Last updated August 15, 2024
This privacy notice for 128 Bits Ltd (doing business as Smart Bird Home Automations) ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services
('Services'), such as when you:
- Engage with us in other related ways, including any sales, marketing,
or events
Questions or concerns? Reading this privacy notice
will help you understand your privacy rights and choices. If you do not
agree with our policies and practices, please do not use our Services. If you still have any questions or concerns,
please contact us at hello@smartbird.io.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can
find out more details about any of these topics by clicking the link
following each key point or by using our
table of contents below to find the section you are looking for.
What personal information do we process? When you visit,
use, or navigate our Services, we may process personal information depending
on how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about
personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal
information.
Do we collect any information from third parties? We do not collect any information from
third parties.
How do we process your information? We process your information
to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your consent. We process your information
only when we have a valid legal reason to do so. Learn more about
how we process your information.
How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise
or guarantee that hackers, cybercriminals, or other unauthorised
third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Learn more about
how we keep your information safe.
What are your rights? Depending on where you are located
geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about
your privacy rights.
How do you exercise your rights? The easiest way to exercise
your rights is by submitting a data subject access request, or by contacting us. We will
consider and act upon any request in accordance with applicable data
protection laws.
TABLE OF CONTENTS
10. CONTROLS FOR DO-NOT-TRACK FEATURES
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to
us when you express an interest in obtaining information about us or our
products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal
information that we collect depends on the context of your interactions
with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the
following:
Sensitive Information. We do not process sensitive
information.
Payment Data. We may collect data necessary to process
your payment if you choose to make purchases, such as your payment instrument
number, and the security code associated with your payment instrument.
All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/gb/privacy.
All personal information that you provide to us must be
true, complete, and accurate, and you must notify us of
any changes to such personal information.
Information automatically collected
In Short:Some information — such as your Internet
Protocol (IP) address and/or browser and device
characteristics — is collected automatically
when you visit our Services.
We automatically collect certain information when you
visit, use, or navigate the Services. This information
does not reveal your specific identity (like your name or
contact information) but may include device and usage
information, such as your IP address, browser and device
characteristics, operating system, language preferences,
referring URLs, device name, country, location,
information about how and when you use our Services, and
other technical information. This information is primarily
needed to maintain the security and operation of our
Services, and for our internal analytics and reporting
purposes.
Like many businesses, we also collect information through
cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related,
diagnostic, usage, and performance information our servers
automatically collect when you access or use our Services
and which we record in log files. Depending on how you interact
with us, this log data may include your IP address, device
information, browser type, and settings and information about
your activity in the Services(such as the date/time stamps associated with
your usage, pages and files viewed, searches, and other
actions you take such as which features you use), device
event information (such as system activity, error
reports (sometimes called 'crash dumps'), and
hardware settings).
- Device Data. We collect device data such as information
about your computer, phone, tablet, or other device you use
to access the Services. Depending on the device used, this
device data may include information such as your IP address
(or proxy server), device and application identification
numbers, location, browser type, hardware model, Internet
service provider and/or mobile carrier, operating system,
and system configuration information.
- Location Data. We collect location data such as
information about your device's location, which can be either
precise or imprecise. How much information we collect depends
on the type and settings of the device you use to access
the Services. For example, we may use GPS and other technologies
to collect geolocation data that tells us your current location
(based on your IP address). You can opt out of allowing us
to collect this information either by refusing access to
the information or by disabling your Location setting on
your device. However, if you choose to opt out, you may not
be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and
administer our Services, communicate with you, for security
and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons,
depending on how you interact with our Services, including:
- To deliver and facilitate delivery of services to the user.
We may process your information to provide you with the
requested service.
- To respond to user inquiries/offer support to users.
We may process your information to respond to your inquiries
and solve any potential issues you might have with the requested
service.
- To send administrative information to you. We may
process your information to send you details about our products and
services, changes to our terms and policies, and other similar
information.
- To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments,
returns, and exchanges made through the Services.
- To enable user-to-user communications. We may
process your information if you choose to use any of our offerings
that allow for communication with another user.
- To request feedback. We may process your
information when necessary to request feedback and to contact you
about your use of our Services.
- To send you marketing and promotional communications.
We may process the personal information you send to us for
our marketing purposes, if this is in accordance with your marketing
preferences. You can opt out of our marketing emails at any time. For
more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
- To deliver targeted advertising to you. We may process
your information to develop and display personalised content and advertising
tailored to your interests, location, and more.
- To protect our Services. We may process your information
as part of our efforts to keep our Services safe and secure, including fraud
monitoring and prevention.
- To identify usage trends. We may process information about
how you use our Services to better understand how they are being used so
we can improve them.
- To determine the effectiveness of our marketing and promotional
campaigns. We may process your information to better understand how to provide marketing
and promotional campaigns that are most relevant to you.
- To save or protect an individual's vital interest. We may
process your information when necessary to save or protect an individual’s
vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information
when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law,
like with your consent, to comply with laws, to provide you with services
to enter into or fulfil our contractual obligations, to protect your
rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process
your personal information:
- Consent. We may process your information if you have
given us permission (i.e. consent) to
use your personal information for a specific purpose. You can withdraw your
consent at any time. Learn more about
withdrawing your consent.
- Performance of a Contract. We may process your personal
information when we believe it is necessary to fulfil our
contractual obligations to you, including providing our Services or at your
request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when
we believe it is reasonably necessary to achieve our legitimate business
interests and those interests do not outweigh your interests and fundamental
rights and freedoms. For example, we may process your personal information
for some of the purposes described in order to:
- Send users information about special offers and discounts on our
products and services
- Develop and display personalised and relevant advertising content for our users
- Analyse how our Services are used so we can improve them to engage and retain
users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can
improve user experience
- Legal Obligations. We may process your information where
we believe it is necessary for compliance with our legal obligations, such
as to cooperate with a law enforcement body or regulatory agency, exercise
or defend our legal rights, or disclose your information as evidence in litigation
in which we are involved.
- Vital Interests. We may process your information where
we believe it is necessary to protect your vital interests or the vital interests
of a third party, such as situations involving potential threats to the safety
of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short:
We may share information in specific situations described in this
section and/or with the following third parties.
We may need to share your
personal information in the following situations:
- Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short:
We may use cookies and other tracking technologies to collect and
store your information.
We may use cookies and similar tracking technologies (like web beacons
and pixels) to gather information when you interact with our Services.
Some online tracking technologies help us maintain the security of our
Services, prevent crashes, fix bugs,
save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online
tracking technologies on our Services for analytics and advertising,
including to help manage and display advertisements, to tailor
advertisements to your interests, or to send abandoned shopping cart
reminders (depending on your communication preferences). The third
parties and service providers use their technology to provide
advertising about products and services tailored to your interests which
may appear either on our Services or on other websites.
Specific information about how we use such technologies and how you can
refuse certain cookies is set out in our Cookie Notice.
Google Analytics
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the
purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this privacy notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from any further
processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal
information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so
we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will do
our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only
access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short:
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children
under 18 years of age, nor do we knowingly sell such personal
information. By using the Services, you represent that you are at
least 18 or that you are the parent or guardian of such a minor and
consent to such minor dependent’s use of the Services. If we learn
that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable
measures to promptly delete such data from our records. If you become
aware of any data we may have collected from children under age 18,
please contact us at hello@smartbird.io.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA),
United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control
over your personal information. You may review, change, or terminate your account at any time,
depending on your country, province, or state of residence.
In some regions (like the EEA, UK,
and Switzerland), you have certain
rights under applicable data protection laws. These may include the
right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; (iv) if applicable, to data
portability; and (v) not to be subject to automated decision-making. In
certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable
data protection laws.
Withdrawing your consent: If we are relying on your
consent to process your personal information, you have the
right to withdraw your consent at any time. You can withdraw your consent
at any time by contacting us by using the contact details provided in the
section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other
than consent.
Opting out of marketing and promotional communications:You can unsubscribe from our marketing and promotional
communications at any time by clicking on
the unsubscribe link in the emails that we send, replying 'STOP' or
'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
You will then be removed from the marketing lists. However, we may still communicate
with you — for example, to send you service-related messages that are necessary
for the administration and use of your account, to respond to service requests,
or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers
are set to accept cookies by default. If you prefer, you can usually choose
to set your browser to remove cookies and to reject cookies. If you choose
to remove cookies or reject cookies, this could affect certain features or
services of our Services.
If you have questions or comments about your privacy rights, you may
email us at hello@smartbird.io.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ('DNT') feature or setting you can
activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognising and implementing DNT signals
has been finalised. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for
online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy
notice.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as
necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated
version will be indicated by an updated 'Revised' date at the top of this privacy
notice. If we make material changes to this privacy notice, we may notify
you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at hello@smartbird.io or contact us by post at:
128 Bits Ltd
__________
__________ United Kingdom
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA
WE COLLECT FROM YOU?
Based on the applicable
laws of your country, you
may
have the right to request access to the personal
information we collect from you, details about how we
have processed it, correct inaccuracies, or delete your
personal information. You may also have the right to withdraw your consent to
our processing of your personal information. These
rights may be limited in some circumstances by
applicable law. To request to review, update, or delete
your personal information, please fill out and submit a
data subject access request.