SensorSafe Data Privacy Policy

Application: Evenflo SensorSafe

DATA PRIVACY POLICY (“Policy”)

The controller within the meaning of the General Data Protection Regulation (“GDPR”):

Evenflo Company, Inc
3131 Newmark Drive
Miamisburg, OH 45342

 

This Privacy Policy governs the use of the Evenflo SensorSafe software application (“Application”) for mobile devices.

Evenflo SensorSafe is an application that connects your mobile device to the sensor technology located in the chest clips of your child’s seat. User can activate the application and connect to the SensorSafe receiver (connected to the OBD port of the vehicle or otherwise) or the SensorSafe chest clip. User is notified when one or more of their chest clips have come undone, when the child is buckled in their seat for over two hours, temperature becomes too hot or too cold, and if the child remains fastened to its seat after the driver has left the vehicle.

In USA, with use of the : the application registers whether the car is in motion or has stopped for an extended period of time, and sends alerts if a child is still in a car seat.

In EU: the application registers when the user moves away from the SensorSafe receiver (eg. vehicle (OBD port)) or the SensorSafe chest clip and the Bluetooth connection breaks and sends alerts if a child is still in a car seat.

Minors

To create an account and to register and use the Application, you must be 18 years or older.

Obtained information and purpose

User Provided Information

We collect information, including personal information, that you provide to us when you download and register the Application. Registration with us via e-mail or your Facebook Account is required to use the Application. When you register with us and use the Application, you may be asked to provide:

  • Your first and last name;
  • E-mail address (user name) chosen by you;
  • Country;
  • Facebook ID when longing via Facebook Account;
  • Information you enter into our system when using the Application; and
  • Additional data that you voluntarily provide to us, e.g. fields filled in by you that are marked as 'voluntary', uploading pictures to your profile etc.

Automatically Collected Information

Application will automatically obtain the following data:

  • Device type; phone and OS version;
  • Behavior of the user in Application
  • If SensorSafe is being used: information if a child is placed in/out of a car seat; location of the mobile device when engine of the vehicle is started/stopped (in USA) or when Bluetooth connection ;
  • Dates and times of when Application visited;
  • Time zone;
  • City;
  • IP address of your mobile device.

The collected and stored information is mandatory for the registration and also for a proper functioning of the Application.

Access permission to camera

When installing Evenflo SensorSafe, we will give you an option to choose your model of the child car seat by scanning the bar code on the car seat box, allowing the Application to select your car seat model automatically. In addition, users are able to customize their profile by using a camera directly in the Application to take a new photo. For these purposes, the Application needs access to the camera of user’s device.

During the installation process or while using particular features of the Application, we will ask for your permission to access your device’s camera. The collected data will be used only for purposes mentioned above.

If you do not want us to access your camera for the purposes set forth above, you can revoke your permission in the settings of your mobile device. Please be informed, by revoking your permission to access your device’s camera, the functionality of the Application may be limited or restricted.

Real time location

In order to use the features of Evenflo SensorSafe, we need to collect information about the precise location of your mobile device. The location information is needed for functions such as:

  • and
  • The family notification that a child might be left in a vehicle alone. This family alert contains the last location of the device when the vehicle stopped.

By enabling the location function on your devices, you agree and consent to the transmission, collection, maintenance, processing, and use of your location data by us to provide and improve location-based services and functions of SensorSafe.

If you do not want us to use your location information for the purposes set forth above, you should not enable the location permission when prompted in the application or turn off the location permission for SensorSafe in the settings of your mobile device.

Please be informed, by turning off the location function or by revoking your permission to collect and store such information, the functionality of the SensorSafe will be restricted or disabled.

 

How and on which basis we use collected information

We use the information we collect to provide, maintain, protect, and improve our current services and products and to develop new ones as well as for other purposes.

The processing of personal data takes place in accordance with Art. 6 Para 1 GDPR on the basis of the consent granted (Art. 6 Para 1 lit. a)), to fulfill contracts (Art. 6 Para 1 lit. b)) or to fulfill a legal obligation or perform a task in the public interest (Art. 6 Para 1 lit. c)). If necessary, we also process your data in order to protect legitimate interests of Evenflo or third parties (Art. 6 Para 1 lit. f)). A legitimate interest may be for purposes such as to prevent fraud, for internal administrative purposes relating to employees and customers, to ensure network and information security, for optimizing and improving the usability of the services we offer, further development of our products and services.

We use personal information collected through Application as described below and described elsewhere in this Policy to:

  • Facilitate the creation and securing of your account on our network (in accordance with Art. 6 Para. 1 lit. a), b), c), f) GDPR);
  • Provide you with our services (in accordance with Art. 6 Para. 1 lit. a), b), c) GDPR);
  • Identify you as a user in our system (in accordance with Art. 6 Para. 1 lit. a), b), c), f) GDPR);
  • Improve our services, Application, and how we operate our business (in accordance with Art. 6 Para. 1 lit. f) GDPR);
  • Comprehend and improve your experience using our sites, products and services (in accordance with Art. 6 Para. 1 lit. a) b), f) GDPR);
  • Respond to your comments or questions (in accordance with Art. 6 Para. 1 lit. a), b), f) GDPR);
  • Assist our support team in providing services (in accordance with Art. 6 Para. 1 lit. a) b), c), f) GDPR);
  • Make sure we provide you with the most relevant information based on your geographical location (in accordance with Art. 6 Para. 1 lit. a), b), f) GDPR;
  • Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages (in accordance with Art. 6 Para. 1 lit. a), b), c), f) GDPR);
  • Provide you with promotional information, share the company news, trends and updates (in accordance with Art. 6 Para. 1 lit. a), f) GDPR);
  • Link or combine personal data with other information we get from third parties in order to help understand your needs and provide you with better service (in accordance with Art. 6 Para. 1 lit. f) GDPR); and
  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity (in accordance with Art. 6 Para. 1 lit. b), c), d), f) GDPR).

Disclosure of data

Personal data may be disclosed to third parties who act on our behalf for further processing in accordance with the purpose for which the data was originally collected or for other lawful processing, such as delivery of services, marketing, data management, development and maintenance of the Application, customer service or technical support.

We may also disclose your personal data based on legitimate interests to other Evenflo affiliates for internal administrative purposes:

  • gb GmbH (Riedingerstr. 18, 95448 Bayreuth, Germany; register number HRB6225)
  • Columbus Trading-Partners GmbH & Co.KG (Riedingerstr. 18, 95448 Bayreuth, Germany; register number HRA4224)
  • Goodbaby (Europe) GmbH & Co.KG (Riedingerstr. 18, 95448 Bayreuth, Germany; register number HRA4062)
  • Goodbaby Czech Republic s.r.o. (Pobřežní 620/3, 186 00 Praha 8, Czech Republic; register number ID 04790316)
  • Goodbaby US Holdings Inc., USA (225 BYERS ROAD, MIAMISBURG, OH 45342)
  • CYBEX GmbH, 18 95448,Bayreuth, Bayern Germany 
  • Cookielab s.r.o., File number 289052, ID number 06809804, Na vinici 882/31, Strasnice, 100 00 Praha 10

A transfer of data to institutions or third parties in countries outside the European Union (“EU”) or the European Economic Area (“EEA”) takes place insofar as:

  • You have agreed to it,
  • It is needed to execute your orders or perform services we offer,
  • It is required by law,
  • As part of the commissioned data processing,
  • For internal administrative purposes.

In the case your data is processed outside EU/EEA, our service providers or affiliated companies are contractually bound to our instructions and are obliged to ensure strict technical and organizational measures. Besides, personal data is transferred to third countries based on the EU Commission's decision on adequacy pursuant to Art. 45 GDPR, including the EU-U.S. Privacy Shield, or based on the decision of the EU Commission of 05.02.2010 (2010/87/EU) on standard contractual clauses pursuant to Art. 46 para. 2 lit. c) GDPR.

Security

We have taken technical and organizational security precautions to protect your personal data against loss, destruction, manipulation and unauthorized access. Connections between the server and Application are protected by employing HTTPS protocol using the SSL/TLS layer. The identity of the server can be verified with the provided X.509 certificate. Data streams are encrypted using Datagram Transport Layer Security (DTLS), and media streams are encrypted using Secure Real-time Transport Protocol (SRTP). For this purpose, only authorized persons have access to the user’s provided data. All our employees and all individuals involved in information processing are under an obligation to observe user privacy and to ensure the confidential use of personal data.

Duration of storage

After the end of the respective purpose or the expiry of these deadlines, the corresponding data are routinely blocked or deleted in accordance with legal requirements.

Any further storage is only possible:

- if statutory retention and documentation obligations exist (for example, commercial and fiscal retention obligations),

- for the settlement of any warranty or liability claims,

- to assert, exercise or defend against legal claims,

- if there is another exception pursuant to Art. 17 Para. 3 GDPR.

 

Opt-Out Rights

You may uninstall the Application at any time. You may use the standard uninstall process that may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via e-mail at mail to: support@sensorsafeapp.com.

In case of deactivation of Application, please inform us, via e-mail at the above address, if you would like us to delete your personal data that we store. We will comply with such request unless we have a legitimate ground to not delete the data.

Right of access, objection and further rights of the data subject

You may contact us at any time if you have questions relating to the collection, processing, or use of your personal information; or if you wish to request the correction, restriction, transmit or deletion of the same; or if you wish to explicitly cancel your granted consent with effect for the future. In addition, you also have the right to object to the processing in accordance with the statutory provisions. Please note that you have the right to have personal data deleted, where such claim is not barred by any legal obligation to retain this data or we do not have a legitimate ground to keep this data.

Any requests for information or objections can be sent in writing to the postal address given below or sent by e-mail to

Right to lodge a complaint with a supervisory authority

According to Art. 77 GDPR you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes the GDPR.

In Bavaria, the competent supervisory authority is the Data Protection Authority of Bavaria for the Private Sector: https://www.lda.bayern.de/en/index.html

Third party services

We are consistently working on the Application in an effort to ensure high quality and reliability of the Application, as well as improvements to the Application including new features. For these purposes, we use third-party services that may result in collection of certain information. The data processing hereto is based on our legitimate interests according to Art. 6 Para 1 lit. f) GDPR.

Firebase

We use a messaging tool Firebase owned by Google Inc. that allows us to send you real-time notification messages. These messages are essential part of our services and functioning of the Application (Evenflo SensorSafe). We will notify you in four instances (e.g.. when one or more chest clips of your child’s seat have come undone, temperature too hot or too cold, when a child is buckled in his or her seat for over two hours, and if a child remains fastened in his or her seat after the driver has left a vehicle). Firebase Messaging Service uses Instance IDs (it is unique ID to a particular app and device, that give Firebase services a way to refer to specific app instances) to determine which devices to deliver messages to. Firebase services encrypt data in transit using HTTPS and logically isolate customer data.

More about Privacy and Security in Firebase: https://firebase.google.com/support/privacy/

Privacy Policy of Google: https://policies.google.com/privacy

 

Mixpanel

We use functions of the mobile phone analysis service Mixpanel. This service is provided by Mixpanel Inc., incorporated under the laws of the State of Delaware, U.S.A. Mixpanel uses cookies that are stored on the user's device, which enable us to analyze the use of Application by the user. The information generated by the cookies is transmitted to Mixpanel and sent to a Mixpanel Inc. server in the U.S. and stored there. On our behalf, Mixpanel will use the logged page views and page activity within the scope of their analysis. Mixpanel collects and stores user data in alias profiles, which are not linked to personal data. Information on the use of logged data can be viewed on Mixpanel's Privacy policy. The user can prevent the recording of protocols about their activities by activating the 'Opt-Out-Cookie'. Please, note that this 'Opt-Out-Cookie', which prevents the recording of data, will be deleted when all cookies are deleted in the user's browser history.

Contact information

If you have any questions regarding using the Application, Service or these Policy, please email us at support@sensorsafeapp.com or contact us via post to the address given below.

Updated: July 2022