Types of Information Collected and Purposes for Collection and Use
Personal Information. This means any information that relates to you, where you are identified or identifiable (either from that information alone, or other information that we hold) which may include your name, address, email address, phone number, any ID number or location data, and in some cases IP addresses.
Aggregated Information. When information is aggregated, it is added to other information about other customers and users. Where information is sufficiently aggregated, it may become anonymized.
Anonymized Information. When information is anonymized, it is converted into a form which means it can no longer be used to identify you. This may be done by removing data, or by other means. Once information is anonymized, is it is no longer considered Personal Information under applicable data protection and privacy laws.
Children’s Personal Information. We do not knowingly collect Personal Information of persons under the age where such collection is permitted. If we are informed that we have collected the Personal Information of a child under the age of majority, we will delete that Personal Information from our systems. If you believe we might have inadvertently collected Personal Information from or about a child under the age of majority, please contact us here.
We collect Personal Information directly from you, and in some cases from third parties. We also collect Personal Information automatically from you, related to your use of our Services and interactions with us. Below, we have identified the types of Personal Information we collect as well as the purposes for collecting and processing your Personal Information. These are set out below together with the legal basis we rely on in each case under GDPR and UK GDPR, to the extent that these laws apply to our collection of your Personal Information depending on your country of residence. In some instances, we have noted where Personal Information is required for the functionality of your product or for us to provide a particular service.
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Purpose |
Categories of Data |
Legal Basis |
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1) Registering your Eeun product or account and maintaining your account with us |
We collect contact information when you create an account and/or register your product. It will include an email address and may also include your name and postal address. We also collect information relating to the actions that you perform while logged into your account. |
We use this information to take steps at your request to enter into, and perform, our contract with you in connection with the Eeun product you have purchased, and also to notify you about changes to our terms, conditions and policies. |
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2) Managing the business relationship with our Customer, Partner and Supplier |
We collect the name, and business contact information (e.g. email address, phone numbers), of the employee of our B2B customers, partners, suppliers with whom we may interact. |
We use Customer, Partner and Supplier Information to comply with tax, financial reporting and other legal requirements, in particular in order to conduct billing activities. Also, we use Customer, Partner, and Supplier Information in order to contact our B2B clients, suppliers, and business partners. We also communicate with them to conduct projects and provide services, as necessary processing to take steps to enter into and perform our contract with them. |
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3) Cookies and first party tracking |
We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information. |
We have a legitimate interest in making our website function and operate efficiently, for example, to support users to log in or fill out forms. |
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4) Conducting behavioural advertising |
We participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policy for more information. We also use cookies and other web tools for data and statistical analysis. |
Where required by law, we obtain your consent prior to collecting personal data using any cookies or other tracking technologies which are not essential for the service provided by our websites or apps. |
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5) Managing your participation in our competitions, sweepstakes or contests |
We collect information such as name, email address, age and in certain circumstances, physical address, that you provide as part of entering one competitions managed by us. When you participate in a sweepstake or contest, we collect information about you, including contact information to notify you if you are selected and to add your name to a winners list. |
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6) Providing customer support |
If you report a problem or contact us for support, we will collect your name, phone number and email address. If you need to return your product, we will collect your physical address and sometimes your credit card number, as well as any other content that you send to us, in order for us to provide support. |
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7) Measuring email interconnectivity |
If you receive emails from us, we use certain tools to capture data related to when you open our message, click on any links or banners contained in the email, or if you make a purchase. |
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8) Customer satisfaction (feedback, customer / technical support and social media) |
If you provide us with feedback or interact with us via one of our customer / technical support channels (‘Live Chat’ agent / chatbot or telephone), or on one of our social media sites, we will collect your name and email address, as well as any other content that you send to us, in order to reply to you and to develop new products and improve current ones. |
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9) Sending you notifications, updates and other service messages |
We will use your contact information to provide you with service messages, including updates about your order, changes to our terms and conditions, and notifications where you leave items in your shopping cart. |
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10) Conducting direct marketing activities, and sharing your Personal Information with third parties for marketing purposes |
When you sign up for one of our marketing lists, we collect your email address and possibly your postal address or phone number. |
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11) Managing your Order Placement and Purchase |
We collect your name, billing address, shipping address, email address, phone number, and credit card number when you place an order on one of our e-commerce sites. |
We use your information to perform our contract to provide you with products or services. |
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12) Conducting surveys to understand your expectations and improve our products and services |
When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider on our behalf, the third party’s privacy policy applies to the collection, use, and disclosure of your information. |
Only when this is authorized by applicable laws, when we have a legitimate interest in understanding your opinions and collecting information relevant to our organization. |
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13) Personalizing the Services |
We use cookies and other tracking technologies and device identifiers to determine your general geographic locations and preference settings in order to personalize the services and optimize your user experience. |
With your consent, we may tailor content we send or display on our websites and other Services (e.g., for your geographic area), to offer your personalized help and instructions, and otherwise to personalize your experiences with the Services. |
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14) Website interactions, logs and analytics |
We use technology to monitor how you interact with our website. This may include noting which links you click on, information that you type into our online forms, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. This may also include information about your device or browser, such as browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, language preferences and/or a date/time stamp for visitors. |
Where required by law, we obtain your consent prior to collecting Personal Information using any cookies or other tracking technologies which are not essential for the service provided by our websites or apps. Where exceptions to the consent requirement apply, we have a legitimate interest in:
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15) Ensuring our compliance with legislation and legal process |
We might use some information such as the information related to your order and purchase. |
We have a necessity to comply with our legal obligations such as providing information in the context of our tax and financial legal obligations. |
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16) Establishing our rights or defend ourselves against any dispute that may arise. |
All the personal information that you might provide to us during your interaction with us or that we may have collected indirectly. |
We have a legitimate interest to ascertain, exercise and / or defend our rights and ensure our business continuity. |
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17) Transferring of your personal data in case of merger, acquisition, restructuring or sale of our business. |
All the personal information that you might provide to us during your interaction with us or that we may have collected indirectly. |
We have a legitimate interest to develop our business activities, which may result in the transfer of all or part of your personal data. |
In addition to the information that we collect from you directly, we may also receive information about you from other third-party sources, including third parties, business partners, our affiliates, outsourced customer service providers, retailers of Eeun products or publicly available sources. When you provide Personal Information to us, we will only use your Personal Information for the purposes set out in this Privacy Policy, and any notification provided to you at the time of collection. Where permitted by applicable law, other compatible purposes of processing may also be used.
Where we process your Personal Information to perform a contract with you or to comply with a legal obligation, the provision of your Personal Information is compulsory so far as it is either a contractual or statutory requirement, or a requirement necessary to enter into a contract. In such cases, provision of your Personal Information is mandatory since it would not otherwise be possible to enter and perform our contract with you, or to comply with our legal obligations.
However, in the case of processing of your Personal Information based on your consent, you can at any time withdraw the consent you previously provided. You can also object to the processing based on our legitimate interest where that is the basis for our processing, in either case by contacting us. No further data processing will be carried out by us, except where we have compelling legitimate grounds for the processing or we need the Personal Information for the establishment, exercise or defence of legal claims.
Information Collected Automatically. We may collect personal data about how you use our services and your interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the services. We use cookies, log files, pixel tags and other technologies to automatically collect information when users access or use our services, such as IP address, general location information, domain name, browser type, device type, device ID, internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. We may also collect or derive location information about you, such as through your IP address. We also collect activity information related to your use of our Sites and Services, such as information regarding what pages you accessed and when, the date and time of your visit, the links clicked, searches, features used, items viewed, and time spent within the services. We may also use pixels in HTML emails to understand if individuals read or open the emails which we send to you.
Disclosing Information
Where it is a legal requirement in your location, we will only disclose your Personal Information to third parties for our marketing purposes if you have granted us permission to do so, and in accordance with the Marketing section below.
We disclose Personal Information in the following ways:
- within Eeun's corporate group, including with our subsidiaries, affiliated companies and divisions. For example, for efficiencies across the group in data storage, and because certain service providers may be contracted to a particular group company. As such, any of the above entities may use your Personal Information in accordance with this Privacy Policy;
- to Eeun’s service providers, for example, cloud service providers. Our service providers are not allowed to use, disclose, or retain your Personal Information except as permitted by us;
- to service providers, advisors or other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of our assets. If Eeun merges with, acquires, or is acquired by another entity, Personal Information will normally be transferred to the successor entity;
- to comply with the law or legal process (such as responding to subpoenas or court orders or regulator requests), to comply with government reporting obligations and to exercise our legal rights or defend against legal claims;
- to protect our legal rights or those of others, such as protecting the Eeun brand or investigating violations of Eeun terms of use, violations of law, intellectual property infringement, misuse of Eeun websites, fraud or potential threats to personal safety; and
- with other third parties with your consent. Please note that if you consent to the disclosure of your Personal Information to a third party, that third party will apply its own privacy practices. You should carefully review the privacy notice of any third party before providing them with your Personal Information.
In addition, we share anonymized information, including usage data about Eeun products, with third parties and service providers for a variety of purposes, including to analyze trends about home networking and utility use, and to show third parties how their products could work with Eeun products.
We may provide the opportunity for you to connect and interface some of our products with one or more third party products and services, which will involve the provision of information from your Eeun or Wemo product to the third party product or service. This occurs, for example, when you use a Eeun smart speaker which is connected to the Amazon Alexa Voice Service or Google Assistant. In these cases, if you purchase, use or download a third party product or service that connects to a Eeun product, your Personal Information may also be collected by that third party, and their use of your Personal Information will be addressed by the third party's privacy policy. We are not responsible for the privacy practices of such third parties, and we encourage you to carefully read their privacy policies.
Marketing
You have the right to ask us not to process your Personal Information for marketing purposes, by either withdrawing your consent or opting out from receiving marketing communications. Where it is a legal requirement in your location, we will inform you before collecting your Personal Information, if we intend to use your Personal Information for marketing purposes, or if we intend to disclose your Personal Information to any third party for marketing purposes.
We will give you choices about your Personal Information. Some choices are presented up front in the form of opt-in notices or acceptance boxes relating to marketing to you or disclosing your Personal Information with third parties. You will always have the choice to opt out later if you change your mind. One form of opt-out is clicking the Unsubscribe link in a marketing email. This will remove you from our marketing email list. Please note that these opt-in/opt-out choices do not apply to the receipt of mandatory transactional website, service or software communications, such as update or downtime information. They also do not apply to or receipt of order or shipping confirmations on Eeun website stores, which you may receive periodically as part of Eeun performing its contract with you, unless you cancel your service or order or terminate use of software in accordance with the applicable terms of use or license agreement.
If you do not wish to receive direct marketing materials from us or a third party on our behalf, in addition to following the "Unsubscribe" instructions in a marketing email.
Where We Store Your Information
The Personal Information that we collect from you may be transferred to, and stored at, various locations globally, in particular the United States where Eeun is headquartered. It may also be processed by Eeun staff or contractors operating outside of your state, territory, province, or country of residence or region who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We also use cloud-based applications and services to store and process your Personal Information, which may result in your Personal Information being stored outside of your state, territory, province, or country of residence or region.
Subject to the requirements of applicable local law, we implement policies and processes designed to ensure a globally consistent level of protection for Personal Information within Eeun.
In addition, where required by law we implement appropriate safeguards to protect your Personal Information when it is transferred internationally, whether within the Eeun group or to third party service providers. If you are resident in:
- The EEA - this may include (i) our entering into standard contractual clauses approved by the European Commission with the party outside the EEA or (ii) entering into Eeun’s Intra Group Data Transfer Agreement; or
- the UK - this may include our entering into the UK international data transfer agreement or addendum issued by the UK Information Commissioner, including in the form of Eeun’s Intra Group Data Transfer Agreement,
- In each case – our implementing supplementary measures (contractual, technical, or organizational) as may be required further to a transfer impact assessment, notably to mitigate any risk of interference by public authorities of third countries.
Data protection standards in countries where we transfer, process and store your Personal Information may be different from those in your country, but Eeun will make sure that an equivalent level of protection to the one in the EEA/UK or your territory or province of residence in Canada is guaranteed by implementing supplementary security measures.
To the extent provided by the applicable law, you have a right to contact us for more information about the safeguards we have put in place to ensure an adequate protection of your Personal Information when it is transferred as mentioned above.
Accessing and Updating Your Personal Information
Please notify us of any changes to your Personal Information so that we can keep it accurate and up to date. You can access and update your Personal Information and communication preferences at any time in the following ways:
- by clicking the "Unsubscribe" link in any email you receive from us;
Your Rights in relation to your Personal Information
Depending on applicable data protection and privacy laws in your location, you may have rights in relation to your Personal Information. Subject to applicable exceptions, these include rights to:
- Right of rectification: correct your Personal Information if it is inaccurate or incomplete;
- Right of portability: transfer Personal Information which you have provided to us, to a third party if we are processing that data either on the basis of your consent or to perform a contract with you;
- Right of erasure: delete your Personal Information, unless we are required to retain it by law, or to establish, exercise or defend legal claims, or for another one of our business purposes, such as performing a contract or fulfilling a warranty;
- Right of access: get access to and / or receive a copy of your Personal Information as well as information about our processing of your Personal Information. Where permitted by applicable law, if you are outside the EEA, UK or California, we may make a reasonable charge if records must be accessed from backed up or archived records;
- Right to withdraw consent: withdraw your consent to our processing of your Personal Information at any time after you have consented, including opting-out of receiving marketing materials. The easiest way to do this is by clicking the "Unsubscribe" link in any email you receive from us;
- Right of restriction: restrict our processing of your Personal Information if you think that the data is inaccurate, our processing is unlawful, or that we no longer need to process your data for a particular purpose (unless we are not able to delete the data due to a legal or other obligation); and/or
- Right to object: object to our processing of your Personal Information on grounds relating to your particular situation, where the legal justification for our processing of your Personal Information is our legitimate interest. We will abide by your request unless we consider that we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise or defend legal claims;
- Digital legacy: If you are a French resident, you have the right to set out instructions (general or specific) about what happens to your Personal Information after your death.
Please address written requests and questions about your rights to privacy@eeun.com.
We will respond to your request promptly upon receipt. If you are in the EEA or UK, this will be within one month of receipt, or, if further time is required, we will inform you of this and the reason for the delay. If we cannot be sure of your identity, we may ask you to verify your identity before we can act on your request. We may conduct identity verification by phone call or by email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission that you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf. If we do not receive this information, the request will be denied.
If your Personal Information has been disclosed to a third party in accordance with this Privacy Policy, we will take reasonable steps to notify the third party of any updated information you provide to us.
Depending on applicable law, you may also have the right to lodge a complaint with your local data protection authority, if you believe that we have not complied with applicable data protection laws. For example, please click here for a list of contact details for the EEA data protection authorities. The UK’s data protection authority is the Information Commissioner’s Office.
Retention of Personal Information
As a general rule, we will only retain your Personal Information to fulfil the purposes for which it was collected, as required for legitimate business purposes as described in this Privacy Policy, or otherwise permitted by law. When we no longer need to use Personal Information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.
Reasons for retaining your Personal Information include:
- Needing to respond to customer complaints and queries, for example regarding orders, products and customer service;
- Defending Eeun against legal claims, in accordance with limitation periods under applicable law; and
- Complying with legal obligations to preserve documents, e.g., retaining evidence of customer sales for tax or accounting law purposes.
Eeun maintains a record retention policy that defines retention periods applicable within the business from time to time.
Cookies, Web Beacons and Other Web Tools
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Sites and Services. We may combine this “usage data” with other personal data we collect about you.
To learn more about how we use cookies, web beacons, pixel tags and other web tools, and how to control which cookies, web beacons and other web tools are used, please see our CookiePolicy.
Advertising and Targeting
We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising on our websites and services, as well as to manage our advertising on third-party sites, mobile apps, and online services. We and these third-party ad companies may use cookies, pixel tags, and other tools to collect activity information on our sites (as well as on third-party sites and services), as well as IP address, location information, device ID, cookie and advertising IDs, and other identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content on our sites and on third-party sites and apps, and to evaluate the success of such ads and content.
You can review and manage your cookie preferences for our sites and opt in or out of certain cookies, including targeting cookies and tags on our sites, either by editing your browser settings or by reviewing and changing your preferences by adjusting your preferences through our cookie preference manager. This can be done here or by clicking the “Privacy Choices” link in the footer of our sites. Cookie preferences are browser and device specific, which means that you need to set the preference for each browser and device you use to access our sites. In addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us, they may just be less relevant to you. For more information, see our Cookie Policy.
Security
We strive to maintain appropriate administrative, technical, and physical safeguards designed to protect the information collected by Eeun websites and Eeun products, although unfortunately the transmission of information via the Internet is not 100% secure. In the event that we are required by law to inform you of a breach to your Personal Information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. It is important to note that if you use a computer or device that can be accessed by others, other people may be able to access unencrypted Personal Information. If you do not want your information to be available to others, exercise caution when using public computers or devices or when using any computer or device to which users unauthorized by you may have access. We recommend that you take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of letters, numbers and other characters when creating passwords, and make sure you use a secure browser. You should also be aware that names that you give your devices (also known as “friendly names”) may be detectable by others outside your home, so you should not use Personal Information as part of your friendly names.
Third Party and Social Media Linked Sites
Eeun websites and online services may contain links to websites or online services operated by third parties. As explained under “Disclosing Information” above, Eeun products may also use or offer products and services provided by third parties, such as a third party app that works with a Eeun Product. Once you leave Eeun websites and Eeun products, your activities are governed by the terms of use and privacy policies of the third party websites and online services. We are not responsible for the privacy practices or the content of these websites and online services, and we encourage you to carefully read the terms of use and privacy policies of any website and online service you visit.
Eeun websites may contain social media features, such as Facebook “Like” buttons. These features may collect certain Personal Information about you, such as your device’s IP address, device identifiers, set cookies to facilitate interaction with social media features or link you to a social media website where you may post Personal Information. All interactions with social media features are governed by the privacy policy of the third-party company providing the feature.
Updates to this Privacy Policy
We may update this Privacy Policy from time to time, so please review it frequently. If we change our Privacy Policy, we will post the revised version here, with an updated revision date. If we make changes to our Privacy Policy that materially affect our processing of the Personal Information which we have previously collected from you, we will notify you by email or by prominently posting a notice on this website.
How to Contact Us
Should you have any privacy-related questions or comments related to this Privacy Policy, please contact us here.
If you have complaints or concerns about this Privacy Policy, please contact us at privacy@eeun.net. We treat all complaints about a breach of privacy laws seriously. Someone from Eeun will investigate your complaint and respond to you within a reasonable time.