Hafele Mobile Privacy Policy

Name: Hafele (Thailand) Limited
Address: 57 Soi Sukhumvit 64, Sukhumvit Road, Phakanong Tai, Phakanong, Bangkok 10260
Contact: info@hafele.co.th, Tel. 02-768-7171

A. INTRODUCTION

Hafele (Thailand) Limited, its affiliates and subsidiaries (“we”, “us”, “our”, “Hafele”) are committed to protecting your data privacy. This Mobile Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

  • Hafele Smart Living
  • Hafele Smart Lock


In this Privacy Policy, “Personal Data” means any information pertaining to a person, which enables the identification of such person, whether direct or indirect, but does not include data of dead person in particular (Section 6 of PDPA). “Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc. “Apps” refers to those mobile applications developed by Hafele that provide end users remote control to Smart Devices and with the ability to connect to Hafele IoT Platform.

For other branded mobile applications powered by Hafele, our Clients control all the Personal Data collected through our Products. We collect the information under the direction of our Clients and the processing of such information shall be limited to the purpose of providing the service for which our Clients has engaged us. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.

B. THE COLLECTION OF PERSONAL DATA

In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

1. Information You Voluntarily Provide Us

a) Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.

b) Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

2. Information We Collect Automatically

a) Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

b) Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

c) Log Information: When you use our app, the system and exception log may be uploaded.

d) Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as robot cleaner and weather service.

3. Smart Devices Related Information:

a) Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

b) Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or videos captured by it.

C. THE OBJECTIVE FOR COLLECTING PERSONAL DATA

The purpose for which we may process information about you are as follows:

1. Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,

2. Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

3. Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

4. Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.

5. Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.

D. DISCLOSURE OF PERSONAL DATA

At Hafele, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

1. To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

2. To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.

3. As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

4. To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

Except for the third parties described above, to third parties only with your consent.

E. RETENTION AND DURATION OF PERSONAL DATA COLLECTION

The Company will keep your personal data for 10 years for both soft file and hard file at the Company’s centre dive. After that, the Company will destroy data by delete it from our saver 

F. CHANGE OF PRIVACY NOTICE

The Company will review the privacy notice regularly in accordance with the practise and the law and relevant regulation. If there are any changes for privacy notice, the Company will inform you the updated information in our website as the earliest convenience. Privacy notice was reviewed latest 2020-06-11. If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

G. SAFETY  & SECURITY MEASURES

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Hafele provides various security strategies to effectively ensure data security of user and device. As for device access, Hafele proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing Email info@hafele.co.th

H. RIGHT OF DATA SUBJECT

The company acknowledges and respects your legal rights in relation to personal information about you which is under the control of the company. According to the conditions stipulating the rights specified in the Personal Data Protection Act B.E. 2562 as follows:

1.      The client has the right to access and obtain a copy of his or her personal data for which the data controller is responsible.

2.      The client shall have the right to object the collection, use, or disclosure of his or her personal data.

3.      The client shall have the right to request the controller to erase, destroy or make it become unidentifiable data.

4.      The client shall have the right to restrict the use of personal data.

5.      The client shall be able to easily withdraw consent as it given.