This Policy
This Policy is issued by "www.honeywellsmartlighting.com" (together, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Site, or recipients of any of our other products, services, personnel of corporate customers and vendors, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (T) below.
Except for specific products or services that provide independent privacy policies, this Privacy Policy applies to the whole website. This Policy is a general privacy policy which outlines how we collect, use, disclose, process, and protect information provided to us or collected by us when using our products or services located on our website. If a specific product or service has a separate privacy policy, that policy will take precedence. Any parts not covered by the separate privacy policy will be governed by this Privacy Policy. Additionally, depending on factors such as the device model you are using, service version or location, how specific products or services collect and process your Personal Data or Personal Information may differ. You should refer to the separate privacy policy for detailed information.
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account). We encourage you to periodically review this page for the latest information on our privacy practices.
You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects under the GDPR are explained in Section (K) below. Similarly, U.S. residents in general and California residents in particular may find information on their rights as a Consumer in Section (Q) below.
Intended Audience: Our Site, products, or services are not directed to children under the age of 13. As a result, our Site, products, or services do not request or knowingly collect Personal Data from individuals under the age of 13. If you are not 13 or older, you should not visit or use our Site, products, or services .
 
List of Contents
A. Collection of Personal Data
B. Creation of Personal Data
C. Categories of Personal Data we Process
D. Purposes of Processing and legal bases for Processing
E. Disclosure of Personal Data to third parties
F. International transfer of Personal Data
G. Data security
H. Data accuracy
I. Data minimization
J. Data retention
K. Your legal rights
L. Terms of Service
M. Direct marketing

N. Business information
O. Analytics and Tailored Advertising
P. Do Not Track
Q. California Consumer Privacy Act Disclosures
R. California’s “Shine the Light” Law
S. Contact Us or Lodge a complaint
T. Definitions
 

(A) Collection of Personal Data

We collect or obtain Personal Data about you from the following sources:

(B) Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us.

(C) Categories of Personal Data We Process

When you register your account on our Site, we may process the following categories of Personal Data about you:
After successfully creating your account, you can use it to log in this site When using our Site, products or services, we may also process the following categories of Personal Data about you:

(D) Purposes of Processing and legal bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
Processing activity
Legal basis for Processing
  • Provision of Site: providing our Site; providing promotional items upon request; and communicating with you in relation to the Site.
 
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Site (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Operating our business: operating and managing our Site; providing content to you; displaying advertising and other information to you; analyzing trends, usage, and activities; communicating and interacting with you via our Site, or develop and display content, features, and advertising tailored to your interests on our services as well as on other platforms and services; and notifying you of changes to our Site-.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Site, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Site for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the safety, and proper use, of our products (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Financial management: sales; finance; corporate audit; and vendor management.
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Surveys: engaging with you for the purposes of obtaining your views on our Site.
  • We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Security: physical security of our premises (including records of visits to our premises).
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Legal compliance:compliance with our legal and regulatory obligations under applicable law.
  • The Processing is necessary for compliance with a legal obligation.
  • Fraud prevention: Detecting, preventing and investigating fraud, breach of policies or terms, and threats or harm.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.
  • The Processing is necessary for compliance with a legal obligation;
  • We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • The Processing is necessary for the establishment, exercise or defence of legal claims.

(E) Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within Huo Ming Technology Guangdong Co., Ltd (Honeywell authorized licensee and the operator of this Site), for legitimate business purposes and the operation of our Site to you, in accordance with applicable law. In addition, we disclose Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(F) International transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within Huo Ming Technology Guangdong Co., Ltd (Honeywell authorized licensee), and to third parties as noted in Section (E) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located, including China, the EEA, the UK, and the US.
If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses and International data transfer agreement.

(G) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(H) Data accuracy

We take every reasonable step to ensure that:
From time to time we may ask you to confirm the accuracy of your Personal Data.

(I) Data minimization

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

(J) Data retention

We take every reasonable step to ensure that your Personal Data is only processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:
  1. we will retain Personal Data in a form that permits identification only for as long as:
(a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or
(b) your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),
  1. the duration of:
(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),
  1. in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

(K) Your privacy rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
  • the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
  • the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

(L) Terms of Service

All use of our Site or services is subject to our Terms of Service. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

(M) Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Site that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Site, products, or services. If we provide Site to you, we may send or display information to you regarding our Site, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Site, products, or services you have requested.
You may unsubscribe from our promotional text list at any time by replying T via text message. After you unsubscribe, we will not send you further text message, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Site, products, or services you have requested.

(N) Business information

Business information – In the course of using our Site, we may ask you to provide business information related to the company where you work. Business information may include information about your company’s practices, policies, processes, and supporting documentation. This business information is stored on our systems, and we use it to provide the solutions you have contracted us to provide and in accordance with the terms and conditions set forth in agreements between us and your company,

(O) Analytics and Tailored Advertising

We use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.
Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. With respect to our web services you can stop all collection of information via a web service by not using that web service. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

(P) Do Not Track

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.

(Q) California Consumer Privacy Act Disclosures

Under the California Consumer Privacy Act (“CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents (“Consumers”). Consumers are also afforded additional rights with regard to the Personal Information we collect about them that include the rights of access, deletion, and to be free from discrimination. This section of our Privacy Policy includes the disclosures required by the CCPA and Section (R) below describes the rights afforded to Consumers. We also describe the methods by which a Consumer may exercise these rights and some of the statutory exceptions that may apply.

Categories of Sources of Personal Information

We collect or obtain Personal Information about you on our Website from the following sources:

Disclosure of Personal Information

Our use of online tracking technologies may be considered a “sale” / “sharing” under California law and you have the right to opt out of these disclosures. Visitors to our US website can opt out of being tracked by these third parties by clicking the “Do Not Sell My Personal Information” link at the bottom of our website. We do not knowingly sell or share (for cross-context behavioral advertising) the Personal Information of consumers under 16 years of age. In the preceding 12 months, we have disclosed the following categories of Personal Information to the following categories of recipients:
Categories of Recipients Categories of Personal Information
Advertising networks, data analytics providers. · Personal Identifiers
Internet Service Providers · Personal Identifiers; and
· Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e)
Vendors who may need access to your personal information to help us provide our services · Personal Identifiers; and
· Categories of personal information; enumerated in Cal. Civ. Code § 1798.80(e)
· Internet or other electronic network activity information
· Commercial Information
Payment processors · Personal Identifiers; and
· Categories of personal information; enumerated in Cal. Civ. Code § 1798.80(e)
· Internet or other electronic network activity information
· Commercial Information
The purposes for which we disclose personal information are described in more detail in Section (E) above.

Consumer Rights under the California Consumer Privacy Act

If you are a Consumer, the CCPA grants you the following rights regarding your Personal Information. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information.

Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:
Verifiable consumer requests to know may be submitted through the following method:

Right to Request Deletion of Personal Information.

Consumers have the right to request that we delete any Personal Information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the Personal Information in order to:
Verifiable consumer requests to delete may be submitted through the following method:

Right to Non-Discrimination.

Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:
  1. Deny you goods or services.
  2. Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level of quality of goods or services.
  4. Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services. 

Notice of Financial Incentive.

We do not offer financial incentives or price or service differences to consumers who provide Personal Information.

Authorized Agent.

Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

(R) California’s “Shine the Light” Law

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this Policy, please submit a written request to support@honeywellsmartlighting.com.

(S) Contact Us or lodge a complaint

If you have questions or concerns with respect to our Privacy Policy or Practices, please read this Policy first. For additional questions, you may contact us at support@honeywellsmartlighting.com. Please note that we take your satisfaction very seriously. Should you have a complaint, please also direct it to the same email address and we will respond to you as soon as we can. You can of course also lodge a complaint with the data protection authority of the country in which you live.

(T) Definitions

The business transfers to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business provided that information is used or shared consistently with Sections 1798.110 and 1798.115 of the CCPA.