We care about your Data
We really care about protecting your data. We have designed our business and its systems from the bottom up with privacy in mind and have taken every step to comply with the General Data Protection Regulation (GDPR) 2018 and UK Data Protection Act 1998, including having Data Protection Impact Assessment (DPIA) and assigning a Data Protection Officer (DPO). The GDPR outlines best practice across Europe and comes into force in May 2018. We are also registered with the UK Information Commissioner’s Office (ICO).
Where do we store your data?
All resident data is stored on the cloud in secure environments. We chose the market leader, Amazon Web Services, as our cloud provider. The GDPR requires us to host in the EU, which we do.
How do we protect your data?
We use the best-in-class cloud based data storage and ensure data is fully encrypted both on the cloud and in-flight to AES-256. Access to data is only granted with valid login credentials to users who have been given access by end users.
Who controls the data? MySense is strictly a ‘data processor’ as defined in Article 28 of the GDPR. We do not own data entered into our system, this is passed to care providers who are themselves classed as ‘data controllers’.
Do we comply with GDPR?
Yes we are compliant with the articles of GDPR. We ensure our partners who act as ‘data controllers’ carry out a Data Protection Impact Assessment (DPIA).
Your personal information:
The protection of your personal information is important to us. We respect your privacy and want you to understand what we do with the information we hold about you.
You can contact MySense’s data protection officer by writing to The Data Protection Officer, MySense Ltd, 7 Bell Yard, London, England, WC2A 2JR. You can also contact our data protection officer at firstname.lastname@example.org.
Personal information we collect:
We may collect the following types of personal information from you when you use MySense services or products:
- Contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account or order. On a strictly opt-in basis, we may also request your job title and the company at which you work in order to better respond to enquiries left on our website.
- MySense account details: when you download and use the MySense app, you will be asked to register with us and create an account. Your account details include your user name, password and your contact details, such as your name, address and email address.
- Payment information: records of the products you purchase from us.
- Delivery information: information relating to the delivery of our products to you.
- Installation and service history: records relating to the installation of our products at your home or property and information relating to the servicing of that product.
- Device information: information about the smartphones, mobiles, computers or other electronic devices you connect to our products, website or MySense app, such as details about the type of device (which can include unique device identifying numbers), its operating system, the browser you use and applications on the device that connect to our products and services. It can also include details of your internet service provider, mobile network and your IP address.
- Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
- Records of your discussions with our customer support teams: when you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our customer service team, use any in-app messaging feature, or contact us through social media such as through Twitter or our Facebook page.
- How you use MySense products: we will collect information about how you are using the MySense product in your home and their performance. For example, this includes information collected about rooms’ temperatures, when contact sensors show doors or windows are open or closed, when motion sensors detect movement, water flow events and when smartplugs are on or off.
- How you use the MySense app / dashboard and our website: when you use the MySense app / Dashboard or our website we collect information about the pages you look at and how you use them. This is to enable us to improve our website and optimise your user experience, ensuring that our services and the content they provide is as relevant as possible to you.
- Location information: we will collect information about your exact location when you choose to share that with us and activity information from the sensors in your MySense product that detect movement in your home.
Even when you don’t actively share your location with us, your smartphone or computer’s IP address may tell us an approximate location when you connect to our website or products but this will be no more precise than the city, county or country you are using your device in.
You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services, or the functionality of our products may be reduced.
What we use your personal information for:
|Purpose||Personal information used||Legal basis for processing|
|Provide our services to you and maintain your account||All the personal information we collect||Necessary for the performance of a contract|
|Take payment for our products and services||Transaction and payment information||Necessary for the performance of a contract|
|Deliver products to you||Delivery information||Necessary for the performance of a contract|
|Installation and servicing||Installation and service history How you use MySense products||Necessary for the performance of a contract|
|Answer your queries or complaints||All the personal information we collect||Necessary for the performance of a contract|
|Maintain and improve our products and services||All the personal information we collect||For the legitimate interest of creating the best products and services that we can|
|Data analytics and statistical research to help us better understand how our products are used in the home and make suggestions and recommendations to you about the use of our products||
· Contact details
· How you use MySense products
· How you use the MySense app / Dashboard and website
· Device information
· Transaction information
· Installation and service history
· Records of your discussions with our customer support teams
|For the legitimate interest of creating the best products and services that we can|
|Staff training||All the personal information we collect||Necessary for the performance of a contract|
|Develop new products and services||All the personal information we collect||For the legitimate interest of improving our range of products and services|
|Determine products and services that may be of interest to you||All personal information we collect (but not your payment information)||For the legitimate interest of improving the relevance of communications|
· Contact details
· Products and services that we have determined may be of interest to you
|Validating referral scheme applications||Contact details||Necessary for the performance of a contract|
|Investigating misuse of your account, fraud and debt collection||All the personal information we collect||Necessary for the performance of a contract|
|For the establishment, exercise or defence of legal claims||All the personal information we collect||For the legitimate interest of operating our business|
Please note that where you have given your consent for us to process your personal data, you have a right to withdraw your consent at any time. This right applies only to processing activities which are carried out on the basis of consent.
We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site, apps and products and developing new products and services.
Sources we collect your personal information from:
We will collect personal information from a number of sources. These include the following:
- Directly from you: for example, when you create your MySense account with us, purchase products and services from us, complete forms we provide to you, enter our competitions and promotions, contact us by phone, email or communicate with us directly in some other way.
- Our website, app / dashboard: provide us with information about how you use them and the devices in your home that you connect to them.
- Other companies we work with: provide us with information to help us deliver our products and services to you, and to understand you better. These include:
o Companies in the same group of companies as us
o Installers and service engineers: who will provide us with information about the installation and maintenance of MySense products in your home.
o Distributors of our product: organisations that sell our product on our behalf and provide a service wrapper
Who we share your personal information with:
We share personal information with the following parties:
- Companies in the same group of companies as us: for the purpose of providing a service to you and understanding your use of our products and services.
- Installers and service engineers: so that they can book appointments with you and provide installation and product maintenance services.
- Delivery companies: to deliver products that you have ordered from us.
- Other service providers and advisors: We use GoCardless to process your Direct Debit payments. More information on how GoCardless processes your personal data and your data protection rights, including your right to object, is available here.
- Market research: occasionally we may ask our market research partners to contact our customers to help us find out how to improve our products and services.
- Statutory services (e.g. National Health Services (NHS) or social services (Council’s)) organisations commissioned by those statutory services who have purchased this product for you: This could include social work teams, healthcare professionals and caregivers
- Anyone to whom you give access to your data: if you give someone else access to your data, they will be able to access information about you. If, for example, you nominate a carer or loved one to be a responder, they will be able to see your daily and historical wellbeing data, either through the dashboard or app.
- Purchasers of our business: buyers who we sell our business to (this is not anticipated in the near future)
- The Government or our regulators: where we are required to do so by law or to assist with their investigations.
- Police and law enforcement: to assist with the investigation and prevention of crime.
We do not disclose personal information to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our products and services, but we will make sure no one can be identified from this information before we disclose it.
In accordance with the marketing preferences you set when creating your account or that you set with us a later date, we may contact you by email, push notification, text, mail or phone with information about products and services we believe you may be interested in.
If you tell us not to email, push notification, text, mail or phone you with direct marketing we won’t contact you in that way.
You can let us know at any time that you do not wish to receive marketing messages by sending an email to us at email@example.com or contacting the customer service team by phone.
You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
The MySense app will send service notifications directly to your smartphone or device through the app when we have something important or interesting to make you aware of or you have asked to be notified about certain events relating to your MySense product, e.g. to check in on you if we notice something out of the ordinary.
Depending on the service you choose, you may also receive these notifications by text message or email depending on your preferences.
You can turn off service notifications at any time through the app or your smartphone system settings.
Transferring your personal information internationally
How long we keep personal information
We will keep your personal information for as long as you have an account with us. After you close your account with us we will keep your personal information for a reasonable period to maintain our records and legal obligations to you.
Your rights in relation to your personal information
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used (which we fulfil by providing this notice);
- the right to access the personal information we hold about you;
- the right to opt-out of receiving direct marketing messages; and
- the right to request the correction of inaccurate personal information we hold about you.
In some situations, you also have:
- the right to blocking or erasure;
- the right to restriction of processing;
- the right to data portability; and
- the right to object, and to object to automated decision-making; which produces legal effects concerning you or which similarly significantly affects you.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the ‘Contacting us’ section below.
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
Changes to this notice
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
In the event of any query or complaint in connection with the information we hold about you, please email us at: firstname.lastname@example.org.
You can also contact our data protection officer by emailing email@example.com.
Version 1.1 – September 2019