and in further improving our Services.
Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to provide you with the full range of our Services.
In order to access certain Services on our Website, you must first complete certain steps to become either a regular My Neato Account holder or a My Neato account holder as a developer. During these steps, you will be required to provide us with Personal Data such as your name, postcode and email address. When you become a My Neato account holder, we will send you a welcome email to provide transactional information about your subscription or to verify your username and password.
Such processing of your Personal Data is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR.
We use your Personal Data to send you important service announcements and updates regarding our Website or about your billing account status. Such service announcements and updates contain important information relevant to your use of our Website and/or our Services.
The processing of your Personal Data for such purposes is necessary for the performance of our Services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you service-related communication.
If you contact our customer service, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your subscription. We will communicate with you by email or telephone, in accordance with your preferences.
Such processing of your Personal Data is necessary for the performance of our Services; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you customer service related communications.
When subscribing to our Services you have the option to consent to receiving newsletters and other information on our products and services. If you “opt-in” we will send you promotional newsletters and inform you about offers, events and surveys via e-mail and through social media platforms. Robot Owners may register their NEATO robots in their My Neato account. We may ask for other information in surveys to assist us with new product development by asking questions about how you like your NEATO robot or how you use it. You do not have to participate in these surveys.
The legal basis for such processing of your data is your consent (Art. 6(1)(a) GDPR). Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to send you our newsletters and other information as described above. You have the option to opt-out of these types of communication at any time by following the respective instructions in such communication.
You have the following rights:
Right of access (Art. 15 GDPR):
You have the right to request confirmation as to whether we process your Personal Data and where that is the case, to request access to the Personal Data we hold about you.
Right to rectification (Art. 16 GDPR):
You have the right to request the correction of inaccurate Personal Data.
Right to erasure (Art. 17 GDPR):
You have the right to request erasure of Personal Data without undue delay under certain circumstances, e.g. if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and where there is no other legal ground for processing.
Right to restriction of processing (Art. 18 GDPR):
You have the right to request us to restrict the processing of your Personal Data under certain circumstances, e.g. if you think that the Personal Data we process about you is incorrect or unlawful.
Right to data portability (Art. 20 GDPR):
Under certain circumstances, you have the right to receive your Personal Data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
Right to object (Art. 21 GDPR):
|You have the right to object to the processing of your Personal Data under certain circumstances, in particular if we process your Personal Data on the legal basis of legitimate interests (Art. 6(1)(f) GDPR) or if we use your Personal Data for marketing purposes.|
You can assert your abovementioned rights by contacting us at the contact details mentioned below.
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at the contact details mentioned below and we will assist you to identify the respective competent supervisory authority.
We store your Personal Data and other information for as long as necessary to enable you to use our Website, to provide our Services to you, to comply with applicable laws (including those regarding document retention), to resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. If you have a question about a specific retention period for certain types of Personal Data we process about you, please contact us at the contact details mentioned below.
We do not use your Personal Data to make decisions with legal or similar effects for you based on the automated processing of your Personal Data only.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to email@example.com.
We are committed to providing you with meaningful choices about the information collected on our Website, and that is also why we provide the opt-out links above. However, we do not recognize or respond to browser-initiated Do-Not-Track signals, because the Internet industry is still working on uniform Do-Not-Track standards.
We do not knowingly collect any Personal Data from anyone under the age of eighteen (18) without parental consent, unless permitted by law. If we learn that a person under the age of eighteen (18) has provided us with Personal Data, we will delete it in accordance with applicable law.
By Email: firstname.lastname@example.org
Or by mailing us at the address below:
ATTN: DPONeato Robotics, Inc.