Smart Products Connection, S.A., hereinafter SPC, is a company based in the Álava Technology Park, Leonardo da Vinci 14 01510 (Vitoria-Gasteiz) Álava, Spain.

At SPC, we are aware of our users' privacy. Therefore, we have developed this Privacy Policy to provide our users with information about how we process their personal data when they use our Salud del Sistema app.

The rest of SPC's products, applications, and websites that do not include a link to this Privacy Policy and include a link to a different SPC privacy policy will be governed by that privacy policy.
We consider "Personal data" to be all information associated with an identified or identifiable natural person.

1. Categories of personal data processed by SPC.

a. Personal data processed when adding an SPC device 

b. Personal data processed when the user contacts our support center 

When the user interacts with our customer service representatives through the app, online, or by phone, we collect personal information such as their name, postal address, phone number, email address, and contact preferences, as well as information about the SPC products they own, such as serial numbers and purchase date. We also record data related to the operating system and version on which the Salud del Sistema app is installed. To improve our customer service, and when applicable law allows it, with the user's prior consent, we may also record and review the user's conversations with service representatives and analyze any feedback they provide through voluntary customer surveys.

2. Purpose

We process the information you provide us with the purpose of managing the Salud del Sistema app. The legal basis for the processing and communication of the data is compliance with a legal obligation. The recipients of the information are the competent public administrations for the fulfillment of legal obligations.

In this way, we will carry out a proper management of the requested service. In this regard, the data you provide us both when creating your account with us and to create your profile will be processed to:

1. Manage the requested service.
2. Send you messages from SMART PRODUCTS CONNECTION, S.A. to inform you about improvements or news in our products and services. Remember that you can always customize these messages through your customer account settings and in section 6 (Rights) we explain how you can request not to receive this type of communication.
3. Prevent abuse and fraud in the use of our services (for example, fraudulent activities, denial of service attacks, spam sending, among others).
4. Transfer of data to organizations and public authorities, provided they are required in accordance with legal and regulatory provisions.

3. Data retention period 

How long do we keep your data?

Your data will be kept as long as the commercial relationship with us lasts, you do not request its deletion, as well as the time necessary to comply with legal obligations. 

4. Legal basis

What is the legal basis for processing your data?

The legal basis for processing your data lies in:

1. The execution of a contract in relation to the purpose indicated in section 1.a above.
2. The user's consent in relation to the purpose indicated in section 1.b.
3. The legitimate interest of SMART PRODUCTS CONNECTION, S.A. in relation to the purpose indicated in section 1.c above.
4. The fulfillment of legal obligations applicable to SMART PRODUCTS CONNECTION, S.A. for the purpose indicated in section 4 above.

5. Recipients

To which recipients will your data be communicated?

Your personal data will be communicated to third parties in the following cases:

1. Your data may be accessed by those providers who provide services to SMART PRODUCTS CONNECTION, S.A., such as content hosting services, instant messaging, notification sending, advertising services, etc. SMART PRODUCTS CONNECTION, S.A. has signed the corresponding data processing agreements with each of the providers that provide services to SMART PRODUCTS CONNECTION, S.A. in order to ensure that these providers will process your data in accordance with the provisions of the applicable legislation.
2. Your personal data may also be transferred to the competent authorities in cases where there is a legal obligation.

6. Google Crashlytics 

We use the crash diagnostics service "Crashlytics" from Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (hereinafter: Google).

Purpose

Crashlytics and error reports generated by the software are used to record and evaluate failures. The information obtained in this way is used to maintain and improve our application. If errors occur during the use of the application or the application closes unexpectedly, specific information such as device type, operating system version, date and time of the error, country from which the request was made, or the configured language of the operating system will be sent to Crashlytics. For more information about data protection in Crashlytics, see: https://fabric.io/terms.

Legal basis

The processing of data is necessary to protect the legitimate interests pursued by the controller (Art. 6 para. 1 letter f of the GDPR). We have a legitimate interest in offering our customers a product free of errors and making its use as easy and safe as possible.

Disable Crashlytics

You can prevent the processing of data by Crashlytics at any time. To do this, disable the logging and transmission of usage information and diagnostic data by Crashlytics in the app settings. This option is disabled when the app is supplied.

Data transmission to third countries

By using Crashlytics, personal data is transmitted to Google. Google operates for us as a service provider within the framework of order processing. Google also processes personal data in the USA and has submitted to the EU-US Privacy Shield. More information about the EU-US Privacy Shield can be found at https://www.privacyshield.gov/EU-US-Framework. 

7. Rights 

What are your rights when you provide us with your data and how can you exercise them?
You have the right to obtain confirmation about whether SMART PRODUCTS CONNECTION, S.A. is processing personal data concerning you or not.
You also have the right to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request the restriction of the processing of your data, in which case we will only keep them for the exercise or defense of claims.
In certain circumstances and for reasons related to your particular situation, you may object to the processing of your data. SMART PRODUCTS CONNECTION, S.A. will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
You may also exercise the right to data portability, as well as withdraw the consents given at any time, without this affecting the lawfulness of the processing based on consent prior to its withdrawal.
If you wish to exercise any of your rights, you can contact us via the email address dpd@spc.es or by writing to the postal address indicated above. Remember to provide as much information as possible about your request: full name, email address you use for the account or portal subject to your request.
Finally, we inform you that you can contact the data protection agency or commission of your country and other competent public bodies for any claim arising from the processing of your personal data.

SYSTEM HEALTH PRIVACY POLICY 

Smart Products Connection, S.A., hereinafter SPC, is a company based in the Technology Park of Álava, Leonardo da Vinci 14, 01510 (Vitoria-Gasteiz), Álava, Spain.
At SPC we are conscious of issues concerning our users’ privacy. We have therefore developed this Privacy Policy in an effort to provide our users with information about how we process their personal data when they use our System Health app.
All other SPC products, applications and websites that do not include a link to this Privacy Policy, but do include a link to a different SPC privacy policy, shall be governed by this Privacy Policy.
We consider "Personal Data" to be all information that is associated with an identified or identifiable natural person.

1. Categories of personal data processed by SPC.

a. Personal data that is processed when adding an SPC device.

When adding an SPC device, the device will be activated in our server through the serial number, which is then recorded. From that moment, the device is linked to our server to record technical and performance data of the device itself.

b. Personal data processed when the user contacts our support centre.

When the user interacts with our customer support representatives through the app, online or by phone, we collect personal information such as their name, postal address, phone number, email address and contact preferences, as well as information about the SPC products that they own, such as serial numbers and date of purchase. We also record data relating to the operating system and version on which the System Health app is installed. To improve our customer service, and when permitted by applicable law, with the prior consent of the user, we may also record and review the user's conversations with the helpdesk representatives and analyse any feedback that they provide us through voluntary customer surveys.

2. Purpose 

We process the information you provide us in order to manage the System Health app with which you intend to register. The legal basis on which the processing and communication of the data is based is the fulfilment of a legal obligation. The recipients of the information are the competent public administrations undertaking the fulfilment of legal obligations.
By doing this, we ensure that the requested service is managed correctly. In this sense, the data you provide us, both when you create your account and when you create your profile, will be processed for the purpose of:
1. Managing the requested service.
2. Sending you messages from SMART PRODUCTS CONNECTION, S.A. to inform you of improvements or new features in our products and services. Remember that you can always personalise this communication through your customer account settings, and in section 6 (Rights) we explain how you can request to stop receiving this type of communication.
3. Preventing abuse and fraud in the use of our services (e.g., fraudulent activities, denial of service attacks, spamming, etc.).
4. Transferring data to public organizations and authorities, provided that it is required in accordance with legal and regulatory provisions.

3. Data retention period

How long do we keep your data?
Your data will be kept for the duration of your commercial relationship with us, as long as you do not request their deletion, and as long as necessary to comply with legal obligations.

4. Legitimacy

What is the legitimacy for processing your data?
The legal basis for processing your data lies in:
1. The performance of a contract regarding the purpose indicated in paragraph 1.a above.
2. The user's consent regarding the purpose indicated in paragraph 1.b.
3. The legitimate interest of SMART PRODUCTS CONNECTION, S.A. regarding the purpose indicated in section 1.c above.
4. Compliance with legal obligations applicable to SMART PRODUCTS CONNECTION, S.A. for the purpose indicated in section 4 above.

5. Recipients 

To which recipients will your data be communicated?
Your personal data will be communicated to third parties in the following cases:
1. Your data may be accessed by those providers who provide services to SMART PRODUCTS CONNECTION, S.A., such as content hosting services, instant messaging services, sending notifications, advertising services, etc. SMART PRODUCTS CONNECTION, S.A. has signed the corresponding data processing contracts with each of the providers that provide services to SMART PRODUCTS CONNECTION, S.A. to ensure that these providers process your data in accordance with the provisions of the applicable legislation.
2. Your personal data may also be disclosed to the competent authorities in cases where there is a legal obligation to do so.

6. Google Crashlytics

We use the “Crashlytics” diagnostic service operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (hereinafter: “Google”).

Purpose
Crashlytics and the error reports generated by the software are used to record and analyze errors. The resulting information is used to maintain and improve our App. If using the App leads to unexpected errors or the App crashes, specific information such as device type, operating system version, date and time of the error, country where the request originated, and language selected for the operating system will be sent to Crashlytics. You can find more information about data protection at Crashlytics here: fabric.io/terms.

Legal basis
Processing is necessary to safeguard the prevailing, legitimate interests of the data controller (Art. 6, para 1 (f) GDPR). We have a legitimate interest in offering our customers a flawless product and in making its use as simple and secure as possible.

Disabling Crashlytics
You can prevent Crashlytics from processing your data at any time by deactivating the recording and transfer of usage information and diagnostics data by Crashlytics in the settings of the App. This option is deactivated in the App’s default delivery state.

Data transfer to third countries
Personal data is transmitted to Google through the use of Crashlytics. Google acts as a service provider for us within the context of commissioned processing. Google processes personal data in the US as well, and has signed up to the EU-US Privacy Shield Framework. You can find more information on the EU-US Privacy Shield Framework at www.privacyshield.gov/EU-US-Framework.

7. Rights 

What are your rights when you provide us with your data and how can you exercise them?
You have the right to obtain confirmation as to whether or not SMART PRODUCTS CONNECTION, S.A. is processing your personal data.
You also have the right to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request that we restrict the processing of your data, in which case we will only keep it for the purpose of pursuing or defending claims.
In certain circumstances and for reasons related to your particular situation, you may oppose the processing of your data, in which case SMART PRODUCTS CONNECTION, S.A. will stop processing the data, except where such processing is for imperative legitimate reasons, or for the exercise or defence of possible claims.
You may also exercise the right to data portability, as well as withdraw consent provided at any time, without this affecting the legality of the processing based on the consent given prior to its withdrawal.
If you wish to exercise any of your rights, you may contact us by email at dpd@spc.es or write to us at the postal address indicated above. Remember to provide as much information as possible about your application: Name and surname, e-mail address that you use for the account or portal to which your request refers.
Finally, we inform you that you may contact the data protection agency or commission in your country, as well as other competent public bodies, in order to make any claim arising from the processing of your personal data.