TP-Link will be the data controller (ie we are responsible for, and control the processing of, your personal information) and can if you have any questions or concerns, please feel free to contact our Data Protection Manager: firstname.lastname@example.org
(1) TP-Link hardware products (“Products”), (2) website(s) that may be accessed athttps://www.tp-link.com/hu(“Site”), (3) services, including technical support and servicesaccessible through the Site(s) (“Web Apps”), (4) software that may be downloaded to yoursmartphone or tablet to access services (“Mobile Apps”), and (5) subscription services, including services that can be accessed using the Web Apps and Mobile Apps (“SubscriptionServices”). The term “Services” means the Sites, Web Apps, Mobile Apps, and SubscriptionServices, which may be used in conjunction with Products and in other ways provided by TP-Link. Some Products and Services of TP-Link can be used together or in ways thatintegrate with products and services from third parties. When process your data we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018 and we are responsible for that personal information for the purposes of those laws.
This Policy may change at any time as we improve and change our Products/Services. We may notify you by placing a prominent notice on this website. You should check this website frequently for updates. Prior versions of this Policy will be kept in an archive for your review and are accessible here. If you do not agree with the terms of the updated Policy, you must stop using the Products/Services.
2. SOURCES AND CATEGORIES OF INFORMATION WE COLLECT
2.1 Information You Knowingly Provide to Us
The Company gathers certain information about you. Information about you is also used by our affiliated entities and group companies, TP-Link Technologies Co., Ltd. In this notice, references to ‘we’ or ‘us’ means TP-Link and our group companies.
We receive and store the information you knowingly provide to us. The provision of information by you is entirely voluntary. When you register or update your account, make a purchase online, or otherwise interact with the Products/Services (e.g., create your account ID in our websites, use the cloud platform, register for the partner program, apply for jobs, purchase a product and so on), you may provide us personal information such as your name, email address, street address, mobile, home, and work phone numbers, payment information, and account information, such as user ID, password, Product and Service preferences, job title, contact preferences, firmware version, IP address, and MAC address, etc (“Personal Information”). You may also provide other information that potentially could be used to identify you, such as the names and images that you associate with account users, your locations, devices, scenes, device configuration details, demographic information, third-party account credentials, schedules and audio/video recordings. Further, you may upload/share/post on our website or through our Products/Services. For example, you may post information in a public space on our website, such as message boards. As another example, you may choose to upload/share/post audio/video content recorded by your Kasa Cam and stored by Kasa Care.
2.2 Information We Receive from Third-Parties
Some third party services that you choose to integrate with may transmit Personal Information into your account with us. You authorize that such “Third Party Information” is covered under this Policy and we may use it just as we use your Personal Information. This information may include but is not limited to, for example, account credentials, names, avatars, profile information, configuration information, images, and linked users (e.g. friends).
You may also voluntarily provide your personal information to us via third-party service providers that help us operate our Services.
2.3 Information We Collect Automatically
Other information automatically collected may include your IP address, location, mobile device information, operating system, browser type, demographic information, application information, URL information such as click-through paths, identity of pages you interact with, time spent on those pages, and other information associated with how you interact with the pages and Services.
3. LEGAL BASIS FOR PROCESSING
Processing will often take place where it is necessary for the performance of the contract between us, such as when you buy something from us. Processing will sometimes take place based on our legitimate interests. Our legitimate interests may be that we are carrying on or may carry on business with your employer or prospective employer.
There is a limited privacy impact on you, and we think that you will expect that we will process your data in this way. Some processing will take place based on your consent. Where you have given consent to any data processing, you have the right to withdraw that consent at any time.
4. HOW WE USE PERSONAL AND NON-PERSONAL INFORMATION WE COLLECT
During your use of the Products/Services, we may gather personal and non-personal information from our users and will use this information in connection with the Products/Services as follows. We gather information directly from you and also via our websites and other technical systems. These may include, for example, our:
- Information (such as your name, user name and email address, shipment address) that isprovided when you register;
- Information in connection with an account sign-in facility (e.g. log-in and passworddetails);
- Communications sent by you (e.g. via phone call, e-mail, instant messaging systems,social medias or website communication forms);
- Device data (e.g. Device ID, MAC address);
The data will be used as follows:
- to identify you at sign-in;
- to provide you with the Services and information which you request;
- to administer your TP-Link Account;
- to communicate with you by email, phone or by post;
4.1 To Provide Our Products or Services and Contact You
We use personal and non-personal information to: deliver the basic functionality of the Products/Services; carry out the contract between us; provide functionality to certain features that you choose to use; provide live chat support, technical support and hotline services; allow you to create, modify, and view your account information; carry out credit reference checks, comply with legal, regulatory and corporate governance obligations and good practice; ensure business policies are adhered to; for operational reasons, such as recording transactions, training and quality control; ensure the confidentiality of commercially sensitive information; prevent unauthorised access and modifications to systems; analyse purchasing preferences and improve services; and allow you to customize, rate, and review the Products/Services. We may use any means that you have provided us to contact you, such as the email address you use to register for and log in to your account. We may contact you in order to respond to your requests and to provide you information about your account. We may also use personal information to process claims we receive in connection with the Products/Services.
4.2 To Market and Improve Our Products/Services and for Other Legitimate Business Interests
The profile you create on our website helps improve your interaction with our Products/Services. This information allows us to personalize the Products/Services; analyse how you use the Products/Services; and communicate promotional offers, special events, user surveys, and other marketing communications with your consent when this is required under applicable law. In certain cases as described below, we may also share some personal information with third parties for these purposes.
Information may be held at our offices and those of our group companies, service providers, credit reference check agencies, representatives and agents as described above. Information may be transferred internationally to China, the United States of America and other countries around the world, including those without data protection laws equivalent to those in the UK, for the reasons described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our information security and data protection policies, which are available on request. International data transfers outside the European Economic Area are protected by Standard Contractual Clauses. Where appropriate for transfers to the United States, the EU-U.S. Privacy Shield will be used.
See the Your Choices section below for information about how you can opt-out of certain communications.
Your information may be stored in our cloud platform as required to use our Products/Services. We may track your IP address and MAC address to make our cloud platform work more efficiently and provide you with more customized Products/Services.
4.3 To Comply with Applicable Laws and Our Policies
We use personal information to comply with our legal obligations and our policies; establish, exercise or defend a legal claim; protect against, identify and prevent fraud, criminal liability and other liabilities; and monitor and report compliance issues.
5. SHARING YOUR INFORMATION
5.1 Our Corporate Family
We may share the information we collect about you with our corporate family, including our affiliates and subsidiaries.
5.2 Other Entities with Your Consent
Some third-party services that you choose to integrate with the Services may receive personal information from your account. You authorize us to transmit your personal information to third parties when you choose to integrate their services with our Services. Information collected by such third-party services is subject to their own terms and policies.
5.3 Service Providers and Other Third-Parties
Your personal and non-personal information may be provided to our partners for use in their promotional and/or marketing practices. Your personal information will be anonymized so that you will not be personally identifiable by such information.
We may also aggregate the anonymized information and provide it to our partners so they may use it to determine and understand how people interact with and use our Services. We will not disclose aggregated information to a partner in a manner that would identify you personally, as an individual, except as outlined below.
We may engage third-party companies and individuals to perform services on our behalf (e.g., without limitation, software maintenance services, advertising serving technologies, e-mail service providers, delivery services, database management, web analytics and other services). These third parties may have access to your personal information. If they do, this access is provided so that they may perform these tasks on our behalf and they are not authorized by us to otherwise use or disclose your personal information, except to the extent required by law.
5.4 Change of Control
TP-Link may elect to buy or sell assets. When buying or selling assets, customer information may be one of the assets that is transferred. Personal and non-personal information may also be transferred or acquired by a third-party in the event that TP-Link is acquired, enters bankruptcy, or goes through some other change of control.
5.5 Legal and Law Enforcement
Please be advised that we may disclose information that you have provided us if we have a good faith belief that such disclosure is necessary to (a) comply with the law or legal process served on us; or (b) protect and defend the rights and property of TP-Link or others. In any event, we will disclose information only in accordance with applicable regulations.
We have implemented measures, including encryption and SSL technology, designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Your account’s privacy and security is protected by your password. In order to prevent unauthorized access to your account and personal information, you should select a strong password and protect it by limiting access to your computer, device, browser or application and by signing off after you have finished accessing your account. If you use a third-party service to sign into your account, you should protect that account accordingly as well.
While we strive to always protect the privacy of your account and personal information in our records, we cannot always guarantee it will be completely secure. The security of your personal information may be compromised by unauthorized entry, unauthorized use, hardware failure, software failure, and other factors at any time.
7. YOUR RIGHTS
You have a number of important rights, which can be exercised free of charge. You have the right to request:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances.
We will not do anything with your data not outlined in this notice.
If you are not satisfied with any complaint you have with us, you also have the right to make a complaint to the Information Commissioners Office, which is the supervising authority in the UK in relation to data processing. You can contact the Information Commissioner at ico.org.uk/concerns/ or by telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
TP-Link gives you choices in how you receive a variety of information that complements our products and services. You can also contact us to change your privacy preferences. For example, you can control how and when you want to receive notifications from us by following instructions within the notices (e.g., clicking on “unsubscribe” at the bottom of notification emails). You may not opt-out of administrative emails for your registered account (e.g. emails about your transactions, policy changes, forgot password and confirmation emails).
With simple controls in apps and Web management page's 'Privacy settings', you can turn on or off different types of information collection, such as TP-Link Cloud services and Tether usage stats in Tether app (for more information about Tether, please click <a href=”https://www.tp-link.com/us/tether/”>here</a>. Please note that some features may not function with certain privacy settings turned off, and some information (such as the association of your TP-Link Cloud account to your Tether) is stored by TP-Link even if all privacy controls are turned off.
We use both session and persistent tracking technologies. Tracking technologies (e.g. cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Products/Services. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
You may encounter tracking technologies/cookies from our third-party service providers, such as Google Analytics, that we have allowed to assist us with various aspects of our operations and Products/Services.
On certain pages of the website you also may encounter tracking technologies from third-parties that we do not control.
For more information about HTTP cookies and how to disable them, you can consult the information at http://www.networkadvertising.org/choices/ and www.allaboutcookies.org/manage-cookies/.
8. ACCESSING, REVIEWING, AND CHANGING YOUR PERSONALINFORMATION
Using the Products/Services, you can access and edit or remove the personal information you have provided to us. The information you can access through the Products/Services may change as the Products/Services themselves change. When you change information or delete your account we may maintain a copy of the original information in our records for no longer than necessary to fulfil the purposes outlined in this Policy and as permitted under applicable law. Additionally, we may use any anonymized or aggregated data that is derived from your personal information after you update or delete it; however we will not do so in a way that identifies you personally.
9. CHILDREN’S PRIVACY
The Products/Services are directed to a general audience and are not intended for children under the age of 13. We do not knowingly collect personal information via our website or online services from users in this age group. We do not guarantee that our websites are suitable for children. If you believe your child has provided personal information to us, please contact us via the email listed in Section 13 below.
10. RETENTION PERIODS
Your data will be held in accordance with the Company’s retention policy, which is available on request. In general, your data will be stored for the duration of your contractual relationship with us.
11. DIRECT MARKETING
Information relating to you will be used to notify you by post, email or other electronic means of our services and those of our group companies and third party business partners, in particular [identify/specify] in which we believe you may be interested. You can withdraw your consent to use of personal data for marketing at any time by contacting us at email@example.com
12. CONTACT US
If you have any questions that this policy could not answer, or if you require further information on a particular point, please do not hesitate to contact us at any time. You can reach our Data Protection Manager at firstname.lastname@example.org
Effective Date: May 23, 2018.