Wiser Privacy Notice

 

1.    What is the scope of this privacy notice?

This privacy notice applies to Wiser (“the service”). It supplements our Data Privacy Policy available at https://www.se.com/in/en/about-us/legal/data-privacy.jsp. It explains what personal information will be collected through your use of the service, how the information will be used and how you can control the collection, correction and/or deletion of information.

Designed for residential end-users, the service helps you keep tabs on your home. It may also interconnect with third-party solution providers to provide additional features. We encourage you to let all home occupants know about the installation and operation of the service and to show them this Privacy Notice.

2.    Who is in charge of data processing?

The processing of personal information is carried out by Schneider Electric India Pvt Ltd. (“we”) as data controller.

As a global company, we commit to ensure an adequate level of protection for personal information in compliance with applicable laws. We have adopted internal policies which impose common rules for the collection, use and disclosure of personal information by all entities globally. To know more, please read our Data Privacy Policy.

3.    What types of personal information do we process?

We process the following categories of personal information:

-       Information that you provide: identification, actions

-       Information read and measured by sensors about energy efficiency, comfort parameters & security, monitoring, entry access, and event logs

-       Information that is created (computed, inferred, or derived): computation, predictions, budgets and analysis, estimates; alerts

 

Source

Categories of personal information

In a nutshell

Information that you provide

- to register and manage your profile

- to perform commands, actions

·           Identification

·           Actions

 

Some items are required to manage the account or to provide the service. For example: account name and contact information

Other items are optional. For example: you may give personalized names to rooms and devices or appliances.

This category also includes settings you set and commands you perform.

For example:

-  to add gateway for controlling the devices

-  to add and name devices for monitoring

-  to monitor energy consumption of specific appliances

- if your setup includes a doorbell: to monitor doorbell requests and allow or deny entry

 

Information read or measured

·           Energy, comfort & security monitoring

·           Event logs

 

Information which devices can send such as energy usage or other variables.

For example: Power consumption, device configuration,

This category also includes events related to your devices and identifiers.

For Example: Gateway or Analyzer ID, logs

Information that is created (computed, inferred or derived)

·           Computation & estimates

·           Alerts

 

These information items are created from a particular duration. For example: calculation of energy consumption for one month, or one week.

This category also includes analysis, generated in response to consumption. For example: generating predictive or budgetary analysis.

4.    Why do we collect and use personal information?

-       To deliver our services and to provide support

-       To improve the service and to develop new features and products

-       For communication, security and other purposes indicated in our Data Privacy Policy

We do not make decisions based solely on automated processing which may produce legal effects or similarly affect you.

We will ask for your consent as required by applicable laws.

4.1       To deliver our services and to provide support

This is to perform the contract with you, either as an individual user or as a legal person, in which case the contract performance is in our respective legitimate interest.

4.2       To improve the service and to develop new features and products

This is based on our legitimate interest, provided that such processing shall not outweigh your rights and freedoms as a data subject.

4.3.      For communications, security, and other purposes

We use personal information for relationship management (including contract management) and to communicate with you. We also process information to ensure the security of products, services, digital content, and the security of our activities and of others. We may also need it to address complaints. Other purposes are found in our Data Privacy Policy. Depending on the circumstances, these activities may be based on the execution of a contract with you, on our legitimate interest, on the legitimate interest of a third party, or for compliance with a legal obligation. We will also ask for your consent as required by applicable laws.

4.4 Inclusion of Consent for international transfers, from legal standpoint for India

You specifically agree and consent, with free will, for the following in the respect of the data provided while using the Mobile Application:

 

 

A.      We are permitted to share, process and/or store any personal information in India and outside India for the purpose as below:

 

A.1 To deliver our services and to provide support

 

This is to perform the contract with you, either as an individual user or as a legal person, in which case the contract performance is in our respective legitimate interest.

 

A.2 To improve the service and to develop new features and products

 

This is based on our legitimate interest, provided that such processing shall not outweigh your rights and freedoms as a data subject.

 

A.3. For communications, security, locating the gateway, configuring the gateway, accessing the gateway and to store the device data as backup.

 

 

 

4.5 Integration with other 3rd party products 

You acknowledge and agree that We are not liable in any manner whatsoever for any issues arising, while integrating any third-party device and/or application by You with Wiser application/gateway.

5.    How long do we keep your personal information?

We keep information as needed to perform the purposes described above, taking into consideration the need to provide the services, marketing requirements, security requirements, legal requirements, and statute of limitations.

To request deletion of your account, see Section 8.

·      Ultimate deletion of your information may be temporarily delayed giving you an opportunity to undo a mistake, to comply with legal requirements and statute of limitations.

·      For marketing purposes, we keep relevant customer information for three years after the end of our relationship or since the last interaction with us.

However, in case of inactivity of the use of the Mobile Application by you for a continuous period of three year, we will provide prior intimation that in case of no response within 7 days, we will delete the account and any associated information with confirmation on the email provided by you during the registration on the mobile application.

6.    Who do we share personal information with and where is it processed?

We do not sell your personal information.

Personal information will be processed by our affiliates and suppliers involved in the provision of the services and in the performance of the purposes. Their activities include hosting and maintenance, performance monitoring and security. As we are a global company, teams and suppliers may have global or multi-country roles, and they can be located anywhere in the world, in countries with different privacy standards than the country of our customers. We take measures to ensure that personal information receives an adequate level of protection.

We have internal policies applied by our affiliates and we conclude relevant contracts with our suppliers to ensure appropriate safeguards. Our group has adopted Binding Corporate Rules (BCR). To obtain more details and copies of safeguards put into place, you may contact global-data-privacy@schneider-electric.com.

We may also share your information, as necessary:

-       with competent authorities, based on a good faith belief that disclosure is necessary to respond to a judicial process, a valid official inquiry, or if otherwise required by law.

-       to defend our legal rights, or to protect the rights or safety of any person or entity.

-       as instructed by you, our customer, or the user.

If you authorize third parties to collect information from connected devices, to access information processed within the service, or to issue commands to connected devices (for instance using a third-party voice assistant), we will also share information with these third parties in order to perform your requests. We do not control these third parties or their privacy practices. You should review their privacy policies before engaging with them.

Google Analytics

The service includes Google Analytics, a Google service which provides us with information about how you use the mobile and the web applications. Google publishes information about its use of information at https://www.google.com/policies/technologies/partner-sites

Google Analytics features are used to understand how often functionalities are used.

Firebase Crashlytics

The service includes Firebase Crashlytics, a Google service which provides us with information about malfunctions of the mobile application. Firebase Crashlytics features are used to investigate software malfunctions and compatibility issues.

7.    How do we secure personal information?

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical, and physical safeguards to protect information against accidental or unlawful destruction, accidental loss and unauthorized alteration.

Please note that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee absolute security.

8.    How to exercise your choices and rights about your personal information?

In order to exercise the data protection rights granted under applicable data protection law, such as the rights to be informed, to access, to rectify, to withdraw consent, to request restriction or erasure, the right to object and data portability, you may:

-       access and edit your personal information and your choices or remove an appliance from your setup, using the application

-       request deletion of your account by contacting Customer Care at Customercare.in@schneider-electric.com

-       make any other data protection right request at Global-Data-Privacy@schneider-electric.com. To ensure the security of your personal information, we may ask you to provide other details to verify your identity.

 

If you choose to combine the service with those provided by third parties, you can exercise your rights by contacting them.

For any suggestion, question, and request, you may contact us as set forth in the “How to Contact Us” section. We will be happy to assist you.

9.    How to contact us?

You may address questions or comments about our privacy practices or this privacy notice to our Group Data Protection Officer (Group DPO):

DPO@schneider-electric.com

If you believe that Schneider Electric has processed your personal information in violation of applicable law, you may file a complaint with the Group DPO at the contact details above or with a supervisory authority.

10.  Changes to this privacy notice

Please note that this privacy notice may change from time to time. We will provide information about material changes.

Last updated: March 2022