Privacy policy of Extralink Smart Life application
Privacy policy of Extralink Smart Life application
Effective date: 17.04.2025 Last updated: 17.04.2025
This Privacy Policy ("Policy") sets out the rules for the processing of personal data and other privacy-related information of Users ("Users") using the Extralink Smart Life mobile application ("Application"). The Application belongs to: BATNA Sp. z o.o.
Olgi Boznańska 3e Street, 42-202 Częstochowa
NIP: 573-290-14-61
Correspondence address: ul. 1 Maja 23, 42-217 Czestochowa
E-mail: [email protected]
In this Policy, we explain how we collect, use, store, and share Users' personal data. Please read this document carefully. By using the Application, you accept the terms described in this Policy. If you have any questions, please contact us at: [email protected].
I. DATA CONTROLLER
The administrator of the personal data (hereinafter: "Administrator") is: BATNA Ltd.
Olgi Boznanska street 3e
42-202 Częstochowa
The Administrator determines the purposes and means of processing your personal data within the framework of using the Extralink Smart Life Application.
II. SCOPE OF APPLICATION
This Policy applies to personal data collected within:
Using the Extralink Smart Life Application (i.e., registering an account, logging in, operating the functions and settings of the Application).
Collaboration with smart devices ("Smart Devices") that the User connects and configures using the Application (e.g., cameras, controllers, sensors, home appliances, health monitoring devices, etc.).
Other interactions where Users provide us with personal data through communication channels provided by the Controller (e.g., support tickets, feedback).
III. TYPES OF DATA PROCESSED:
Data Provided Voluntarily by the User
Account registration data: first and last name (optional), email address, phone number (optional), username/password. This data is used to create and maintain the User's account in the Application and for authentication during login.
Profile data: profile picture (if the User adds it), nickname, language settings, time zone, etc.
Information related to handling support tickets: when contacting us through support forms, emails, or other channels, we may request email address, phone number, or other necessary data to resolve the issue.
Additional information: depending on the function of the Application, we may request access to certain permissions on the User's mobile device (e.g., camera, microphone, photo gallery, location). This scope is described in detail in section 3.3.
Data Collected Automatically
Information about the mobile device: device type and model, IP address, operating system and version, push identifiers, Application version, language settings, network information, access date and time, logs regarding the operation of the Application.
Data about activity in the Application: information on how the User uses the Application, e.g., clicks, screen transitions, time spent in the Application, errors, and other data necessary to ensure service stability, security, and improve the quality of the Application.
Device Permissions and Access Rights
Depending on the functions the User uses in the Application, we may request permission to enable specific settings in the smartphone's operating system (Android/iOS). The User can always opt out of granting us access, but in that case, some features may not work properly. For example:
Location (GPS): enabled for searching nearby Wi-Fi networks, configuring device automation, displaying weather data, using location-based scenarios.
Camera: allows scanning QR codes when adding devices or attaching photos/videos, e.g., for service requests.
Photo gallery/album: allows uploading photos or videos to the Application (e.g., in error reports, when changing avatars).
Microphone: enables voice commands or recording sound messages (e.g., voice control, creating video content).
Storage (device memory): allows storing and reading local files necessary for the Application to work (e.g., error log records).
Notifications (push alerts): allow displaying alerts related to the Application or devices (e.g., security notifications).
Smart Device Data
When specific smart devices are connected to the Application, we may collect additional information, e.g.:
Device identification data: name, model, MAC address, serial number, device ID, software version, connection status, configuration parameters (e.g., SSID, Wi-Fi password, country or region, network operator).
Operational data: depending on the device's functions (e.g., video or audio recording from a camera, sensor data – temperature, humidity; in the case of health devices – height, weight, BMI, body composition, etc.).
If a device records video or audio (e.g., a camera), the Application may process these recordings only with the User's consent and solely for the purposes for which the User provides such data (e.g., enabled live view, recording alarm events).
IV. PURPOSES AND LEGAL BASES FOR PROCESSING DATA
We process Users' personal data for the following purposes and legal bases:
Providing electronic services – enabling the use of the Application and its functionalities (e.g., creating an account, logging in, configuring devices), managing the account, maintaining services based on Art. 6 sec. 1 lit. b of the GDPR (necessary for the performance of a contract).
Ensuring the security and stability of the Application – including diagnosing faults, preventing abuse, defending against hacker attacks, which constitutes our legitimate interest (Art. 6 sec. 1 lit. f of the GDPR).
Handling support requests and inquiries from Users – e.g., via email, contact functions in the Application, which is necessary for the performance of a contract (Art. 6 sec. 1 lit. b of the GDPR) or based on our legitimate interest in providing adequate customer service (Art. 6 sec. 1 lit. f of the GDPR).
Marketing activities, sending notifications about products and services – based on the voluntary consent of the User (Art. 6 sec. 1 lit. a of the GDPR) or our legitimate interest (Art. 6 sec. 1 lit. f of the GDPR), subject to respecting the regulations on providing electronic services and telecommunications law (including receiving marketing communications).
Profiling and personalizing content – adjusting displayed content, recommendations, analyzing the preferences and behavior of the User in the Application. Processing is based on consent (Art. 6 sec. 1 lit. a of the GDPR) or based on legitimate interest (Art. 6 sec. 1 lit. f of the GDPR), provided that profiling does not produce legal effects or similarly significantly affect the User.
Fulfilling legal obligations – resulting from national or EU regulations (e.g., responding to requests from public authorities), which constitutes the performance of a legal obligation imposed on the Controller (Art. 6 sec. 1 lit. c of the GDPR).
Establishing, pursuing, or defending against claims – based on our legitimate interest (Art. 6 sec. 1 lit. f of the GDPR).
V. SHARING PERSONAL DATA
We may share personal data with the following categories of recipients:
Data processors - companies we work with based on data processing agreements (e.g., hosting providers, IT services, payment operators, auditing, legal firms, etc.).
Affiliated entities within the capital group - if necessary for providing services (with appropriate confidentiality principles).
Public authorities, courts - if required by law or necessary to defend our rights and interests.
Personal data will not be transferred to third countries (outside the EEA) without applying the appropriate safeguards under the GDPR (e.g., standard contractual clauses).
VI. DATA RETENTION PERIOD
Personal data will be stored as long as necessary to fulfill the purposes outlined in this Policy, namely:
Data processed based on a contract - for the duration of the contract for the use of the Application, and then until the expiration of the limitation period for potential claims (generally up to 6 years).
Data processed based on consent - until consent is withdrawn.
Data processed based on legitimate interest - until an objection is raised or the interest ceases to exist.
Legal obligations - for the period required by law, particularly tax or accounting regulations.
After the relevant periods have passed, the data will be deleted or permanently anonymized in a manner that prevents the identification of individuals.
VII. RIGHTS OF DATA SUBJECTS
Under the GDPR, you have the following rights:
Right of access to data – you may obtain confirmation of whether we process your data and receive a copy of it.
Right to rectification – you may request rectification or completion of data if they are incorrect or incomplete.
Right to erasure ("right to be forgotten") – you may request the deletion of data, provided there are no grounds for further processing.
Right to restriction of processing – you may request the restriction of processing in certain situations (e.g., disputing the accuracy of the data).
Right to data portability – in relation to data processed based on consent or a contract and in an automated manner.
Right to object – in the case of data processing based on our legitimate interest or for direct marketing purposes.
Right to withdraw consent – at any time, without affecting the lawfulness of processing carried out before its withdrawal.
To exercise your rights, please contact us at: [email protected] or in another form that is convenient for you. In response, we may request additional information necessary to verify your identity.
VIII. VOLUNTARY DATA PROVISION AND CONSEQUENCES OF REFUSAL
Providing personal data (e.g., during account registration) is voluntary but necessary to use the full functionality of the Application. If the User does not consent or withdraws consent for certain permissions (e.g., access to the camera, location), certain features of the Application may become unavailable.
IX. DATA SECURITY
We use appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration, or destruction, including:
Encrypting network connections and data transmission.
Limiting data access only to authorized employees and data processors.
Regular security audits and tests to prevent potential threats.
Despite our efforts, no method of data transmission over the Internet or data storage provides 100% security. If we become aware of potential security breaches, please contact us immediately.
X. CHILDREN AND MINORS
The Application is not intended for individuals under the age of 13 (or another minimum age required by law in the relevant jurisdiction). We do not knowingly collect personal data from children without the consent of their parents or legal guardians. If we determine that we have inadvertently collected such data, it will be promptly deleted.
XI. CHANGES TO THE PRIVACY POLICY
We reserve the right to amend this Policy, particularly to adapt it to changes in the law, the development of the Application, or modifications in data processing methods. We will inform you of any significant changes by updating the content in the Application and (where possible) by sending email notifications. The "last updated" date is provided at the beginning of this Policy.
XII. CONTACT
If you have any questions or concerns about this Policy or the processing of your personal data, please contact: BATNA Sp. z o.o.
Olgi Boznańska 3e Street, 42-202 Częstochowa
Correspondence address: ul. 1 Maja 23, 42-217 Częstochowa
E-mail: [email protected]
We recommend regularly reviewing this Policy to stay up-to-date with any changes.
Thank you for trusting and using the Extralink Smart Life Application!
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