Privacy Policy
Privacy PolicyVersion 1.0, effective from September 10, 2024.
In this Privacy Policy, we describe the types of data, including Personal Data (collectively, the “Data“), that we process when you use ASEKO Applications, Devices, and Websites (the “Services“), the way we use and share this Data, and your options for accessing and updating the Data.
This Privacy Policy (the “Policy“) may be updated from time to time. The applicable latest published version of the Privacy Policy is available at www.asekopool.com/pool-live-pool-remote-privacy-policy-android-en. The Data controller is ASEKO (as defined below).
Definitions
The following definitions are used in this Privacy Policy:
Applications mean the applications developed and provided to users by ASEKO, namely ASEKO Pool Live, ASEKO Pool Remote, and Pool.aseko.cloud.
ASEKO means ASEKO, spol. s r.o., with its registered office at Maternova 610/5, Kunratice, 148 00 Praha 4, Czech Republic, ID No.: 40766471, Tax ID No.: CZ40766471, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Entry 2870.
Websites mean any websites owned by ASEKO, including but not limited to https://www.asekopool.com.
Terms of Use mean the Terms of Use of the Applications available at www.asekopool.com/pool-live-pool-remote-privacy-policy-android-en.
Personal Data means any data relating to an identified or identifiable natural person.
User Account means a user account created by the User for accessing and using the Applications.
ASEKO Devices mean the physical products of ASEKO pool technology, a list of devices can be found here https://www.asekopool.com/cs/products-cz/.
Any other terms used in this Policy have the same meaning as those assigned to them in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR“).
Why We Collect Data and What We Collect
We collect Data for various reasons, such as:
a) To provide you with the Services or information. We may collect Data, including your Personal Data, which is necessary for us to provide you with the Applications, support, and Services, including license validity checks and updates, providing support, reporting issues and errors, and other processing related to the use of ASEKO Applications, Devices, or information. We may use the collected Data in the development and testing of the Applications. The Personal Data necessary for you to receive the Applications, support, or Services is explicitly provided by you during the creation of a User Account or is collected during the use of the Applications. We may use third-party service providers who act as data processors to assist us in providing the Application products to you or in our business operations. For example, we may use third-party service providers to provide data storage and backup services. With your consent, your Personal Data may also be transferred to third-party service providers acting as independent data controllers who provide products and services complementary to the Applications (further data processing carried out by these service providers is governed by their privacy policies). The legal basis for this Data processing is the performance of the contract between you and us.
b) To protect ourselves from unauthorized use of the Applications or Services. We may collect Data necessary to protect us from unlawful or unauthorized use of the Applications or Services or which is necessary to ensure the security of the Applications or Services, including Personal Data provided by you (see above) and Data collected during the use of the Applications and Services. The legal basis for this Data processing is the legitimate interest of ASEKO in protecting itself against unlawful use of the Applications and Services.
c) Information collected from Website visitors. As a visitor to our Websites, ASEKO servers automatically log certain information, such as your Internet Protocol (“IP”) address, your operating system, browser ID, your activity on our sites, and other information about how you interacted with our Websites. We may also collect this information using cookies or other tracking technologies. We only collect Personal Data that is reasonable or necessary to achieve the purpose of your interaction with ASEKO as a visitor to our Websites. We anonymize the collected information and use such anonymized Data for statistical purposes and market research. We may compile aggregate statistics to help us understand how visitors use our Websites or use the collected information to operate the Websites, market and advertise our activities, operate our activities, improve design and content to better serve you. The legal basis for this Data processing is our legitimate interest in improving the functioning of our Websites and in protecting the rights and interests of ourselves and other users.
In these activities, we may also use the following third-party service providers:
Anonymous analytics:
● Google – we use Google Analytics services on our sites.
d) For the purpose of promoting and selling ASEKO products and Applications. We may use feedback voluntarily provided to us regarding our activities. In accordance with applicable legal regulations, we may use it in the form of quotes or in other ways in accordance with the terms of use. We may also use the Data we collect and aggregate to help determine appropriate marketing and advertising for our activities. In doing so, we may share anonymous aggregated Data with third parties who assist us in this effort and for data collection for marketing purposes through third-party lead forms (e.g., LinkedIn and Meta).
In these activities (including data collection via lead forms), we use the following third-party service providers who act as independent data controllers for their own marketing purposes, or as joint data controllers within the mechanisms provided by these platforms:
- LinkedIn (LinkedIn Ireland Unlimited Company)
- Meta (Meta Platforms Ireland Limited)
The legal basis for this Data processing is our legitimate interest in promoting and marketing our activities. We could provide you with an eventual list of involved third-party service providers upon your request.
e) For ASEKO’s internal records and for the protection of the rights and interests of ASEKO and other users. We may collect Data necessary to preserve evidence of any communication between you and us, your contact information, and any issues or disputes between you and us. We may use and disclose this Data if we believe, in our sole discretion, that it is legitimate and appropriate to protect our rights and interests and the rights and interests of other users of our Websites, or if we believe that a violation of this Privacy Policy has occurred that could affect ASEKO’s interests. The legal basis for this Data processing is our legitimate interest in maintaining internal records and protecting the rights and interests of ourselves and other users.
f) To comply with legal obligations established by law. We may use and disclose your Personal Data if required by law, for example, in response to a court order, or administrative, tax, or other proceedings. The legal basis for this Data processing is the fulfillment of our legal obligations.
In the activities listed above, we may also use the following third-party service providers:
● Ecomail – a service for sending mass email messages to Users in connection with the use of the Applications (their changes, changes in documentation, etc.).
You may object to the processing of your Personal Data for purposes b) to e) at any time.
The categories of Data that are part of the processing may include:
● Name, surname,
● Email address,
● Phone number,
● Registration number of registered ASEKO units,
● Cookies,
● IP address,
● Connection speed, time zone, language,
● Data regarding the device and software you use,
● Browser ID,
● Photos – in case of using the functionality to read the Device barcode,
● Your activity on our Websites and other information about how you interacted with our Websites,
● Data created or uploaded during the use of the Devices, especially Device settings or their names,
● Information within Device settings – GPS location, preferred language,
● Information about transactions made in the Applications (purchase, transaction status, billing information),
● Data provided in email communication if you contact ASEKO.
For the avoidance of doubt, ASEKO states that it does not collect any data regarding the user’s payment card; this is entered directly to the relevant bank operating the payment gateway used, and ASEKO does not have access to it. Data transfer during payment transactions is carried out via the secure HTTPS protocol, which encrypts this information.
If necessary, we will ask for your consent to the collection and processing of your Personal Data as described above. This may occur on the Websites or in the Applications, always in a clear and distinct manner. You can manage your Personal Data as described in the Transparency section below.
Children
Our Websites and Services are not intended for and are not purposefully offered to children. If we become aware that a person under the age of 16 has provided us with information directly, we will make an effort to delete this information from our systems.
Transparency
To respect your privacy, we inform you before using your Personal Data about the categories of Data we collect and the purposes for which we use them. We also inform you in the Policy about the Data management options you have. For this purpose, we use this Policy, the Terms of Use, etc. If you wish to access and manage your Data, you can do so by sending an email to support@aseko.cloud through which you can update and manage your Data. If you wish to obtain more detailed information on this topic, please do not hesitate to contact us.
Sharing
The collected Personal Data is shared with third parties in accordance with this Policy and the Terms of Use.
We may share your Data with certain business partners and third parties who assist us with our business operations, such as service providers according to our instructions. We do not grant these business partners permission to use or disclose Personal Data except when necessary to provide the Services for our or your benefit or to meet legal requirements. We may also share your Data with individual representatives of your company if you act within a legal entity. Furthermore, Personal Data may be shared in the event of providing technical support for the Applications or Devices with a third-party expert (contractual partner).
Your Personal Data may also be shared with other organizations or individuals if we obtain your consent to do so.
In collecting data for marketing purposes, particularly through lead forms on third-party platforms (such as LinkedIn and Meta Platforms), the Data (including Personal Data) is processed by ASEKO as the primary controller, and simultaneously by these platforms. The operators of these platforms (specifically Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company) act in relation to certain activities either as joint data controllers or as independent data controllers, for purposes related to the provision of their advertising and measurement services.
In the event of joint data processing, we adhere to the relevant agreements that stipulate the division of responsibility between us and the platform concerned (e.g., in connection with the Lead Ads feature). Details on the scope and responsibility of the platforms are available in their respective Privacy Policies (e.g., the “Joint Controller Addendum” for Meta Platforms).
We may also share your Data with certain third parties if we are obligated to do so under applicable law (especially with tax authorities or other state authorities exercising their legal powers) or if such sharing is necessary to achieve the purposes defined above (especially with state authorities or possibly with parties harmed by your unlawful conduct).
In accordance with the requirements of the California Consumer Privacy Act (CCPA), we hereby notify you that ASEKO will not a) retain, use, sell, or otherwise disclose any Personal Data for purposes other than those described in this Policy; or b) retain, use, sell, or disclose such Personal Data outside of the direct relationship between you and ASEKO; or c) use Personal Data other than as described in this Policy or the Terms of Use (ii) in any other specific agreement you have entered into with ASEKO.
Security and Data Storage
We understand that it is important that your information is secure and confidential and stored in accordance with the GDPR. We take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, considering the risks associated with processing and the nature of the Personal Data. Only ASEKO internal and authorized persons have access to the Personal Data, unless stated otherwise in this Policy.
We use partners to host our Websites and process your Data in accordance with this Policy. When selecting partners, we ascertain whether they comply with legal regulations and security standards to ensure that your Data is stored in a safe place with appropriate security measures.
The current hosting partner is IXOXI s.r.o., ID No.: 28451082, Nad výpustí 142 149 00 Praha 4.
Location of Stored Personal Data
All servers containing Personal Data processed by ASEKO are located in the Czech Republic, in the TTC DC2 Prague Data Center. Data backup is securely stored on ASEKO premises at Vídeňská 340, Vestec, 252 50, Czech Republic.
Transfer of Your Personal Data
ASEKO may occasionally process or transfer some of your Personal Data (such as name and email address) outside the EU. Any such transfer will be carried out in accordance with applicable data protection laws and this Policy and will be based on an appropriate adequacy decision of the European Commission, in particular on Standard Contractual Clausespublished by the European Commission.
Data Retention, Withdrawal of Consent, Data Access, and Your Rights
If you decide to stop using the Applications or Services at any time, you may request ASEKO to delete the Data from our servers by sending an email to support@aseko.cloud or through the User Account. After deletion, we may retain the data in a pseudonymized form for the purpose of a record regarding the data erasure. The deletion will be carried out within 24-48 hours to allow for revocation in case of error by clicking on the link sent by email.
In general, we retain your Data for as long as is necessary to achieve the purpose for which it was collected. We may retain your Data if necessary for compliance with legal obligations and/or our defense in the event of a breach of the Terms of Use and/or this Policy. We may also keep copies of your Data in Web logs and/or as part of a backup for security reasons, if stated in the Terms of Use or in the text of the consent received prior to the collection of Personal Data. These backups will not be accessible as separately defined information. Furthermore, we may retain Data for the purpose of protection against damages in the event of litigation in accordance with applicable legislation. However, please note that you must create a backup of all data you have placed on our servers in case of loss. In the event that you cease to use our Services, we will not be responsible for the preservation of any of your data.
If you do not log in to any ASEKO Application for a period of 2 years, access to the User Account and Application may be revoked, and the Personal Data “pseudonymized”. The User will be notified of this at least 2 months in advance.
You can manage your Personal Data at support@aseko.cloud or through the User Account at account.aseko.cloud. You are responsible for the accuracy of the Personal Data you provide to us. We expect you to review the Personal Data you provide to us and update your Personal Data or report any discrepancy to ASEKO if one occurs.
EU residents may, in accordance with applicable law, request a copy of the information we hold about them. For this purpose, please contact support@aseko.cloud. We may charge a fee for this service in accordance with applicable law.
In addition to any other rights established in the relevant local applicable data protection legislation, you have the right to: (i) request access to your Personal Data; (ii) request the rectification of your Personal Data; (iii) request the erasure of your Personal Data; (iv) request the restriction of processing of your Personal Data; (v) request data portability of Personal Data; or (vi) object to the processing of your Personal Data.
● Right of access. You have the right to obtain from us confirmation as to whether or not your Personal Data is being processed, and, where that is the case, request access to your Personal Data. The information about the processing of Personal Data includes the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom your Personal Data have been or will be disclosed, etc. However, this right is not absolute, and the interests of others may restrict your right of access. Furthermore, you may have the right to obtain a copy of your Personal Data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
● Right to rectification. You have the right to request from us the rectification of inaccurate Personal Data. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
● Right to erasure (right to be forgotten). In certain circumstances, you may have the right to request that we erase your Personal Data.
●Right to restriction of processing. In certain circumstances, you may have the right to request that we restrict the processing of your Personal Data. In that case, the respective Personal Data will be marked and may only be processed by us for certain purposes.
● Right to data portability. In certain circumstances, you may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those Personal Data to another entity.
● Right to object. In certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us, and we may be required to no longer process your Personal Data.
These rights can be exercised via the email address support@aseko.cloud.
You may also contact ASEKO to obtain up-to-date information on the processing of your Personal Data and all recipients of the Personal Data.
You can file a complaint regarding the processing of your Personal Data with the relevant supervisory authority for Personal Data protection, which in the Czech Republic is the Office for Personal Data Protection, located at Pplk. Sochora 727/27, 170 00 Praha 7- Holešovice, telephone number: +420 234 665 111. More information can be found at https://www.uoou.cz.
Changes to This Policy
This Policy is current as of the effective date set forth above. We may change this Policy from time to time, so please review it periodically. We will post any changes to this Policy on the Websites. If we make any changes to this Policy that materially affect our practices with regard to Personal Data we have previously collected from you, we will endeavor to notify you of such change in advance by highlighting the change on the Websites.
Further Information and Contact
If you have any questions or concerns or believe that this Privacy Policy has been violated in any way, please notify us immediately at support@aseko.cloud.
Cookies and Other Tracking Technologies Used by ASEKO
Version 1.0, effective from September 10, 2024.
Terms used in this document have the same meaning as in the ASEKO Personal Data Processing Policy available at www.asekopool.com/pool-live-pool-remote-privacy-policy-android-en.
We use cookies to identify you when you visit our Websites, to provide the Services when you use our Websites, and to improve our Websites and the Services we provide (the “purpose“). Personal Data collected through these technologies will be stored and processed for a maximum of 2 years.
YOUR CONSENT/WITHDRAWAL OF CONSENT
You acknowledge that the Websites will use cookies, as explained above, for the described purpose.
If you do not wish for Cookies to be stored on your device in connection with your use of the Websites, you must cease using the Websites and disable Cookies through your browser settings for these Websites or overall (see below). Please note that disabling Cookies will affect the functionality of our Websites and may prevent you from accessing some features on the Websites. For more information on how to delete or block cookies, visit: http://www.aboutcookies.org/how-to-delete-cookies/.
TECHNOLOGIES WE USE
Cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. If you have not adjusted your browser settings to refuse cookies, our system will issue cookies as soon as you visit our Websites. There are two types of cookies:
Persistent cookies: These cookies remain on the user’s device for the period specified in the cookie. They are activated each time the user visits the Website that created that cookie.
Session cookies: These cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once the browser is closed, all session cookies are deleted.
Clear GIFs, pixel tags, and other technologies. Clear GIFs are small graphical files with a unique identifier that have a similar function to cookies. Unlike cookies, which are stored on the computer’s hard drive, clear GIFs are embedded invisibly on web pages. In connection with the Websites, we may use clear GIFs (also known as web beacons, web bugs, or pixel tags), including for tracking the activities of Website visitors, facilitating content management, and compiling statistics about Website usage. We and our third-party service providers also use Clear GIFs in HTML emails sent to our customers to track email response rates, ascertain when our emails are viewed, and track whether our emails are forwarded.
“FIRST” AND “THIRD” PARTY COOKIES
The distinction between a “first-party” or “third-party” cookie refers to the domain that places the cookie.
First-party cookies are cookies set by the website that the user is visiting at that time (e.g., cookies placed by us). We may also sometimes use cookies to test new features of our Websites on a portion of our users.
Third-party cookies are cookies that are set by a domain other than that of the Website being visited by the user. If a user visits a website and another entity sets a cookie through that website, it would be a third-party cookie.
HOW TO DELETE AND BLOCK OUR COOKIES
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including cookies that are necessary for the website to function), you may not be able to access all or parts of our Websites. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies as soon as you visit our Websites.
WHAT COOKIES DO WE USE AND WHY?
In general, our Websites use Cookies to distinguish you from other users of our Websites. The cookies used on our Websites, regardless of whether they are used for service purposes or for commercial purposes, are divided into the following categories:
a) Strictly Necessary
b) Performance
c) Functionality
d) Marketing and Targeting
“Strictly Necessary” cookies ensure functions without which our Websites cannot be used for their intended purpose. These cookies are used exclusively by us and are therefore “first-party cookies”. This means that all information stored in these cookies is returned to our Websites. For example, a cookie may record that you are logged into your User Account, and you will remain logged in when visiting various subpages of our website. These cookies thus serve the purpose of enabling us to:
a) Identify you as a user logged in to our Websites,
b) Ensure that you connect to the correct service on our Websites when we make any changes to the way the Websites work,
c) For security purposes.
Acceptance of these cookies is a condition of using the Website, so if you disable these cookies, the Website may not function correctly, and we may not be able to provide our Services to you.
Performance cookies collect information about how you use our Websites, e.g., which pages you visit most often or if you encounter errors. These cookies do not collect any information that could identify you and are used only to help us improve how our Websites work, understand what interests our users, and measure the effectiveness of our advertising.
We use Performance cookies to:
a) Perform web analytics: Provide statistics on how our Websites are used,
b) Obtain data on the number of Website users who have viewed a particular product,
c) Help us improve the Websites by measuring any errors that occur,
d) Test different website designs.
Some of our Performance cookies are managed for us by third parties. We do not permit third parties to use cookies for purposes other than those listed above.
Functionality cookies are used to provide Services or to remember settings to improve your visit. We use Functionality cookies for these purposes:
a) To remember the settings you have used, such as layout, text size, language, preferences, and colors,
b) To remember whether you have engaged with a specific component or product list on the Websites so that it is not displayed again,
c) To display when you are logged into the Websites,
d) To provide and display embedded video content.
Some of these cookies are managed for us by third parties. We do not allow third parties to use cookies for purposes other than those listed above within the Services we provide to you.
Marketing and Targeting cookies are used to find out the visitor’s interests and tailor advertising to their personal needs. This type of cookie is only used on the website asekopool.com.