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

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 

 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. 

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.

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 as well as targeted marketing through social media and search engines. 

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 personal data such as browsing habits on our and others’ websites, in our app as well as your transaction history for the purposes of targeted marketing.

We can also use your personal data to carry out re-marketing to you, or to target others that may have interest similar to yours by creating  custom and lookalike audiences on search engines and social media. For this purpose, we use data we have obtained from you and about you , which is associated, and then shared,  with a pseudonymous (hashed) identifier in lieu of information that can be used to identify you.  

With your 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.

If you object to our use of your data to create custom and lookalike audiences, you can assert your rights both against us using the instructions in Section 13 at the end of this policy, and/or against the operator of the social platform or search engine:  
- for Facebook : you can change your relevant settings directly through this page : https://www.facebook.com/settings/?tab=consent_settings 
- for Google : https://myadcenter.google.com/home?sasb=true&ref=ad-settings.

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.

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.

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.

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 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.

We may share your data with:

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 search engines, social media platforms and sales systems

Data derived from the use of cookies, such as device identifiers, location data, IP addresses, Arlo account information

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.

Country outside of the EU/EEA:

Appropriate safeguards:

USA

Standard Contract Clauses.

 Date

 Description of change 

 15 Dec. 2023

 General yearly update