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SUMMARY - PRIVACY NOTICE |
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General Your privacy is very important for us at Verisure Arlo Europe DAC, trading as Arlo Europe (“Arlo Europe”, “we”, “us”). At Arlo Europe we take security seriously and we want you to have the same peace of mind about the way we process your personal data as you do from the protection of our security cameras. As the data controller, we are committed to ensuring that all applicable data protection legislation is complied with and that your personal data is appropriately protected. Scope This Privacy Notice is applicable to all processing of personal data in relation to you as a current or potential customer and user of our products and services ("User”) as well as if you navigate or interact with our website www.arlo.com (“Website”), (“Website visitor”). Collected personal data When you enter into an agreement with us to use our services, you provide us with certain personal data. This may be data such as contact details, login details, order and payment details as well as information about how you use our services. Your personal data may also be made available to us via other sources such as public registers or partners. To ensure the best experience on our platforms, we also use cookies which may contain personal data collected when you use our website and app. More about our cookie usage can be found in our cookie policy here. Our processing of your personal data Your personal data is used to provide you with the best possible information on products and services we offer. - Administration and performance of contracts, - Provision of Arlo App which enables you to use our products and services, - Provide customer service and technical support in relation to our products and services, and - Training and quality assurance. When visiting our website, we process your personal data for the following reasons: - To analyse the use of our Website and ensure functionality, and - To provide and administer our online shop. Regardless of whether you visit the website or app your personal data may also be processed for the following purposes: - Marketing, including individually targeted direct marketing, - Customer satisfaction surveys, customer reviews and business development, - Administration in connection with acquisitions, restructuring, etc., - Defending our legal interests in the event of a dispute, and - Complying with legal obligations, including sharing personal data with law enforcement or other authorities. We do not sell your personal data on to third parties. We do not use personal data for incompatible purposes, and we only retain personal data during the period for which it is necessary. In some cases, it may be necessary to disclose your personal data to other group entities including IT providers, our outsourced customer service provider or companies with whom we cooperate to provide our products and services. Please see section 7 for more information about who we share your personal data with. Your rights You have the right to be informed about how we collect, process, store and use your personal data. You also have a right to request changes to how your personal data is being processed, as well as the right to access to your personal data and in certain situations to have your personal data erased, to restrict the processing of your personal data as well as right to data portability. You can choose to manually delete your videos and account details via the Privacy Centre in the Arlo app. You also have in some instances rights to object to our processing of your personal data. If we process your personal data based on your consent, you always have the right to withdraw your consent. If you believe that we have processed your data in an unlawful manner, you have the right to lodge a complaint to the Data Protection Authority in your home Member State. Complete Privacy Notice This is a summary of our Privacy Notice. If you want to know more about how we process your personal data and about your rights as a data subject, please refer to our complete Privacy Notice https://www.arlo.com/en_gb/arlo-privacy-notice-uk
Contact details If you have any questions regarding this Privacy Notice, our processing of your personal data or if you wish to exercise your rights, please do not hesitate to contact us: Verisure Arlo Europe DAC, Arlo Europe, company registration number 658538 Postal address: Building 4100, Cork Airport Business Park, Cork, Ireland, T22 AP97 Visiting address: Building 4100, Cork Airport Business Park, Cork, Ireland, T22 AP97 E-mail: dpo@verisure.com Website: www.arlo.com
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CONTENT
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1 GENERAL ► |
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2 DATA CONTROLLER AND DATA PROTECTION OFFICER ► |
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3 OUR processing OF PERSONAL DATA ► |
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4 COLLECTION OF PERSONAL DATA ► |
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5 RETENTION OF PERSONAL DATA ► |
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6 WITH WHOM DO WE SHARE PERSONAL DATA? ► |
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7 AUTOMATED DECISION-MAKING, including profiling ► |
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8 WHERE IS YOUR DATA PROCESSED? ► |
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9 YOUR RIGHTS ► |
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10 WE PROTECT YOUR PERSONAL DATA ► |
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11 Cookies ► |
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12 CHANGES TO THIS PRIVACY NOTICE ► |
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13 CONTACT DETAILS ► |
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COMPLETE PRIVACY NOTICE |
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1 General ► |
▼ 1. general1.1 Your privacy is very important to Verisure Arlo Europe DAC, trading as Arlo Europe, registration number 658538, (“Arlo Europe”, “we”, “us”). Our mission is that you feel comfortable with us processing your personal data. The purpose of this Privacy Notice (“Privacy Notice”) is to explain how we ensure that your personal data is processed in compliance with applicable legislation. 1.2 This Privacy Notice is applicable to all processing of personal data in relation to you as a current or potential customer and user of our products and services (“User”) and if you navigate or interact with our website www.arlo.com (“Website”), (“Website visitor”). 1.3 If you as a User choose to process third parties’ personal data via our products and services, Arlo Europe will process their personal data and assume that you have previously informed them that we will process their personal data and that you have shared the contents of this Privacy Notice with them. |
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2 DATA CONTROLLER AND DATA PROTECTION OFFICER ► |
▼ 2. dATA CONTROLLER AND DATA PROTECTION OFFICER2.1 Arlo Europe is the data controller for the processing of your personal data and is thus responsible for ensuring that the processing of personal data complies with applicable legislation. You can find our contact details in the end of this Privacy Notice. 2.2 The personal data which you capture by your Arlo devices belong to you and you are the data controller for such capture. In some situations, we may act as a data processor in terms of the content that you capture and record your device(s). We do not access your content for any other reason than for providing you with service at your request. 2.3 Arlo Europe forms part of the Verisure group of affiliates (“Verisure” or the “Group”) and personal data is shared between the entities of Verisure. Any handling of personal data for which an Verisure entity is the data controller will be explained in separate privacy notices made available when your personal data is first collected by that Verisure entity, for example where you or the business you work for engages Verisure to provide a service. You can find out more about our Group at www.verisure.com or by contacting us using the contact details in section 13. 2.4 Arlo Europe have designated Rita Crowley as our Data Protection Officer (“Data Protection Officer”). The Data Protection Officer is inter alia responsible for monitoring that our processing of personal data is carried out in accordance with applicable legislation. 2.5 The Data Protection Officer can be reached via the e-mail dpo@verisure.com. |
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3 OUR processing OF PERSONAL DATA ► |
▼ 3. OUR processing OF PERSONAL DATAAs a User of our services and products, we process your personal data for the following purposes: · Administration and performance of contracts, · Provision of Arlo App which enables you to use our products and services, · Provision of customer service and technical support in relation to our products and services, and · Training and quality assurance. 3.2 Website visitors: As a Website visitor, we process your personal data for the following purposes: · To analyse the use of our Website and ensure functionality, and · To provide and administer our online shop. 3.3 Common for both Users and Website visitors: Regardless of being a User or Website visitor, we also process your personal data for the following purposes: · Marketing, including direct marketing and individually targeted direct marketing, · Customer satisfaction surveys, customer reviews and business development, · Administration in connection with acquisitions, restructuring, etc., · Defending our legal interests in the event of a dispute, and · Complying with legal obligations, including sharing personal data with law enforcement or other authorities. · More information about our processing of personal data is provided in the tables below, including information about why we process your personal data, what personal data we process to achieve those purposes and for how long we retain your personal data for each specified purpose.
PURPOSES
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4 COLLECTION OF PERSONAL DATA ► |
▼ 4. from where do we collect your personal data4.1 Users: We receive the personal data we process from you. We do not collect personal data from other sources. In case we collect information from other sources, we will inform you about such collection separately.4.2 Website visitors: We receive the personal data we process from you. We do not collect personal data from other sources.4.3 It is necessary that you provide certain personal data to us at Arlo Europe in order to enter into an agreement with us and for us to provide our products and services to you. In case you do not provide us with the necessary personal data, it is not possible for us to provide our products or services to you and thus enter into an agreement with you. |
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5 AUTOMATED DECISION-MAKING, including profiling ► |
▼ 5. Automated decision-making, including profiling5.1 We do not use automated individual decision-making. 5.2 However, we do use profiling for data analysis and market research, which means that we perform an automated form of processing of your personal data for evaluating personal aspects or make predictions about you. In particular, we pursue the purpose of dividing our customers and interested parties into different target and user groups in the context of market research (User segmentation), for insights into different target groups and their respective usage habits and interests, demographics and the marketing of these findings in the context of advertising services provided to third parties. We also use personal data to administer customer relations, for example to handle customer service matters, price adjustments and customer satisfaction surveys. 5.3 The purpose of our profiling and the types of personal data being processed for each profiling is described in detail in Section 3 above. None of the aforementioned processing results in significant or legal decisions being made about you on a wholly automated basis. 5.4 If you have any questions regarding the profiling, please do not hesitate to contact us. You will find our contact details in Section 13 below. If you do not wish us to use profiling for the purpose of providing individually targeted direct marketing, you always have the right to object to such processing by contacting us. We will cease to use your personal data for that purpose when we have received your objection. |
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6 RETENTION OF PERSONAL DATA ► |
▼ 6. retention OF PERSONAL DATA6.1 We will only retain your personal data for as long as it is needed for the purposes we collected the personal data and as described in this Privacy Notice. When we no longer need your personal data we will remove the personal data from your systems and databases, including any back-ups. More specific retention periods are provided in the tables above in Section 3, under the heading “Retention period”. |
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7 WITH WHOM DO WE SHARE YOUR PERSONAL DATA? ► |
▼ 7. with whom do we share your personal data7.1 We may share your personal data with reliable external parties, such as to other group companies, IT providers and companies with whom we partner to provide our services. We may also need to disclose personal data at the request of public authorities or to other parties in the context of court proceedings, mergers and acquisitions or similar. In the tables below, you will find information about which external parties we may disclose personal data to and which categories of personal data will be disclosed in such case.
7.2 We will not sell your personal data to any other party. |
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8 WHERE IS YOUR DATA PROCESSED?► |
▼ 8. WHERE IS YOUR DATA PROCESSED?8.1 We aim to always process your personal data in the EU/EEA. In some circumstances we may need to transfer your personal data to a country outside of the EU/EEA (“Third Country”). In case your personal data is transferred to a Third Country, we will ensure that your personal data will continue to be subject to an essentially equivalent level of protection as in the EU/EEA. 8.2 We transfer your personal data to recipients in United Kingdom and Switzerland which are subject to EU Commission’s adequacy decision. This means that the EU Commission has assessed that the level of data protection in this country is essentially equivalent to that of the EU/EEA and that it is therefore possible to transfer personal data to such country without additional safeguards. 8.3 When we transfer personal data to a Third Country which is not subject to an adequacy decision, we apply a relevant transfer mechanism, that is applicable safeguard to ensure that an essentially equivalent level of data protection is ensured in the Third Country, specified in the table below.
8.4 Please contact us for more information about the legal basis for a specific transfer or if you want to receive a copy of the relevant transfer mechanism or information about the security measures taken in the context of the transfer. The contact details are provided in the end of this Privacy Notice (Section 13). |
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9 YOUR RIGHTS ► |
▼ 9. your rights9.1 Our responsibility for your rights ► ▼ 9.1.1 In our capacity of a data controller, we are responsible for ensuring that your personal data is processed in compliance with applicable legislation and that you can effectively exercise your rights as a data subject. You may contact us at any time if you wish to exercise your rights. You will find the contact details in the end of this Privacy Notice. 9.1.2 We have an obligation to respond to your requests to exercise your rights within one month from receiving your request. If your request is complex or if we have received many requests, we have the right to extend this deadline by two more months. If we are unable to take the action you have requested within one month, we will inform you of the reason for the delay and of your right to lodge a complaint with a supervisory authority and to seek a judicial remedy. 9.1.3 You will not be charged for any information, communication or measures that we implement. However, if your request is manifestly unfounded or excessive, we may charge an administrative fee for providing the information or taking the action requested or refuse to act on your request altogether.
9.2 Your right to access, rectification, erasure and restriction ►▼ 9.2.1 You have the right to request:a) Access to your personal data. This means that you have the right to request access to personal data that we hold about you. You also have the right to be provided, at no cost, with information about which personal data we are processing about you. We have the right to charge a reasonable administration fee if you request further copies. If you make a request by electronic means, e.g. via email, we will provide you with the information in commonly used electronic format. b) Rectification of your personal data. At your request or on our own initiative, we will correct, anonymise, delete or complete data that we know to be inaccurate, incomplete or misleading. Also, you have the right to complete any incomplete personal data if something relevant is missing. c) Erasure of your personal data. You have the right to request that we erase your personal data if there is no compelling reason for us to continue processing the data. Compelling reasons for use to continue processing may be: i. Processing is necessary for the right of freedom of expression and information, ii. Processing is necessary to comply with a legal obligation, iii. Processing is necessary for reasons of public interests in the area of public health, iv. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes or v. Processing is necessary for the establishment, exercise or defence of legal claims. Your personal data will be erased if none of the circumstances above are applicable and if i. The personal data is no longer needed for the purpose for which we collected them, ii. We process your personal data based on your consent and you withdraw your consent, iii. You object to us processing your personal data which is based on a legitimate interest assessment, and we have no compelling interests that overrides your interests or rights and freedoms, iv. We have processed the personal data unlawfully or v. We have a legal obligation to erase the personal data. d) Right to restrict processing. This means that we temporarily restrict the processing of your data. You have the right to request restriction when: i. you consider your data to be inaccurate and you have requested rectification as defined in paragraph 9.2.1 b), while we establish the accuracy of the personal data, ii. the processing is unlawful, and you do not want the data to be erased, iii. as the personal data controller, we no longer need to process the personal data for our processing purposes, but you need them to be able to establish, exercise or defend a legal claim, or iv. you have objected to processing as defined in paragraph 9.3 while waiting for our assessment of whether our legitimate interests override yours. 9.2.2 We will take all reasonable measures possible to notify everyone who has received personal data as stated in Section 7 above if we have rectified, erased or restricted access to your personal data after you have requested us to do so. At your request, we will provide you with more information about the recipients of your personal data.
9.3 Your right to object to processing ►▼ 9.3.1 You have the right to object to the processing of your personal data if our processing is based upon legitimate interest or performance of a task carried out in the public interest (see Section 3 above). If you object to such processing, we will only continue to process your data if we have compelling reasons for doing so that override your interests or rights and freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims. 9.3.2 If you do not wish that we use your personal data for direct marketing purposes, you always have the right to opt out at the end of any such email or to change your consent in the Arlo app or on your account online. We will cease to use your personal data for that purpose once you have declined from receiving marketing material. .
9.4 Your right to withdraw consent ►▼ If we process your personal data based on your consent as the legal basis, you always have the right to withdraw your consent. You can do this at any time by contacting us. Our contact details are found in the end of this Privacy Notice.
9.5 Your right to data portability ►▼ 9.5.1 You have right to data portability when we process your personal data by automated means and when the legal basis for the processing is your consent or performance of a contract. 9.5.2 Right to data portability means that you have the right to receive the personal data we process about you in machine-readable format which allows you to transfer these personal data to another data controller. You may also request us to transfer the personal data directly to another data controller.
9.6 Your right to complain to the supervisory authority ►▼ You have the right to lodge a complaint with the Data Protection Authority in your home Member State if you are not satisfied with our processing of your personal data. |
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10 We protect your personal data ► |
▼ 10. we protect your personal dataWe are committed to ensuring that you always feel comfortable when providing your personal data to us. We have therefore implemented both technical and organisational security measures, including access restrictions and regular internal controls, to best protect your personal data against, for example, unauthorised access, alteration or loss. Should a data breach that materially impacts you or your personal data, e.g. entailing risk of fraud or identity theft, occur, we will contact you to explain what has happened and to provide you with advice on how you can mitigate any potential adverse effects of such data breach relevant for you.
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11 cookies ► |
▼ 11. cookiesWe cookies and similar technologies ("cookies") on our website and app in order to, inter alia, improve your experience with us and to simplify and adapt our website to your needs and preferences. If you would like to know more about our use of cookies, please refer to our Cookie Policy here.
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12 changes to this Privacy Notice► |
▼ 12. changes to this Privacy Notice12.1 This Privacy Notice was updated in February 2023.12.2 We have the right to change this Privacy Notice at any time. The latest version of the notice will always be available on our website.12.3 When we make changes that are not purely linguistic or editorial, you will be notified of the changes within a reasonable time prior to the changes taking effect. If you do not agree to the changes, you have the right to object to the processing before the changes take effect. |
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13 contact details ► |
▼ 13. How to contact USOur Data Protection Officer acts as the main point of contact for all matters relating to our Privacy Notice. The Data Protection Officer or the local contact person can be contacted by email at dpo@verisure.com. If you have any complaints or questions about how we use your personal data, please do not hesitate to contact us: Verisure Arlo Europe DAC, Arlo Europe, company registration number 658538 Postal address: Building 4100, Cork Airport Business Park, Cork, Ireland, T22 AP97 Visiting address: Building 4100, Cork Airport Business Park, Cork, Ireland, T22 AP97 E-mail: dpo@verisure.com Website: www.arlo.com
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