KINGLUMI PRIVACY POLICY
Last Updated：December 27, 2023
This Privacy Policy is aimed at the Users of Caimeta AIoT lighting system. The purpose of this Privacy Policy is to provide Users with information about the processing of their personal data in accordance with the information obligations set in General Data Protection Regulation (GDPR).
Kinglumi Co., Ltd. (“Kinglumi” or “we”) is committed to protecting personal data and ensures full compliance with the local laws, rules, and regulations while doing international business. Kinglumi focuses on GDPR Compliance and fully supports the implementation of GDPR in Europe.
This Privacy Policy is applicable to the personal data processed by Kinglumi relating to the Users (“Users” or “you”) of the Caimeta Apps used to control the smart luminaires and controllers produced by Kinglumi (also referred to as “Service”). Such Users on behalf of their businesses or as individuals use our service.
This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. We will not make substantial changes to this Privacy Policy or reduce the rights of Users under this Privacy Policy without providing a notice thereof.
PERSONAL DATA PROCESSED AND SOURCES OF DATA
We collect two types of information concerning the Users: (i) account data; (ii) Analytics data.
Account data, including an email and a password, is received directly from Users who use our Caimeta Apps. In such situations, account data will be considered to be personal data under applicable laws and process such data in accordance with this Privacy Policy.
Analytics data is collected whiling you are using our Apps, such as IP address, Operating system, etc. Individuals cannot be recognized from the analytics data, either alone or when combined or linked with account data.
So Kinglumi may process the following categories of data:
Account data:
· E-mail address;
· Password;
Analytics data:
· IP address;
· Operating system of App devices (tablet, phone), i.e. iOS or Android;
· Time of visit;
· Language preference;
· Location;
· Time zone;
When you are writing feedback on the Apps, following data will be asked to provide:
· E-mail address or phone number;
MEASURES TO ENSURE DATA SECURITY
Kinglumi has been taking following initiatives to protect User’s data in the use of its products and solutions.
All communication is encrypted among Cloud server, luminaires, and App devices through AES-CCM algorithms and the HTTPS protocol.
Kinglumi minimizes Users’ data collection.
Kinglumi has moved the Cloud server from Tokyo AWS to Frankfurt AWS in order to be in accordance with GDPR to ensure all data is stored and backed up in Europe.
While the Apps are accessing Wi-Fi, Bluetooth, location, etc. , the Apps will ask Users to get permission first.
Users can delete their account data on the Apps any time, and all the data will be erased. Users can also log on a webpage to delete their account data. (The webpage will be available in May 2024)
PURPOSES AND LEGITIMATE GROUNDS OF PROCESSING
Purposes of processing
To provide our Service and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
We process personal data to be able to offer the Service to our Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the User or towards the organization the User represents. We may use the data for example to offer essential functionalities of the Service and to provide access to the Service.
For our legal obligations (legal ground: compliance with a legal obligation)
We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities.
For claims handling and legal processes (legal ground: legitimate interest)
We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting our Users regarding our Service and for informing Users of changes in our Service. We may also process personal data to market our Service, for example in the form of sending newsletters.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may process information regarding the use of the Service to improve the quality of our service, for example, by analyzing any trends in the use of our Service. Where possible, we will do this using only aggregated, non-personally identifiable data.
Legitimate grounds for processing
We primarily process personal data of Users on a contractual basis. For Users acting as representatives of our customer or partner organizations, personal data is primarily processed based on our legitimate interest whilst fulfilling our contractual obligations towards the organizations they represent.
We may also process personal data based on our legitimate interests, for example, in connection with analytics and marketing. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy.
In certain cases Users may be requested to grant their consent for the processing of personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.
PERSONAL DATA RECIPIENTS
We do not share personal data with third parties outside Kinglumi’s organization unless one of the following circumstances applies:
It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to personal data to perform the Service, Kinglumi has taken appropriate contractual and organizational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.
For legal reasons
We may share personal data with third parties outside Kinglumi’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security, or technical issues; and/or (iii) protect the interests, properties or safety of Kinglumi, our Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.
To authorized service providers
We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing, and support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.
For other legitimate reasons
If Kinglumi is involved in a merger, acquisition, or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.
With explicit consent
We may share personal data with third parties outside Kinglumi’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. You have the right to withdraw this consent at all times.
Anonymous and aggregate data
Please note that the above principles regarding disclosure of data apply to personal data. We may disclose aggregate data to third parties, but solely to the extent such aggregate data is in anonymous format and does not include any personal data.
STORAGE PERIOD
Kinglumi does not store personal data longer than is legally permitted and necessary for the purposes of providing the Service or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
We will store Analytics Data relating to the Service no longer than reasonably necessary.
USERS’ RIGHTS
Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and what personal data we process regarding you.
Right to withdraw consent
In case the processing of your personal data is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our Service.
Right to restriction of processing
You may request us to restrict processing of personal data, for example, when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Service.
Right to data portability
You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights
The above-mentioned rights may be used by sending a letter or an E-mail to us on the addresses set out below. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
DIRECT MARKETING
Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience, and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
LODGING A COMPLAINT
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.
CONTACT INFORMATION
Name: Kinglumi Co., Ltd.
Correspondence address: Bldg 3, Nangang 3rd ind. Zone, Tangtou,Shiyan, Bao'an,
Shenzhen China 518108
Contact: info@kinglumi.com
Website: www.kinglumi.com