This personal data protection policy sets forth the basis upon which JCM processes your personal data when you provide them as a result of accessing, downloading, installing and using the application and agreeing to the HONOA License. Protecting personal data is vitally important to JCM, to which end we believe that properly processing your data, based on transparency with our clients, creates trust and peace of mind.
Who is the data controller?
Identity: JCM Technologies S.A.
Tax ID Number: A-08827974
Headquarters: Carrer Costa d’en Paratge, 6B, 08500 , Vic, Barcelona, Spain
Telephone: (+34) 938 833 231
If you have any questions, requests or concerns regarding how we process your personal data, please contact email@example.com
Which personal data do we process?
The personal data we collect through registration for the service, such as name and surnames, email and address are essential to be able to activate the service, and for the purposes described for Registration in the system. JCM does not process or have access to image or voice data in the system.
We collect precise and approximate location data from users’ mobile devices if they allow us to do so, either when the user has the app in the background or on the screen, for the purposes set forth in services.
Users may use HONOA without allowing JCM Technologies S.A. to collect location data from their mobile devices. However, this may affect HONOA’s functions. For example, if a user does not allow location data to be collected, they cannot use hands-free opening services.
Why are we processing your personal data?
The data collected or received through HONOA shall be processed for the following purposes:
Registration and sign-up in system and administrative management: The data collected are essential to verify your identity. The data you enter must be truthful and updated.
Services: HONOA uses data to provide, personalise, maintain, and improve our services. These services include:
- Registering and managing installation devices
- Remote opening services
- Status control over installations
- Hands-free opening services
- Carrying out operations necessary to continue offering our services, such as correcting software errors and operative problems, conducting data analyses, tests, and studies, and supervising and analysing use and activity trends.
Customer service: to answer questions, requests for information, improvements or queries you may have regarding the service
Service analysis and improvement: to better understand user needs and expectations and in order to improve our service, JCM may process information to improve HONOA service and functions.
Compliance with legal obligations: there may be regulations mandating the storage of personal data to comply with certain legal obligations or to provide for liabilities. For example, the General Data Protection Regulation enables blocking personal data or individuals who have exercised their right to deletion during the period wherein liabilities may arise, so as to be able to file, exercise or defend oneself against claims. Your data may also be kept to prevent us from sending you sales communications, if you have requested to no longer receive them.
How long will we store your data?
The personal data provided shall be stored the time necessary for the purpose for which we process your data, to attend to your requests or needs, and to fulfil our legal obligations or to defend our interests or for statistical or historical purposes.
The criteria to determine the period we store your personal data is:
- Personal data obtained to create an account to access the service: as long as the system is operative and installed to open doors.
- Personal data obtained upon contacting us for a query: during the period necessary to attend to your query.
- Personal data obtained upon providing your consent for sending sales communications: until you cancel your subscription.
What is the legitimacy for processing your data?
The legal basis for processing your personal data may be:
- Contract execution: to conduct the service associated with the license obtained through registration in the HONOA video door phone service.
- Legitimate interest related to:
- Statistics: to help us to better understand your needs and expectations, and thereby improve our services.
- To allow the application to function through technical and operational cookies, to maintain tools and guarantee their proper operation, and for ongoing improvement.
- Compliance with legal obligations that entail personal data processing.
With whom can we share your data?
With competent authorities to fulfil legal obligations, such as courts and tribunals and public administrations with competence in the matter.
Your personal data may be processed or stored in countries other than the European Economic Area (EEA), depending on where our service providers are located. Your data shall only be transferred outside the EEA if comparable guarantees are offered.
JCM guarantees an adequate degree of security in the service provided with HONOA, by means of encryption protocols in communication between video door phone devices and interested party devices. Neither JCM nor any third party may access the image and voice information.
The provided service does not permit recording images or reproduction in continuous mode.
User access to images and voice from the system under exclusive personal and household use.
The service user and interested party with access to view the images and voice from the HONOA system may only use the images viewed and access voice for exclusive personal use within the scope of their household.
HONOA is not a video surveillance system for security purposes, so the user must be aware of limitations in this regard.
The user shall not hold JCM liable for inappropriate use of images and voice and must consider the limitations set forth in possible data processing.
What are your rights as an interested party?
Data protection regulations grant you rights so you have control over your data.
How to exercise your rights: you may exercise them at any time by sending an email to firstname.lastname@example.org. To process your request, you must prove your identity.
You are entitled to the following rights:
Access and rectification: the right to obtain confirmation as to whether we are processing your personal data and to access your personal data, and to request that inexact data be corrected.
Deletion: request that your data be deleted when the data are no longer necessary for the purposes for which they were collected, in addition to other reasons.
Processing limitation: interested parties may request that the processing of transferability of their data be limited. In this case, we shall only store your data to file or defend against claims.
Opposition: interested parties may oppose processing their data under certain circumstances set forth in the GDPR. In these cases, we shall cease processing your data or, if applicable, we shall cease doing so for that specific purpose, barring legitimate reasons or to file or defend against possible claims.
Transferability: you may request a download of your personal data to transfer them, as well as send them to a different entity.
Protection of Rights: in the event of any violation of your rights, especially when you have not been able to satisfactorily exercise them, you may file a claim with the Spanish Data Protection Agency (www.agpd.es) or another competent supervising authority. You may also obtain further information on the rights to which you are entitled by addressing these entities.