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Last Updated: August 7, 2018
Effective Date: 07 Aug 2018
The controller of your Personal Data collected via our Neato App according to Art. 4(7) GDPR is Neato Robotics, Inc., 8100 Jarvis Avenue, Newark, California, USA 94560 (“Neato”).
Personal Data is information that identifies you or can be used to identify or contact you (“Personal Data”). Such Personal Data may include your name, address, email address, telephone number, birth date (primarily for eligibility purposes), billing and credit card information.
In order to use all functions of our Neato App you have to register. Therefore, you have to provide your email address, a password and your country as mandatory information.
This data is required to set up and manage a user account for you. We also need this and where necessary other data in order to be able to respond to any queries you may have.
We collect the above data in order to provide you with our Neato App, Art. 6 (1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data you will not be able to use the Neato App.
When you use the Neato App, we automatically receive certain information about your mobile device and use of the application, including a mobile device identifier (IDFA on Apple products like the iPhone and iPad or similar advertising identifiers) and your IP Address, which we require for the transmission of requested content, operating system, version, and other similar information, such as time spent in different portions of the Neato App. Such aggregated information does not allow us to identify you and is used by us to analyse trends, to administer the Neato App, to monitor our Neato App’s use, and to gather general information about the use of our Neato App. When you use the Neato App, we further process information about your location (address) to route you to the right customer support agent and to help you find where you can purchase accessories that will keep your robot running at peak performance and locale (language spoken) in order to localize the messages sent to you. Moreover, we process information about your location to access the list of Wi-Fi networks during our process to connect the robot to Wi-Fi and the cloud/app, to reroute you to closer servers for better experience and for security reasons in order to block and report malicious users.
The legal basis for such processing of your Personal Data are our legitimate interests (Art. 6(1)(f) GDPR) in customizing the content of our services in line with user preferences and in further improving our services.
When you use the Neato App, we process information about your floor plan in order to be able to determine no-go lines, go areas, show maps and other map-related features. In addition, we process information concerning your cleaning schedule in order to provide you with the option to schedule time and date of the cleaning.
Such processing of your Personal Data is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data you will not be able to use our features concerning the floor plan and cleaning schedule.
We process information concerning your cleaning and statistics in order to provide you with information about your historical cleaning runs to see trends and figure out how to fix any issues your robot is having and to gather statistics on the use of current features to impact future enhancements.
Our Neato App uses the following permissions:
Your location may also be required for security reasons in order to block and report malicious users and to route you to the right customer support agent and to help you find where you can purchase accessories that will keep your robot running at peak performance.
We use Crashlytics, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Crashlytics will send us certain technical information about your device and your app installation in case your app crashes. We use such data exclusively to determine the reason for the crash and to correct errors in our app. Basically, such information does not contain Personal Data. However, we cannot exclude the possibility that Personal Data or pseudonymous data may also be collected in the form of meta data.
The use of Crashlytics is based on our legitimate interest in recognizing, investigating and correcting errors in our Neato App and thus being able to offer our Neato App in accordance with the contract and the fact that your legitimate interests do not outweigh, Art. 6 (1)(f) GDPR.
We collect pseudonymous usage statistics about your use of our Neato App using Google Firebase, a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Based on your iOS IDFA or your Android advertising ID, general, non-personal statistics about how and by which user groups our Neato App is used are created.
The use of Firebase Analytics is based on our legitimate interest in a demand-oriented design, the statistical evaluation and the efficient advertising of our Neato App and the fact that your legitimate interests do not outweigh, Art. 6 (1)(f) GDPR.
We will not share, sell, transfer or otherwise disseminate your Personal Data to third parties, unless required by law according to Art. 6(1)(c) GDPR, unless required for the purpose of your contract according to Art. 6(1)(b) GDPR, unless we are allowed to do so on the basis of a data processing agreement according to Art. 28 GDPR or you have given us express consent to do so according to Art. 6(1)(a) GDPR.
We share some of your Personal Data with other Neato companies to the extent necessary for such companies to provide services on our behalf. In particular, we are using other Neato companies to send marketing communication to you if you have given us your consent to do so.
We also use third-party service providers to offer or facilitate services on our behalf and share your Personal Data with such providers to the extent necessary for such providers to perform their services on our behalf. In particular, we use a call center provider to facilitate customer service and a social media agency to manage our social media campaigns.
Some of the companies we share your Personal Data with as described above are located outside of the European Economic Area.
In order to grant sufficient protection of your Personal Data in this context, we use standard data protection clauses adopted by the European Commission according to Art. 46(2)(c) GDPR with such companies or certifications of such companies under the EU-U.S. Privacy Shield according to Art. 45(1) GDPR. You can request further details by contacting us at the contact details as mentioned below.
We may also be required to disclose your Personal Data to government or law enforcement officials in response to a lawful request by a public authority or if we have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements according to Art. 6(1)(c) GDPR. We can also disclose your information in order to pursue our legitimate interest in applying or enforcing our terms and conditions or in responding to any claims, in protecting our rights or the rights of a third party, in protecting the safety of any person or in preventing any illegal activity (including for the purposes of fraud protection and credit risk reduction) according to Art. 6(1)(f) GDPR.
If required under applicable data protection laws, we will collect your prior consent before sharing your Personal Data with other companies. In such cases, the legal basis is Art. 6(1)(a) GDPR.
You have the following rights:
Right of access (Art. 15 GDPR):
You have the right to request confirmation as to whether we process your Personal Data and where that is the case, to request access to the Personal Data we hold about you.
Right to rectification (Art. 16 GDPR):
You have the right to request the correction of inaccurate Personal Data.
Right to erasure (Art. 17 GDPR):
You have the right to request erasure of Personal Data without undue delay under certain circumstances, e.g. if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and where there is no other legal ground for processing.
Right to restriction of processing (Art. 18 GDPR):
You have the right to request us to restrict the processing of your Personal Data under certain circumstances, e.g. if you think that the Personal Data we process about you is incorrect or unlawful.
Right to data portability (Art. 20 GDPR):
Under certain circumstances, you have the right to receive your Personal Data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
Right to object (Art. 21 GDPR):>
You can assert your abovementioned rights by contacting us at the contact details mentioned below.
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at the contact details mentioned below and we will assist you to identify the respective competent supervisory authority.
We store your Personal Data and other information for as long as necessary to enable you to use our Neato App, to provide our services to you, to comply with applicable laws (including those regarding document retention), to resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. If you have a question about a specific retention period for certain types of Personal Data we process about you, please contact us at the contact details mentioned below.
We do not use your Personal Data to make decisions with legal or similar effects for you based on the automated processing of your Personal Data only.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to firstname.lastname@example.org.
We are committed to providing you with meaningful choices about the information collected on our Neato App, and that is also why we provide the opt-out links above. However, we do not recognize or respond to browser-initiated Do-Not-Track signals, because the Internet industry is still working on uniform Do-Not-Track standards.
We do not knowingly collect any Personal Data from anyone under the age of eighteen (18) without parental consent, unless permitted by law. If we learn that a person under the age of eighteen (18) has provided us with Personal Data, we will delete it in accordance with applicable law.
By Email: email@example.com
Or by mailing us at the address below:
Attn.: For the attention of the DPO
Neato Robotics, Inc.
8100 Jarvis Avenue
Newark, California 94560 USA