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Privacy notice

Last updated October 17, 2023

 

This privacy notice for AFI Europe N.V. and its subsidiaries (“AFI”, "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our Services through our Mobile Application ("Services", “Mobile App”), such as when you:

  • Download and use our mobile application (AFI Home), or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

This notice is supplemental to the Privacy Statement on our website at www.afi-home.com, and expands how our Mobile App collects and uses the personal information you provide, for how long it is kept and for which purposes. Please note that if, other than using the Mobile App you are a customer of ours, a business partner or an employee, additional terms may apply to you as prescribed on our website, or in any other agreement we may have with you.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at dataprotection@afi.global or in writing to AFI Europe N.V., Herengracht 456, 1017CA, Amsterdam, the Netherlands

 

  1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you register to the Mobile App or use the Services through it, communicate with us through the Mobile App or in connection to it, when you utilize the Services through the Mobile App, or otherwise when you contact us.

 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Mobile App, the choices you make, and the Services and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • usernames
  • passwords
  • contact preferences
  • contact or authentication data
  • billing addresses

Sensitive Information. Our Mobile App do not collect or process sensitive information. 

 

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). We may also collect information about the phone network associated with your mobile device, your location, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our Mobile App you are utilizing.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the Mobile App. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the operation and security of our Services, for troubleshooting, and for our internal analytics and reporting purposes.

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

  1. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer our Services through the Mobile App, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, to keep your account secured and in working order.
  • To deliver and facilitate delivery of Services to you. We may process your information to provide you with the requested service.
  • To respond to your inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details relevant to the Services you use, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your requests, payments, and other matters related to the Services.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

 

  1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the "data controller" under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. 

 

  1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following third parties. 

 

We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Service Providers. We may share your information with trusted service providers to process it for us, based on our instructions and in compliance with our Privacy Notice and appropriate confidentiality and security measures. For example, we use service providers to help operate our data centers, develop and maintain the Mobile App, deliver our Services, improve our internal business processes, and offer additional support to customers and users.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

In each such case where we engage with such third-parties, we contractually require confidentiality and security measures to safeguard your information in accordance with this Privacy Notice, and prohibit any use of your information for any purpose other than to assist us in providing the Services.

 

  1. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

 

In Short: We may transfer, store, and process your information in countries outside the EU.

 

Our Mobile App is hosted on servers around the world operated by reputable cloud vendors. If you are using our Mobile App or utilizing our Services from the EU, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the USA, Israel and other countries.

 

In any such case where we transfer, store or process your information in such countries, we implement appropriate safeguards in accordance with applicable privacy laws to protect the information we transfer, including by using European Commission approved standard contractual clauses. 

 

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than forty eight (48) months past the termination of your account, however certain information may be kept longer under applicable laws.

 

When we have no longer have a legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. 

 

  1. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.

 

  1. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: Subject to applicable privacy laws you have the right to access, correct or delete your information. You can also object to the use of your data. 

 

We respect and maintain your rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (vi) if applicable, to data portability; and (vii) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. 

 

To exercise your rights and for any query related to your information please contact us. We will consider and timely act upon any request in accordance with applicable data protection laws.

 

If you are located in the EEA and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority.

 

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided above.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may still retain your information in our files if it relates to an ongoing agreement we may have with you, to  prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. 

 

 

  1. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may email us at dataprotection@afi.global or in writing to AFI Europe N.V., Herengracht 456, 1017CA, Amsterdam, the Netherlands.