Privacy Policy
I-VENT d.o.o. (hereinafter: “I-VENT”) developed the I-VENT Remote Control V2 app as a free app (hereinafter: ”App”).
At I-VENT, we respect your right to privacy and strive for the highest level of data protection and privacy.
This policy (together with Terms and Conditions and any other documents referred to in it) covers how we collect, use, disclose, transfer and store information received about users from the European Economic Area, Serbia and the UK (collectively referred to as “Europe”) and/or information obtained about Europe users’ mobile devices through their use of the App.
This policy also sets out the basis for processing any personal data we collect from you while using our App or our services or that you provide.
By using our App and our services, you agree with the collection, storage and use of information according to this Privacy Policy, Slovenia Personal Data Protection Act (Official Gazette of RS, no. 163/2022) and General Data Protection Regulation (GDPR).
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Be assured that the people with access to your data will keep your information confidential and only access and use the information on your account when needed to provide our services and on a need-to-know basis only.
The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, available in the App I-VENT Remote Control V2 unless otherwise defined in this Privacy Policy.
Data Controller
Data controller within the meaning of the General Data Protection Regulation (GDPR) and the applicable Slovenian Personal Data Protection Act is:
I-VENT, pametno prezračevanje, d.o.o., Robbova ulica 2, 1000 Ljubljana, Slovenia.
Information we collect from you
Pursuant to Art. 4 GDPR, ‘personal data’ means all information relating to an identified or identifiable natural person (hereinafter referred to as the “the data subject”); an individual is considered as being identifiable if the individual can be directly or indirectly identified, in particular by means of an identifier such as a name, an identification number, location data, an online identifier, or one or more special characteristics expressing the physical, physiological, genetic, mental, economic, cultural or social identity of this individual.
As further described in this Privacy Policy, we collect your personal data when you use our App. In all of these cases, we will only process personal data that you provide directly to us or that we automatically collect from you as specified in this Privacy Policy. Except as otherwise described in this Privacy Policy or unless you permit us to do so, we will only use personal data for the purposes described in this Privacy Policy or as otherwise disclosed at the time we request such data from you (i.e., from your interactions, use, and experiences with our products).
The personal data we collect is used for providing and improving the App, including monitoring the usage of the App. We do not keep any data other than data strictly necessary for operations.
Some system authorizations shall be required to make full use of our App. You will be asked to grant the appropriate permissions when using the App. Please note, however, that proper use of the App requires access to certain features of your mobile device (smartphone or tablet) and access to your personal information.
You will also need to enable access to the camera for device identification and Bluetooth for connecting the ventilation system to the App.
1. Classical Personal Information
Before using the service for the first time, you need to register and create an account to use all our App’s functions. For the initial registration and creation of an individual account, we process your first and last name, address, e-mail address and phone number (for the purposes of account recovery or unavailability of the e-mail address).
This data is required to set up and manage your user account. Without such personal data, you cannot use our App.
The personal data on your first and last name, e-mail address and phone number can be used for marketing purposes with your consent.
2. Technical Information
In addition to the personal data listed above, whenever you use our App, the server automatically collects data about your device that is necessary for you to use our App and data that enables us to maintain and analyze the functioning of the App, to personalize the operation of the App and to monitor your App use. That information helps us to improve our services and App for enhancing security, analytics, and research purposes to ensure we provide you with the best experience. Such aggregated information does not allow us to identify you.
Such information includes, amongst others, information on the type of device(s) you are using for our App, persistent identifiers, such as IP address, device identifiers, operating system version, the configuration of the App, the time and date of your use of the App, communication between devices, time of use of App and use of units, and other diagnostic data.
As you navigate through and interact with our App, we may use automatic data collection technologies to collect certain information about your devices, data, equipment, and patterns, including:
- details of your use of and visits to our App, including App performance data, time, information on time in each mode, schedules, traffic data, location data, logs, possible problems and other communication data and the resources that you access and use on the App;
- information about your devices, computer, and internet connection, including your IP address, operating system, and browser type; and
- information about the status and use related to connected devices through our App embedded software.
The data is anonymized so that our services can be continuously optimized.
In a non-anonymized form, the above-mentioned log file data, SSID of the user, phone model, local IP address in WiFi and configuration of ventilation units are used solely to detect malfunctions and ensure system security, including detection and tracking of inadmissible access attempts and fraud and abuse attempts. It will be stored for 7 to 14 days for this purpose and then deleted. Log file data whose further storage is required for evidential purposes are excluded from deletion until the final clarification of the respective incident and can be forwarded to the investigating authorities in individual cases.
If you do not provide this information, we will not be able to provide our services, and you will not be able to use the I-VENT Remote Control V2 App.
3. Other Information
After registration, you can use our App to control the ventilation systems available to you and to overview the analytics of the living parameters of the place where the ventilation systems are installed.
According to the above, when you use our App, we collect and store information about average CO2, humidity, temperature, and VOCs (volatile organic compounds) values in your living area for ventilation system adjustment.
We process those living parameters to provide you with information about your indoor air quality, to figure out how to fix or improve your indoor air quality and to gather statistics for further delivering and improving our service and also for analytics purposes.
In addition, we collect and store information concerning your use of the App, log-in to the App, and information about the listed living parameters for data analysis, identifying usage trends, evaluating and improving our service, products, App, and your experience for a period of two years.
Legal basis
In each case where we process your personal data, we do so lawfully under one of the legal basis set out under European and Slovenian data protection law.
The legal basis that we rely upon are the following:
- Consent: The personal data you provide in relation to the use of our App is processed with your explicit and unequivocal consent based on article 6(1)(a) GDPR. You have given Your consent for processing Personal Data by I-VENT by registration and use of service for one or more specific purposes. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection, and we will also make clear how you can withdraw your consent. We will ask for your consent before sharing any information with our advertising partners for interest-based advertising and before conducting any surveys. You can withdraw your consent and cease to use our service from us at any time by deleting your account or by contacting us at appsupport@i-vent.com. In such a case, we will no longer use your personal data for electronic communication. Such withdrawal of consent does not affect the legality of processing your personal data before it.
- Legitimate Interests: We can process your personal data to pursue our legitimate interests, according to Art. 6(1)(f) GDPR. This covers information that we process for the purposes that can be reasonably expected within the context of your use of our App to pursue our legitimate interests to ensure you have the best experience when using our App and to make sure your information is secure. We pay special attention to your data protection rights, ensuring that our legitimate interests do not override your data protection rights. We rely on our legitimate interests for data processing for analytics, attribution, and fraud prevention.
- Legal Obligation: We may also be required to disclose your Personal Data to government or law enforcement officials in response to a lawful request by a public authority or if we have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements according to Art. 6(1)(c) GDPR.
- Contractual Necessity: This covers personal data that we process to provide you with the service that you have requested – and that we have agreed – to provide you, that is, to deliver and improve our services, to provide customer support, to deliver special features in our App. Processing of your personal data is necessary for the performance of our services. The legal basis is Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such personal data and that without such personal data, you will not be able to use our features concerning the App.
Your Rights
In accordance with the GDPR, you have the following rights:
- Right of access (Art. 15 GDPR): You have the right to request confirmation as to whether we process your personal data and, where that is the case, to request access to the personal data we hold about you.
- Right to rectification (Art. 16 GDPR): You have the right to request the correction of possible inaccurate personal data.
- Right to erasure (Art. 17 GDPR): You have the right to request the erasure of Personal Data without undue delay under certain circumstances, e.g., if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based and where there is no other legal ground for processing.
- Right to restriction of processing (Art. 18 GDPR): You have the right to request us to restrict the processing of your personal data under certain circumstances, e.g., if you think the personal data we process about you is incorrect or unlawful.
- Right to data portability (Art. 20 GDPR): Under certain circumstances, you have the right to receive the personal data you have provided us with in a structured, commonly used, and machine-readable format, and you have the right to transmit that information to another controller without hindrance or ask us to do so.
- Right to object (Art. 21 GDPR): You have the right to object to processing your personal data under certain circumstances, particularly if we process your personal data on the legal basis of legitimate interests or if we use your personal data for marketing purposes.
You can review and amend your personal data anytime by contacting us at appsupport@i-vent.com.
If you would like to exercise any of your rights or formally complain about how I-VENT has processed your personal data, you can contact us at appsupport@i-vent.com.
Data Retention Periods
I-VENT only keeps your personal data for a period detertmined by this policy and as long as it is necessary to provide service through the App. If you no longer wish to use our App or you withdraw your consent to processing your personal data for that purpose, we will block your personal data within our system and not use the data for electronic communication anymore.
Data retention periods may be subject to regulation in sector legislation and depend on the national legislation you are based in. Different sector legislation provide for mandatory retention periods which require I-VENT to delete personal data after the expiry of the data retention period.
I-VENT will also retain Technical Data for internal analysis purposes. Technical Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our App, or we are legally obligated to retain this data for longer time periods.
All data is stored at servers located in the EU member states.
Cookies
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites you visit and stored on your device’s internal memory.
Our App does not use these “cookies” explicitly. However, our App may use third-party code and libraries that use “cookies” to collect information and improve their services. You can either accept or refuse these cookies and know when a cookie is being sent to your device. If you refuse these cookies, you may be unable to use some portions of their service.
Service Providers
We may employ third-party companies and individuals due to the following reasons:
- To facilitate our service;
- To provide the service on our behalf;
- To perform App-related services; or
- To assist us in analyzing how our App is used.
We want to inform our App users that these third parties have access to their personal data. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose other than performance of their contractual obligations.
Any sharing of your personal data with other I-Vent entities or service providers will be made under applicable data protection laws and will be limited to the extent necessary. We have carefully selected these companies and continuously monitor their compliance with our instructions. These companies are contractually prohibited from using your personal data for purposes other than those described in this Privacy Policy. The legal basis for our sharing of your personal data with such companies is Art. 28(1) GDPR or, alternatively, our legitimate interests in commissioning those companies with the services described above (Art. 6(1)(f) GDPR).
App store
The service is available in so-called app stores operated by third parties. App download usually requires a prior registration in the respective app store. We have no influence over the personal data processed in this context. Solely responsible in this context is the operator of the respective App Store. Further information can be found in the privacy policy of your respective App Store.
Security
We value your trust in providing us with your Personal Information. Thus, we strive to use all industry-standard efforts and commercially acceptable means of protecting it. While we make every effort to ensure that your information is secure on our system, no method of transmission over the Internet or method of electronic storage is 100 % secure and reliable, and we cannot guarantee its absolute security. We undertake to continue enhancing our security procedures as new technology becomes available.
Links to Other Sites
Our App may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Children’s Privacy
We do not knowingly collect personally identifiable information from children. We encourage all children never to submit any personally identifiable information through the App. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personally identifiable information through the App without their permission. If you have reason to believe that a child has provided personally identifiable information to us through the App, please get in touch with us.
You must be at least 15 years of age to consent to processing your personally identifiable information (in some countries, we may ask for your parent’s or guardian’s approval).
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page.
This policy is effective as of 1 October 2023.
Contact Us
If you have any questions, comments or suggestions about our Privacy Policy, do not hesitate to contact us by sending a written request to the email address appsupport@i-vent.com.
In Ljubljana, 1 October 2023
I-VENT d.o.o.
Milan Kuster, director
