We, the company SenseGuard GmbH, appreciate your interest in our company and our products. The protection of your privacy is an important concern for us. Below we inform you about how your personal data is processed when using the Water Monitor App in connection with digital devices and we inform you about your rights in accordance with the General Data Protection Regulation of the European Union (GDPR).
The controller responsible for the processing of your personal data is: SenseGuard GmbH Address: Feldmühleplatz 15, 40545 Düsseldorf, Germany. You can reach our data protection officer as follows: Data Protection Officer of SenseGuard GmbH Adress: Feldmühleplatz 15, 40545 Düsseldorf, Germany. E-Mail: dataprotection@suru-water.com.
We process various personal data that you provide to us when using digital devices via the Water Monitor App for various purposes. Below you will find further information about the specific personal data and the purposes for which we process this personal data, as well as the legal basis for this processing.
In order to make full use of the functionalities of the Water Monitor App and the associated digital devices, it is necessary to create a user account and log in each time you use the Water Monitor App. For this purpose, we collect the following registration and login data: Name, e-mail address, password. The processing of your personal data is necessary in order to provide you with the Water Monitor App and its functionalities. The legal basis for processing is Art. 6 para. 1 lit. b GDPR (performance of a contract).
We process certain personal data when you use the Water Monitor App in connection with digital devices.
When using the Water Monitor App in conjunction with a digital device, the following categories of data are collected: • Usage Data (Usage data, i.e. usage-related information during the usage period, such as water pressure, water temperature and water flow measured by the device, type, time and frequency of an alarm, timestamp). • Technical Data (Technical data, i.e. device-related information such as device ID and serial number, firmware version, battery status, connectivity information and settings and signal strength, error codes, time zone-related data and information about other installed devices). • User Contact Data (Contact information of the user, such as e-mail address, building address, telephone number, first name, last name). • Sharing Contact Data (Contact information of the contact provided by the user to share access to the Water Monitor App, such as name, e-mail address). The processing of such data is necessary to ensure the full functionality of the device as a water consumption display system and as a protection system for the detection of volume and time-based leaks and micro-leaks, to alert the user in the event of an emergency, to monitor the use of the device and to provide the user with statistical information (e.g. on water consumption). The legal basis for the processing of the user's personal data is Art. 6 para. 1 lit. b GDPR (performance of a contract). The personal data of the Sharing Contact is processed in accordance with Art. 6 para. 1 lit. f GDPR (legitimate interest).
If you contact us by e-mail or via the contact form, your e-mail address and all other data you provide will be processed by us in order to answer your questions or concerns in the best possible way. The legal basis for the processing of personal data in this case is Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest in the processing is to offer good customer service and the optimal processing of your inquiries.
We process certain personal data in the event of a malfunction or damage reported by the SURU devices you use or directly by you, including access to your personal data by the SenseGuard support team to analyze and resolve the reported malfunction or damage and for the purpose of contacting you. This includes your contact information and the necessary information on the respective incident ("incident data"). In order to provide you with optimal support and service and to be able to reach you, the incident data may be transmitted to the LIXIL Group's regional support entity in the country in which you are located ("Regional Support Entity"). We may also share your contact details and information on the specific incident data with external service providers (e.g. installers) acting on our behalf in the event that service requests require an on-site visit. The legal basis for the processing of personal data in this case is Art. 6 para. 1 lit. b GDPR (performance of a contract).
We process certain personal data in order to connect your account with partners with whom we work ("Cooperation Partners"), such as water suppliers and insurance companies, and to enable you to receive specific offers and benefits from these Cooperation Partners in connection with the use of the Water Monitor App. For more information on how your personal data is processed in this context, please refer to our Partner Data Access Policy . If a specific Cooperation Partner is not yet available to connect your account in the Water Monitor App, we will contact you via your e-mail address as soon as the respective cooperation partner is available for the connection, provided you give us your consent to do so. The legal basis for the processing in this case is Art. 6 para. 1 lit. a GDPR (consent).
We process certain personal data in order to link your account with partners we cooperate with (“cooperation partners”), such as water utility providers and insurance companies, and to enable you to receive specific offers and benefits from these cooperation partners in connection with the use of the Water Monitor App. Further information on how your personal data is processed in this context can be found in our Partner Data Access Policy. If a specific cooperation partner is not yet available for linking your account in the Water Monitor App, we will contact you via your email address as soon as the respective cooperation partner becomes available for linking, provided that you have given us your consent to do so. In this case, the legal basis for the processing is Article 6(1)(a) GDPR (consent).
We use the Facebook SDK for iOS and Android in our WaterMonitor App (hereinafter: “Meta SDK”), a software development kit provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Meta”), for tracking, marketing, and targeting purposes.
The Meta SDK enables us to analyze user behavior within our WaterMonitor App and to measure the success of our advertising campaigns on Instagram and Facebook.
In particular, app usage data (such as feature views) and event data (e.g. app installations and app events such as app launches, registrations, etc., IP address, timestamps, etc.) may be processed. Additional collected information includes device information (e.g. operating system and operating system version, screen resolution, device identifiers, app version, device model, language and region, as well as event timestamps) and technical connection data (IP address, timestamps, etc.).
This enables us to statistically evaluate and optimize the use of our app and the effectiveness of our advertising measures. In particular, we can measure whether, and through which advertisement on Facebook or Instagram, a user became aware of our app. In addition, we can draw users’ attention to our offers and products again, for example by displaying personalized advertising on other websites of the respective third-party providers and within the advertising networks operated by them, tailored to the interests of the respective user.
Furthermore, Meta may match the collected information with your Facebook account data. This means that your use of our WaterMonitor App may be linked to your Facebook user account if you are a Facebook user and logged into your Facebook account. Meta uses the collected data for analytics purposes and for its own advertising purposes. Users can manage their settings and object to the use of their data for advertising purposes in their Facebook profile settings.
The profile settings can be accessed here: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
A transfer of data to Meta Platforms, Inc., based in the United States, cannot be ruled out. The transfer of data to the United States is based on the adequacy decision of the European Commission pursuant to Article 45 GDPR within the framework of the EU-U.S. Data Privacy Framework; Meta Platforms, Inc. is certified under the EU-U.S. Data Privacy Framework.
The use of the Meta SDK is based on your consent pursuant to Section 25(1) sentence 1 TDDDG and Article 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future.
When using the Meta SDK, there is joint controllership between us and Meta within the meaning of Article 26 GDPR, limited to the collection of the data and its transfer to Meta within the scope of using the Meta SDK. Any subsequent processing of this data by Meta is carried out under Meta’s own responsibility under data protection law.
You can review the agreement on joint processing at the following link: https://www.facebook.com/legal/controller_addendum
Under this agreement, we are particularly responsible for properly informing data subjects and for the data protection-compliant implementation of the Meta SDK in our WaterMonitor App. Meta is responsible for the security of Meta products. If you wish to exercise your data subject rights (e.g. access, deletion, correction), we recommend that you contact Meta directly.
Of course, you may also direct your requests to us. We will then support you to the best of our ability.
The Water Monitor App uses New Relic, a system and performance analysis tool from New Relic, Inc., San Francisco, CA, 188 Spear St, San Francisco, USA. New Relic uses cookies that enable an analysis of the use and performance of the Water Monitor App. For this purpose, various information about your usage behavior of the Water Monitor App (e.g. performance-related telemetry data) or your IP address is processed. This information about your use of the app is used to evaluate the performance of the Water Monitor App. The information about your use of the Water Monitor App (including your IP address) is transmitted to a New Relic server in the USA. This data transfer is based on the adequacy decision of the EU Commission pursuant to Art. 45 GDPR on the EU-U.S. Data Privacy Framework; NewRelic, Inc. is certified under the EU-U.S. Data Privacy Framework. The processing of personal data by NewRelic is based on your consent in accordance with Art. 6 para. 1 lit. a GDPR. IX. Push Notifications The Water Monitor App uses the customer interaction platform “OneSignal”. OneSignal, Inc., 201 S.B. Street, San Mateo, CA 94401, USA, is responsible for operating OneSignal. OneSignal enables the Water Monitor App to send you push notifications to the device you are using. OneSignal may also analyse push notifications to better understand your interests and preferences in receiving push notifications. For this purpose, SURU processes the following personal data: IP address (including geolocation data), email address, a unique identifier of the end device used and the user, information about your interactions with the SURU Water App, device-specific information (such as type and version of operating system used, network provider, browser used, language setting, time zone, network status type, etc.), usage-specific information (e.g. session duration, time-stamp) and location information. This information will be transferred to OneSignal, Inc. servers in the USA. This transfer is based on the adequacy decision of the EU Commission pursuant to Art. 45 GDPR on the EU-U.S. Data Privacy Framework; OneSignal, Inc. is certified under the EU-U.S. Data Privacy Framework. The processing of personal data is based on your consent pursuant to Art. 6 para. 1 lit. a GDPR. You can enable or disable receiving push notifications at any time for the Water Monitor App.
There is no legal or contractual obligation to provide us with your personal data, with the exception of the personal data required for registration and logging in to the Water Monitor App. Otherwise, we only ask you for data that is necessary for the provision of our services. Without this personal data, we cannot offer you the full functionality of the Water Monitor App and digital devices and our services may be limited.
To provide the Water Monitor App and its functionalities and services, we also work with external service providers who process the personal data. The processing of personal data by such service providers is carried out on our behalf and in accordance with our instructions (so-called "processors", see Art. 4 no. 8 GDPR). We use the following service providers or categories of service providers: • IT service provider (including hosting, security checks, algorithm testing, account management, system and performance analysis). • Support service providers (including the processing of support requests and the sending of push notifications).
We may also transfer personal data to recipients who process personal data under their own controllership for their own purposes (see Art. 4 no. 7 GDPR). This includes the transfer to the following recipients or categories of recipients: • subsidiaries of the LIXIL Group, and regional support units. • Cooperation partners (further information can be found in our data access policy for partners)
for the purposes set out in this Privacy Policy. Such a transfer takes place in the following cases: • Handling of user requests and incidents by a LIXIL Group company ("Regional Support Unit") or other external service providers contracted by LIXIL located outside the EEA, see Section B.IV. • Transfer of personal data to cooperation partners outside the EEA, see section B. V. • Transfer of personal data to Smart Home partners based outside the EEA, see section B.VI. • Processing of personal data by service providers acting on our behalf, including system and performance analysis of the Water Monitor App by New Relic, Inc., sending of push notifications by OneSignal, Inc. and hosting of our services by Amazon Web Services. A transfer to a third country only takes place in compliance with the applicable data protection regulations, in particular the guarantee of an adequate level of data protection. Most of our service providers based in the USA are certified under the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/s/). In this respect, the data transfer takes place in accordance with Art. 45 GDPR. We have taken appropriate security precautions with the other data recipients in third countries, i.e. standard data protection clauses pursuant to Art. 46 para. 2 lit. c GDPR, which ensure the security of your personal data. We transfer data to third countries that are not based on Art. 45 or Art. 46 GDPR if you have given your consent to do so. For further information on this or for a copy of the above security measures, please contact us using the contact details provided in Section A.
The Water Monitor App uses Sentry, a performance monitoring and error tracking tool provided by Sentry, Inc., San Francisco, CA, 45 Fremont St, San Francisco, USA. Sentry uses cookies that enable an analysis of the use and performance of the Water Monitor App. For this purpose, various information about your usage behavior of the SURU Water App (e.g. performance-related telemetry data), your IP address or device information, browser information and details of error messages (including stack trace) is processed. This information about your use of the app is used to evaluate the performance and monitor errors within the Water Monitor App. The information about your use of the Water Monitor App (including your IP address) is transmitted to a Sentry server in the USA. This data transfer is based on the adequacy decision of the EU Commission pursuant to Art. 45 GDPR on the EU-U.S. Data Privacy Framework. The legal basis for this data processing is our overriding legitimate interest in the continuous provision and security of THE Water Monitor App in accordance with Art. 6 para. 1 sentence 1 f) GDPR.
In general, we only store personal data for as long as it is necessary in connection with the originally defined, explicit and legitimate purpose. In addition, we are subject to various statutory archiving and documentation obligations. The retention periods for such retention and documentation obligations can be up to ten years. With regard to possible legal claims, the retention period is also determined by statutory limitation periods, which can be up to thirty years, whereby the generally applicable limitation period is three years.
We keep the technical measures to ensure data security up to date, in particular to protect your personal data from risks during the transmission of data and from combination with prior knowledge on the part of third parties. These measures are constantly adapted to the latest state of the art. To prevent unauthorized access to your personal data by third parties, the connection is encrypted using SSL technology.
You have the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR). If personal data is processed on the basis of your consent, you have the right to withdraw your consent in accordance with Art. 7 para. 3 GDPR. We would like to point out that your withdrawal only affects future processing on the basis of your consent. Insofar as the personal data is processed for the purpose of safeguarding our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR, you have the right to object in accordance with Art. 21 GDPR. Further information on your right to object can be found at the end of this privacy policy. To exercise the aforementioned rights, you can contact us, preferably by e-mail to contact@suru-water.com. To facilitate the processing of your request, it would be helpful if you could provide information in your message about where you have had contact with us (e.g. in which country and under what circumstances). Please note that we may ask you to provide proof of your identity in order to verify the legitimacy of your exercise of rights. If you believe that the processing of your personal data is unlawful, you have the right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR). This right of complaint is without prejudice to other administrative or legal remedies. Information about your right to object in accordance with Art. 21 of the General Data Protection Regulation (GDPR) You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you on the basis of Article 6 para. 1 lit. f GDPR (processing of personal data on the basis of a balancing of interests); this also includes the creation of profiles on the basis of these provisions (Article 4 no. 4 GDPR). If you decide to object to the processing, we will stop processing the personal data concerning you unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You also have the right to object at any time to the processing of personal data concerning you for the purpose of advertising; this also applies to the creation of profiles, insofar as these are related to advertising measures. If you decide to object to the processing for advertising purposes, we will stop processing your personal data for these purposes. The objection does not require any particular form. The objection should preferably be submitted by e-mail to the offices listed in Section H.