Your privacy is important to LINGCO.
- We will be transparent about the different types of information We collect and how We use them.
- We will ask your permission before offering an additional service which requires the use of Sensitive Personal Data.
- We will use best-in-class data security tools to keep your data safe and protect the LINGCO Products from unauthorized access.
In this Policy, You will find out the purposes and practices of collection, processing of your Personal Data, including how We use, store, share, transfer Personal Data, and find ways to execute your rights of access, update, delete or protect your Personal Data.
We strongly encourage You to take some time to read this Policy in full. Once You have accepted this Policy during Account registration, or if You have started to use Valta Home Services and do not expressly object to the contents of this Policy, We will consider that You fully understand and allow Us to collect and process information as described in this Policy. If You have any question about this Policy, please do not hesitate to contact Us at email@example.com
The following terms when capitalized in these Terms will have the meaning assigned to them hereunder:
1.1. Account means the account that LINGCO will create for Customer to access and use the Services.
1.2. Authorized User means an individual for whom at the direction of Owner of Account access and use the Services has been granted under an Account.
1.3. Customer means collectively Owner of Account and its Authorized User(s).
1.4. Owner of Account means the individual who register an Account. This individual automatically becomes the “Owner” of that Account and can authorize individual(s) (Authorized User) to access and use the Services of that Account.
1.5. Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information We have access to about that individual.
1.6. Products (“Smart Devices”) means Valta Home products equipped with human-machine interface and have the ability to transmit data via a wireless network.
1.7. Sensitive Personal Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. It is a subset of Personal Data. When We collect Sensitive Personal Data from You, We will generate an explicit notification and ask for your consent before We collection Sensitive Personal Data from You.
1.8. Services (“Valta Home Services”) means the services delivered to Customer by the Software Application downloaded and installed on authorized mobile phones and tablets (“Mobile Terminals”). These services also include but not limited to inter-operation with Products, e-commerce, third party services, customer services, marketing (direct and indirect) and administrative services.
1.9. Software Application (“Valta Home App”, “App”) means the access and use rights with respect to Valta Home mobile application that LINGCO will provide to Customer to use Valta Home Services.
2. Information You Voluntarily Provide to Us
2.1. When You register an Account with Us, We collect your name and contact details, such as your email address, phone number, user name, and login credentials.
2.2. If You authorize login to the Account through a third party, We will obtain from the third party your Account information (such as portrait, nickname, region, gender, etc.) which will be bound with your LINGCO Account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as setting up the necessary agreements and policies with the third party regarding sharing personal information and processing of your Personal Data.
2.3. During your interaction with Services, We may further collect your nickname, profile picture, country code, language preference and time zone information, home name, your member settings, your device information (e.g. device operating system version), unique identifiers and Product configurations and usage and diagnostic analytics (e.g. log information and location data).
2.4. When You provide user feedback, We will collect your email address, phone number and your feedback content.
2.5. When You purchase goods from Valta Shop, We will collect your name, email address, billing address, shipping address, goods purchased, and other necessary information We to process your purchase order (including, for example, payment information from third party digital payments companies).
2.6. When You are using Services such as customer service, marketing service, and administrative service, You will provide necessary the information for that particular service in order to process and response to your requests.
3. Personal Data Collected by Additional Services
In order to optimize the user experience, LINGCO offers You optional Services. We may collect and use certain Personal Data if You consent to use these additional Services. If You opt out of these options, You may continue to use the basic Services, but additional Services will not be available. These additional Services include:
3.1. Personal Data Collected by Services related to Location-based
You may enable or disable Valta Home’s location-based services by configuring the privacy setting of ‘location services’ for the App on the Mobile Terminal. Once the location service is turned on (enabled), We will collect and process your location data for Valta Home’s location-based services. We may collect information about your real-time location, for instance, when You choose to set up a “Geo-fence” which detects the crossing of a preset boundary by the Mobile Terminal to trigger action(s) or to use Weather Service to report local weather.
When You create a “Geo-fence”, your location information will be generated and shared with Google Map Service. Please note that in this particular case your data privacy will also be subject to Google’s data protection terms. You will need to refer to Google’s Data Processing and Security Terms for more details.
You may disable the collection and use of your location information by changing the setting on your Mobile Terminal. Once Valta Home’s location-based services are disabled, We will immediately cease to collect your location information.
3.2. Personal Data Collected by Services related to Camera
You may enable or disable Valta Home’s camera services by configuring the privacy setting of the camera for the App on the Mobile Terminal.
With the permission to use the camera turned on, You may use the camera on your Mobile Terminal’s to scan the QR code to pair with a Smart Device. The camera will only be active while performing these specific functions.
3.3 Personal Data Collected by Services related to Photo/ Video Processing
You may enable or disable the permission to upload or download photo/video by configuring the privacy setting of ‘photo/ video’ for the App on the Mobile Terminal.
Once the permission is turned on (enabled), We will collect and process your photo/video data for Valta Home’s photo/ video processing services. You will be able to, for example, download avatar for your personal information page in the App or upload real-time video for your security camera.
3.4. Personal Data Collected by Services related to Voice
You may enable or disable the permission to use microphone services by configuring the privacy setting of microphone for the App on the Mobile Terminal.
Once the permission is turned on (enabled), We will collect and process your voice data for Valta Home’s voice services. We will collect your voice information, for example, for voice recognition of your command (for Google Assistant or Alexa).
3.5. Data and File Storage (Android):
Android uses a data and file system that’s similar to disk-based file systems on other platforms. You may enable or disable the permission to use this local storage by configuring the privacy setting of “storage” for the App (App-specific storage) on the Mobile Terminal (Android devices).
The purpose is to ensure the stable operation of the App. After You have given the permission to perform read/write operations on the local storage of your Mobile Terminal, pictures, files, system log can be accessed from the local storage to provide You with functions such as notifications and logs.
3.6. Permission to Access Notifications
You may enable or disable the permission to access notifications by configuring the setting of “notifications” for the App on the Mobile Terminal.
Once the permission is turned on (notifications enabled), We will send You notifications regarding the status of Smart Devices or Services. You will be able to receive notifications regarding the real-time status of Smart Devices, for example, motion detection status of an IR sensor for intrusion detection.
3.7. Permission to Connect Bluetooth Devices
You may enable or disable Bluetooth connectivity by configuring the setting of “Bluetooth” on the Mobile Terminal.
Once the permission is turned on (Bluetooth enabled), You will be able to control, monitor, discover and configure Valta Home Smart Devices that can communicate via Bluetooth. We will use Bluetooth to perform these functions: (a) collect device status data for display, (b) perform device control, (c) discover and add new Smart Devices.
4. Information We Collect Automatically
4.1. Mobile Device Information: When You interact with the Services, in order to provide and maintain the normal operation of the Services, to improve and optimize the Services, We automatically collect data from the Mobile Terminal:
- model number, IP address, the type and version of the operating system;
- Valta Home App version number, push notification identifier, log files;
- Information about other Installed Apps;
- Information on mobile network and Personal Area Network (Bluetooth, Zigbee etc.).
4.2. Usage Data: During your interaction with our Services, We automatically collect data relating to the usage of the App, including activities such as clicks, downloads, messages sent/received, your responses to notifications and other usage data while You interact with the Services.
4.3. Error Logs: When You are using the App, the system error log may be uploaded. The upload information will also include IP address, language preference setting, operating system version, date or time of access. These information will facilitate us to accurately identify any anomaly and to improve your experience over time.
We are not able to identify a specific individual by using device data or logs alone. However, when these types of anonymous information are combined with personally identifiable information (Personal Data), We will be able to identify the action(s) of a specific individual. Unless We have obtained your request or unless otherwise required by data protection laws and regulations, We will aggregate or desensitize such information.
5. Smart Devices Related Information
Basic Data of Smart Devices: When You connect your Smart Devices with the Services, We may collect basic information about your Smart Devices such as device name, device ID, online status, time of activation, firmware version, and upgrade information.
Network Connection Data of Smart Devices: Based on the type of Smart Device You need to connect to, the basic data collected includes: Wi-Fi SSID and password, device MAC address etc.
Data Reported by Smart Devices: Depending on the type of the Smart Devices, We collect different sets of data. For example, a PIR sensor will upload detection status data.
6. Legal basis of Processing Personal Information
We process your data including information You voluntarily provide to Us (Section 2), and Personal Data collected by additional services (Section 3), information We collect automatically (Section 4), and Smart Device related information (Section 5), to provide You with the Services that You have requested under a binding agreement, including but not limited to delivering services according to the Terms of Service.
We may process Personal Data relating to You if one of the following applies:
- You have given your consent for one or more specific purposes. Note: Under some legislations LINGCO may be allowed to process Personal Data until You object to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases;
- Processing is necessary for the performance of an agreement with the You and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation and to establish, exercise of defend legal claim to which LINGCO is subject;
- Processing is necessary for legal purposes by LINGCO in Court or in the stages leading to possible legal action arising from improper use of the Products and Services;
- Processing is related to a task that is carried out in the public interest, upon request of public authorities, and/ or in the exercise of official authority vested in LINGCO;
- Processing is necessary for the purposes of the legitimate interests pursued by LINGCO, including but not limited:
- Ensuring that our networks and information are secure;
- Administrating and generally conduct business within our company; and
- Preventing or investigating suspected or actual violations of law, breaches of a contract, or non-compliance with the LINGCO policies.
In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
7. Our Interests of Processing Personal Information
7.1. Products and Services: We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means We process your information for things like:
- offering and improving Products and Services;
- developing new products and features;
- understanding how people use our Products and Services;
- performing research that improves our Services for our users and benefits the public;
- sending You direct marketing and other communications from LINGCO;
- protecting against harm to the rights, property, and safety of Valta Home, our users, and the public
- detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our Services;
- maintaining and improving the integrity of our computing systems, and protecting our users’ data security;
- enforcing legal claims, including investigation of potential violations of applicable Terms of Service.
7.2. Non-marketing Communication: We process your Personal Data to send You important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, We will also send You notifications related to the Services You have purchased, such as alert services. You can manage these communication options in “Notifications Settings” in the App (“Me / Message Center / Settings / Notifications Settings”). When You decide to disable the “Enable Notifications” option, We will no longer process your information for such purpose.
7.3. Data Analysis: In order to analyze the usage of the Products We provide and improve your user experience, We will analyze the data for the purpose of:
7.3.1. identifying the cause(s) of any malfunction during while using the Services. Under such circumstance, You may not able to opt-out because it is important to take the remedial actions and maintain the quality of the Services, and;
7.3.2. analyzing how You interact with the Services to improve your user experience. Under such circumstance, if You do not agree to our analysis of your data, You may opt-out by changing the “Data Analysis” option in the App (“Me / Settings / Privacy Settings / Data Analysis”). When You decide not to enable the “Data Analysis” function, We will no longer process your information for such purpose.
7.4. Marketing Communication and Personalization: We would like to use your Account data, usage data, Smart Device information to provide personalized recommendations based on your preferences. These recommendations may be relating to Products, Services and invitation to participate in events (such as usage surveys). If You do not want Us to process your Personal Data for personalized recommendations, You may opt out by changing the “Personalization” option in the App (“Me / Settings / Privacy Settings / Personalization”).
If there is any change in the purposes for processing your Personal Data, We will inform You via email and/or prominent notice on our website of its purposes and the options You may have.
8. Data Sharing with Third Parties
Under no circumstance do We share personal information for any commercial or marketing purpose unrelated to the activation and delivery of Valta Home Services without asking You first. The following are the limited cases where We may share personal information:
With service providers who perform certain business-related functions for Us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to Us.
With our third party suppliers who supply You with Smart Devices, and/or networks and systems through which You access and use our websites and Services.
To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with bankruptcy or similar proceedings). In such an event, You will be notified via email and/or prominent notice on our website of any change in ownership, and options You may have regarding your Personal Data.
We will disclose information if We are legally required to do so, or if We have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- comply with any applicable law, regulation, legal process or enforceable governmental request;
- enforce our Service Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;
- protect the rights, property or safety of Us, our users, a third party or the public as required or permitted by law; or
- detect, prevent or otherwise address security, fraud or technical issues.
- except for the cases mentioned above, We only disclose your Personal Data to a third party with your consent.
9. International Transfer of Collected Information
LINGCO will comply with applicable data localization requirements in the corresponding jurisdictions with respect to storage of data. Due to operational requirements, We may transfer, store and process your Personal Data in jurisdictions other than where You use Valta Home Services. Laws in the countries where your Personal Data are stored may differ from the laws applicable to your country of residence. In case for data transfers from the EU to third countries, We will ensure that an appropriate level of data protection safeguards protection is provided for by committing to the General Data Protection Regulation (GDPR) contractual clauses (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).
If You would like to learn more about data protection safeguard for your particular jurisdiction, please do not hesitate to contact Us at firstname.lastname@example.org
10. Security Measures
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. LINGCO provides various security strategies to effectively ensure data security of users and devices.
Device access – LINGCO’s proprietary algorithms to ensure data isolation, access authentication and user authorization.
Data communication – commercial grade best practices to protect your sensitive data and enhance your privacy using security algorithms and data encryption with dynamic key server.
Data processing – application of data filtering and validation, and data audit.
Data storage – all Sensitive Personal Data are encrypted before storage.
If You have reasons to believe that your Personal Data is no longer secure, You could immediately notify us of your concern by email at email@example.com
11. Data Retention
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for, unless there is a specific legal requirement for Us to keep the data for a longer period. We determine the appropriate retention period based on the volume, nature, and sensitivity of your Personal Data, and after the retention period ends, We will delete your Personal Data.
Personal Data will not be retained when You request LINGCO to remove your Personal Data, We will accordingly complete the task. When We are unable to do so for technical reasons, We will ensure that appropriate measures are executed to prevent further use of your Personal Data.
12. Your Responsibility
We would like to remind You that it is your responsibility to ensure, to the best of your knowledge, that the data You provide Us with, are accurate, complete and up-to-date. If You share with Us data of other people (e.g. give access to a friend to control the Products in your house) it is your responsibility to collect such data in compliance with local legal requirements. For instance, You should inform such other people, whose data You provide to Us, about the content of this Policy and obtain their consent.
You are free to provide your Personal Data and usage data to Us when using the Services. Unless otherwise specified, all data requested by the Services is mandatory and failure to provide this data may result of failure to provide the Services. For data that states is not mandatory, You are free not to communicate this data without consequences to the available or the functioning of the Services. If You chose not to provide us with your data, We might not be able to response to requests that you may have.
You are responsible for any third-party Personal Data obtained, published or shared through the Services and confirm that they have the third-party’s consent to provide the data to LINGCO.
13. Your Rights Relating to Your Personal Data
LINGCO generally stores your personal information on our servers until You delete or edit it, or for as long as You remain a Customer of LINGCO in order to provide You with Services. In addition, LINGCO may store your personal information to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
You have the right to delete the information on the Valta Home Smart Devices by resetting it to the defaults.
You can access, amend or delete your personal information from our servers through the controls in your Account:
- Correct inaccurate or incomplete Personal Data about You: a) modify your Account information (email address and password): “Me / Settings / Account and Security “; b) modify the nickname and/or time zone: “Me / Settings / Personal Information”;
- Delete your Account: “Me / Settings / Account and Security / Delete Account”, when You confirm the deletion of your Account, your Personal Data will be deleted accordingly.
14. Children’s Privacy
Only individuals aged 18 and older are permitted to act as Home Owners of Valta Home Accounts. Authorized Users must be over the age of 13 (or equivalent minimum age in the jurisdiction where they reside) and may use the Services under the supervision of a parent or legal guardian and only if they agree to be bound by Valta Home Children’s Privacy Statement and this Privacy Agreement on their behalf.
16. Contact Us
For Customers in Asia:
Lingco International Limited
6D Leapont Centre
18-28 Wo Liu Hang Road
Fo Tan, New Territories
Hong Kong SAR
Policy last updated on 10 August, 2022
Policy active as of 10 August, 2020.