PRIVACY AND COOKIES POLICY
Updated May 22nd, 2018
Key changes from the previous version:
- Updated to meet the GDPR requirements.
Haltian Products Oy (“We” or “Company”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website snowfoxfamily.com and any of its subdomains (our "Website") and register and use our products and services, and our practices for collecting, using, maintaining, protecting, and disclosing that information.
We provide the Snowfox service (“Service”) for the end-user (“You” or “Your”), who utilizes a Snowfox tracker device (“Device”) and mobile applications (“Apps”) to use and access the Service. The Service is linked to the Snowfox cloud (“Cloud”).
Usage of the Service requires registration through the Apps by creating a user account. The data collected during registration and use of the Service, Device and Apps constitutes a register kept for the purpose of maintaining and administering the necessary personal and other information as well as for improving and carrying out the Service.
If you are a resident of European Union, when collecting, saving, using or distributing your personal data, We will comply with the General Data Protection Regulation (GDPR) and the complying national laws.
If you are a resident of Norway, when collecting, saving, using or distributing your personal data, We will comply with the Personal Data Act of 2000 (Lov om behandling av personopplysninger).
The Device is designed to be carried by a child, if You choose to make a child a Trackee. The Trackee child uses the Device solely as a carry-on accessory and not as the Service end-user. When You register for and use the Website, Apps, Device and Service, You consent to Internet-enabled location-based services, including the collection, use and disclosure of Your Trackee child’s information, geo-location, image (if you have provided it), and other information you have provided, to Guardians and our third party affiliates that participate in providing the Service. Those third parties include our Cloud partner, Kii Corp., our customer service provider, Zendesk, and our payment processor, Klarna, all of which may be contacted through us with any inquiries You may have. No one under age 13 may provide any information to or on the Website, Service, Device or the Apps. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
Sources of Data
We collect several types of information from and about users of our Website, Service, Device and Apps, including information:
- by which You and other users may be personally identified, such as name, postal address, email address, telephone number, image, and geo-location ("personal data"); and
- about your internet connection, the equipment you use to access our Website, Service, Device and Apps, and usage details.
Personal data will be collected from You and automatically during registration, as You fill in forms, and when you contact us to report a problem or seek assistance. Details of transactions you carry out through our Website and Apps, and of the fulfillment of your orders, will be also be collected, and you may be required to provide financial information to us or to our business partner before placing an order. Personal data is also collected by Your and the Trackee’s and Guardian’s subsequent use of the Website, Service, Device and Apps.
We also use technologies to do automatic data collection via the Website, Service and Device. Information collected automatically may include usage details, geo-location, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
The Website also uses Google Analytics cookies. We use the free Google Analytics tool (see http://www.google.com/analytics/) to collect and analyze our site's statistics. Google Analytics mainly uses first-party cookies to report on visitor interactions on the Website. No personally identifiable information is collected by the cookies, and they are only used for the statistical collection of data like visits and page hits. Google Analytics’ cookies store IP addresses but we cannot link those addresses to any individual or path through the Website. Google uses the cookies to get information and assess visitors’ use of the Website in the form of statistical reports that we can access. The Google Analytics’ code is incorporated into the Website’s code, which means that our site serves the cookies, but Google has access to the cookies. If you want to stop being tracked by Google Analytics across all websites, go to Google's site at: https://tools.google.com/dlpage/gaoptout. Google Analytics' terms require us to reproduce the following wording in this Policy:
To find out more, you can also read Google's Legal notes for Google Analytics.
We also use Google Remarketing Tag and Facebook Pixel, and allow Your interaction with related social networking services including Facebook and Twitter, all of which may collect personal data about Your usage.
By accessing and using the Website, Service, Device and Apps., You, the Trackee and the Guardian give consent to collect personal data related to the use of the Device(s), Apps and Service linked to Your user account.
How We Use Information Collected About You and the Trackee and Guardian
Phone number and email address
This information is used as a sign-in identifier and to assign the allowed voice call numbers to the Device. Your and the Guardian’s phone numbers, names, and email address, and the phone number of the Device are shared to all Guardians assigned to a specific Device. This is necessary in order to allow Guardians to communicate in case of emergency or for other need for contact between Guardians.
Your and the Guardian’s email address and phone number are used to receive important notifications about the service status. The email address and the phone number are used when We need to inform You about scheduled maintenance breaks, sudden service interruptions, other related technical information about the Service and its use (including notices about ongoing or additional Service, account and subscription features), and to respond to You or a Guardian if You or the Guardian contact us.
Other personal information
Your and the Trackee’s name and avatar image, and any other information you provide about Yourself, Trackee or the Guardians, are stored so that they may be shown in the App for other Guardians and to fulfill any other purpose for which You have provided it. Other than geo-location when the Device is in service, We do not have any other information about the Trackee than what you add: avatar image and/or the nickname of the Tracker. You decide what personal information is stored about the Trackee.
Information necessary to process Your order is collected by our business partner, Klarna, including card issuer information, identification of You and the Device, Your email address, phone number, postal address and Your social security number if you choose to provide it. This information may also be used to enforce our rights arising from any contracts entered into between You and us, including for billing and collection.
Places are geographical areas created by You. A place is a set of coordinates and other parameters that define an area that will trigger location related events when assigned to Device(s) in the Service. Places are visible for guardians to whom You have given access to the Device.
Error reporting and feedback data
Whenever You or a Guardian send us anonymous feedback through the Apps feedback functionality, We will collect the following information:
- Free text (Your feedback)
- Date and time
- Mobile application version
- Device firmware version
- Phone manufacturer and model
- Phone operating system version
If You or a Guardian send us feedback without enabling the anonymous setting, or seek customer service via email through our business partner Zendesk, We and Zendesk will, in addition to previously mentioned items, collect the following information:
- Your account contact information, phone number and email
- List of Devices assigned to Your account
- Device Owner identification
We may also share with You or any Guardian associated with a Device any error reporting or feedback data provided by You or that Guardian in order to resolve any functionality issues.
Information Collected About the Device
Whenever You add a new Device to the Service, it is linked to Your user account. Each Device can have only one Owner. The Owner can assign other users (“Guardians”) to have read-only access to specific Device data and events.
You can assign places to a Device. Places are references to places You have defined under Your user account.
This information is used to allow Guardians to have read-only access to Device specific data and settings, so that they can receive Device events and information. This information also allows them to make voice calls to the Device.
The Device sends its location information and events to the Cloud. This data is displayed in the Apps and used by the Service to create location related events and alerts.
The following information is stored in order to let the App display notifications about button activity:
- timestamp when a short button press was made
- timestamp when a long button press was made.
Voice call information
The Service will store the timestamp and the incoming voice call number from voice calls made to the Device. It also stores whether the call was answered or not, or if it was rejected (not white listed). This data is used to show related information in the Apps.
Device battery level
The Service will store Device battery level information to be shown by the Apps. This information is also used to create battery level notifications and alerts.
Other Device related information
The Service will store the following information so that the related notification can be shown by the Apps and to support Service maintenance:
- timestamp and version of applied software update
- timestamp of when the Device was powered on
- Your application type (iOS or Android) and the application version number
Fault codes and logs
In case the Device makes a reset due to software or hardware error, a log file is stored for error debugging and analysis purposes.
What Are the Security Methods to Protect Your Data
We undertake to use, and to have our business partners and service providers use, commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Any payment transactions will be encrypted by our business partner, Klarna.
The Device uses encrypted communication between the Device and the Service. The Device does not permanently store any user or location history data locally, so Your private data cannot be retrieved from the Device in case the Device is lost or stolen.
The Service uses standard web security provided by our Cloud partner Kii Corp. More information about the Service and the Cloud’s security can be read from http://kii.com
Phone number uses SMS verification to ensure that the account is created by a legitimate person.
We undertake to use commercially reasonable endeavors to keep the Device firmware up-to-date through our automated firmware update method, and the Service up-to-date with software updates to our Cloud and Apps.
The safety and security of Your information also depends on You. Where We have given You (or where You have chosen) a password for access to certain parts of our Website, or to our Service, Apps or Device, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although We do our best to protect Your personal information, We cannot guarantee the security of Your personal information transmitted to our Website or via our Service, Apps or Device. Any transmission of personal information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, Service, Apps or Device.
Who Has Access to Your Data and How Data May Be Distributed
We may disclose aggregated anonymous information about our users without restriction.
A very limited number of our and our business partners’ and contractors’ technical staff have access to Your, the Guardian’s and the Trackee’sdata in case of malfunction, support ticket, or service maintenance. Technical staff having access to such data are bound by confidentiality obligations.
By accessing and using the Service, You, the Guardian and the Trackee give consent that Your and their data may be distributed to and hosted in the Cloud and shared with our Cloud partner. Data belonging to all users, regardless of where they reside, may be distributed to and hosted within the European Union and the European Economic Area.
Your data is not shared to any other internal or external personnel or parties without Your permission. Please note that there can be exceptions based on Your country due to local laws or authorities and that We may be obligated to disclose Your data to authorities or third parties pursuant to applicable law or an order of a regulatory or statutory authority.
We may sell, transfer or otherwise share some or all of our assets, including Your and Trackees’ personal data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Where Is Your Data Hosted
What Are Your Rights and Responsibilities
Name of Personal Data File: The name of the personal data file is the customer data register of the Service.
Right to review: You have a right to review Your personal data collected to our register. Right to review shall be requested by submitting a request to firstname.lastname@example.org.
Right to prohibition: You have a right to prohibit the use of Your personal data for direct advertising, remote sale or other direct marketing as well as for marketing and attitude surveys. Written notice of prohibition shall be submitted to email@example.com.
Right/responsibility to correct incorrect data: You are responsible for updating Your personal data and for securing that the information provided by You is correct at all times. In case of incorrect data You must promptly amend any such incorrect data through Your user account.
Right to be forgotten: You have a right to request for us to erase all Your personal data from all our systems unless it is needed for completing legal or contractual obligations.
When Your Device is unregistered through the Apps, all data collected from the Device is removed from the Service. The resulting state equals to hard factory reset functionality where the Device and its data is reset to its original state. When You delete Your account, all active data under Your account is deleted. After deletion of Your account, however, copies of Your, the Guardian’s and the Trackee’s data may remain stored in our archived files but is only kept for disaster recovery purposes for a limited amount of time.
Controller and Contact Information
Haltian Products Oy
5/2018 | 1.3.0 | EN