1. INTRODUCTION

This Privacy Policy applies to the Fumis WiRCU application (“the Application”), which together with the Fumis WiRCU device forms the WiRCU product (“the Product”).

In this Privacy Policy “we” or “us” means Fumis.

In order for us to provide you with a fully functional Product, we need to process certain personal information held electronically or otherwise. We will always treat this information in an appropriate manner and in accordance with the relevant data protection laws. The purpose of this Privacy Policy is to explain how we collect your personal information, what we do with it, how we look after it and how long we keep it for.
 

2. WE NEED TO HOLD CERTAIN INFORMATION ABOUT YOU SO THAT WE CAN SUPPORT THE USE OF THE PRODUCT 

During your use of the Product, we may collect and store certain information. Such information may have the nature of:
    i) personal information of the user (you) and/or
    ii) technical information on operation of the Product and devices to which it is attached or otherwise connected or associated to (for example, what temperature your heating appliance is set to and for what period of time).
We only collect and store information directly associated with the operation or functionalities of the Product or its connected devices.

 

What personal information?	Why do we need it?
Contact information (e.g. your full name, home or business address, phone number, e-mail address)	• So that a unique ‘ticket’ can be formed based on the submitted data in order to help our customers receive comprehensive support and the best possible user experience, as explained in the following bullets below,     • So that we know who our customers are when we provide them with our technical support in regard to operation of the Product or any device connected to the Product,     • So we may present you with suggestions given by third parties in regard to operation of the Product, offers to provide services or products in this regard and to promote upgrades or customer services or otherwise support operation of the Product (eg. based on the historical overview of the operating of the heating appliance, since the submission of the data based on which the user’s ticket was created).
MAC address of the Fumis WiRCU device	• So that you can connect the Application with your Fumis WiRCU device through the cloud,     • So that we can identify the Product in order to provide you with support,     • So that you can access information on previous settings of your heating appliance, as well as receive better technical support.

 

The Product may use tracking technologies that monitor activities of the Product and log them into your device or externally. Such data may indicate your preferences and/or activities in regard to operation of the Product or its connected devices.

Legal bases for processing personal data under EU data protection laws

If you are based in a European country where the EU rules on personal data protection apply, we need to tell you the legal basis on which we process your data.

We rely on the following legal bases:

so that we can fulfil our contractual obligation in connection with the Product (for example, in order to provide you with technical support under the purchase agreement),

so that we can comply with laws and as necessary to resolve disputes and enforce our agreements,

legitimate interests – so that we can operate an efficient and effective business but not at the expense of your overriding privacy interest.

We do not solicit any personal information from children. If you are not of legal age (18 years or older), please note that you are not authorized to use the Product without parental of guardian supervision.

Automated decisions

We do not use your personal information in an automatic way.

3. WE SOMETIMES HAVE TO SHARE YOUR INFORMATION 

3.a) Sharing your information within our organization

Your personal data will be processed by us for the purposes explained above. In doing so, some of our people, including managers, sales department, technical support etc., will have access to your personal data as needed to carry out their duties. Other departments may also need to use your personal information to carry out their responsibilities.

3.b) Sharing your information with trusted third parties

Like any large business, we sometimes use third party service providers to enable us to carry out our business activities more effectively and to ensure consistency in the way we operate. In some cases, these third parties will have access to your personal data.

Where we use third parties to process your personal data on our behalf, we will always carry out checks to ensure that there are appropriate protections for the safeguarding your personal data. We will also monitor the performance of these third parties (and their approved subcontractors) to ensure that your personal data remains secure.

Any third-party service provider that we instruct will only process your personal data for the same purposes for which we may use your personal data (as outlined above), as is strictly necessary to perform its obligations to us, and in the ways instructed by us.

Our key service providers at the date of this notice are as follows:

ATech Elektronika d.o.o. (Slovenia) – appointed to provide technical support for the Fumis WiRCU device hardware and the Application software,

nChain d.o.o. (Slovenia) – appointed to provide technical support for the Application software,

Amazon Web Services Inc. (USA) – appointed to host information in a cloud,

authorized service technicians for maintenance and repair of the heating appliance, which your heating appliance manufacturer selects with the utmost professional care and which need to be familiar with your data and data regarding the heating appliance that is in your possession, sourcing from the submitted ticket, in order to successfully implement the needed actions in case the heating appliance suffers some technical problems, on a case-by-case basis. For further information on the authorized service technicians please contact your heating appliance manufacturer.

We may update this list from time to time to inform you of any new key third party providers that we engage with who will process information on our behalf.
Other than that, we may also pass your personal data to regulatory bodies, government agencies and other third parties as required by applicable legislation from time to time.

3.c) Sharing information with the developer of the Application

We will share some of the collected information (data on operation of the Product) with the developer of the Application – company Atech Elektronika d.o.o., Slovenia ("Atech”). Such data is processed solely for the purpose of statistics and research, automatically anonymised and entered in Atech’s databases in such way it can no longer be associated with you. By doing so, Atech will be able to analyse customer software usage for its own purposes and develop the design and layout of the Application in order to improve the content to better match the interest of our users, including you. The described data may be collected also before the user’s submission of the data based on which the ticket shall be created (see point 2 of this Privacy Policy).

Transferring your personal information outside EU

We do not transfer any of your personal information outside EU.

4. WE PROMISE TO KEEP YOUR INFORMATION SAFE AND JUST FOR AS LONG AS NEEDED 

4.a) We promise to keep you information safe

We will always treat your personal information in an appropriate manner and keep it protected. We do this by implementing policies, standards and procedures and enforcing them. We take disciplinary action where appropriate.

4.b) We promise to keep your information just for as long as needed

After the end of your use of the Application (e.g., termination of the contract, uninstalling the application etc.), your personal data will be deleted in an effective and secure manner. However, before the deletion, you will have the option to take over your submitted data in 90 days since the end of your use of the Application, at the latest. In case you shall need help by Fumis doing this, a special fee may be charged to you in accordance with the applicable price list.
We will however retain certain records for evidential purposes and in order to allow us to meet our regulatory requirements and/or for the establishment, exercise or defence of legal claims or defence against such claims, or pursuant to other reasons sourcing from legislation.

5. YOUR DATA IS YOUR DATA 

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during your use of the Application, please keep us informed and the Application up to date.
The Application has functions that will make it easier for you to manage the personal information that we hold about you. The Application enables you to see what personal information is held about you and automatically updates this when necessary. You will remain the owner of the submitted personal information also during the use of the Application, as well as after the termination of its use.

You have the right within certain legal parameters to ask us:

to see what personal information we hold about you;

to correct your personal information;

to erase your personal information;

not to use your personal information in a particular way;

to restrict how we use your personal information;

not to make solely automated decisions about you.

If you wish to exercise these rights, please contact us by e’mail: support@fumis.si. We may charge a fee for the administration involved in processing this request.

Lodging a complaint?

If you have a complaint about the way we have used your personal information, you may use your right to make a complaint to the ‘Data Protection Regulator’ for your country or, if the processing was done by a third party, you may complain to the ‘Data Protection Regulator’ in their respective countries.

Changes to our Privacy Policy

We will keep this Privacy Policy updated and keep you informed of any material changes to the way we process your personal information. Future changes will be posted on our website and, where appropriate, notified to you by e-mail or by using the Application. We encourage you to read about the changes so that you keep up to date.

The Privacy Notice was last updated on 12.12.2022.