PRIVACY POLICY – MYVALLOX CLOUD – EFFECTIVE FROM 25.5.2018

1. Introduction
2. The Data Collected by Vallox
3. Purposes of Use of Data
4. Disclosure of Data
5. Your Rights
6. Data Security
7. Transfers of Personal Data Outside EU / EEA // International Transfers of Personal Data
8. Children’s Privacy
9. Changes to The Privacy Policy
10. Questions or Concerns?

1 CONTROLLER AND CONTACT PERSON

Vallox Oy Business I.D. FI06723509 Myllykyläntie 9, 32200 Loimaa, Finland (“Vallox”, “we”, “us” or “our”)

Contact person in matters related to the processing of personal data: Vallox Info Vallox Oy Myllykyläntie 9, 32200 Loimaa, Finland +358 10 7732 200 Info@Vallox.com

2 INTRODUCTION

Vallox considers privacy and the protection of personal data as very important elements of the user experience of myvalloxcloud.com and of any related services or applications (the “Ser-vice”), as described in our Terms of Service.

In this Privacy Policy the term “personal data” means information that relates to an identified or identifiable natural person, which we collect to our client register. This Privacy Policy tells you about the ways in which Vallox protects your privacy and your personal data that Vallox processes.

Vallox acknowledges that you as the user of the Service are concerned about how Vallox uses and discloses your personal data. Vallox is dedicated to openness regarding the ways in which Vallox uses and discloses any personal data, and Vallox is committed to complying with data protection and privacy laws that apply to it. Importantly, Vallox wants to give you control over the personal data about you that Vallox processes when you use the Service.

Vallox may use third party service providers for processing of personal data in relation to of-fering the Service to you.

Vallox would like to remind you that this Privacy Policy applies to personal data that Vallox process when you use the Service. It does not apply to any links to third parties’ websites and/or services that you may encounter when you use the Service. Vallox kindly encourages you to carefully familiarize yourself with the respective privacy policies applicable to any web-sites and/or services operated by third parties. Please be aware that Vallox is not responsible for the privacy practices of any such third parties.

By using the Service, you accept the privacy practices described in this Privacy Policy.

3 THE DATA COLLECTED BY VALLOX

The personal data is primarily collected from you as information voluntarily provided to us, but may also be collected from external sources or through automated means. In this Section 2 we describe in detail the personal data we collect.

3.1 Data that you provide

Vallox may collect the following information from its users ("Users", "you") that may, in cer-tain circumstances, constitute following personal data:

• Username;
• Password;
• E-mail address;
• Address;
• Phone number;
• Name;
• Business ID or personal identity number;
• Billing and payment information;
• Product and order information;
• Client contacts and feedback;
• Information concerning the use of the Service;
• Information necessary for communications;
• Permits and consents; and
• Other data obtained under the User’s consent

3.2 Data provided by other sources

Vallox may also collect personal data, where lawful to do so, from public sources and third party service providers.

3.3 Automatically collected data

The Service may automatically collect the following information from Users of the Service that in certain circumstances may constitute personal data:

• Air quality measurement and ventilation control are key functionalities of the services of Vallox, and thus air quality measurement results and other corresponding data related to the ventilation system are collected through the services of Vallox and presented to you in the Service.
• The logging technology used in the Service may automatically collect the URL of the site from which you came and the site to which you are going when you leave the Service. Vallox may also collect the Internet protocol (IP) address of the device you use to access the Service, information about the operating system of your device, as well as the name of your Internet service provider.
• Vallox may place a “cookie” on the hard drive of the device that you use to access the Service. Cookies are text files that are saved on the hard drive of your device by means of your browser, enabling Vallox to recog-nize your browser. Most of the currently available browsers give you the option of managing cookies by, for example, disabling them entirely, ac-cepting them individually, and deleting saved cookies from your hard drive. Vallox would like to remind you that if you completely disable cookies on your browser, you might not be able to use some features of the Service.
• Google Analytics is an element of the Service. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the website, the Internet Protocol address, and the type of operating system used in the devices used to access the Service. By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

Moreover, details of transactions you carry out through the Service, and details of your visits to the Service including, but not limited to, traffic data and other communication data may also be collected by Vallox.

4 LEGAL BASES FOR PROCESSING AND PURPOSES OF USE OF DATA

Legal grounds for processing your personal data are either compliance with the agreement entered into between us, compliance with legal obligations to which we are subject, our legit-imate interest, or your consent as further described below.

• Contractual and statutory obligations: Processing of your personal data to certain extent is necessary to enable us to fulfil the agreement we have concluded with you. For example, when you enter into agreement with us and/or use our services, it is necessary for us to process your personal data so that we can carry our contractual obligations to provide you the services. This also creates certain statutory obligations for us related to e.g. product safety.
• Our legitimate interest: We process your personal data based on our le-gitimate interest in particular to offer you first-class customer experience related to our Service and to provide you the most relevant online and newsletters content as well as for administrative purposes and to prevent-ing and resolving possible misconduct.
• Consent: Based on your consent, we can process your personal data to sending you electronic direct marketing.

The provision of your personal data as described in this Privacy Policy is partially a contractual requirement. For example, when you enter into an agreement with us or register to the Ser-vice, you are required to provide us with certain personal data for processing purposes speci-fied in this Privacy Policy. Failure to provide us personal data may prevent us from performing our contractual obligations, which may lead to you being unable to use the Service.

Vallox uses the collected data described in Section 3 for the following purposes:

• To manage and develop the client relationship;
• To provide and develop the Service;
• To prevent and investigate fraud and other misuses;
• To protect rights of Vallox and/or property of Vallox;
• To operate and improve products and services of Vallox;
• For marketing (when permitted on the basis of Controller’s legitimate in-terest or when the data subject has opted-in to receiving direct electronic marketing);
• For payment control;
• For analytics and statistics;
• For opinion and market research;
• To personalize user experience; and
• For other comparable purposes.

5 DISCLOSURES OR TRANSFERS OF DATA

Vallox does not sell, lease, rent or otherwise disclose or transfer the personal data relating to our Users to third parties unless otherwise stated below in this section 5.

The personal data collected in, through or from the Service may be disclosed to the following categories of third parties in following situations:

• To service providers, such as payment processors enabling Vallox to pro-vide the Service to you;
• To public authorities, such as law enforcement if Vallox is legally obliged to so or if Vallox is required, or in need to, protect its rights or the rights of third parties; and
• To the subsidiaries and affiliates of Vallox; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, acquisition, consolidation, restructuring, or the sale of substantially all of stock and/or assets of Vallox, bankruptcy, or other corporate reorganization, in accordance with this Privacy Policy.

We use partners, whether affiliated or unaffiliated, in providing the Service. We transfer your personal data to these parties, called data processors, to process such data as necessary for the specified purposes of processing. Such processing conducted by data processors may in-clude in particular provision of technical support to us, storing of data or other corresponding automated data processing activities. For the sake of clarity, Vallox may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual Users of the Service.

6 YOUR RIGHTS

If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

You also have the right to lodge a complaint with the competent data protection supervisory authority regarding our processing of personal data. For such complaints, please follow the instructions provided by the competent supervisory authority.

Pursuant to applicable data protection laws you may have the following rights with respect to the personal data Vallox holds about you:

6.1 The right to know the content and extent of data Vallox holds about you

If you would like to know what personal data Vallox holds about you, you can approach Vallox with a written request by using the contact details in the beginning of this Privacy Policy. Val-lox is committed to respond swiftly to your possible inquiry.

Please consider that Vallox reserves the right to charge a small processing fee if less than twelve (12) months has passed since your last inquiry relating to personal data Vallox holds about you.

6.2 The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated

The easiest way to correct, delete, or update the personal data you have provided to the Ser-vice is to log in to the Service and enter the necessary changes there. If you have additional questions regarding the correction, deletion, or updating of the personal data Vallox holds about you, please contact Vallox by using the contact details in the beginning of this Privacy Policy.

6.3 Right to be forgotten

You as a data subject also have the right at any time to request us to erase personal data concerning you and processed by us and we are obliged to erase the data if there is no longer a legal ground for processing the data. Please note that certain data processed by us may be subject to statutory retention requirements, and regardless of a request of erasure, such data we cannot erase until the end of the applicable statutory retention period.

For requests related to the erasure of your data, please contact us by using the contact details in the beginning of this Privacy Policy.

6.4 Right to restriction of processing

Under certain circumstances, you may have the right to obtain from us restriction of pro-cessing of your personal data. Should the restriction of processing apply, the respective per-sonal data will be marked and may only be processed by us for certain defined purposes.

6.5 Right to data portability

Under certain circumstances, you may have the right to receive such personal data that you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another entity without hindrance from us.

For requests related to your right to data portability, please contact us by using the contact details in the beginning of this Privacy Policy.

6.6 The right to opt out of receiving electronic direct marketing communications from Vallox

All electronic direct marketing communications that you may receive from Vallox, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from Vallox in the future. If you have any additional questions about electronic direct market-ing received from Vallox, please contact Vallox by using the contact details at the end of this Privacy Policy.

7 DATA SECURITY

Vallox has taken and is committed to maintain appropriate technical and organization measures to protect personal data from unauthorized access or against loss, misuse or altera-tion by third parties. Despite these efforts to store personal data collected in and through the Service in a secure operating environment that is not available to the public, Vallox cannot guarantee the security of personal data during its transmission or its storage in the systems of Vallox. Furthermore, while Vallox attempts to ensure the integrity and security of personal data, Vallox cannot guarantee that its security measures will prevent third-parties such as so-called hackers from illegally obtaining access to the personal data. Vallox does not warrant or represent that personal data about you will be protected against loss, misuse, or alteration by third parties.

8 TRANSFER OF PERSONAL DATA OUTSIDE EU / EEA // INTERNATIONAL TRANS-FERS OF PERSONAL DATA

Vallox does not transfer any personal data outside EU/EEA.

9 RETENTION TIME OF PERSONAL DATA

The retention time of the collected personal data is subject to the legal basis and processing purpose for which the data were collected. We will retain your personal data for as long as they are necessary for carrying out the processing purposes specified in the Privacy Policy, such as the fulfilment of our contractual obligations (e.g. return and limited warranty periods), or for providing other customer service. When we no longer need the collected personal data, the data will be safely destroyed or irrevocably anonymized.

The retention periods for personal data are determined in accordance with the following crite-ria:

• Your personal data will be retained for as long as the agreement between you and us is in force;
• Related personal data will be retained for as long as the legitimate inter-est of us can reasonably be considered valid. The validity of our legiti-mate interest is determined by, for example, the use of our Service and the communication between you and us, such as customer service com-munication.
• Related personal data will be deleted when you withdraw your consent or object to the processing of your personal data for direct marketing pur-poses. In this case, however, we may keep the information regarding your objection to receiving direct marketing.

10 RELATED PERSONAL DATA WILL BE DELETED WHEN YOU HAVE REQUESTED THE ERASURE OF YOUR DATA AND THERE IS NO LONGER A LAWFUL BASIS FOR PRO-CESSING YOUR PERSONAL DATA. CHANGES TO THE PRIVACY POLICY

Vallox may, from time to time, change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend at the top of this page. Vallox encourages you to review this Privacy Policy regularly for any changes. If Vallox will materially change the ways in which Vallox uses and discloses personal data, Vallox will post a notice in the Service and send an e-mail to our registered Users. Your continued use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

11 QUESTIONS OR CONCERNS?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data Vallox holds about you, please con-tact us by using the contact details mentioned in the beginning of this Privacy Policy. Vallox always seeks to swiftly resolve any concerns you may have concerning its Service or the Pri-vacy Policy of the Service.