iO.e Smart
device Privacy Policy
Welcome aboard!
So you have purchased our iO.e
Smart device hardware (“Products”) and are starting to use the iO.e Smart device software (“IOlight app”, “app” or “application”) and all its functionalities! Any information you
share with us will help us to provide you with services related to Products and IOlight app to improve them to make them even better.
IOUCYS (“we”, “our” or “us”) explains here our ways
of collecting and using information, and how we protect your privacy. In this
Privacy Policy, “personal data” means information that can be used to identify
an individual, either from that information alone, or from that information and
other information we have access to about that individual. We collect both
personal and non-personal data to enable and facilitate the best user
experience possible.
What information is collected and how do we use it?
Types of Personal Data Collected
- In order to provide our services to you, we will ask you to provide
necessary personal data that is required to provide those services. If you
do not provide your personal data, we may not be able to provide you with
our products or services.
- Connecting
your IOlight app with your Products, we may
collect your:
- Names of your rooms
- Images of your rooms
- Name of your accessories
- Which room name each accessory is allocated
- Sharing your content, we may collect:
- Personal information of your contacts (eg.
names, email addresses, telephone numbers)
- When you share content or invite users to use Products, please
note that other users may see personal data you share.
- In providing the above
services, we may also collect data:
- Products ID,
- Firmware version
- Your devices’ OS versions, models and operating systems
How the Personal Data is used
- To provide you with our Products and IOlight app , processing your orders, performing contractual obligations between
you and us, to ensure the functions and safety of our products, to verify
your identity, to prevent and trace fraudulent or inappropriate usage
- To develop our products and services, together with general and
statistical information
- To personalise Product design and to
provide you with services tailored for you, for example, recommending and
displaying information and advertisements regarding products suited to
you, and to invite you to participate in surveys relating to your use of Products.
- To conduct investigations regarding our products and services
- If you participate in our lottery, contest or other promotions, we
may use your personal data to manage such activities
- To provide maintenance services, monitor software licenses, to
improve our products or analyse the efficiency
of our operations
Other Information
We use statistical data that does not specifically
identify you (non-personal data) to help in our operations and improve our
products and services and provide a better user experience for you. Here are
some of the non-personal data we may collect and how we use them:
- When you opt-in to participate in our User Experience Improvement
Program, we may gather statistics relating to your use of our products
functions, on an anonymous basis. This may include information relating to
your use of IOUCYS official website, Products and services. If there is an
abnormal shutdown or breakdown, we may collect information relating to your
mobile device to diagnose the problem.
- When you use our website, online services, interactive
applications, email messages and advertising, we may use cookies and other
technical elements (e.g. pixel labels) to collect and store non-personal
data. These enable us to provide you with a better experience and improve
our overall service quality, e.g. in saving your preferred language
settings, sending emails in a readable format, to determine whether the
emails have been opened or not, etc.
- When you first use and activate your Products, the device’s unique
identification code and approximate geographical information may be
collected.
You have control over your information!
We recognise that privacy
concerns differ from person to person. Therefore, we provide examples of ways
we make available for you to choose to restrict the collection, use, disclosure
or processing of your personal data and control your privacy settings, such as
controlling the settings under the User Experience Improvement Program.
Access, Updating or Correcting Your Personal Data
- You have the right to request access and/or correction or any other
personal data that we hold about you. When you update your personal data,
you will be asked to verify your identity before we proceed with your
request. Once we obtain sufficient information to accommodate your request
for access or correction of your personal data, we shall process in
accordance with the laws of your country. While we try our utmost in
acceding to your requests, unreasonably repetitive or unrealistic requests
or those that put others’ privacy at risk may be declined.
- We normally provide such services for free but reserve the right to
charge a reasonable fee.
- If you believe any information we are holding on you is incorrect
or incomplete, please write to or email us as soon as possible at the email
address below mailto:joe@ioucys.com.
Withdrawal of Consent
- You may withdraw your consent for the collection, use and/or
disclosure of your personal data in our possession or control by
submitting a request. This may be done by emailing mailto:joe@ioucys.com. We will
process your request within a reasonable time from when the request was
made, and thereafter not collect, use and/or disclose your personal data
as per your request.
- Please recognise that your withdrawal of
consent could result in certain legal consequences. Depending on the
extent of your withdrawal of consent for us to process your personal data,
it may mean that you will not be able to enjoy Products, IOlight app and services.
Who do we share your information with?
Unless we tell you in this privacy policy, we will
keep your personal information confidential. We may disclose your personal data
on occasion to third parties in order to provide the products or services that
you have requested. Some of these third parties may be located outside your
home country.
Disclosure may include the scenarios listed in this
section below. In each case described in this section, you can be assured that the
usage of Products and app will only share your personal data in accordance with
your consent. You should know that when IOUCYS shares your personal data with a
third party under any circumstance described in this section, IOUCYS will
ensure that the third party is subject to practices and obligations to comply
with the relevant data protection and privacy laws of your country. IOUCYS will
contractually ensure compliance by any foreign Third Party Service Providers
with the privacy standards that apply in your home jurisdiction.
Disclosure to IOUCYS companies and Third Party Service Providers
- In order to conduct business operations smoothly, the IOUCYS entity
which collects your personal data may disclose your personal data from
time to time to other IOCYS companies (in communications, social media,
technology or cloud business), or our third party service providers which
are our mailing houses, delivery service providers, telecommunications
companies, data centres, data storage
facilities, and customer service providers, agents, related corporations,
and/or other third parties (together “Third Party Service Providers”).
Such Third Party Service Providers would be processing your personal data
on IOUCYS’ behalf or for one or more of the purposes listed above.
- Personal data will only be shared by IOUCYS to provide or improve
our products or services and will not be shared for use for marketing
purposes.
Disclosure to Others
IOUCYS may disclose your personal data without
further consent if required or permitted by law in the following cases:
- cases in which the disclosure is required or authorized based on
the applicable laws and/or regulations;
- cases in which the disclosure is necessary to respond to an
emergency that threatens the life, health or safety of the individual or
another individual;
- cases in which the disclosure is necessary for the prevention of
crime or legal proceedings;
- cases in which the purpose of such disclosure is clearly in the
individual’s interests, and if consent cannot be obtained in a timely way;
- cases in which the disclosure is necessary for any investigation or
proceedings;
- cases in which the disclosure is to any officer of a prescribed law
enforcement agency upon production of written authorisation
signed by the head or director of that law enforcement agency, or a person
of a similar rank, certifying that the personal data is necessary for the
purposes of the functions or duties of the officer; and/or
- cases in which the disclosure is to a public agency and such
disclosure is necessary in the public interest.
Information Not Requiring Consent
- We may share anonymised information and
statistics in aggregate form with third parties for business purposes, for
example with advertisers on our website, or we may tell our business
partners the number of customers in certain demographic groups who
purchased certain products or who carried out certain transactions.
- For the avoidance of doubt, in the event that we are permitted by
law to collect, use or disclose your personal data without your consent,
such permission granted by the law shall continue to apply.
Information Safety Safeguards
We are committed to ensuring that your personal
data is secure. In order to prevent unauthorised
access, disclosure or other similar risks, we have put in place reasonable
physical, electronic and managerial procedures to safeguard and secure the
information we collect. We have put in place the following security procedures
and technical and organisational measures to
safeguard your personal data:
- Your personal data is stored on secure servers that are protected
in controlled facilities.
- All data saved in the back-end is classified into different levels
based on the importance and sensitivity of the data, e.g. whether the data
contains personal data.
- In the data centers, clusters that contain sensitive data are
grouped together in the network topology, and will be placed in rooms with
additional physical security protection.
- Data exchanged between Products and IOlight app are encrypted using Secure Sockets Layer (“SSL”).
- There is regular review of information collection, storage and
processing practices, including physical security measures, to guard
against unauthorized access to systems.
- Access is restricted to IOUCYS employees and Third Party Service
Providers who need to know that the information in order to process it,
and who are subject to strict contractual confidentiality obligations and
may be disciplined or terminated if they fail to meet such obligations.
- There are also access controls for all server clusters used for
cloud-based data storage and process.
- Most data used for IOUCYS’ products and/or services is stored in a
storage system. By using column family based access control mechanism,
IOUCYS employees are only allowed access to the data column families they
are granted access to.
- Please note also that for the above, IOUCYS may use overseas
facilities operated and controlled by IOUCYS to process or back up your
personal data. Currently, IOUCYS has data centres
in the US. As a result, we may transfer to and store your personal data at
our overseas facilities. However, this does not change any of our
commitments to safeguard your personal data in accordance with this
Privacy Policy.
Information safety is very important to us. We will
take all practicable steps to safeguard your personal data. Through our
protective measures above, especially encrypted storage and transmission, your
data is as secure as it can be. Certain details of encrypted data cannot be
accessed by anyone except by you.
When this Privacy Policy applies
Our Privacy Policy does not apply to products and
services offered by a third party. Products, IOlight app and services may include third party’s products or services. When you use
such products or services, they may collect your information too. For this
reason, we strongly suggest you to read the third party’s privacy policy as you
have taken time to read ours. We are not responsible for and cannot control how
third parties use personal data which they collect from you. Our Privacy Policy
does not apply to other sites linked from our services.
Minors
We consider it the responsibility of parents to
monitor their children’s use of our products and services. Nevertheless, it is
our policy not to require personal data from minors or offer to send any
promotional materials to persons in that category. IOUCYS does not seek or
intend to seek to receive any personal data from minors. Should a parent or
guardian have reasons to believe that a minor has provided IOUCYS with personal
data without their prior consent, please contact us to ensure that the personal
data is removed and unsubscribe them from any of the applicable IOUCYS
services.
Updates To The Privacy Policy
We keep our Privacy Policy under regular review. If
we change our Privacy Policy, we will post the changes on all the IOUCYS websites
(www.ioucys.com), so that you may be aware
of the information we collect and how we use it. Such changes to our Privacy
Policy shall apply from the time that we post the same on the IOUCYS websites.
Your continued use of products and services on the websites, mobile phones
and/or any other device will be taken as acceptance of the updated Privacy
Policy. We will seek your fresh consent before we collect more personal data
from you or when we wish to use or disclose your personal data for new
purposes.