Chipolo Privacy Statement

We, Chipolo, d.o.o. (“we”)have created this privacy statement to demonstrate our firm commitment to the individual’s right to privacy.

We offer object location services to users of our mobile tracking devices (“Chipolo device(s)”), through our website under www.chipolo.com (the “Website”) and/or our Chipolo mobile application (the “Chipolo app”) (collectively referred to as the “Services”). This Privacy Policy describes: the information we collect from users; how we use that information; and your rights in connection with our collection and processing of the information.

 

Consent

By using this Website, you consent to the collection and use of the Personal Information as described below. If we decide to make changes to this Privacy Statement, we will post changes on this site so that you will always know what information we collect, and how we use it. From time to time, as may be required by applicable law, we may also seek your explicit consent to process certain data and information collected on this Website or volunteered by you.

 

Definition of Personal Information

In this Privacy Policy, the term “personal information” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, payment information, such as your credit card or PayPal account, or, in certain circumstances, location information, an IP address or the unique identifier allocated to each Chipolo device.

 

Data Controller

The owner and data controller of your personal information collected, processed, used and stored by the Services and/or the Chipolo device(s) is: Chipolo, d.o.o., Gabrsko 12, 1420 Trbovlje, Slovenia, a limited liability company incorporated under the laws of Republic of Slovenia full member of the European Union.. We can be contacted by email at: [email protected]

 

Location of Storage and Processing of Personal Information

Your personal information is stored and processed in Europe by ourselves and our EU based contractual cloud sub-processors. We are subject to the EU data protection regulation.

 

Personal Information that we Collect

When you register for our Services we will collect and store certain personal information necessary to set up your account with us, such as your first and last name and email address and shipping address. We will further generate, and store with your account, a unique identifier allocated to each Chipolo device that will be registered for your account. Whenever you sign in on your account through the Chipolo app on a mobile device or through our webpage, we will further collect your location information and your Chipolo devices’ location information (provided your Chipolo devices are in reach of the mobile device), as collected and sent by the Chipolo app, and associate such information with your account with us.
In addition, we will collect, and store with your account, detailed location information about your Chipolo device(s) as collected and sent via other users’ mobile devices with an installed and activated Chipolo app; these users will not have access to such information (see Section 6 on “Our Use and Sharing of your Chipolo Device Location Information” below). Likewise, we will collect location information about other users’ Chipolo device(s) tracked and transmitted to us by the Chipolo app on your mobile device (provided the Chipolo app is activated on your mobile device).
Whenever you use our Services, we may further collect additional information about your usage of our Services, including by making use of third party web analysis tools (see Section 11 on “Integration of Third Party Web Analysis Services and Social Functionalities” below), such as your frequency and scope of your use of the Services, the duration of your online sessions, the sites you visit, information you read, content that you use or create, advertisements that you view or click on, your communications with other users and third parties, information about the mobile device on which you have installed the Chipolo app, and the geographic location of the computer system or device that you are using to log-into our Services.
If you decide to interact with a social network when using our Services, we may further collect certain personal information made available through your social network account (see Section 8 on “Your Sharing of your Personal Information with Social Networks” below). We will further collect any personal information you may actively provide to our service personnel if you contact our customer support through our Website and/or Chipolo app.

Payment information needed for you to complete your order on our Website, such as your credit card or PayPal account are not stored on our serves.

 

How we Use and Process your Personal Information

Our Object Location Services

We will use and process

  • your personal information from your registration and usage of our Services (including your location information and your Chipolo devices’ location information) to provide you with our object location services, e.g., to help you track and find your Chipolo devices which are in reach of your mobile device, to remember the last known location of your Chipolo devices, and/or to communicate to you the location of your Chipolo device(s) in reach of other users’ mobile devices;
  • your location information (i.e., the location of your mobile device that has tracked a Chipolo device of another user) to help other users of the Services to find their lost Chipolo device(s) by sending anonymous location updates to those other users when the Chipolo app on your mobile device “finds” their lost Chipolo device(s); (see Section 6 on “Our Use and Sharing of your Chipolo Device location information” for further details on how our service works).

 

Further Uses of your Personal Information

In addition, we may use and process your personal information (including your location information and your Chipolo devices’ location information

  • to provide you with support and handle requests and complaints;
  • to send you updates, notices, and additional information related to the Services;
  • to create anonymous, statistical and aggregated data and reports (i.e., in a form where such data does not enable the identification of a specific user). See Section 9 on “Our Use and Sharing of Aggregated Information” below;
  • to comply with any applicable law and assist law enforcement agencies under any applicable law, when we have a good faith belief that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
  • to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services.

 

Our Use and Sharing of your Chipolo Device Location Information

The Services are based on a community of all users of the Services sharing location information with us. Whenever a Chipolo app is activated on a user’s mobile device, we will collect detailed location information about any Chipolo device(s) in reach of such mobile device, as collected and sent to us by the mobile device. Any location information we receive about Chipolo device(s) located through a Chipolo app will be stored by us on our cloud server. Such information can be associated by us with the account for which the Chipolo device(s) have been registered (by linking the unique Chipolo device identifier with the account information), for instance, where necessary to help you to track your Chipolo device(s) in reach of other users’ mobile devices with an activated Chipolo app.
However, your location information will be completely anonymous to other users, unless you actively decide to share these data, e.g., by choosing to share access to your Services’ account with other people you trust, or by using social networks (see Section 8 on “Your Sharing of your Personal Information with Social Networks” below). We will not identify you personally to other users or otherwise make your location information available to any third party in personal identifiable form without your prior consent.

 

Our Use and Sharing of your Personal Information

We may share your personal information (including your location information and your Chipolo devices’ location information) with our third party service providers or subsidaries, as authorized by us to collect, process and use your personal information as data processors on our behalf, such as, for instance, cloud based and hosting services, technical service providers, mail carriers, communication agencies and customer support service providers; these parties may be located in countries outside of your jurisdiction, including but not limited to the USA. We only provide these third parties with the minimum amount of personal data necessary to provide the services on our behalf, and the third parties are not permitted to use your personal data except for the limited purpose of completing the requested service or transaction. An updated list of the parties engaged by us for the processing of your personal information may be requested from us at any time. Other than as indicated above, we will not share your personal information with any third parties, unless compelled by law to do so or if you have given your prior consent (for our use of aggregated information, see Section 9 on “Our Use and Sharing of Aggregated Information” below).

We do not sell or rent your personal data to third parties for marketing purposes unless you have granted us permission to do so.

We may respond to subpoenas, court orders, or legal process by disclosing your personal data and other related information, if necessary. We also may choose to establish or exercise our legal rights or defend against legal claims.

Circumstances may arise where, whether for strategic or other business reasons, we decide to sell, buy, merge or otherwise reorganize business in some countries. Such a transaction may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchases, or the receipt of it from sellers. It is our practice to seek appropriate protection for information in these types of transactions. In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

We may collect and possibly share personal data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of out terms of use, or as otherwise required by law.

 

Your Sharing of your Personal Information with Social Networks

You may choose to share information between your Services’ account and some of your social network accounts (such as your Facebook account). Through this option, you may choose to have personal information and other content about you (e.g., the location of your Chipolo device(s) and thus also of your tracked items) available, transmitted and shared through the Services with your other social network account(s). By setting your Services’ account to integrate with social networks including by signing onto the Services by using your social network account (such as your Facebook account), you share information (including personal information) between the Services and such social networks.
The social network’s use of (personal) information is governed by that social network’s privacy policy and controlled by the social network, not by this Privacy Policy or us. When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked to permit the social network to share your personal information stored on such social network with the Services. We collect your information from your social network account only in accordance with your privacy settings you have set up under your social network accounts.

 

Our Use and Sharing of Aggregated Information

We use information about our users’ website activities and usage of our Services (including location information) in anonymous, statistical or aggregated form, i.e., in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes. We also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to our service providers or business partners.

 

Cookies

Cookies are small text files that our Services ask to place on your computer’s hard drive and onto your mobile device’s memory. If your browser is set to accept cookies, then your browser adds the text in a small file. We use cookie technology for various purposes, such as to facilitate your use of our Services, e.g., to remember you when you return to our Website, identify you when you sign-in, authenticate your access, enable your use of specific functionalities, keep track of your specified preferences or choices, tailor content to your preferences or geographic region, display personalized browsing history, or provide technical support.
We may further use cookies to monitor site usage, conduct research and diagnostics to improve our content, products, and services, and to help us analyze web traffic in general.
Cookies also enable us to display interest-based advertising on our Website using information you make available to us when you interact with our sites, content, or services. Interest-based ads are displayed to you based on cookies linked to your online activities.
Our cookies expire after they have fulfilled their purpose. Our Services use cookies that expire when you close your browser (i.e., session cookies) or that expire after a set period of time (i.e., persistent cookies). Cookies that are placed by third parties (see below) will have their expiration period determined by the third party, not us.
You can decide whether or not to accept cookies. The “Help” feature on most browsers will explain how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. To learn how to manage privacy and storage settings for Flash cookies click here. Because cookies allow you to take advantage of many of our online features and functionalities, consider leaving them turned on.
While our Website and Chipolo app at this time do not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser, as indicated above.

 

Integration of Third Party Web Analysis Services and Social Functionalities

In addition, our Services integrate the following services of third parties which may also place cookies on your computer’s hard drive and/or your mobile device’s memory. We do not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Privacy Policy.
You can change your settings to refuse these third party cookies or to warn you before cookies are placed. However, if you choose not to accept cookies, you may not be able to take advantage of some of our features and services through our Services.

 

Google Analytics (Google)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use our Website, to track and examine the use of our Chipolo app, to prepare reports on website activity and providing other services relating to usage of our Services. As a rule, any information generated by the cookies about your use of our Services will be transmitted to and stored by Google on servers in the United States.
Google may also use the data collected to contextualize and personalize the ads of its own advertising network and/or share the data with other Google services. You may opt-out from the collection of information stored and generated by the Google Analytics cookies as well as the use of such data by Google by downloading and installing the browser-plugin which is available here.

 

Social Plugins and Social Widgets

Our Services integrate social plugins, widgets and other features from third party social networks, including the following:

  • Twitter Tweet-Button, social widgets and other features allowing interaction with the Twitter social network as provided by Twitter, Inc.; further information on Twitter’s privacy practices can be found under https://twitter.com/privacy.
  • Facebook Like-Button, social widgets and other features allowing interaction with the Facebook social network as provided by Facebook. Inc.; further information on Facebook’s privacy practices can be found under https://www.facebook.com/about/privacy/.

These social plugins, widgets and other features allow the respective third party social networks to place cookies on your browser and to collect certain information, which may be associated with your name and personal social network account information. These social plugins, widgets and other features are operated solely by the respective third parties, and their service providers, and you should carefully read their privacy policies before you decide to use the respective functionalities. We have no control over or access to the information collected, stored or used by such third party social networks, and the information practices by such third parties are not covered by this Privacy Policy. If you do not wish to associate any information collected via the plugins, widgets and/or other features with your personal social network account information, you should refrain from using these social functionalities and log-out from your social network account before visiting our Services. Please further see Section 8 on “Your Sharing of your Personal Information with Social Networks” above for more details on sharing your information through social networks.

 

Controlling your Personal Information

You have the right, at any time, to know whether your personal information has been stored and can consult us to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any of your personal information, as well as to oppose their processing for any and all legitimate reasons. Requests should be sent to us at the contact information set out under Section 2 on “Data Controller” above. If you request the deletion of your account and your personal information, we will delete such information, however please note we may not delete information from our back-up systems.

 

Information Security

We implement commercially reasonable systems, applications, organizational measures and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access, disclosure, modification or use of information. We bind our employees to observe your privacy and confidentiality rights. However, these measures are unable to provide absolute assurance. Therefore, although we take great efforts to protect your personal information, we cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

 

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time by giving notice to you on this page and sending an email notice to you if you are a registered user. If you object to any of the changes to this Privacy Policy, you must cease using the Services and may request us to erase your personal information. Unless stated otherwise, the then-current privacy policy applies to all personal information we have about you. If there are any changes to this Privacy Policy, they will be posted on the Website and in the Chipolo app and sent to the last email address you provided (if applicable). Any changes will be effective 20 days after their initial posting or after the email was sent (or whichever date is later). However, if we amend this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.
You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services after being notified of such changes will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must cease any further use of the Services.

 

Last modified: 05/12/2016