Terms and Conditions
Protecting your privacy is a core part of Sweet Tech’s mission. Therefore, we have throughout the product development process of “Handy” built in safety and data protection by default.
In order for you to understand these Terms and Conditions we have defined some important concepts:
Personal Data
Means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly. Examples of personal data includes name, an identification number, location data, an online identifier such as IP address, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special Categories of Personal Data
Means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly. Examples of personal data includes name, an identification number, location data, an online identifier such as IP address, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Controller
Means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor
Means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
IN SHORT:
Here is a summary of our commitment to secure your personal data when using the Handy device.
1. What kind of data do we collect and why
1.1 Overview
What data we process depends on your interaction with us and your use of the Handy device. See below for various alternatives:
1.2 Purchase of the Handy device
When you purchase the Handy device from our website, we collect:
We use this information to process your purchase, fulfill your order, accounting purposes and register your Handy device for warranty purposes.
The processing is necessary for the performance of a contract to which you are a party. Legal basis is therefore GDPR art. 6 (1) b.
1.3 Using the Handy device offline
We have developed the Handy device with privacy as default. Therefore, when you use the Handy device offline, we do not process any personal data.
1.4 Connect the Handy device to the online world
Note that default WIFI setting is off. The machine will not connect before the user activity presses the WIFI button. If you choose to connect your Handy device to the internet, we will need to collect:
We need this information in order to connect the Handy device to the internet.
During the internet connection:
The legal basis for the processing is the performance of our contract with you and your consent (GDPR art. 6 (1) b) cf. art. 9 (2) b).
1.5 Using online synchronization with third parties or handyfeeling.com (operator use)
When you as the owner and operator of the Handy device use online synchronization with third party service providers, we collect the personal data in order to connect to the internet, please see sec. 1.4. In addition, we collect:
The purpose of the processing is to enable you to synchronize your Handy device with third part service providers of your choice. We may in the future also use this information to provide payment services.
In order for us to be able to connect your Handy device to the service you want to synchronize with, you will need to provide your unique connection key to the third-party supplier. The unique connection key is generated randomly but will be connected with your name if the third-party supplier you wish to synchronize with has it.
The key alone will not reveal your name. You may at any time regenerate a new unique connection key.
When you use the online synchronization with videos, our processing of your personal data will take place only during the session. When you log off, we will within one hour delete the session data. Please be aware that your Handy device will store the video script file in its persistent memory to enable video synchronization from handyfeeling.com. The data stored inside your Handy device will be deleted when its overwritten by new scripts.
In addition to the processing we perform, the provider of the service with which you synchronize, will be processing your personal data. We will be the controller of the personal data that we process as described in these Terms and Conditions. However, the third-party service provider you chose to synchronize your Handy device with, will be the controller of the personal data that it process for its own purposes. Such data will typically consist of any payment details, product choices and other related data. Please consult the privacy policy of such provider.
The legal basis for the processing is the performance of our contract with you and your consent (GDPR art. 6 (1) b) cf. art. 9 (2) b).
1.6 Using the Handy remote control (remote partner use)
When you use the Handy remote control, a remote partner, such as a girlfriend or boyfriend, may control the device. If you choose to use Handy device this way, we collect the personal data in order to connect to internet, please see sec. 1.4. In addition, we collect:
of the remote partner. We need this information to connect the remote partner to your Handy device.
The purpose of the processing is thus to operate the Handy device remotely.
The legal basis for the processing is the performance of our contract with you and your consent (GDPR art. 6 (1) b) cf. art. 9 (2) b).
The processing will take place only during the remote session. This data will be stored in volatile memory and will be gone the moment the connection is finished.
1.7 Update your Handy device
When you update your Handy device, we process:
The data is collected to make sure that your Handy device receives the correct update.
The data is not stored in any persistent medium and is used and deleted after the update request have been fulfilled (<1second). The processing is necessary for the performance of a contract to which you are a party.
The legal basis for the processing is the performance of our contract with you and your consent (GDPR art. 6 (1) b) cf. art. 9 (2) b).
1.8 Complaints
Any complaints must be processed in accordance with our General terms and conditions. We will need the following personal data in order to process your complaint regarding faults and/or defects on your Handy device:
To protect your privacy, please do not include personal identifiable information including photographic or video images as relevant proof.
The processing is necessary for of technical maintenance to ensure the performance of a contract to which you are a party. Thus, the legal basis for the processing is GDPR art. 6 (1) b.
If we require additional information in order to process your complaint, we may request performance and usage details for the unit in question. Under these circumstances we will explicitly ask for your prior consent in accordance with GDPR art. 9 (2) a.
1.9 Contact us
If you contact us we may need to process information that identifies you such as your name, email address and country of residence etc. in order to answer your question or respond to your request, comment or complaint. We may retain this information to assist you in the future and to improve our customer service. We also use your personal data to establish and manage our relationship with you and provide quality service.
We are considered to have a legitimate interest to process your personal data whenever you contact us as the processing is necessary to manage our relationship with you and to improve our services in accordance to GDPR art. 6 (1) f. Since the communication is solely based on your initiative, the processing will be in your interest as well as ours.
2. Where we process your data/third parties
2.1 Service providers
We use third party services for analytics, marketing and hosting.
We will only process your personal data with third parties as described in these Terms and Conditions. The third parties will be responsible for any processing of personal data for their own purposes. Please find links to their privacy policy under the description of each third party below.
2.1.1 Google Analytics:
We use Google Analytics for the purpose of creating a website experience tailored to users’ needs and continuing optimization of our website. In this context, pseudonymized user profiles are created and cookies are used. The information generated includes:
are transmitted to and stored on a server belonging to Google in the USA. The European Standard Contractual Clauses are the legal basis for the transfer.
Sweet Tech will be controller of the personal data that we process for our own purposes of marketing through Google Analytics. However, Google will be the controller of the personal data they process for its own purposes.
Read more: https://policies.google.com/privacy
2.2 Business transactions
Personal data may also be provided to third parties in connection with a business transaction, including a prospective or completed merger, acquisition or stock sale (including transfers made as part of insolvency or bankruptcy proceedings). Any change of corporate control or disclosure for the purpose of determining whether to proceed or continue with such transaction or business relationship will be securely protected by non-disclosure agreements.
3. Safety measures
The protection of your personal data is a high priority for us. Our security measures include physical, technical and administrative measures. Everyone at Sweet Tech who handles personal data has received training and guidance on how to handle personal data safely. We adopt industry standard software and guidelines to protect your personal data and other confidential information.
Handy connects to our servers and communicates with third party service providers and remote-control partners through an encrypted connection (secure socket layer – SSL).
The Handy operator may at any time change the unique connection key.
All communication between users and Sweet Tech’s servers is secured with HTTPS. This is our guarantee that the processing of personal data is in line with legal requirements and with the highest level of security. Please note that HTTP access is not blocked.
Connections between our server and Handy is by encrypted HTTPS connection.
Your Handy is only identified through your changeable Connection Key.
Logs scramble sensitive data like Connection Key and IP addresses. Logs are deleted by default after 7 days.
We will launch a bounty program to hunt down security holes in 2021.
Our product design mythology is anonymity by default and only store the minimum data to get services to work or not store data at all if we do not need it.
4. Your rights as a data subject
Subject to applicable law, you may have certain rights with respect to our processing of your personal data.
We will provide you with the right to have access to a copy of, rectify, correct and update the personal data that we have about you in accordance with GDPR chapter 3. You may also have the right to restrict processing or have your data deleted. If our processing is based on your consent, you may also withdraw any consents you have given at any time. Please contact us at contact@thehandy.com
Also, please let us know if you consider that our processing of your personal data infringes applicable law.
If you believe that we process your data in violation of your rights, you have the right to complain to the Norwegian Data Inspectorate (“Datatilsynet). You should always contact us directly before sending a complaint to the Norwegian Data Inspectorate, so that we can try to resolve or clarify the issue.
5. How long we store personal data about you
We will not to store personal data for longer than needed or instructed by you. We will however retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
6. Changes in the Terms and Conditions
We may update our Terms and Conditions based on changing business practices, technology and legal requirements. Any such changes will be posted on this page. If we make a significant change in the way we use or share your personal information, you will be notified via email and/or through other prominent notice within at least 30 days prior to the changes taking effect.
7. Contact information
Sweet Tech AS,
(organisation/VAT number: NO 920 411 029 MVA)
Lilletorget 1
0184 OSLO
Norway