privacy policy for ES Remote

ES Energy Save Holding AB (publ), company registration number 559117-1292, Nitgatan 2, 441 38 Alingsås, (”Energy Save“, ”we” or ”us”) is the controller for the processing of your personal data regarding ES Remote.

Energy Save cares about your personal integrity and strives to always protect your personal data in the best possible way. It is Energy Save's goal to comply with all applicable laws and regulations for personal data protection. This privacy policy explains what kind of information Energy Save collects including why and how Energy Save processes your personal data. The privacy policy describes how we collect, use, store, disclose and protect your personal data and it explains your rights in relation to Energy Save regarding the processing of your personal data.

When we mention the Service, we mean our application ES Remote and related web pages (the “Service”). When you use the Service, interact with us, or as a representative or contact person on behalf of your organization, communicate with us, Energy Save collects your personal data and processes it in accordance with this privacy policy. Therefore, it is important that you read and understand the privacy policy before you interact with us, use the Service or enter into an agreement with Energy Save.

Energy Save uses cookies and similar technologies on our website. You can read more about cookies in section 5.3 and in our Cookie consent form on our website.

Some sites in the Service may contain links to services from third parties and such services may link to the Service. This privacy policy does not cover information about such processing that takes place within other services. Energy Save is not responsible for the activities of third parties, their processing of your personal data or their information practices. If you follow a link to any of these third-party services, please note that they have their own privacy policies which you should check before submitting any personal data to them.

Contents

Section 1: About our processing of personal data. Here we describe what personal data is and how we process personal data in general.

Section 2: Our processing. Here we describe in more detail how we process your personal data when you use our Service and interact with Energy Save.

Section 3: How we collect your data, where it is processed and how we share it. Here we describe how we collect and obtain data, which parties we may share the data with and where your personal data is processed.

Section 4: Security. Here we describe Energy Save's technical and organizational security measures applied to protect your personal data.

Section 5: Your rights. Here you can read about the rights you have towards us and how you can exercise them.

Section 6: Changes to the privacy policy and contact details. As our privacy policy may change over time as a result of new or changed processing activities, we encourage you to continuously read the latest version of the privacy policy and contact us if you have any questions at the contact details provided in this section.

1.                 About our processing of personal data

1.1               What is personal data and what is a processing of personal data?

Personal data is any kind of information that can be directly or indirectly attributed to a living natural person. Encrypted data and various types of electronic identities (e.g. IP numbers) are personal data if they can be linked to natural persons.

Processing of personal data is everything that happens with the personal data. Every action taken with personal data constitutes processing, regardless of whether it is performed automatically or not. Examples of common types of processing are collection, registration, organization, structuring, storage, processing, transmission and deletion.

2.                 Our processing

Energy Save is responsible for the processing of your personal data carried out by Energy Save and such personal data processing carried out by our suppliers on behalf of us.

2.1               When you use the Service

Purpose

Processing performed

Categories of personal data

To be able to provide, evaluate, develop and improve the user experience in the Service as well as development and adaptation of services, products and systems.

 

·      Collecting and storing for the purpose of providing functionality in the Service.

·      Collecting, storing and analysing behaviour in the Service after given consent.

·      Production of documentation to improve IT systems with the aim of generally increasing the security of Energy Save and our users.

·      Customisation of the Service to make it more user-friendly.

·      Collection of data from your ES heat pump in order to improve our services and products.

·      Name and email address.

·      Technical data concerning devices used and their settings (e.g. language setting, IP address, browser settings, time zone, operating system, screen resolution and platform and user-generated data, such as browsing history)

·      Information about how you have interacted with us and used the Service, from where and how long different pages were visited, response times, download errors, how you access and leave the Service, etc.

Lawful grounds:

(i)            Fulfilment of agreement. Processing in connection with our provision of the Service and Premium Services so that we can fulfil our agreement with you.

(ii)           Legitimate interest. In the event that you represent a corporate customer, we process your personal data based on our legitimate interest in providing the Service and the Premium Services in accordance with our agreement with your employer, which we deem to be justified in a balancing of interests between our interest and your interest in protecting your personal integrity.

(iii)          Legitimate interest. Processing also takes place with the support of Energy Save's legitimate interest in developing functions in its systems for adaptation to user behaviour, increased security and increased user-friendliness, which we deem to be justified in a balancing of interests between our interest and your interest in protecting your personal privacy.

(iv)          Consent. Technical data about your device and how you interacted on our website is collected when you visit our website. You are always given an opportunity to approve or deny the use of cookies when you use the Service. You can read more in section 5.3 or in our Cookie policy.

Retention period:

Until the user account is terminated.

See Energy Save’s Cookie Policy for information on retention period for cookies.

Source: The data is collected from the data subject.

Sharing: The data may be shared with our IT service providers.

 

2.2               Provision of support and customer service, case management and processing of data subject requests

Purpose

Processing performed

Categories of personal data

Handling of customer cases, support and customer service.

 

Follow-up of customer service matters.

 

Handling of requests for rectification, deletion or record extracts in accordance with this privacy policy and applicable data protection legislation in order to comply with applicable data protection legislation. 

 

 

·      Identification of the customer for customer service matters and other requests.

·      Email communication with customers and answering questions for customer service.

·      Investigation of complaints and support matters (including technical support).

·      Investigation and handling of complaint cases.

·      Handling requests for rectification, deletion or record extracts according to this privacy policy.

·      Follow-up of Energy Save's handling of your case.

·      Statistics.

·      Name

·      Date of birth

·      Contact details including address, phone number and email address

·      Customer number

·      Case number

·      Conversation history and notes in your customer service case

·      Service and delivery information

·      Technical information about your equipment

Lawful grounds:

(i)             Legitimate interest. The processing takes place with the support of Energy Save's legitimate interest in being able to defend itself against legal claims in the event of complaints, which we deem to be justified in a balancing of interests between our interest and your interest in protecting your personal integrity.

(ii)           Fulfilment of agreement. The processing is required for the fulfilment of Energy Save's commitments according to the agreement with you.

(iii)          Legal obligation. Processing required to fulfil a request for deletion, correction or record extract takes place with the support of Energy Save's legal obligation to satisfy the data subject's request according to the applicable data protection legislation.

Retention period: Until the customer service case has been closed and for a period of 12 months thereafter. When requesting the deletion of personal data in accordance with the applicable data protection legislation, the data is deleted immediately after the request has been fulfilled, with the exception of data in Energy Save's system that Energy Save is obliged by law to save.

Source: The data is collected from the data subject. Case numbers are generated internally by Energy Save's system.

 

2.3               Surveys and questionnaires

Purpose

Processing performed

Categories of personal data

To be able to implement and manage participation in surveys and handle questionnaires and analyse the results thereof and compile statistics.

·      Communication before and after participation in a survey or filling in a questionnaire.

·      Telephone calls and email correspondence with participants.

·      Collection, storage, processing and analysis of responses and data in the survey or questionnaire.

·      Compilation of statistics, which are compiled on a completely anonymous basis.

·      Name

·      Age

·      Contact details (e.g. address, email and phone number)

·      Information provided in the survey or survey including the sales estimate

·      Name or alias that you enter to participate in the survey or fill in a questionnaire

Lawful grounds: Consent. You will be asked to provide your consent in connection with the specific survey or questionnaire.

Retention period: During the time that the survey (including any evaluation) is in progress. You will be given information about the time period of the survey in connection with being invited to participate.

Source: The data is collected from the data subject.

Sharing: Where applicable, the data is shared with partners who help Energy Save with the survey. You will be informed in each individual case if this is applicable for the survey in which you are participating.

 

2.4               Security purposes

Purpose

Processing performed

Categories of personal data

Security purposes and prevention of abuse of service or to prevent and investigate crimes against Energy Save.

·      Collection and storage of IP addresses.

·      Protection and improvement of our IT environment against attacks and intrusions.

·      Preventing spamming, phishing, harassment, attempted unauthorized logins to user accounts, or other actions prohibited by law or our terms.

·      Investigation of possible fraud or other violations of the law.

·      IP addresses

·      Information about how our digital services are used, for example activities and system calls.

·      Technical data concerning devices used and their settings (e.g. language setting, IP address, browser settings, time zone, operating system, screen resolution and platform).

·      User Generated Data

(e.g. browsing history).

Lawful grounds:

(i)            Consent. Technical data about your device and how you interacted with our platform is collected through the use of cookies. You are always given an opportunity to approve or deny the use of cookies when you use the Service. You can read more in section 5.3 or in our Cookie Policy.

(ii)           Legitimate interest. The processing takes place in support of Energy Save's legitimate interest in monitoring security and calls in its systems and to ensure the investigation of legal claims and other rights, which we deem to be justified in a balancing of interests between our interest and your interest in the protection of your personal privacy.

Retention period: The data is stored for 13 months from the IP address's visit or system call to the Service or Energy Save's system, with the exception of ongoing investigations. See also the Energy Save Cookie Policy for information on storage time for cookies.

Source: The data is collected from the data subject.

Sharing: The data may be shared in individual cases with the police or the judiciary within the framework of a police investigation.

3.                 How we collect your data, where it is processed and how we share it

3.1               Collection of personal data

We collect data from you based on your or your organization's interaction with Energy Save and how you use our services.

3.2               With whom we may share your personal data?

Energy Save does not sell your information to anyone else. We only pass on the information in accordance with what is described below. Energy Save always takes the utmost care when transferring your personal data.

·         Legal Obligations. We will share user accounts and personal information when we believe it is necessary for Energy Save to comply with applicable law, to enforce our terms, or to protect rights, property, Energy Save, our users, or others. This includes sharing information with other companies and organizations for fraud prevention. This does not mean under any circumstances that Energy Save sells, rents or shares personal data of users for commercial purposes contrary to this privacy policy.

·         Corporate Transactions. If all or parts of Energy Save's operations are sold or integrated with other operations, your personal data may be disclosed to our advisors, any buyer and their advisors, and passed on to the new owner of the business.

·         Cookies and other similar technologies. If you allow cookies and other similar technologies when using our Service, information about how you use the Service may be collected using cookies and other similar technologies. This information can be used for customer segmentation and for marketing and advertising in the Service. For the purposes stated above, this information is shared with our partners for social media, advertising and analysis to the extent necessary for the purpose.

·         Processors. In cases where it is necessary for us to be able to offer our services, we share your personal data with companies that are so-called processors for us. A personal data processor is a company that processes the information on our behalf and according to our instructions. We have processors who help us with:

(i)        Marketing; and

(ii)       IT services regarding operation and security.

·         When your personal data is shared with processors, it only happens for the purposes for which we have collected the information (e.g. to be able to fulfil our obligations according to the agreement or our terms and conditions).

·         Companies that are independent controllers. We also share your personal data with certain companies that are independent personal data controllers and where Energy Save therefore does not decide how the personal data is processed. Independent controllers can be government authorities towards whom we have obligations to disclose information according to law or in case of suspicion of crime.

When your personal data is shared with a company that is an independent controller, the company's privacy policy and personal data management apply.

3.3               Where do we process your personal data?

We always aim for your personal data to be processed within the EU/EEA. However, in the case of technical support or similar, we may have to transfer the information outside the EU/EEA.

Regardless of the country in which your personal data is processed, we take appropriate technical and organizational measures to ensure that the level of protection is equivalent to ours. In cases where Energy Save uses, or will use, subcontractors or cooperates with partners established outside the EU/EEA area, Energy Save is responsible for ensuring that these partners can guarantee a level of security equivalent to that maintained within the EU.

In order to ensure adequate protection for your personal data during transfers to countries outside the EU/EEA when there is no decision on an adequate level of protection from the European Commission, Energy Save has, in applicable cases, entered into agreements with the respective recipients of personal data containing standard contractual clauses decided and approved by the European Commission, including but not limited to the standard clauses decided by Commission Decision 2021/914/EU or 2010/87/EU.

In addition, Energy Save takes, when the level of protection in the recipient country cannot be considered equivalent to that within the EU/EEA, additional protection measures such as, for example, pseudonymisation, IP anonymisation and encryption. Additional information can be obtained via the contact details below.

4.                 Security

We wish to ensure that your personal data is processed securely. To prevent unauthorized use or exposure of your personal data, we use appropriate and reasonable physical, technical and organizational security measures in relation to the amount and sensitivity of personal data, to ensure an appropriate level of security.

Energy Save also uses i.a. Transport Layer Security (TLS) which is a protocol for the secure transmission of data via the Internet (or other networks). As a customer, you need to check that TLS is not turned off in the settings of your browser. In order to prevent unauthorized access when processing your debit or credit card number, one-way encryption is also used.

5.                 Your rights

5.1               Your rights as a data subject

·              Right to record extracts (right to access)

You have the right to request information free of charge about which personal data we have registered about you and how this is used. If you want such information, you can contact us according to the contact details below. To protect your privacy and your personal data, we may require you to identify yourself in connection with your request.

Keep in mind that if we receive a request for access, we may ask for additional information to ensure efficient handling of your request and that the information is provided to the right person.

·              Right to rectification

Energy Save wants to ensure that your personal data is correct and up to date. Therefore, you can change your personal data in your user account at any time, you are also free to contact our customer service.

·              Right to erasure and right to portability

You can request at any time that we delete personal data concerning you or that we delete your user account in the Service. Energy Save will then delete the relevant personal data if they are no longer necessary for the purposes for which they were collected or otherwise processed. Energy Save will also do this when you withdraw your consent to the processing. In addition, you have the right to request that Energy Save transfer your personal data to another controller in an electronic format.

We may refuse your request if there are legal obligations that prevent us from deleting certain personal data. This can, for example, follow from accounting and tax legislation, banking and money laundering legislation, but also from consumer law legislation. In some cases, our processing may also be necessary for us to establish, assert or defend legal claims. Should we not comply with your request for deletion, we will instead, to the greatest extent possible, block the personal data from being used for purposes other than the purpose that prevents the requested deletion.

·              Right to withdraw consent

If processing is based on your consent, you have the right to withdraw your consent for future processing of your personal data at any time. If you withdraw your consent, we will stop the processing.

·              The right to object to certain types of processing and the right to limitation

You always have the right to object to the processing of your personal data based on a balancing of interests, i.e. processing supported by Energy Save's legitimate interest, and you also have the right to object to us processing your personal data to send you offers or information based on your history (direct marketing). If you object to such processing, we will cease personal data processing and will only process the data to establish, exercise or defend legal claims, to protect the rights of others or if you have given your consent.

Furthermore, you have the right to request that Energy Save limit its processing of the personal data in certain cases. If you believe that the personal data we process is not correct, you can request limited processing during the time we need to check whether the personal data is correct. If you have objected to processing based on a legitimate interest assessment, you can request limited processing for the time we need to check whether our legitimate interests outweigh your interests in having the data deleted.

·              Right to lodge a complaint with a supervisory authority

You can file a complaint with the Swedish Authority for Privacy Protection (IMY) if you believe that Energy Save's processing of your personal data is not in accordance with applicable law.

5.2               How do we handle social security numbers?

We will only process your social security number when it is clearly justified with regard to the purpose, necessary for secure identification or if there is some other considerable reason. We always minimize the use of your social security number as much as possible by, in cases where it is sufficient, using your date of birth instead.

5.3               Cookies

In order to be able to deliver our services with the highest possible quality, Energy Save uses cookies and similar technical means of storage in the Service.

When you use the Service for the first time, you will be asked if you agree to our use of cookies. You can remove cookies from your browser at any time and adjust your settings for the use of cookies. You can read about how to do this in our cookie policy which can be found at the link below.

Here you can read Energy Save's policy for cookies and similar technical storage devices, which provides more information about which cookies and pixels are in the Service, who places them and what they are used for.

6.                 Changes to the privacy policy and contact details

6.1               Changes

Energy Save reserves the right to make changes to this privacy policy at any time to the extent that the changes are necessary. All changes are published in the Service. You should therefore review this policy periodically to ensure that you are happy with the changes. In the event of changes of material importance, we will, however, notify you via e-mail, if you have notified us of your email address, that changes have taken place.

If the changes concern such personal data processing that we carry out based on your consent, we will give you the opportunity to give your consent again.

6.2               Contact details

If you have any questions related to this privacy policy, if you suspect that there may have been a breach of it or if you wish to contact us regarding our processing of your personal data, please contact Energy Saves by sending a letter or email to the addresses as listed below.

Energy Save AB
Email: cloud@energysave.se

Postal address: Nitgatan 2, 441 38 Alingsås

The privacy policy was last updated 21-08-2023