Smart App Privacy Policy

  • INTRODUCTION
    • Why do we have a Privacy Policy?

At AimLite Lighting Products, we take your privacy very seriously. Our company develops the Smart App products and services under the Smart App brands. We require your personal information to carry out some of our business processes and provide you with a satisfactory customer experience.

This Privacy Policy (“Policy” hereinafter) sets out AimLite Lighting Products’ commitment to the protection of your privacy and aims to establish and maintain your confidence in our privacy practices while engaging with our Smart App system.

We have adopted this Policy to inform you how we collect your personal information via the Smart App, how we protect it and to help you understand what personal information we collect, why we collect it, what we do with it, your privacy rights and choices and how to reach us for questions.

The purpose of this Policy is to ensure that AimLite Lighting Products meets its legal obligations under the Act respecting Access to documents held by public bodies and the Protection of personal information (“Access Act” hereinafter).

This Policy is governed by and interpreted in accordance with the laws of the province of Quebec, Canada. Any dispute arising from or related to this policy will be subject to the exclusive jurisdiction of the courts of the province of Quebec.

We strongly encourage you to take some time to read this Policy in full. If you do not agree to this Policy, please do not provide us with your personal information.

  • What is Personal Information?

For the purposes of this Policy, personal information means any information (or set of information) concerning a natural person that we can use to directly or indirectly identify you. Your phone number, birthday and communication preferences are examples of personal information.

  • When Does This Privacy Policy Apply?

The Smart App system consists of different parts and functionalities which require different types of personal information to provide a satisfactory user experience. This Policy defines how the Smart App collects the personal information of its users and other people. For example, it covers the following:

  • When you use the Smart App.
  • When you use our Smart App products, their functionalities or their applications.
  • When you contact or interact with our consumer care team with regards to the Smart App.

The Policy does not apply to personal information that the law considers public in nature.

  • COLLECTING YOUR INFORMATION
    •  What types of personal information do we collect and why?

We collect and use your personal information differently depending on how you interact with the Smart App, what products you purchase from us, and how you use them. Personal information is collected only when it is necessary to provide users with an enjoyable Smart App experience. More specifically, we collect personal information to:

  • Communicate with you.
  • Ensure the effectiveness and functionality of our products and the Smart App.
  • Understand and improve your experience as a customer on an ongoing basis.
  • Offer useful information and content and promote our services and programs.
  • Meet our legal and regulatory obligations.

Some of your personal information is necessary for our Smart App or for our products to work as intended or to provide you with certain functionalities. If you choose not to share your personal information, we will not be able to provide you with the full functionality of our products, system or applications.

We also collect your personal information if you voluntarily share it with us. This type of data will provide you with more personalized experiences.

Below is an overview of the general categories of information that we collect depending on your use of our products and the Smart App:

Information Source Purpose of collection Examples of Information Obtained
Customer Service Information

We use personal information to provide you with consumer support for the Smart App, respond to your inquiries, fulfill your requests, and deliver general customer service.

 

Additionally, we may use this personal information to improve and customize our products and their functionalities, as well as to train our customer service employees.

When you contact our customer support or communicate with one of our customer service representatives via the Smart App, we will collect the following personal information:

  • A log of your interactions with the Smart App customer service agent.
  • The questions or requests you addressed to our team and the status of these requests.
  • Any additional data sources available to us, if necessary, to provide effective customer support.
Cookies and Similar Tracking Technologies Information We use personal information to provide the requested functionalities, enhance security where applicable, improve our Smart App ecosystem, personalize your experience and suggest products and services that may interest you.

The personal information collected depends on the choices you make. In general, we might collect the following information:

  • User unique ID (stored in a cookie for tracking and may be stored on our servers).
  • IP address, referring URL, browser, operating system cookie information.
  • CSS animations and dynamic content, visitors’ clicks/touches on elements, changes to input field (like text fields, CSS selector or timestamp).
  • Elements and session metadata, input on fields, system errors, window size and changes to size, page snapshot, whether a user clicked on a link, and other events.
  • We do not record any keystrokes.

 
Usage Information Relating to our Products and Their Functionalities

We use this information to provide the requested functionalities in the Smart App, improve or develop our products and new technologies through analytics, personalize our product functionalities to suit you better and support our marketing needs.

 
  • User device information.
  • Log information and usage patterns or behavioural data.
  • Location information, to the extent this is strictly necessary for us to provide you with the requested use of our services.
  • Location data provided by your device using these services will remain on your device.
  • With regards to our Smart App, location data is provided through your operating system, because this is a requirement when enabling the Bluetooth connection to your lights. Your location data will not be shared with us.
  • Other information about your use of our product or your setup.

 
Online Feedback Information We use this personal information to provide other users with insights into the value of our Smart App.

When you use this functionality, we will collect the following personal information:

  • Your comments and review.
  • Your identity (if provided).

 
Social listening Information We use this data to gain an overall view of people’s perceptions of our brand and to resolve issues related to our products and their functionalities.

When you interact or communicate on social media in a public manner, your personal information may be collected by a third party that provides social listening services to us. The personal information collected can include, depending on what you choose to make public, information such as:

 

  • Your publicly displayed name or username.
  • Date of birth or age if publicly available.
  • Topics or areas of interest you have shared or interacted with.
  • Posts, comments, and any other content you have shared publicly.

The collection and use of this information by the third-party social listening service is subject to their privacy policy and terms.
User interactions If you modify your Smart App settings or marketing consent status, these changes will be recorded by our back-end systems.

The back-end systems will collect information which can be considered personal information including:

  • The change request.
  • The timestamp of that request.

 
Contact Forms    If you submit a contact form or sign up for our newsletters or marketing offerings via the Smart App, we will collect certain personal information about you.

The personal information that you submit will be collected to fulfil the purpose for which it was intended.

In general, we might collect the following personal information:

 

  • Full Name.
  • Email Address.
  • Consent status and timestamp.

 
Third-party Information

In addition to our Smart App, we may also obtain information about you from other sources, such as social media platforms, joint marketing partners, or providers of products and functionalities that complement the Smart App ecosystem, such as voice assistant providers.

Once this functionality is enabled, we may collect and process functional data such as registration data, usage and diagnostic information.

We do not receive or collect the audio.

 

The personal information collected is highly dependent on your choices and which third parties are involved.

If you would like to receive specific information regarding this, please contact us.

 

  • Are you required to provide us with your personal information?

When requesting your personal information, we specify whether the information is mandatory and inform you of the consequences if you choose not to provide it. For instance, to arrange a consultation with one of our experts, you must identify yourself and provide your contact details. In contrast, participating in our surveys is completely optional and will not impact the functionality of our products.

  • Do we collect personal information from children?

Our Smart App is designed for use by adults and is not intended for children under the age of 14. We do not knowingly collect information from individuals under this age. If you are under 14, please refrain from sharing your information with us unless you have explicit consent from a parent or guardian.

Protection of children under the age of 14: We strongly recommend that you monitor and supervise your child’s use of our products, systems, functionalities, and applications, including websites and other digital channels, to ensure they do not share personal information with us without your permission.

  • USING YOUR PERSONAL INFORMATION
    • How do we use your personal information?

We use your personal information solely for the purposes we have disclosed to you.

Occasionally, we may wish to use your personal information for additional purposes. In such cases, we will seek your consent in advance.

Below is an overview of the general purposes for which we may use your information:

Purpose Example
Providing support (upon your request)
  • Providing support through various communication channels, including Smart App customer care. You can call, chat, or send us messages via the Smart App.
Personalized Communication
  • Personalized email, messages and other digital channels, such as social media. This includes certain market surveys.
Product and Product Functionality Personalization
  • Personalizing our products and their functionalities by tailoring them to your preferences and interests based on the personal information received through the Smart App.
Compliance With Legal Obligations
  • Disclosing personal information to government institutions or supervisory authorities as required in all countries where we operate, for purposes such as tax and national insurance deductions, record keeping, and reporting obligations.
  • Conducting compliance audits, adhering to government inspections, and responding to other requests from government or public authorities. This includes responding to legal requests such as subpoenas, pursuing legal rights and remedies, and managing any internal complaints or claims.
Defence of legal claims
  • Establishing, exercising, or defending legal claims to which we are or may be subject.
Product development
  • Improving our products, product functionality, or Smart App, as well as developing new technologies or functionalities. This may include conducting certain market surveys

 

  • Do we communicate your personal information?

We do not sell or rent your personal information.

We share your personal information under three specific conditions:

  1. When required by law;
  2. With your explicit consent, or;
  3. With third parties acting on our behalf.

Additionally, we may share your information with third parties when you request or authorize it. Prior to sharing, we diligently ensure that your personal information will be safeguarded with the same level of protection required in Québec.

In certain instances permitted by law, we may share your personal information with third parties without your consent.

  • When and how do we ask for your consent concerning your personal information?

We ask for your written or verbal consent in situations in which the law requires us to do so. For instance:

  • When we wish to collect personal information that you are not required to provide, such as for displaying advertisements tailored to your profile.
  • When a third party requests your personal information and we need your permission to share it.
  • When we wish to use your personal information for purposes other than those previously indicated, and you are under no obligation to authorize this secondary use.

If you do not give consent, we will explain the possible consequences of your refusal.

If you do give consent, we will provide you with the procedure for withdrawing your consent should you change your mind and explain the implications of doing so.

To ensure that your consent is fully informed, we will provide all necessary information in advance in a transparent, clear, and concise manner, enabling you to make an informed decision.

  • When do we communicate your personal information with third parties without your consent?

Smart App’s activities sometimes require us to share your personal information with third parties so they can carry out specific tasks or functions on our behalf. In these situations, we may be required to share your personal information with third parties without your consent. For example, we may communicate your personal information without your consent to the following third parties:

  • Service providers who collect this personal information for us, such as for data hosting purposes.
  • External legal counsel.
  • Regulatory authorities, ministries, public bodies, and government agencies who request it, based on powers granted by law or when this information is necessary for the application of an Act in Québec.
  • Police departments, if the information is necessary for an investigation they are conducting or if the information is the subject of a search warrant or production order.
  • Courts that order us to provide the information.

In cases where we share your personal information with service providers to perform necessary services, we require them, by written contract, to commit to protecting your information through measures that are as strict as our own. We ensure that our suppliers use your personal information solely to provide the services required.

  • Is Your Personal Information Communicated to Other Provinces or Countries?

Yes. However, before doing so, we ensure that your personal information will be protected to the same degree it is here in Québec. The public bodies and government agencies of these other regions similar to those in Québec and Canada may access your information in accordance with their local laws.

  • HOW WE KEEP YOUR PERSONAL INFORMATION SECURE
    • What security measures have we implemented to protect your personal information?

We implement generally recognized security and cyber security standards to protect your personal information for the entire period it is in our possession.

When deciding which measures to apply, we consider several factors, including the sensitivity of the information and the context in which it will be used.

Our security measures fall into three main categories:

1.     Technological security measures Passwords, data encryption, firewalls, management of access privileges, logging of actions of our employees concerning your personal information.
2.     Physical security measures Secure access to our premises and secure locations for our equipment and hardware.
3.     Organizational security measures Only employees who require access to your personal information to perform their duties shall have access to it. Identification and authentication procedures are in place when you contact us or use our Smart App.

 

We review these security measures regularly to ensure they are properly applied and continue to be fully effective and appropriate, given the evolution of our systems and information technologies.

We have also established procedures for detecting and managing security incidents that may affect your personal information. If AimLite Lighting Products becomes aware of a confidentiality breach involving your personal information that constitutes a risk of serious harm to you, we will notify you in writing. In such a case, the Access to Information Commission will also be notified.

A confidentiality breach is defined as any unauthorized access, use, or disclosure of personal information, as well as the loss of such information or any other breach in its protection.

  • How can you help protect your personal information?

We encourage you to take control of your information. Please keep your information up to date and accurate.

When managing access to the Smart App, it is essential that you choose a strong password that only you know. Your password must be complex enough to prevent someone from guessing it based on information found on social media or the Internet. We recommend that you create a password consisting of a mix of uppercase and lowercase letters, special characters, and numbers. Avoid any personal references such as your name or date of birth. You should also change your password regularly and ensure it is different from passwords you use on other sites.

  • What should you do if your personal information is compromised?

If you have reason to believe your personal information has been compromised, please contact our access to information and privacy team immediately.

  • RETENTION OF PERSONAL INFORMATION
    • How long do we keep your personal information?

We use your information to provide you with the best experience possible, from improving our products to delivering customer service.

We retain your personal information only for as long as needed, after which we anonymize or delete it when there is no longer a consumer, legal, or business need for its retention. Anonymization permanently and irreversibly breaks the link between the information and your identity. We are committed to adhering to recognized best practices for anonymization.

If you have questions regarding the retention period applicable to a specific situation, please contact our access to information and privacy team.

  • YOUR RIGHTS AND RESPONSIBILITIES
    • What are your responsibilities concerning your personal information?

It is your responsibility to ensure, to the best of your knowledge, that the personal information you provide us with is accurate, complete, and up to date. Additionally, if you share other people’s personal information with us, you must collect such information in compliance with local legal requirements.

If you decide to sell or share our products with others, please be aware that certain products might locally store personal information related to you or your use of the product. In such cases, if you intend to share, return, or sell the device, please make sure to:

  1. Ensure you are comfortable with third parties accessing any personal information contained within the products if you give them access to the Smart App.
  2. Perform a factory reset of the product before returning or selling it. Instructions on performing a factory reset can be found in the product manual or on our website.
  3. Obtain consent from any individual whose personal information you provide to us as part of your usage.
  • What are your rights regarding your personal information?

You have the right to access your personal information. This means that only you can exercise this right unless you authorize the disclosure of your personal information to a third party.

If you believe that we hold personal information about you that is inaccurate, incomplete, or ambiguous, or if you believe that we have collected, used, disclosed, or retained this information contrary to the Access Act, you have the following rights:

  • Withdraw consent: You have the right to withdraw your consent at any time. This applies where you have previously given your consent to the collection of your personal information.
  • Object to Data Collection: You have the right to object to the collection of your personal information if it is carried out on a legal basis other than your consent.
  • Access your information: You have the right to know if we are collecting your information, to obtain details regarding certain aspects of the collection, and to receive a copy of the collected information.
  • Verify and seek rectification: You have the right to check the accuracy of your information and request updates or corrections.
  • Restrict Data Collection: Under certain circumstances, you have the right to restrict the collection of your personal information. In such cases, your information will be stored, but not collected for any other purpose.
  • Request Deletion: Under certain conditions, you have the right to request the erasure of your information from our records.
  • Lodge a complaint: You have the right to bring a claim before the appropriate forum, as provided for in the Access Act.

Please note that the law provides certain restrictions on the exercise of these rights, and we will advise you if any such restrictions apply.

  • How to submit a request?

If you wish to exercise any of these rights, we may require you to identify yourself and provide proof of identification to verify your request.

Please send your written request for access or correction to one of the responsible officers at AimLite Lighting Products responsible for access to documents and the protection of personal information. A response will be sent to you within 30 days following the receipt of your request.

Their contact information is provided below:

Mr. Pascal Auger
Vice-President IT
AimLite Lighting Products
2233 Rue de l’Aviation,
Dorval, Québec H9P 2X6
privacy@ascotcapitalgroup.com
(514) 342-1199 ext. 1249