Evolux Privacy Agreement

Privacy Policy of Zutto Technologies Mobile

Effective date: June 1, 2020


Updated: June 1, 2020


Zutto Technologies Inc. and its affiliates (“we,” “us,” “our,” “Zutto Technologies”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our information privacy practices regarding the personal data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):


Evolux mobile app

In this Privacy Policy, “Personal Data” means information that can be used to identify an individual, either from that information alone or from that information combined with other information we may have access to about that individual. “Smart Devices” means non-standard computing devices produced or manufactured by hardware manufacturers, with a human-machine interface and the ability to transmit data by connecting wirelessly to a network. These devices include smart home appliances, smart wearables, smart air purification devices, and so on. “Apps” means the mobile applications developed by Zutto Technologies that give end users remote control of Smart Devices and the ability to connect to the Zutto Technologies IoT platform.


For mobile applications of other brands that run on technology developed by Zutto Technologies, our Customers control all personal data collected through our Products. We collect the information under the direction of our Customers, and the processing of that information is limited to the purpose of providing the service for which our Customers have engaged us. If you are an end customer of one of our Customers and no longer wish to receive communications from one of our Customers that uses our service, please contact the Customer you interact with directly.


What Personal Data We Collect

In order to provide our services, we ask users to provide the personal data necessary to deliver those services. If you do not provide your personal data, we may be unable to provide you with our products or services.


Information You Provide Voluntarily


Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, username, and login credentials. During your interaction with our Products, we may collect additional information about the nickname, profile picture, country code, language preference, or time zone you have entered in your account.
Feedback: When you use the feedback and suggestion features in our Products, we will collect your email address, mobile phone number, and the content of your feedback in order to address your issues and fix device malfunctions in a timely manner.


Information We Collect Automatically


Device Information: When you interact with our Product, we automatically collect information from your device, such as: the MAC address of your devices, IP address, wireless connection information, operating system type and version, app version number, push notification identifier, log files, and mobile network information.
Usage Data: During your interaction with our Sites and Services, we automatically collect usage data related to visits, clicks, downloads, messages sent/received, and other uses of our Sites and Services.
Log Information: When you use our app, system and exception logs may be uploaded.
Location Information: We may collect information about your geographic location, in real time, either precise or approximate, when you use our specific Products or Services, Lloyds Smart.


Information Related to Smart Devices:


Basic Smart Device Information: When you connect your Smart Devices to our Products or Services, we may collect basic information about your Smart Devices, such as: device name, device ID, connection status, activation time, firmware version, and update information.
Information Reported by Smart Devices: Depending on the different smart devices you choose to connect to our Products or Services, we may collect various information reported directly by your smart devices. For example, please enter information about the smart device report.

Purpose and Legal Basis for Processing Personal Data

The purposes for which we may process information about you are described below:


Providing Services to You: We process your account and profile data, device information, usage data, location information, and Smart Device–related information to provide you with the Products and Services you have requested or purchased from us. The legal basis for this processing is the performance of our contract with you under the Terms of Use.
Improving Our Services: We process device information, usage data, location information, and Smart Device–related information to ensure the functions and security of our Products, develop and improve our Products and Services, analyze the effectiveness of our operations, and prevent and track any fraudulent or inappropriate use. The legal basis for this processing is the performance of our contract with you under the Terms of Use.
Non-Marketing Communications: We process your personal data to send you important information about the Services, changes to our terms, conditions, and policies, and/or other administrative information. You cannot opt out of these communications, as this information may be important. The legal basis for this processing is the performance of our contract with you under the Terms of Use.
Marketing Communications: We may process your personal data to provide you with marketing and promotional materials about our Products and Services. In that case, every communication we send you will include instructions that allow you to opt out of receiving future communications of that kind. The legal basis for this processing is your consent. In addition, if you agree to take part in our sweepstakes, contests, or other promotions, we may use your personal data to manage those activities.
Personalization: We may process your account and profile data, usage data, and device information to personalize product design and provide you with services tailored to your needs, such as recommending and displaying information and ads about products suited to your needs and inviting you to take part in surveys about your use of our products. The legal basis for this processing is your consent.
Legal Compliance: We may process your personal data as we deem necessary or appropriate to: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public and government authorities; (d) enforce our terms and conditions; (e) protect our operations, business, and systems; (f) protect our rights, privacy, safety, or property and/or those of other users, including you; and (g) allow us to pursue available remedies or limit the damages we may sustain.

Who Do We Share Personal Data With?

At Zutto Technologies, we only share personal data in the ways described to you. We may share your personal data with the following recipients:


Our third-party service providers who perform specific business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provisioning, IT services, customer support, email delivery services, and other similar services that enable them to provide services to us.
Our customers and other business partners who provide you, directly or indirectly, with your smart devices and/or the networks and systems through which you access and use our Sites and Services.
An affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including, without limitation, in connection with any bankruptcy or similar proceedings). In that case, you will be notified by email and/or a prominent notice will be posted on our website about any change in ownership, new incompatible uses of your personal data, and choices you may have regarding your personal data.
As we deem necessary or appropriate to: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) enforce our terms and conditions; (e) protect our operations, business, and systems; (f) protect our rights, privacy, safety, or property and/or those of other users, including you; and (g) allow us to pursue available remedies or limit the damages we may sustain.
Affiliates or subsidiaries within our corporate family, for the purpose of carrying out ordinary business activities.

Except for the third parties described above, to other third parties only with your consent.


International Transfer of Collected Information

To facilitate our operations, we may transfer, store, and process your personal data in jurisdictions other than the one where you live. The laws in these countries may differ from the laws applicable in your country of residence.


Your Rights Regarding Your Personal Data

We respect your rights and control over your personal data. You may exercise any of the following rights:


Through the “Profile – Personal Center” section


No fee is required, and we aim to respond within 30 days. If you decide to email us, please make clear in your request what information you would like changed, whether you would like your personal data deleted from our database, or let us know what limitations you would like to place on our use of your personal data. Please note that, for security reasons, we may ask you to verify your identity before taking any action you request.


You may:


Request access to the personal data we process about you,
Request that we correct inaccurate or incomplete personal data about you,
Request the deletion of personal data about you,
Request restrictions, temporarily or permanently, on our processing of some or all of your personal data,
Request the transfer of your personal data to you or to a third party where we process the data based on your consent or a contract with you, and where our processing is automated, and
Opt out of or object to our use of personal data about you where our use is based on your consent or our legitimate interests.

Security

We use commercially reasonable physical, administrative, and technical safeguards to protect the integrity and security of your personal data. Zutto Technologies applies a variety of security strategies to effectively ensure the security of user and device data. For device access, Zutto Technologies proprietary algorithms are used to ensure data isolation, access authentication, and authorization requests. For data communication, communication using security algorithms and transmission encryption protocols is used, along with commercial-grade encrypted transmission of information based on dynamic keys. For data processing, strict data filtering and validation and full data auditing are applied. For data storage, all confidential user information is securely encrypted for storage. If you have any reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you may have with us has been compromised), you must notify us of the problem immediately at privacidad@lloydselectronica.com.


Data Retention

We process your personal data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your personal data, and when the retention period ends, we will delete your personal data. Where we cannot do so for technical reasons, we will ensure that appropriate measures are in place to prevent any further use of your personal data.


Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes we make to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice in the mobile apps before the change takes effect. We encourage you to check this page periodically for the latest information about our privacy practices.


Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us at:


Zutto Technologies S.A. de C.V.


Mailing address: Av. Ejército Nacional 505-1602 Col. Granada, C.P. 11520, Miguel Hidalgo, CDMX, Mexico


Email: contacto@lloydselectronica.com