Privacy Policy

October 2, 2022

Your privacy is important to Sowilo DS. This Privacy Policy describes our policies and practices regarding the collection, use, disclosure, transfer, and storage of your personal information and sets forth your privacy rights.

Sowilo Design Services Ltd. (“Sowilo DS”) is headquartered in Canada. This Privacy Policy applies to the Sowilo DS mobile application, other back-end web properties (e.g., app.sowilodesign.com), hardware/devices and any other services, applications or other products we may offer (collectively the “Services”) that supports the Sowilo DS mobile application.

If you have purchased Sowilo DS hardware, such as the Heimdall Pro, and have connected via the Sowilo DS App or Sowilo DS web services via a Sowilo DS account (a “User”) you should read this Privacy Policy in conjunction with the Sowilo DS Terms of Service, which govern your legal and contractual relationship with Sowilo DS.

By using Sowilo DS Services, you agree to the terms and conditions contained in this Privacy Policy and any other agreement that we might have with you. If you do not agree, you should not use the Services.

What Personal Information We Collect

Collecting your personal information is necessary so that we can supply you with the Services you have purchased or requested.

Sowilo DS collects personal information about Users to fulfill a contract.

  • We collect customer personal information directly from customers to create accounts. With some exceptions, the personal information collected is limited to the kinds of information that can be found on a business card: first name, last name, email and phone number.

  • When you contact support you might provide additional information necessary for us to provide support services, including testing and diagnostics, and quality control processes around your use of Sowilo DS Services.

 

We collect personal information for marketing purposes through web forms and other forms of electronic communications, including e-mails from prospective and actual clients in relation to the marketing, sales, support, and product delivery process (including for product demonstrations and trials). This personal information is provided to us voluntarily and the purposes for collection will be obvious, for example if you want to access an article or sign up for updates from us.

  • You may opt-out of receiving marketing communication by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe.

  • If you have any difficulties managing your email or other communication preferences with Sowilo DS, please contact us at privacy@sowilodesign.com.

Peripheral data from any Sowilo hardware is collected via the Sowilo DS mobile application. Device information is ingested and sent to backend cloud services hosted on AWS. Temperature data, voltages and errors logs are pulled from the devices. You can opt out of sending all this data in the mobile application.

How We Use Your Personal Information

Sowilo DS does not sell the personal information we collect and is only shared with affiliates and third parties who are facilitating the delivery of the Services (i.e some user info is stored via AWS Cognito). We use the personal information we collect to:

  • To provide you with the Services you have requested or purchased from us.

  • To fulfill and support our contractual obligations to you.

  • To send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Sowilo DS, you may not opt out of receiving these communications.

  • To process for our legitimate interests related to the Services, for example to better understand user needs, concerns and interests and develop, deliver, and improve our Services including customer experience, communications and support, content, and advertising and corporate communications so that Sowilo DS can operate optimally as a business.

  • To process for our legitimate interests related to internal purposes such as auditing, data analysis, network and IT security.

  • The MAC address of Sowilo DS devices (i.e Heimdall Pro) is stored for internal audit logging, analysis and debugging.

Collection and Use of Non-Personal Information

We also collect non-personal information, in other words data in a form that does not identify an individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

  • Information regarding user activities and use of our Services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our Services are of most interest, how they are used, and how they can be improved. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.

  • Information such as language, location, and the time zone where Sowilo DS Services are used so that we can better understand customer behaviour and improve our Services.

  • Non-personal log data is collected from Sowilo DS devices when enabled in the Sowilo DS mobile application. This can be disabled in the mobile application settings dropdown.

If we do combine non-personal information with other non-personal information such that an individual can be identified, or combine it with personal information, the combined information will be treated as personal information for as long as it remains combined.

Bluetooth and Location-Based Services

Sowilo DS services will not collect, use, or share precise location data, including the real-time geographic location of your Sowilo DS devices or other identifiers based on Internet protocol (IP) data.

However, for an android mobile device to be allowed the use of Bluetooth from the android mobile application coarse based location permission is required. No location data is collected by the Sowilo DS mobile application.

Bluetooth Paired Devices

Paired device data is stored locally in persistent storage on your mobile device and is not transferred to any Sowilo DS Services outside of the mobile application.

Phillips Hue Connect

When a user clicks the button on the gateway, giving the Sowilo DS mobile application access to the Phillips Hue Bridge, data is persisted locally on the mobile phone via the mobile application. No data gathered from the Hue Bridge is sent to any Sowilo DS cloud services.

Consent and Our Relationship with You

We take your privacy concerns and preferences seriously. Where you have contacted Sowilo DS and/or registered an interest in receiving information about Sowilo DS Services (including pricing or quotations) or have provided your personal information for marketing purposes (including event registration, subscribing to our blog, or content downloads), you have given your consent to receiving communications by phone, e-mail, or otherwise from Sowilo DS in response to your inquiries. When you subscribe to Sowilo DS Services and establish a commercial and contractual relationship with us, we are required to communicate with you and obtain and maintain associated data and information in order to fulfill our contractual and other legal obligations to you, for compliance, record-keeping and other legal and business purposes, and to provide you with ongoing information about Sowilo DS Services and to enhance your ability to use our Services.

Unsubscribe and Withdraw Consent

If you are not or no longer a customer of Sowilo DS and wish to cease receiving communications from Sowilo DS you can click the “unsubscribe” button on communications from Sowilo DS or contact privacy@sowilodesign.com.

If you choose to delete your account, which can be done via the Sowilo DS mobile application, your personal data will be deleted immediately. We do not have a recovery method or grace period for your data. If you wish to reopen an account, you will need to go through the sign-up process.

Use of the Sowilo DS Web Application

Our Services gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp, and a history of the pages you view. We use this information to understand and analyze trends, to administer the Services, to learn about user behaviour related to the Services, and to gather broad demographic information about our user base as a whole.

We use cookies for authentication and for the tracking of users inside of our web application. Logging out of Sowilo DS Web Applications removes the associated cookies. If you turn cookies off when visiting our Service, you will not have access to the Sowilo DS Web application.

Do not track

We do not track users to subsequent sites and do not serve targeted advertising to them. Sowilo DS does not, therefore, respond to Do Not Track (DNT) signals.

Disclosure to Third Parties

Sowilo DS does not disclose any of your personal data with any third parties for marketing. However, in order to provide our Services, we may engage third parties or other members to carry out data-processing activities that involve access to personal and non-personal customer data. These organizations are identified below with their locations and the types of services they provide for us.

  • Amazon Web Services, Inc. Infastructure provider with servers hosted in the United States

  • Smart Bear Inc for Bugsnag, a logging tool with servers hosted in the United States.

  • Google Cloud Service as an Oauth provider

  • Apple Cloud Service as an Oauth provider

Protection of Personal Information

Sowilo DS takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction.

Sowilo DS Services use Secure Sockets Layer (SSL) encryption and/or other features where personal information is collected. When making online purchases, you should use an SSL-enabled browser such as Safari, Firefox, or Internet Explorer. Doing so protects the confidentiality of your personal information while it’s transmitted over the Internet. Personal data is encrypted at rest and we restrict access to your personal data to those employees who need to know that information to provide the Services to you.

Location of Services

We use service providers located outside of Canada to process personal information. Personal information may be stored on the servers of cloud-based service providers located in the United States.

For data subjects in the EU, we will not store or process your information outside of the EU unless we have determined that there is an adequate level of protection and legal safeguards consistent with any applicable EU legislation and regulations. 

For more information on where and how long your personal data is stored, please contact Sowilo DS at privacy@sowilodesign.com.

Retention of Personal Information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law or our document retention policies and procedures.

If you correspond with us by email, post service, or via any other form of communication, we may retain the correspondence and information contained in it and use it to respond to your inquiry; to notify you of updates or Services that may be relevant to you; or to keep a record of your complaint, request, and the like. If you would like us to remove you from our contact list or exercise your rights related to your personal information, please contact us at privacy@sowilodesign.com

Sowilo DS has a legitimate interest in maintaining personal information of those who communicate voluntarily with us.

Keeping Personal Information Accurate

Sowilo DS makes it easy for you to keep your personal information accurate, complete, and up to date. Users should log in to an account from time to time to review and update the personal information that has been provided or contact us directly.

Children

For the safety of minors, and in compliance with the Children’s Online Privacy Protection Act, we (i) do not permit children under 13 years of age to become registered users of the Site; and (ii) request that children between the ages of 13 and 17 not fill out any personal information on our Service without first receiving the approval of a parent or guardian. If you are under 13 years of age, you may not use the Service.

Your Data Protection Rights

You have the right to request from Sowilo DS for copies of your personal data. We may charge you a small fee for this service. You have the right to request that Sowilo DS corrects any information you believe is inaccurate or complete any information you believe to be incomplete. You have the right to request that Sowilo DS will erase all your personal data, or object to the company’s processing of your personal data. You have the right to request Sowilo DS transfer the data that we have collected to another organization or directly to you.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at via email at privacy@sowilodesign.com

Changes and Updates to this Policy

As our Services and company changes from time to time, this Privacy Policy is expected to change as well. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification of privacy policy changes for certain Services).

We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

Contact

If you need further assistance, have questions about the privacy aspects of our products or services, or would like to make a complaint, please send an email message with your questions or comments to: privacy@sowilodesign.com, or send by mail to:

Sowilo Design Services, Ltd.
1000 Innovation Drive, Suite 500

Kanata, Ontario K2K 3E7

Canada