Privacy policy

Introduction and Scope

This Privacy Statement applies to HeatLink-branded devices and technologies powered by SALUS North America. This statement describes the manner in which SALUS North America, Inc. and SALUS Canada, Inc. (collectively, “SALUS” "we", "us" and "our") use personal information in connection with HeatLink-branded Internet connected and smart home products, devices and equipment (collectively, “Devices” or “Products”) including through the HeatLink Smart Home websites and mobile software applications powered by SALUS (collectively, “App” or “Apps”) that link to this policy. This statement applies to such users in countries in the Americas only. Any reference to “you”, “your”, or “yours” in this privacy notice shall mean the user of the Mobile or Web App and Device.

Any personal information you supply via our Apps or Devices (and by other means described in this Privacy Statement) will be treated in accordance with applicable law.

When you provide personal information about others, you must ensure you have the consent of those individuals to provide the information to us and that we may use it in the ways described in this Privacy Statement.

Account owners must be 18 years old. Our Devices and Apps are not intended for or directed at persons under 13 years of age. SALUS does not knowingly collect, use or disclose personal information from anyone under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will delete such information from our records in accordance with applicable law.

By connecting our Devices to the Internet and using our Apps you are accepting the terms of this Privacy Statement. If you do not agree with this Privacy Statement, then please refrain from downloading and using our Apps, or connecting our Devices to the Internet.

Privacy Contact

If you have any questions or concerns about SALUS’ personal information policies or practices or information contained in this Privacy Statement, please contact our Director, Global Privacy Compliance via email at: dataprotection@salus-tech.com, or by post at:

Director Global Privacy Compliance, SALUS North America, Inc., 850 Main Street, Redwood City, CA 94063, USA.

Information We Collect and Receive

We collect and receive the following types of information:

Information you provide directly. This includes the personal information you enter and submit to register Account or Profile Information on our App, and depending on the App may include:
- First and Last Name
- Email Address
- Password
- Country
- Telephone Number
- Address
- Language
- Unique Device Reference or Identifier
Information we collect or receive when you use the Device or Apps.
- This includes the personal information passively or automatically sent to us when you install and use our Devices and Apps, and depending on the App may include:
  - Unique Device Reference (Device ID) and Device Type
  - IP Address
  - Device Mac Address
  - Device location (if geolocation is activated and enabled through your smart Device or phone)
  - Names you give to your locations or Devices
  - Images of a personal nature that you decide to upload
  - Distance alerts or geo-fencing set up
- This also includes information about Device and App properties and information that will be treated as personal information when combined with Account or Profile Information for as long as it remains combined. This includes:
  - How you use Devices in your home: For example,
    - User behaviour when logging on or using our Devices or Apps;
    - Usage history, including household energy and electricity, patterns and use;
    - Device configuration, settings, and schedules including temperature and if Device is set to vacation mode; and
    - Device status - whether active or disabled (on/off).
  - Performance of the Devices.
  - Device Type, Browser Type, Operating System and Application Version.
- In addition, we may also receive limited information relating to your location because, even when location services is not enabled on a smart Device or phone, the IP address associated with the smart Device, phone or computer may provide an approximate location when you connect to our App.

Some of our Apps offer the functionality to switch off “Data Collection” within the App Settings. Please refer to settings within the App you use. Where Data Collection is switched off this means the App will be automatically disabled and your mobile device or computer cannot be used to manage your equipment or service, and you will also not receive important alerts or notifications.

You may still be able to manage and control most of our Devices manually through the available on-device interface or controls. Please refer to Device User Guide for further instructions.

How We Use the Information We Collect or Receive

We use the information we collect and receive for the following purposes:

To provide services through the Device and Apps. We and our authorized third parties may use personal information in connection with providing the Devices and Apps. For example:
- We and our authorized third parties may use personal information to run the Devices and Apps, including to:
  - Register and activate Devices;
  - Enable you to control your Devices and to view real-time Device settings and status, and to monitor energy usage; and
  - Enable us to perform analytics to diagnose and resolve problems, and to monitor the stability of your Devices.
- We and authorized third parties may use personal information to support the Devices and Apps, and meet contractual obligations, including to:
  - Identify, authenticate and communicate with you to provide technical support, customer services, and assist you with the installation, use or configuration of your Devices and apps;
  - Provide customer service and support to your Device and App, whether remotely or in person; and
  - Address complaints and claims, and process refunds or a product replacement.
To communicate with you. We and our authorized third parties may use personal information to communicate with you, including to:
- Send you servicing communications by email – such as important notices, alerts, scheduled maintenance, updates or changes to our services (as these are important to the safe, secure and effective functioning of connected Devices, you are not able to opt out of receiving these);
- Send you information on new features or functionality of existing products you may own, and information to help you improve the way you use our Devices and Apps, or to request your feedback, including through surveys; and
- Send you email communications containing promotional information on SALUS, HeatLink, and other products, and services. Refer to “Your Communications Choices” below for details on how to update your choices.
To improve the services. We and our authorized third parties may use personal information to:
- Gain a broader understanding of the performance and use of our Devices and Apps over time;
- Personalize the content you see, based on the details given by you and/or your activity on the App;
- Identify, develop and deliver improvements to our services and products, for example to assess and enhance the battery life of Devices, stability of Apps, or identify issues with heating system or Smart Home Device and connections; and
- Provide useful information on how to better utilize your heating, ventilation and cooling systems, and enhance the use of connected Devices and Apps you own.
To protect the Devices, the Apps, and Us. We and our authorized third parties may use personal information to:
- Engage in audits, including to help meet our service standards, improve our service to you, or for training purposes; and
- Investigating any suspected breach of our terms, or otherwise to enforce our rights or the rights of our third party partners.

Our Use of Cookies and Other Technologies

SALUS uses cookies to enable functionality of our Apps and improve the user’s experience. Cookies are small text files which are stored in the memory of your computer or other device such as mobile phones or tablet devices. Cookies are created when you visit a website or load an App using cookies.

We and third parties use cookies to save information about registered users on our Apps such as your username and password, provide secure log in, assess how our Apps are used, and personalize your experience. It may be possible to disable some cookies through your Device or browser settings. Please note, however, that certain features of our Services may not be available if cookies are disabled or deleted.

Cookies are small text files which are stored in the memory of your computer or other device such as mobile phones or tablet devices. Cookies are created when you visit a website or other service that uses cookies (such as our Apps). Cookies are commonly used to improve the user’s experience and provide more information about the user’s experience and behaviour. This information is generally used to make content and services more relevant and useful during future visits.

Other Technologies

We may use other technologies including web beacons and JavaScript that sometimes work together with cookies, and other means within our mobile applications to uniquely identify your device. These other technologies help enable features on our websites and within our mobile applications.

Third Party Technologies

In some cases, content and functionality on the Devices and Apps may be provided by third parties that may collect or receive information about your use of the Services, including through cookies and other technologies. In addition, we and our partners and advertisers on the Devices and Apps may work with other third-party vendors to help deliver advertisements targeted to your interests. These third parties may include ad networks and analytics providers, and they use cookies or other technologies to collect information about your online activity (e.g., the sites and pages you have visited) over time and across different apps and online services in order to help advertisers deliver particular ads that they believe you would find most relevant. Third-party vendors that perform these functions may be members of the Network Advertising Initiative or the Digital Advertising Alliance, and you can opt out of participating vendors’ delivery of targeted advertising to you by visiting those sites at: Network Advertising Initiative, Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

“Do Not Track” Signals

Some web browsers may transmit “do not track” signals to our websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites and online services should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy on responding to these signals.

Sharing of Personal Information

We may share information with the following types of parties:

Our affiliates. We may share information with current and future affiliates, including for administration purposes; the purpose of providing our Devices, Apps and services to you; to better understand your use of our Device and Apps; and provide technical support and other services to you.
Our partners. We may share information with certain third parties including to enable our Apps on different mobile devices and operating systems, and help connect or control our products with other technologies. These include HeatLink and other partners, as well as service providers, data processors, advisors, and companies offering voice controlled personal assistants or other technologies to support control of connected devices, which we may share your information with for purposes including to: provide users with information on similar and relevant products or services; support our IT; provide Internet cloud-based technology solutions; help develop, test, host and manage our Apps and websites; enable control of our devices through other technologies; send communications to our customers; help us analyze the data we hold; help support stable operation of our Apps and connected Devices; back-up and secure data; process payments; provide us with legal advice; and generally help us deliver our products and services to you.
Installers and service engineers. We may provide information to these partners so that they can book appointments with you and provide installation, maintenance services, and any onsite support of our Devices and Apps, or your heating, ventilation and air conditioning (HVAC) systems.
Delivery companies. We may provide information to these partners so that they can deliver any products that you have ordered from us directly or where we need to send out a replacement under warranty.
Market research. Occasionally we may provide information to market researching partners to ask them to contact our customers to help us find out how to improve our products and services.
Other parties in connection with corporate transactions. We may provide your information to third parties in connection with a purchase, merger or transfer, or in the event of a bankruptcy.
Other parties when required by law or as necessary to protect our services. We may disclose your information to other parties in order to:

Comply with the law or respond to legal process (including a search warrant or other court order);
Assist government or our regulators, for example initiatives related to the energy industry;
Verify or enforce compliance with the policies governing our Services; and
Protect the rights, property, or safety of SALUS and HeatLink or any of our respective affiliates, third parties, business partners or customers.

Other parties at your request or with your consent. In addition to the disclosures described in this Privacy Statement, we may share information about you with third parties when you consent to, request, or direct such sharing.

These and other third parties may collect or receive information about your use of our Services, including through the use of cookies, web beacons, and other technologies, and this information may be collected over time and combined with information collected on different websites and online services, including, for example, to deliver ads that are more relevant to you, both on and off our websites. Social networking services may be able to collect information about you, even if you do not click on or interact with their content on our Services or have an account with the social networking service.

International Transfers of Personal Information

We may need to store and share personal information across our teams in countries around the world supporting the Devices and Apps to design, research, develop, engineer, manufacture, sell, distribute, and provide technical support to customers and end users of our Devices and Apps.

Some third-party providers may process personal information on our behalf and these are known as our third-party data processors. We also use third-party data processors located in different geographical locations to help us run our business, provision and support our IT systems, and ensure the stable operating of our Apps and connected Devices. As a result, personal information may be transferred, stored and accessed outside the countries where we and our data processors are located. By submitting your personal information, you agree to this transfer, storing or processing.

To the extent your information is collected or stored in the United States, please note that U.S. privacy laws, regulations, and standards may not be equivalent to the laws in your country of residence and such information may be subject to lawful access by U.S. courts, law enforcement, and governmental authorities. By using our Devices or Apps, or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to, in, and out of the United States.

Security and Retention of Personal Information

We endeavour to apply technical, administrative and physical measures designed to protect the privacy and security of your personal information and to use it in a manner that is consistent with your relationship with us and the practices described in this Privacy Statement. However, we cannot guarantee that your personal information will be completely secure or free from unauthorized access by third parties. You use our services and provide us with your Personal Information at your own risk.

You can help ensure that your contact information and preferences are accurate, complete and current by logging in to your account. For any other Personal Information we maintain, we will consider any access, correction or deletion requests, to the extent we are not required to retain the data by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are impractical, or for which access, correction or deletion is not required by applicable law. Requests can be made by contacting us as directed in the section “Privacy Contact”.

We keep your personal information for as long as is necessary for the purposes for which it is processed. These periods vary depending on the nature of the information and your interactions with us, as required or permitted by law.

Your Communications Choices

When you provide your personal information to us including your contact details we or our authorized third parties may use this information to send you commercial and promotional email communications. You may review and update information you have submitted at any time through the App or Device by updating information in the “profile” section of your App.

You can request to opt out and stop receiving commercial and promotional email communications by:

Requesting to remove your details from the mailing lists associated with the email communication you receive from us or our authorized third parties, via the “Unsubscribe” link or other method for unsubscribing presented in any email communications.
Updating your notification preferences where available via our website or mobile Apps.
Contacting us via the details in the section “Privacy Contact”.

Note, opting out of promotional emails will not end transmission of important service-related emails that are necessary to the on-going use of our services.

Your California Privacy Rights

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year. We comply with this law by giving users the ability to tell us not to share personally identifiable information with third parties for their direct marketing purposes. To make such a request, please contact us as directed in the section “Privacy Contact”. We may need additional information to process your request.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal information, please contact our Data Protection Officer using the contact details in the section “Privacy Contact”.

Changes to This Privacy Statement

Last Updated and Effective Date: June 14, 2018.

From time to time, we may revise this Privacy Statement to reflect changes to the scope of the Services or for other reasons. Therefore, it is important to check the effective date of the Privacy Statement posted here each time you use the Services. If we make any material revisions to this Privacy Statement, we will place the updated Privacy Statement on our website or App or on the Device. By continuing to use the Services after we make changes, you indicate your consent to those changes.