Smartee Privacy Policy

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

At SPC, we are aware of our users' privacy. Therefore, we have prepared this Privacy Policy to provide our users with information about how we handle their personal data when they use our Smartee app along with our wearables compatible with Smartee.

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 creating an SPC account

When creating an SPC account, we ask the user for their email address and password. Additionally, we record:

First name
Last name(s)
Date of birth
Genre
Postal Code
Weight
Height
Profile photo

Likewise, the user must fill out a simple questionnaire about their eating and sports habits, and that information is also recorded.

b. Personal data processed when adding an SPC device

When adding an SPC device, the user can provide the wearable's serial number, which is recorded. From that moment on, the device is linked to the user.

If the SPC wearable has the capability to display contacts, these will be read from the device. Contacts will also be read from the device when receiving a call in order to show the contact name on the SPC wearable.

In the event that the SPC wearable has the capability to display the weather, the device's location will be queried to check the local weather and display it on the SPC wearable.

c. Personal data processed when the user transfers their workouts, location, and activity data from an SPC wearable

Every time the user syncs their SPC wearable, either through automatic synchronization or manually, we record the workouts registered with the SPC wearable (such as running, walking, cycling, swimming training, hiking, gym activities, etc.) and activity data (such as steps, distance, pace, standing time, active time, calories burned, heart rate, sleep, location, menstrual cycle information, etc.) from the device to their Smartee account.

d. Data we collect when synchronizing workouts and physical activity data with the Smartee web service

Smartee regularly synchronizes information about physical activity and workouts with the web service. With each synchronization connection, we record data related to the transmission and the device on which the Smartee app is installed, such as the IP address used during synchronization, the date and time of synchronization, diagnostic/crash logs, the device's geographic location, operating system and its version, and information about the network used for synchronization (e.g., Wi-Fi or mobile).

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

When the user interacts with our customer support representatives through the Smartee 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 Smartee app is installed. To improve our customer service, and when applicable law permits, with the user's prior consent, we may also record and review the user's conversations with support representatives and analyze any feedback they provide through voluntary customer surveys.

f. Access to information in the Google Fit profile

If the user wishes, they can grant Smartee access to the information contained in Google Fit. The Smartee app reads information from Google Fit to complete the user's weight and height data and transfers to Google Fit the activity, steps, distance, sleep, and heart activity information that has been monitored by the SPC wearable.

2. Purpose

We process the information you provide us with the purpose of managing the Smartee app in which you will register. 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:

Manage the requested service.
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.
Prevent abuse and fraud in the use of our services (for example, fraudulent activities, denial of service attacks, spam sending, among others).
Transfer of data to organizations and public authorities, provided they are required in accordance with legal and regulatory provisions.
The data collected may be used by a third party to monitor your physical activity, as long as you are registered in a fitness or nutritional program (with prior consent).

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:

The execution of a contract in relation to the purpose indicated in section 1.a above.
The user's consent in relation to the purpose indicated in section 1.b.
The legitimate interest of SMART PRODUCTS CONNECTION, S.A. in relation to the purpose indicated in section 1.c above.
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:

Your data may be accessed by those providers who offer 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 offer services to SMART PRODUCTS CONNECTION, S.A. in order to ensure that these providers will process your data in accordance with the provisions of current legislation.
Your personal data may also be transferred to the competent authorities in cases where there is a legal obligation.
The collected data may be used by a third party to monitor your physical activity, provided that you are enrolled in a fitness or nutritional program (under prior and express consent).

6. 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.

SMARTEE PRIVACY POLICY

Smart Products Connection, S.A., hereinafter SPC, is a company based in the Technology Park of Álava, Leonardo da Vinci 14, 01510 (Miñano), 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 Smartee app in conjunction with our Smartee-enabled wearable devices.

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 creating an SPC account

When creating an SPC account, we ask the user for their email address and password. In addition, we record:

First name
Surname(s)
Date of birth
Gender
Postcode
Weight
Height
Profile photo

The user must also fill in a simple questionnaire about their eating and sporting habits, this information is also recorded.

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

When adding an SPC device, the user can provide the serial number of the wearable device, which is then recorded. From that moment, the device is then linked to the user.

If the SPC wearable has the ability to display contacts, these will be read from the device. Contacts will also be read from the device when receiving a call in order to display the contact name on the SPC wearable.

In case the SPC wearable has the ability to display the weather, the location of the device will be consulted to check the weather in the area and display it on the SPC wearable.

c. Personal data that is processed when the user transfers their workouts, location and activity data from an SPC wearable device.

Each time the user syncs their SPC wearable device, whether automatically or manually, workouts registered with the SPC wearable device are recorded (such as runs, walks, bike rides, swimming sessions, hiking, fitness activities, etc.) and activity data (such as steps, distance, pace, standing time, activity time, calories burned, heart rate, sleep, location, menstrual cycle information, etc.) are sent from the device to the user's Smartee account.

d. Data we collect when syncing workouts and physical activity data with the Smartee web service

Smartee regularly syncs fitness and training information with the web service. With each sync connection we record data relating to the transmission and the device on which the Smartee app is installed, such as information about the IP address used when syncing, the date and time of the sync, diagnostic and locking records, the geographic location of the device, the operating system and device version, and information about the network used for the sync (e.g. Wi-Fi or mobile).

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

When the user interacts with our customer support representatives through the Smartee 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 Smartee 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.

f. Access to information in the Google Fit profile

If the user so wishes, they can give Smartee access to the information contained in Google Fit. The Smartee app reads information from Google Fit to complete the user's weight and height data and transfers to Google Fit the activity, steps, distance, sleep and heart activity information that have been monitored by the SPC wearable.

2. Purpose

We process the information you provide us in order to manage the Smartee 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:

Managing the requested service.
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.
Preventing abuse and fraud in the use of our services (e.g., fraudulent activities, denial of service attacks, spamming, etc.).
Transferring data to public organisations and authorities, provided that it is required in accordance with legal and regulatory provisions.
The data collected may be used by a third party to monitor your physical activity, provided that you are enrolled in a fitness or nutritional programme (subject to your prior consent).

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, for as long as you do not request their deletion, and for as long as is necessary to comply with the legal obligations.

4. Legitimacy

What is the legitimacy for the processing of your data?

The legal basis for the processing of your data lies in:

The performance of a contract in relation to the purpose indicated in paragraph 1.a above.
The user's consent in relation to the purpose indicated in paragraph 1.b.
The legitimate interest of SMART PRODUCTS CONNECTION, S.A. in relation to the purpose indicated in section 1.c above.
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:

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, the sending of 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. in order to guarantee that these providers will process your data in accordance with the provisions of the legislation in force.
Your personal data may also be disclosed to the competent authorities in cases where there is a legal obligation to do so.
The data collected may be used by a third party to monitor your physical activity, provided that you are enrolled in a fitness or nutritional programme (subject to your prior and express consent).

6. 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.

CONTENTS AND THE QUALITY OF SERVICE

SMART PRODUCTS CONNECTION, S.A. does not assume any responsibility arising from the contents linked on the Website, provided they are external to it, nor does it guarantee the absence of viruses or other elements in them that may cause alterations in the computer system (hardware and software), in the user's documents or files, excluding any liability for damages of any kind caused to the user for this reason.

In the event that any user, client, or third party considers that the content or services provided by the linked pages are unlawful or harm the goods or rights of the user, a client, or a third party liable for compensation, and, in particular, consist of:

- Activities or contents that may be considered criminal under Spanish criminal law.

- Activities or contents that violate intellectual or industrial property rights.

- Activities or contents that endanger public order, criminal investigation, public safety, and national defense.

- Activities or contents that endanger the protection of public health, respect for human dignity and the principle of non-discrimination, and the protection of health and childhood.

You may notify SMART PRODUCTS CONNECTION, S.A. of this; however, receipt of such communication shall not imply knowledge for the purposes of the liability provided for in article 17 of the LSSICE.

SMART PRODUCTS CONNECTION, S.A. is not responsible for the lack of usefulness or suitability for a specific use of this Website. It is also not liable for any harm the User may suffer due to errors or omissions that the contents of this Website may have, although it commits to periodically verify and monitor its contents and information.

USE OF THE WEB PORTAL

SMART PRODUCTS CONNECTION, S.A. will not be held responsible under any circumstances for the use that Users may make of the Website or the Contents, nor for any damages or losses that may arise from it.

LINKS TO OTHER WEBSITES

Any third-party link to the Website must be to its main page, with “deep links,” “framing,” and any other use of the Website’s content for the benefit of unauthorized third parties expressly forbidden.

Through this Website, the User may access websites belonging to and/or managed by third parties.

The presence of such links is purely informative and does not in any case constitute an invitation to contract products or services offered on the destination Website. The User accesses the content under their sole responsibility and according to the terms of use governing those sites. The User acknowledges and agrees that SMART PRODUCTS CONNECTION, S.A. is not directly or indirectly responsible for any damages caused by access to such links.

If SMART PRODUCTS CONNECTION, S.A. becomes effectively aware that the information or activity referred to by such links is unlawful, constitutes a crime, or may harm the goods or rights of a third party subject to compensation, it will act with due diligence to remove or disable the corresponding link as soon as possible.

INDUSTRIAL PROPERTY

The use of the website does not grant the user any rights over trademarks, trade names, distinctive signs, or designs of any kind that appear on the website.

Articles, news, legislation, and other public content whose intellectual property rights do not belong to SMART PRODUCTS CONNECTION, S.A. are published solely to inform the users of this site.

SMART PRODUCTS CONNECTION, S.A. holds the rights to the source code, design, navigation structure, databases, and the various software elements of the website, as well as the industrial and intellectual property rights related to the content included therein.

APPLICABLE LAW AND JURISDICTION

SMART PRODUCTS CONNECTION, S.A. reserves the right to take civil or criminal actions it deems appropriate for the improper use of its website or for the breach of these terms.

The relationship between the user and the provider shall be governed by the laws in force and applicable within the Spanish territory. Should any dispute arise, the parties may submit their conflicts in accordance with the rules on jurisdiction and competence in this regard. SMART PRODUCTS CONNECTION, S.A. is domiciled in ARABA/ÁLAVA, Spain.