Last update: 18/06/2024
Issued by the Hager Group Cybersecurity and Privacy Department for the Hager BERKER GmbH Co.KG

Introduction

At Hager, we respect your privacy and we want to be transparent about the types of personal information we collect about you and how we use it. In this Privacy Notice (the " Privacy Notice "), we explain who we are, how we collect, share and use the personal data we collect when using the App and how you can exercise your privacy rights. Please also note our Privacy Resource Center.

In case you have questions not answered in this document or if you wish to contact us about this, you can reach our data protection officer by sending an email to: dsb.hagergroup@verimax.de 

The data protection officer is independent in their role and will treat your requests confidentially. 

We recommend that you read this Privacy Notice in its entirety to be fully informed. However, you can click on the corresponding link in this Note below to go directly to the section you are looking for.
In addition to our explanations, we will provide you with the applicable GDPR reference. Local data protection laws may also apply or influence points but will not be referred to directly here. 

Agenda

Introduction 1

1. Definition 
2. Your privacy rights and how you can exercise them 
3. What data do we treat as personal data 
4. Personal data we collect and process 
5. The Use of your personal data by the Hager Group 
a. Entity Responsible for the Processing of your personal data 
b.  For what purposes we use your personal data 
c. The legal basis for processing 
d. Transfers of your data 
e. Retention of your data 
6. Protection of your data 
7. Minors 
8.Updates to this Notice 
9. Contact Us 
10. Data Protection Officer 



 

1. Definition

The Smart Home Service, hereinafter also referred to as the service, is the server-based service to your Smart Home device. 

The Smart Home device is the controller to be activated which performs the networking of the peripheral devices connected to it and which communicates with your mobile device. 

The Smart Home system is the system composed of the Smart Home device, the peripheral devices connected to it and the App for the Smart Home device to manage and/or control building installations and/or not stationary products. 

Hager is the Hager affiliate who managed the App that you are using and is the data controller for all personal information that is collected by this App. For more information about this App, please see the “About Us” or "Terms and Conditions" section of our App. 

Mobile device is Smartphone, PC or PC tablet. 

The Reference user is the member of the family responsible for the use of the Smart Home system and its services. 

The system is the Smart Home system set up at the home of the reference user.  

App is the Hager solution you are using with your Mobile device and which is available in your country. 

General information on how data transmission functions in the Smart Home system:  

If the peripheral devices connected to the Smart Home device communicates information to the Smart home device (ex: call logs, snapshots etc.), this information is stored with appropriate mechanisms or measures such as in an encrypted form. If you log into the system via the App for your Smart Home device inside or outside your home, the App creates a direct https://secured link to your device  

Https (hypertext transfer protocol secure) is a hypertext transfer protocol. It is possible to make data inaudible and unreadable in the transfer process. This is achieved through encryption and authentication. Authentication serves to verify the identity of the connecting partner when establishing the communication.  

This means that you alone see the information on your home. When logging in outside your home, the Hager server connects you with your Smart home device. Your Smart home device and your mobile device can communicate with each other, and your Smart home device can receive commands. At no time will information on your home be collected by us or stored on the Hager server.

2. Your privacy rights and how you can exercise them

To make you feel at ease with the processing of your personal data by the Hager Group or its subsidiaries we will inform you anytime about what personal data the Hager Group is processing about you within its retention period (GDPR Art. 15 (1)).  Furthermore, we will inform you upon request about the processes your data is involved in. Please note that we will provide you a copy of the process your personal data has been involved in within its retention period, for further copies a fee may apply (GDPR Art. 15 (3)). You also have the right to erasure and restrict the processing of your personal data (GDPR Art. 17 & 18).
Nonetheless, we may need to store or use your data to comply with legal obligations even if you requested to exercise any of the rights above (GDPR Art 17 (3) (b)). We might also use collected data in legal actions (GDPR Art. 17 (3) (e)). 
You may rectify your personal data at any time (GDPR Art. 16). 

For parts of the processes, we may obtain your explicit consent (GDPR Art. 6 (1) (a)).  For personal data collected for these processes you also have the right to data portability (GDPR Art. 20). You may request to receive this data in a structured, commonly used, and machine-readable format or request to have this data transferred to another data controller (GDPR Art. 20 (1) (2)).

For parts of the process your data may be transferred to or accessed by a business partner in a third country, we will provide you upon request with the safety measures in place to protect your data (GDPR Art. 15 (2)).

Please use this link for any questions or requests relating to this Notice, raise any concerns or exercise your rights. The Hager Group will make sure to apply all your rights upon request without undue delay. 
Any complaints about the Hager Group concerning your personal data can be filed with the supervisory authority: 
Unabhängiges Datenschutzzentrum Saarland 
Fritz-Dobisch-Straße 12
66111 Saarbrücken
Tel. (0681) 94781-0
Email: poststelle@datenschutz.saarland.de

3. What data do we treat as personal data

The Hager Group and its subsidiaries consider any data that identifies you or can be used to identify you as personal data (GDPR Art. 4 (1)). Therefore, we will treat any such information with the security measures and practices outlined in this privacy statement. (GDPR Art. 9 &10).

4. Personal data we collect and process 

We collect various types of personal information via your use of this App and this information will be processed in accordance with the purposes described below. 

Information that you provide
In order to use the App and to benefit from our services, we process the personal information below: 

- Identification data: Name, email and password.

Information that we collect automatically 
We collect and process to a limited extent and in anonymous and aggregate form, personal information concerning users of the App. The data collected includes your IP address or your device identifier (e.g. IMEI number), operating system version, the dates on which you access and use the App, application version (client & server), application setting (e.g. language) and orientation (portrait / landscape), etc. 

Collecting this information enables us to better understand the visitors who use our App, where they come from, and what content on our App is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our App. 

5. The Use of your personal data by the Hager Group

a. Entity Responsible for the Processing of your personal data
The App that you are using is managed by BERKER GmbH Co.KG (hereafter "Hager"), who is the data controller for all personal information that is collected and processed.

b. For what purposes we use your personal data
We use your personal information for performing our contract with you in order to:
- provide you technical assistance requested by you,
- to create your account in the App,
- to administer and monitor the stability and performance of the App in order to improve it,
- to ensure that content from the App is presented in the most effective manner for you and your devices,
- to communicate efficiently with you and to answer any questions or queries you may have.

We may also use your personal information for the purposes of our legitimate interests as part of our effort to keep our App safe and secure.

For using the App solution, you have to scan the QrCode on the indoor station and download the dedicated App. For a detailed description please refer to the specific description in the terms of use of the solution you have subscribed to. 

We will use the personal information we collect from you only for the purposes described in this Notice.

c. The legal basis for processing 
We will process the personal information collected via this App for: 

- the performance of a contract or for steps taken prior to entering into a contract, in accordance with Art. 6 (1) (b) GDPR. Without data processing, contractual services cannot be fulfilled,
- legitimate interests: Personal information may be collected and processed by Hager Group as a controller for the improvement of its information security systems in order to be compliant with security requirements and data protection in force in accordance with Art.6 (1) (f). 

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

d. Transfers of your data 
We operate at a global level and, as a result, your personal information may be transferred to, and processed in, countries other than the country in which you are resident. In some cases, these countries may be located outside the European Union / European Economic Area (EU/EEA) and therefore may have data protection laws that are different to the laws of your country of residence. 
Specifically, servers used for providing you the requested service are located in Germany but we may share or give access to your personal information to group entities, third party service providers and partners who may be operating from outside the EU/EEA (for example, we may use web hosting providers or cloud computing service providers who store or access your personal information outside the EU/EEA). 
Where that is the case, we make sure that your personal information is transferred to third countries outside the EU/EEA that are deemed "adequate" by the European Commission (the list of adequate countries is available here, or alternatively, where your personal information is not sent to a country that provides adequate protection, we will put in place appropriate safeguards to ensure that your personal information remains protected while it is being processed outside the EU/EEA in accordance with applicable privacy laws. These appropriate safeguards may include signing the European Commission’s Standard Contractual Clauses with the Hager affiliate, third party service provider or partner outside the EU/EEA with whom we share your personal information. For further information about transfers of personal information outside the EU/EEA, please refer to the "How to contact us" section below.

e. Retention of your data 
We will retain your personal information for as long as necessary to enable us to fulfil our legal, pre-contractual and contractual obligations or our herein indicated legitimate interest. We also will retain your personal information unless you request us to erase them if the purpose of their use requires your consent or if you withdraw such as consent. 

Once the purpose for processing your personal information no longer exists, or the period of retention has expired, or if you ask us to delete your personal information or if you withdraw your consent, please be aware that we may continue to store your personal information for a limited period of time if necessary to comply with applicable legal, tax or accounting requirements. 

When we no longer have a purpose to process your personal information, we will make sure your personal information is either archived, deleted or anonymized.

6. Protection of your data 

We are committed to ensuring the protection of your personal data. We use strong safeguards to protect the privacy and security of personal data collected when using the App, employing technological, physical and administrative security measures such as encryption, access control and secure protocols. We make sure to apply the most appropriate measures for each situation and each stage of processing your personal data. 

7. Minors

Minors under 16 years are not supposed to use the App unless the minor's legal representative has given his or her consent.

8.Updates to this Notice

This Privacy Notice may be updated to reflect legal, technical or business developments. The update date is listed at the top of this Note.

9. Contact Us

Please use this link for any questions or requests relating to this Notice, raise any concerns or exercise your rights.

10. Data Protection Officer 

Martina Renner 
Verimax GmbH
Warndtstraße 115, 66127 Saarbrücken
dsb.hagergroup@verimax.de