Privacy Policy for Skill from Tholz Smart Home

Updated in: 29/09/2021

THOLZ SMART HOME, its affiliates and subsidiaries (“we”, “us”, “our”, “THOLZ”) are committed to protecting your privacy. This Mobile Privacy policy (“Policy”) describes our practices regarding the privacy of information in Personal Data that we process through individual use of the following services, products and related mobile applications (collectively, the “Products”):

• Application THOLZ SMART HOME (For Products with version 1.0 or later) You can still use several THOLZ services when you are not logged in or even without creating an account, such as browsing or searching for any features in the Products.

In this Privacy Policy, “Personal Data” means information that can be used to identify an individual, only from this information, or from this information and others to which we have access related to that individual. “Smart Devices” refers to those non-standard computing devices, produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connects wirelessly to a network, including: smart home appliances, smart portable devices, among others. "Apps" refers to those mobile apps developed by THOLZ that provide remote control to end users for Smart Devices and the ability to connect to the Platform THOLZ.

For other third-party mobile apps with technology from THOLZ, our customers control all Personal Data collected through our products. We collect information under the guidance of our Customers and the processing of such information will be limited to the purpose of providing the service for which our Customers have chosen us. If you are a customer of one of our Customers and no longer wish to be contacted by one of our Customers who use our service, contact the Customer with whom you interact directly.

Which Personal Data We Collect

To provide our services to you, we will ask you to provide us with your Personal Data as required. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

1. Information you voluntarily provide to us

• Account or Profile Data: When you register an account with us, we may collect your contact details, such as your email address (email), phone number, username and access credentials. During your interaction with our products, we may collect your nickname, your profile picture, your country code, your language preference or time zone information in your account.
• Feedback: When using the feedback and suggestion features in our Products, we will collect your email address (email), mobile number and the content of your feedback to resolve your issues and resolve device failures in a timely manner.

2. Information we automatically collect

• Device information: When you interact with our product, we automatically collect device information such as MAC address, IP address, wireless connection information, operating system type and version, application version number, identifier of push notifications, log files and information from the mobile network.
• Usage Data: During your interaction with our Sites and Services, we automatically collect usage data related to visits, clicks, downloads, sent and/or received messages and other uses of our Sites and Services.
• Registration information: When you use our application, error and system logs may be uploaded.
• Location Information: We may collect real-time information about your precise or non-accurate geographic location when you use our specific Products or Services, such as robot cleaning services and weather data, as applicable.

3. Related information of Smart Devices:

• Basic Smart Device Information: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices, such as device name, device ID, on-line status, activation time, firmware version and update information.
• Information Reported by Smart Devices: Depending on the different Smart Devices you choose to connect to our Products or Services, we may collect different information reported by your Smart Devices. For example: smart weight or fitness trackers can report your height, weight, body fat (BFM), BMI, and skeletal muscle mass (SMM); smart cameras can report images or videos captured by it.

Purposes and Legal Basis for Processing Personal Data

The purpose for which we may process information about you is as follows:

• Provide you services: We process your account and profile data, device information, usage data, location information and information related to the Smart Device to provide you with our products and services that you have requested or purchased. The legal basis for this processing is to perform our contract with you in accordance with our Terms of Use.
• Improve our services: We process your device information, usage data, location information and information related to the Smart Device to ensure the functions and security of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations and to prevent and track data from fraudulent or inappropriate use. The legal basis for this processing is to perform our contract with you in accordance with our Terms of Use.
• Communication without marketing purposes: We process your Personal Data to send you important information about the Services, changes to our terms, conditions and policies and/or other administrative information. Because this information may be important, you cannot opt out of receiving such communications. The legal basis for this processing is to perform our contract with you in accordance with our Terms of Use.
• Communication for marketing purposes: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do, each communication we send you will contain instructions that will allow you not to receive future communications of this nature. The legal basis for this processing is your consent. In addition, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.
• Personalization: We may process your account and profile data, usage data, device information to customize the product design and provide customized services to you, recommend and display information and advertisements related to suitable products to you and invite you to participate in surveys related to the use of our Products. The legal basis for this processing is your consent.
• Legal compliance: We may process your Personal Data as we believe is necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, security or property; and/or other users, including you; and (g) to enable us to seek available solutions or limit the damage we may suffer.

If there is any change in the purposes of processing your Personal Data, we will inform you of this change by email and/or through a prominent notice on our website about such changes and the choices you may have regarding your Personal Data.

Who do We Share Personal Data With?

At THOLZ, we only share Personal Data so that we can warn you. We may share your Personal Data with the following recipients:

• With our third-party service providers who perform certain business-related functions such as website hosting, data analysis, payment processing and credit cards, providing infrastructure, IT services, customer service, email delivery services and other similar services to enable them to provide services to us.
• With our customers and other business partners who provide you, directly or indirectly, with your Mobile Devices and/or networks and systems through which you access and use our Sites and Services.
• With an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposal of any or all of our business, assets or shares (including, without limitation, with respect to any bankruptcy or proceeding). In such case, you will be notified by email and/or a prominent notice on our website about any change in ownership, incompatible new uses of your Personal Data and choices you may have regarding such Personal Data.
• How we believe it is necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and governmental authorities, including public and government authorities outside their country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, security or property, and / or other users, including you; and (g) to enable us to seek available solutions or limit the damage we may suffer.
• With subsidiaries or affiliates within our corporate structure to carry out regular business activities.

Except with the third parties described above, with third parties only with your consent.

International Transfer of Collected Information

To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from laws applicable to your country of residence. When we do so, we will ensure that an adequate level of information protection is provided by using one or more of the following approaches contained in the agreement based on standard contractual clauses approved by the European Union, in accordance with the GDPR, Art. 46.

If you would like more details about the safeguards we have in place, you can contact us directly as described in this Privacy Policy.

Your Rights Related to Your Personal Data

We respect your rights and control over your Personal Data. You may exercise any of the following rights:

• Through "I > Personal Center > Account and Security" or through "I > FAQ and feedback" on our Products (for Product version 1.0 and later)
• By sending us an email at suporte@tholz.com.br (for Product version 1.0 and later).

You do not have to pay any fees to assert your personal rights. According to different data protection laws, your request for personal rights will be treated in accordance with Law 13.709/2018 - General Data Protection Law (LGPD).

If you decide to email us at your request, please make it clear what information you would like to change, whether you would like to have your Personal Data deleted from our database, or tell us what limitations you would like to put on our use of Personal Data.

Please note that we may ask you to confirm your identity before taking further action on your request for security reasons.

You can:

• Request access to the Personal Data we process about you;
• Request that we correct inaccurate or incomplete Personal Data about you;
• Request the deletion of Personal Data about you;
• Request restrictions, temporarily or permanently, on the processing of some or all Personal Data about you;
• Request the transfer of Personal Data to you or to third parties, where we process the data based on your consent or through a contract and where our processing is automated;
• Not wanting or refusing our use of Personal Data about you, where our use is based on your consent or our legitimate interests.

Any request, complaint, request for information or exercise of rights of the holder can be made by written message to the address Santo Inácio de Loyola Street, 70, Centro, Campo Bom – RS, 93700-000, Brazil, containing at least the following information and documents:

1. Full name of the applicant;
2. Applicant's ID and CPF numbers;
3. E-mail address used for registration on the Platform;
4. Copy of RG and CPF;
5. Description of the request.

Eventually, other information or documents may be requested to meet the request, if there is doubt about the veracity of the information provided or the identity of the applicant.

About account deletion: You will find the Delete function in "I > Personal Center (Portrait) > Account and Security > Delete Account".

Security

We use commercially reasonable physical, administrative and technical safeguards to preserve the integrity and security of your Personal Data. THOLZ provides various security strategies to effectively ensure the security of users and device data. As for device access, THOLZ’s proprietary algorithms are employed to ensure data isolation, access authentication and authorization request. As for data communication, communications using security algorithms and encryption protocols for transmission and transmission of commercial-grade information encryption based on dynamic keys are supported. As for data processing, rigorous data filtering and validation and complete data auditing are applied. As for data storage, all users' sensitive information will be securely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you may have with us has been compromised), you must immediately notify us about the problem by sending an email to suporte@tholz.com.br.

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature and sensitivity of your Personal Data and after the end of the retention period, that data will be destroyed. Where we are unable to do so for technical reasons, we will ensure that appropriate measures are taken to prevent any further use of your Personal Data.

Changes to This Privacy Policy

We may update this Privacy Policy at least annually to reflect changes in our information practices. If we make material changes, we will notify you by email (send to the email address specified in your account) or through a notice in the mobile apps before the change takes effect. We encourage you to periodically review this page for the latest information about our privacy practices.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

THOLZ SMART HOME

Postal Address: Santo Inácio de Loyola Street, 70, Centro, Campo Bom – RS, 93700-000, Brazil.

E-mail: suporte@tholz.com.br