About Us
Arlo Europe Privacy Policy
1st March 2024
General
Your privacy is very important for us at Verisure Arlo Europe DAC, trading as Arlo Europe (“Arlo Europe”, “we”, “us”). At Arlo Europe we take security seriously and we want you to have the same peace of mind about the way we process your personal data as you do from the protection of our security cameras. As the data controller, we are committed to ensuring that all applicable data protection legislation is complied with and that your personal data is appropriately protected.
Scope
This Privacy Notice is applicable to all processing of personal data in relation to you as a current or potential customer and user of our products and services ("User”) as well as if you navigate or interact with our website www.arlo.com (“Website”), (“Website visitor”).
Data controller and data processor
If the domestic purpose exemption does not apply, the User is the data controller for the processing of personal data captured by your Arlo devices. In some situations, we may act as a data processor in terms of the content that you capture and record with your device(s). We do not access your content for any other reason than for providing you with service at your request.
Collected personal data
When you enter into an agreement with us to use our services, you provide us with certain personal data. This may be data such as contact details, login details, order and payment details as well as information about how you use our services. Your personal data may also be made available to us via other sources such as public registers or partners.
To ensure the best experience on our platforms, we also use cookies which may contain personal data collected when you use our website and app. More about our cookie usage can be found in our cookie policy here.
Our processing of your personal data
Your personal data is used to provide you with the best possible information on products and services we offer.
As a user of our services and products, your personal data may be processed for the following reasons
- Administration and performance of contracts,
- Provision of Arlo App which enables you to use our products and services,
- Provide customer service and technical support in relation to our products and services, and
- Training and quality assurance.
When visiting our website, we process your personal data for the following reasons:
- To analyse the use of our Website and ensure functionality, and
- To provide and administer our online shop.
Regardless of whether you visit the website or app your personal data may also be processed for the following purposes:
- Marketing, including individually targeted direct marketing,
- Customer satisfaction surveys, customer reviews and business development,
- Administration in connection with acquisitions, restructuring, etc.,
- Defending our legal interests in the event of a dispute, and
- Complying with legal obligations, including sharing personal data with law enforcement or other authorities.
We do not sell your personal data on to third parties. We do not use personal data for incompatible purposes, and we only retain personal data during the period for which it is necessary.
In some cases, it may be necessary to disclose your personal data to other group entities including IT providers, our outsourced customer service provider or companies with whom we cooperate to provide our products and services. Please see section 7 for more information about who we share your personal data with.
Your rights
You have the right to be informed about how we collect, process, store and use your personal data. You also have a right to request changes to how your personal data is being processed, as well as the right to access to your personal data and in certain situations to have your personal data erased, to restrict the processing of your personal data as well as right to data portability. You can choose to manually delete your account details via the Privacy Centre in the Arlo app. You also have in some instances rights to object to our processing of your personal data. If we process your personal data based on your consent, you always have the right to withdraw your consent. If you believe that we have processed your data in an unlawful manner, you have the right to lodge a complaint to the Data Protection Authority in your home Member State.
Complete Privacy Notice
This is a summary of our Privacy Notice. If you want to know more about how we process your personal data and about your rights as a data subject, please refer to our complete Privacy Notice https://www.arlo.com/en_gb/about-us/privacy-policy .
Contact details
If you have any questions regarding this Privacy Notice, our processing of your personal data or if you wish to exercise your rights, please do not hesitate to contact us:
Verisure Arlo Europe DAC, Arlo Europe, company registration number 658538.
Postal address: Building 4100, Cork Airport Business Park, Cork, Ireland, T22 AP97
Visiting address: Building 4100, Cork Airport Business Park, Cork, Ireland, T22 AP97
E-mail: dpo@verisure.com
Website: www.arlo.com
CONTENT
1 GENERAL |
2 DATA CONTROLLER AND DATA PROTECTION OFFICER |
3 OUR PROCESSING OF PERSONAL DATA |
4 COLLECTION OF PERSONAL DATA |
5 RETENTION OF PERSONAL DATA |
6 WITH WHOM DO WE SHARE PERSONAL DATA? |
7 AUTOMATED DECISION-MAKING, INCLUDING PROFILING |
8 WHERE IS YOUR DATA PROCESSED? |
9 YOUR RIGHTS |
10 WE PROTECT YOUR PERSONAL DATA |
11 COOKIES |
12 CHANGES TO THIS PRIVACY NOTICE |
13 CONTACT DETAILS |
1. GENERAL
1.1 Your privacy is very important to Verisure Arlo Europe DAC, trading as Arlo Europe, registration number 658538,(“Arlo Europe”, “we”, “us”). Our mission is that you feel comfortable with us processing your personal data. The purpose of this Privacy Notice (“Privacy Notice”) is to explain how we ensure that your personal data is processed in compliance with applicable legislation.
1.2 This Privacy Notice is applicable to all processing of personal data in relation to you as a current or potential customer and user of our products and services (“User”) and if you navigate or interact with our website www.arlo.com (“Website”), (“Website visitor”).
1.3. If you as a User choose to process third parties’ personal data via our products and services (and the domestic purpose exemption does not apply), Arlo Europe will process their personal data and assume that you have previously informed them that we will process their personal data as your data processor.
2. DATA CONTROLLER AND DATA PROTECTION OFFICER
2.1 Arlo Europe is the data controller for the processing of your personal data and is thus responsible for ensuring that the processing of personal data complies with applicable legislation. You can find our contact details in the end of this Privacy Notice.
2.2 If the domestic purpose exemption does not apply, the User is the data controller for the processing of personal data captured by the Arlo devices. In some situations, we may act as a data processor in terms of the content that you capture and record your device(s). We do not access your content for any other reason than for providing you with service at your request.
2.3 Arlo Europe forms part of the Verisure group of affiliates (“Verisure” or the “Group”) and personal data is shared between the entities of Verisure. Any handling of personal data for which an Verisure entity is the data controller will be explained in separate privacy notices made available when your personal data is first collected by that Verisure entity, for example where you or the business you work for engages Verisure to provide a service. You can find out more about our Group at www.verisure.com or by contacting us using the contact details in section 13.
2.4 Arlo Europe have designated Rita Crowley as our Data Protection Officer (“Data Protection Officer”). The Data Protection Officer is inter alia responsible for monitoring that our processing of personal data is carried out in accordance with applicable legislation.
2.5 The Data Protection Officer can be reached via the e-mail dpo@verisure.com.
3. OUR PROCESSING OF PERSONAL DATA
3.1 Users:
As a User of our services and products, we process your personal data for the following purposes:
- Administration and performance of contracts,
- Provision of Arlo App which enables you to use our products and services,
- Provision of customer service and technical support in relation to our products and services, and
- Training and quality assurance.
3.2 Website visitors:
As a Website visitor, we process your personal data for the following purposes:
- To analyse the use of our Website and ensure functionality, and
- To provide and administer our online shop.
3.3 Common for both Users and Website visitors:
Regardless of being a User or Website visitor, we also process your personal data for the following purposes:
- Marketing, including direct marketing and individually targeted direct marketing,
- Customer satisfaction surveys, customer reviews and business development,
- Administration in connection with acquisitions, restructuring, etc.,
- Defending our legal interests in the event of a dispute, and
- Complying with legal obligations, including sharing personal data with law enforcement or other authorities.
More information about our processing of personal data is provided in the tables below, including information about why we process your personal data, what personal data we process to achieve those purposes and for how long we retain your personal data for each specified purpose.
PURPOSES
Users |
Administration and performance of contracts |
Provision of Arlo App which enables you to use our products and services |
Provide customer service and technical support in relation to our products and services |
Customer satisfaction surveys, customer reviews and business development |
Website visitors |
To analyse the use of our Website and ensure functionality |
To provide and administer our online shop |
Common purposes for both Users and Website visitors |
Marketing, including direct marketing and individually targeted direct marketing |
Training and quality assurance |
Administration in connection with mergers and acquisitions, restructuring, etc. |
Defending our legal interests in the event of a dispute |
Complying with legal obligations, including sharing personal data with law enforcement or other authorities |
Users |
Administration and performance of contracts | |||
What we do: We use your personal data to provide and administer your placed order(s) and purchase(s) of our products and services. We may also use your personal data to communicate with you, if necessary to provide and administrate your order(s) and purchase(s). Personal data relating to your shipping address is shared with different parcel services depending on your location. We will share your shipping and contact information for the purpose of shipping your order. We also process your personal data to manage any complaints or claims concerning warranties or refunds.
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Categories of personal data: Contact details such as first and last name, address, telephone number and e-mail address. Order and payment details such as order history and payment details. Additional information you provide in your communications with us. |
Legal basis: Performance of a contract. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is performance of a contract, you have the right to data portability. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: The personal data is retained for the duration of the contractual relationship and thereafter for a period which is necessary to handle statutory complaints from you regarding products and services. |
Provision of Arlo App which enables you to use our products and services | |||
What we do:
In order to use our Products and Services, you need to register your Arlo camera in the Arlo App. You are the controller for the use of your Arlo cameras and the content you capture. Arlo Europe is the controller for the provision of the Arlo App. Arlo Europe may capture and either e-mail or send push messages through our apps with portions of the video, depending on your preferences and settings. We can also analyse the data to identify motion or other events. Please note that the processing is done by artificial intelligence and not human monitoring centres. |
Categories of personal data: Contact details such as first and last name, address, telephone number and e-mail address. Images and sounds of your own use of the Arlo products and services, such as images, videos and audio that may include your personal data and the personal data of others if they are present in the monitored area. Device data, such as IP address of the requesting device, data and time of request, information about the operating system, online identifier and volume. |
Legal basis:
Performance of a contract. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is performance of a contract, you have the right to data portability. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: As a controller of the content which is visible to you via the Arlo App, you determine the retention period of the images and sounds of your own use of the Arlo products and services. The content is automatically erased after the end of the chosen Arlo plan or if you, at any time, decide to delete the data earlier, on that date. The data is not recoverable after deletion. The personal data, apart from the images and sounds of your content, is stored and used throughout the contractual relationship and up to 12 months after the contractual relationship ends. |
Provide customer service and technical support in relation to our products and services | |||
What we do: We process your personal data when you get in contact with our customer service, for example regarding a problem with any of our products or services or, if you want to ask questions about the products and services. You have different ways to get in touch with us. This includes contacting our support by email or phone, our website, chat or online tickets. All incoming calls, chat transcripts and online ticket conversations are recorded and stored in a secure third-party database, read more regarding this under the purpose Training and quality Assurance below. |
Categories of personal data: Contact details such as first and last name, address, telephone number and e-mail address. Order and payment details such as order history and payment details. Registration details such as the device number of your Arlo product. Additional information you provide in your communications with us. |
Legal basis: Performance of a contract. For the legal basis of recording of incoming calls, chat transcripts and online ticket conversations, please read more under Training and Quality Assurance below. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is performance of a contract, you have the right to data portability. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: The personal data is stored and used throughout the contractual relationship and up to 12 months after the contractual relationship ends. A recording of a incoming call, chat transcript or email is stored for up to 90 days. |
Training and quality assurance | |||
What we do: We process your personal data to analyse our products and services, for example based on customer surveys. The purpose of these analyses is to improve and develop our products and services, for example by enabling us to optimize our service offering. In order to offer you good customer service and technical support, we at Arlo Europe work with continuous training of our staff. In the context of the training, we may process data about you as a User as we use examples from actual situations involving you as the User and Arlo Europe in the training material to exemplify how the work should be conducted. However, if recorded conversations or other personal data appear in training material, it is always pseudonymised, which means that it is not possible to link the data directly to you without additional information.
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Categories of personal data: Contact details such as first and last name, address, telephone number and e-mail address. Audio material in the form of your incoming call between you and Arlo Europe. Chat transcripts, emails and online ticket conversations. Additional information you provide in your communications with us. |
Legal basis: Consent Before we start recording your message to us or an incoming call to the customer care centre, we give you an option to consent to the recording. If you do not actively consent to the recording, you may continue your communication with us without it being recorded. You may always withdraw your consent by contacting us. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: The personal data is stored and used throughout the contractual relationship and up to 12 months after the contractual relationship ends. The recorded phone calls, chat transcripts or email are stored for 90 days unless you withdraw your consent earlier. |
Website visitors | |||
To analyse the use of our Website and ensure functionality | |||
What we do: We analyse and process your personal data to improve, develop, maintain and manage our website and service including to ensure website functionality. For these purposes, we also use third party tracking services that collect aggregated data about visitors to our websites. For more information about our use of cookies and similar technologies, please read our Cookie Policy here. |
Categories of personal data: Usage data such as cookie information and behaviour on websites such as browsing habits and visit history (e.g. which pages you have visited on our website and the duration of the visit). Device data such as IP-number. |
Legal basis: When processing personal data in the form of cookies which is necessary for the functioning of the website, we base such processing on our legitimate interest, as we assess that our interest in developing, maintaining and improving our website functionality and customer service outweighs your interests or fundamental rights and freedoms requiring protection of personal data. However, when processing personal data in the form of non-essential cookies in order to analyse the use of our website we base the processing on your consent. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is legitimate interest, you have the right to object to processing of your personal data. You can change or withdraw your consent at any time by clicking on the cookie settings icon, which appears at the bottom right of our website. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: Please see our Cookie Policy for more information about for how long we process your information for this purpose. |
To provide and administer our online shop | |||
What we do: Arlo Europe offers you the possibility to purchase its products and services via its own online shop. In order to help you to choose the right products and services as well as to complete the purchase and ensure that your order is sent to you, we process personal data such as payment details and contact details about you. Once you have become a User, please see the purpose “administration and performance of contracts” above. |
Categories of personal data: Contact details such as first and last name, address, telephone number and e-mail address. Order and payment details such as order history and payment details. Additional information you provide in your communications with us. |
Legal basis: Performance of a contract. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is performance of a contract, you have the right to data portability. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: The personal data is stored and used throughout the contractual relationship and up to 12 months after the contractual relationship ends. |
Common purposes for both Users and Website visitors | |||
Marketing, including direct marketing and individually targeted direct marketing | |||
What we do: We process your personal data for marketing purposes, including for the purpose of market segmentation. Our marketing measures may consist of newsletters, telephone calls, sms, information about new products, special offers or competitions. If you wish to receive individually targeted marketing, which is personalised based on your individual preferences(“profiling”), you may consent to such targeted marketing. Targeted marketing may entail, for example, that we analyse your use of our services and products such as when you usually make purchases and tailor our marketing measures based on such individual insights. We may also analyse your browsing habits on our and others’ websites, in our app as well as your transaction history for the purposes of targeted marketing. With your explicit consent, you may share content of your choosing with us which we may then use on our social media channels for marketing purposes. |
Categories of personal data: Contact details such as name, address, telephone number and e-mail address. Browsing habits and visit history such as which pages you have visited on our (and others’) website and the duration of the visit. Order and payment details such as order history and payment information. Additional information you provide us with. |
Legal basis: Legitimate interest as we assess that our interest in sending general and segmented marketing to you outweighs your interests or fundamental rights and freedoms requiring protection of personal data. We ensure that the regulatory requirements for marketing via electronic messages are fulfilled. Consent is the legal basis for processing of personal data for the purposes of individually targeted marketing and other direct marketing as well as sharing the content of your choosing on our social media channels as part of our marketing measures. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is legitimate interest, you have the right to object to processing of your personal data. When we process your personal data based on your consent, you have right to withdraw your consent at any time. If you do not want to receive direct marketing from us, you can object to processing of your personal data at any time. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: For you as our User: the personal data is stored and used throughout the contractual relationship and up to 2 years after the contractual relationship ends assuming that you have not objected to our direct marketing before that. For those who are not yet our User: We retain your personal data for direct marketing purposes for 2 years from receiving your contact details, assuming that you have not withdrawn your consent for direct marketing before that. We will seize with direct marketing immediately if you withdraw your consent. If you choose to become a User, the information provided under the heading “For you as our User” will apply. |
Customer satisfaction surveys, customer reviews and business development | |||
What we do: We use your personal data, such as data derived from statistical compilations, market segmentations and customer satisfaction surveys, for the purposes of conducting market and customer analyses. The results of our analyses are used for improving, replacing and developing new products and services, processes or working methods with the goal of developing our business and constantly improving in meeting our Users’ expectations and needs. For example, we may process your personal data to offer new solutions or to adapt our website and/or app in accordance with our Users’ preferences. We always pseudonymise, and if possible anonymise, the personal data we process to the greatest extent possible for achieving the purpose of the processing. |
Categories of personal data: Contact details such as name, telephone number, postal address and e-mail address. Purchasing and usage patterns such as information about how you use our services and your buying patterns (e.g. during which months/days during the week you usually use our services). Order and payment details such as order history and payment information. Usage data such as cookie information and behaviour on web site such as browsing habits and visit history (e.g. which pages you have visited on our website and the duration of the visit). Additional information you provide us in for example customer surveys.
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Legal basis: Legitimate interest as we assess that our interest in developing our business to better meet our Users’ and Website visitors’ expectations and needs outweighs your interests or fundamental rights and freedoms requiring protection or personal data. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is legitimate interest, you have the right to object to processing of your personal data. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: The personal data is stored and used throughout the contractual relationship and up to 12 months after the contractual relationship ends.
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Administration in connection with mergers and acquisitions, restructuring, etc. | |||
What we do: If Arlo Europe is to be restructured, e.g. divided into several different businesses, or if a third party acquires Arlo Europe or our customer database, Arlo Europe will disclose your personal data and that of other customers to the acquiring company. That company will continue to use your personal information for the same purposes as those stated in this Privacy Notice, unless you are informed otherwise in connection with the transfer. |
Categories of personal data: All categories of personal data listed in this Privacy Notice. |
Legal basis: Legitimate interest as we assess that our interest in enabling an acquisition or restructuring process, assuming that the acquiring company carries out similar operations as Arlo Europe, outweighs your interests or fundamental rights and freedoms requiring protection of personal data. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is legitimate interest, you have the right to object to processing of your personal data. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: If Arlo Europe ceases to exist, e.g. through a merger, liquidation or bankruptcy, or if Arlo Europe’s customer database is transferred to an acquiring company, we will erase the personal data as long as the retention of such personal data is not required by law. In such case, your personal data will be processed in accordance with this Privacy Notice. |
Defending our legal interests in the event of a dispute | |||
What we do: In the event of a dispute, such as a payment dispute, we have the right to use your data for the purpose of establishing, defending or enforcing the legal claim.
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Categories of personal data: All categories of personal data listed in this Privacy Notice.
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Legal basis: Legitimate interest as we assess that our interest in defending our interests in the event of a dispute outweighs your interests or fundamental rights and freedoms requiring protection of personal data. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. As the legal basis of this data processing is legitimate interest, you have the right to object to processing of your personal data. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this Privacy Notice. |
Retention period: The personal data is retained as long as they are needed to establish, defend or enforce a legal claim, for example in the event of a dispute over payment, however a maximum of 3 years. |
Complying with legal obligations, including sharing personal data with law enforcement or other authorities | |||
What we do: We may process your personal data to comply with our legal obligations under applicable law, e.g., legislation regarding accounting, audit and tax. In some jurisdictions sharing of personal data with law enforcement or other authorities may not constitute a legal obligation. We may share personal data even in the absence of legal obligation if we consider it is important for the purpose of prevent or investigate crime.
| Categories of personal data: All categories of personal data listed in Section 3 above.
| Legal basis: Compliance with a legal obligation. or Legitimate interest if the sharing does not constitute a legal obligation as we assess that our interest in providing proportional assistance to competent authorities outweighs your interests or fundamental rights and freedoms requiring protection of personal data. Your rights: You always have the right to request access to your personal data and that we rectify your personal data if it is incorrect. You may also have right to request that we restrict the processing of your personal data and that we erase personal data concerning you. When the legal basis of this data processing is legitimate interest, you have the right to object to processing of your personal data. Information about what these rights entail in practice and how you can exercise your rights is found in Section 9 of this privacy notice.
| Retention period: The personal data is retained for as long as necessary to comply with the applicable legal obligation, for example seven years when it comes to our obligations under the Accounting Act. |
4. FROM WHERE DO WE COLLECT YOUR PERSONAL DATA
4.1 Users: We receive the personal data we process from you. We do not collect personal data from other sources. In case we collect information from other sources, we will inform you about such collection separately.
.4.2 Website visitors: we receive the personal data we process from you. We do not collect personal data from other sources.
4.3 It is necessary that you provide certain personal data to us at Arlo Europe in order to enter into an agreement with us and for us to provide our products and services to you. In case you do not provide us with the necessary personal data, it is not possible for us to provide our products or services to you and thus enter into an agreement with you
5. AUTOMATED DECISION-MAKING, INCLUDING PROFILING
5.1 We do not use automated individual decision-making.
5.2 However, we do use profiling for data analysis and market research, which means that we perform an automated form of processing of your personal data for evaluating personal aspects or make predictions about you. In particular, we pursue the purpose of dividing our customers and interested parties into different target and user groups in the context of market research (User segmentation), for insights into different target groups and their respective usage habits and interests, demographics and the marketing of these findings in the context of advertising services provided to third parties. We also use personal data to administer customer relations, for example to handle customer service matters, price adjustments and customer satisfaction surveys.
5.3 The purpose of our profiling and the types of personal data being processed for profiling is described in detail in Section 3 above under the purpose of providing individually targeted direct marketing. None of the aforementioned processing results in significant or legal decisions being made about you on a wholly automated basis.
5.4 If you have any questions regarding the profiling, please do not hesitate to contact us. You will find our contact details in Section 13 below. If you do not wish us to use profiling for the purpose of providing individually targeted direct marketing, you always have the right to object to such processing by contacting us. We will cease to use your personal data for that purpose when we have received your objection.
6. RETENTION OF PERSONAL DATA
6.1 We will only retain your personal data for as long as it is needed for the purposes we collected the personal data and as described in this Privacy Notice. When we no longer need your personal data we will remove the personal data from your systems and databases, including any back-ups. More specific retention periods are provided in the tables above in Section 3, under the heading “Retention period”.
7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA
7.1 We may share your personal data with reliable external parties, such as to other group companies, IT providers and companies with whom we partner to provide our services. We may also need to disclose personal data at the request of public authorities or to other parties in the context of court proceedings, mergers and acquisitions or similar. In the tables below, you will find information about which external parties we may disclose personal data to, and which categories of personal data will be disclosed in such case.
Categories of personal data that are shared: | |
Companies belonging to the Verisure Group | All categories of personal data. |
Arlo Inc. which provides the platform for the Arlo Services | Video material, Arlo account information, purchase history and other personal data provided through the platform |
Outsourced Customer support | Contact information such as name, email address, telephone number, and postal address, purchase history data |
Billing providers such as billing systems in order to send out and manage invoices | Contact information such as name, email address, telephone number, and postal address, social security number, purchase history data |
Software providers such as cloud-service providers, platform providers, and data analysts to manage our website, IT systems and store our technical data | Device data such as IP address, Arlo account information, purchase history data |
Sales support providers such as marketing platforms and sales systems | Data derived from the use of cookies, such as device identifiers, location data, IP addresses |
Parcel delivery service providers | Contact information such as name, email address, telephone number, and postal address, purchase history data |
Authority or equivalent third party in connection with audits, court proceedings or other similar purposes. This is in order to comply with legal obligations and to protect our legal interests in the event of a dispute | All categories of personal data. |
The acquirer or other successor in the event of mergers, divestments, restructuring, reorganization, dissolution and other sale or transfer of Verisure's assets | All categories of personal data. |
We will not sell your personal data to any other party.
8. WHERE IS YOUR DATA PROCESSED?
8.1 We aim to always process your personal data in the EU/EEA. In some circumstances we may need to transfer your personal data to a country outside of the EU/EEA (“Third Country”). In case your personal data is transferred to a Third Country, we will ensure that your personal data will continue to be subject to an essentially equivalent level of protection as in the EU/EEA.
8.2 We transfer your personal data to recipients in United Kingdom and Switzerland which are subject to EU Commission’s adequacy decision. This means that the EU Commission has assessed that the level of data protection in this country is essentially equivalent to that of the EU/EEA and that it is therefore possible to transfer personal data to such country without additional safeguards. If the recipient of personal data processes personal data in the United States and participates in the EU-US Data Privacy Framework, we rely on the EU Commission’s adequacy decision for such transfers.
8.3 When we transfer personal data to a Third Country which is not subject to an adequacy decision, or where the recipient is not subject to the EU-US Data Privacy Framework, we apply a relevant transfer mechanism, that is applicable safeguard to ensure that an essentially equivalent level of data protection is ensured in the Third Country, specified in the table below.
Country outside of the EU/EEA: | Appropriate safeguards: |
USA | Standard Contract Clauses. |
8.4 Please contact us for more information about the legal basis for a specific transfer or if you want to receive a copy of the relevant transfer mechanism or information about the security measures taken in the context of the transfer. The contact details are provided in the end of this Privacy Notice (Section 13).
9. YOUR RIGHTS
9.1 Our responsibility for your rights
9.1.1 In our capacity of a data controller, we are responsible for ensuring that your personal data is processed in compliance with applicable legislation and that you can effectively exercise your rights as a data subject. You may contact us at any time if you wish to exercise your rights. You will find the contact details in the end of this Privacy Notice.
9.1.2 We have an obligation to respond to your requests to exercise your rights within one month from receiving your request. If your request is complex or if we have received many requests, we have the right to extend this deadline by two more months. If we are unable to take the action you have requested within one month, we will inform you of the reason for the delay and of your right to lodge a complaint with a supervisory authority and to seek a judicial remedy.
9.1.3 You will not be charged for any information, communication or measures that we implement. However, if your request is manifestly unfounded or excessive, we may charge an administrative fee for providing the information or taking the action requested or refuse to act on your request altogether.
9.2 Your right to access, rectification, erasure and restriction
You have the right to request:
a) Access to your personal data. This means that you have the right to request access to personal data that we hold about you. You also have the right to be provided, at no cost, with information about which personal data we are processing about you. We have the right to charge a reasonable administration fee if you request further copies. If you make a request by electronic means, e.g. via email, we will provide you with the information in commonly used electronic format.
b) Rectification of your personal data. At your request or on our own initiative, we will correct, anonymise, delete or complete data that we know to be inaccurate, incomplete or misleading. Also, you have the right to complete any incomplete personal data if something relevant is missing.
c) Erasure of your personal data. You have the right to request that we erase your personal data if there is no compelling reason for us to continue processing the data. Compelling reasons for use to continue processing may be:
i. Processing is necessary for the right of freedom of expression and information,
ii. Processing is necessary to comply with a legal obligation,
iii. Processing is necessary for reasons of public interests in the area of public health,
iv. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes or
v. Processing is necessary for the establishment, exercise or defence of legal claims.
Your personal data will be erased if none of the circumstances above are applicable and if
i. The personal data is no longer needed for the purpose for which we collected them,
ii. We process your personal data based on your consent and you withdraw your consent,
iii. You object to us processing your personal data which is based on a legitimate interest assessment, and we have no compelling interests that overrides your interests or rights and freedoms,
iv. We have processed the personal data unlawfully or
v. We have a legal obligation to erase the personal data.
d) Right to restrict processing: This means that we temporarily restrict the processing of your data. You have the right to request restriction when:
i. You consider your data to be inaccurate and you have requested rectification as defined in paragraph 9.2.1 b), while we establish the accuracy of the personal data,
ii. The processing is unlawful, and you do not want the data to be erased,
iii. As the personal data controller, we no longer need to process the personal data for our processing purposes, but you need them to be able to establish, exercise or defend a legal claim, or
iv. You have objected to processing as defined in paragraph 9.3 while waiting for our assessment of whether our legitimate interests override yours.
9.2.2 We will take all reasonable measures possible to notify everyone who has received personal data as stated in Section 7 above if we have rectified, erased or restricted access to your personal data after you have requested us to do so. At your request, we will provide you with more information about the recipients of your personal data.
9.3 Your right to object to processing
9.3.1 You have the right to object to the processing of your personal data if our processing is based upon legitimate interest or performance of a task carried out in the public interest (see Section 3 above). If you object to such processing, we will only continue to process your data if we have compelling reasons for doing so that override your interests or rights and freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims.
9.3.2 If you do not wish that we use your personal data for direct marketing purposes, you always have the right to opt out at the end of any such email or to change your consent in the Arlo app or on your account online. We will cease to use your personal data for that purpose once you have declined from receiving marketing material.
9.4 Your right to withdraw consent
If we process your personal data based on your consent as the legal basis, you always have the right to withdraw your consent. You can do this at any time by contacting us. Our contact details are found in the end of this Privacy Notice.
9.5 Your right to data portability
9.5.1 You have right to data portability when we process your personal data by automated means and when the legal basis for the processing is your consent or performance of a contract.
9.5.2 Right to data portability means that you have the right to receive the personal data we process about you in machine-readable format which allows you to transfer these personal data to another data controller. You may also request us to transfer the personal data directly to another data controller.
9.6 Your right to complain to the supervisory authority
You have the right to lodge a complaint with the Data Protection Authority in your home Member State if you are not satisfied with our processing of your personal data.
10. WE PROTECT YOUR PERSONAL DATA
We are committed to ensuring that you always feel comfortable when providing your personal data to us. We have therefore implemented both technical and organisational security measures, including access restrictions and regular internal controls, to best protect your personal data against, for example, unauthorised access, alteration or loss. Should a data breach that materially impacts you or your personal data, e.g. entailing risk of fraud or identity theft, occur, we will contact you to explain what has happened and to provide you with advice on how you can mitigate any potential adverse effects of such data breach relevant for you.
11. COOKIES
We use cookies and similar technologies ("cookies") on our website and app in order to, inter alia, improve your experience with us and to simplify and adapt our website to your needs and preferences. If you would like to know more about our use of cookies, please refer to our Cookie Policy here.
12. CHANGES TO THIS PRIVACY NOTICE
12.1 This Privacy Notice was updated in December 2023.
12.2 We have the right to change this Privacy Notice at any time. The latest version of the notice will always be available on our website. Please find the version history of this Privacy Notice below
Date | Description of change |
15 Dec. 2023 | General yearly update |
12.3 When we make changes that are not purely linguistic or editorial, you will be notified of the changes within a reasonable time prior to the changes taking effect. If you do not agree to the changes, you have the right to object to the processing before the changes take effect.