Honoa: Privacy Policy

Date of last update: 27 March 2024.

1. PURPOSE

This privacy policy regulates how personal data are processed in the Honoa Application (hereinafter, the "Application").

2. DATA CONTROLLER

The controller responsible for processing personal data through the Application is the company JCM Technologies, S.A.U. (hereinafter, "JCM"), with corporate headquarters at Pol. Ind. Sot dels Pradals C/Costa d’en Paratge, 6 B 08500 Vic (Barcelona), contact telephone number +34 938 833 231 and email info@jcm-tech.com.

3. PERSONAL DATA

JCM shall solely collect appropriate, pertinent data limited to needs based on the purposes for which they are processed, as applicable in each case.

The user guarantees the authenticity of the data they provide and shall be the sole party liable for any false or inaccurate statement.

4. PURPOSES OF PROCESSING

The personal data shall be processed by the controller for the following purposes, as applicable to each case:

Maintaining the contractual relationship with the interested party.
Managing registration, maintenance, and de-registration of the user accessible through the Application.
Generation of statistics, both for improving this Application and the JCM Cloud Platform, as well as for the development of future tradeable Services.
Sending communications related to news, deals, contests, drawings, events, and/or corporate information on JCM and its products and/or services.
Prevention, detection, and control over abuse and fraud committed to or through the Application.
Managing compliance with legally stipulated obligations.
Consultation, and if applicable, investigation and response to messages received from Customer Service.

5. LEGITIMACY OF PROCESSING

The legal basis for processing the personal data is the user's consent, which may be granted for the following purposes:

Managing registration, maintenance, and de-registration of the user accessible through the Application.
Sending communications related to news, deals, contests, drawings, events, and/or corporate information on JCM and its products and/or services.
Consultation, and if applicable, investigation and response to messages received from Customer Service.

The user has the right to withdraw their consent at any time, this not affecting the legality of processing before said withdrawal.

The legal foundation for processing of personal data is compliance with a legal obligation, if it has occurred, for the following purposes:

Managing compliance with legally stipulated obligations.
Consultation, and if applicable, investigation and response to messages received from Customer Service.

Processing personal data for the aforementioned purposes is necessary so that JCM can comply with obligations set forth by applicable law.

Finally, the legal basis for processing personal data is the controller's legitimate interest, if it has occurred, for the following purposes:

Prevention, detection, and control over abuse and fraud committed to or through the Application. Interest is based on the data controller's desire to keep the Application a secure place.

6. RECIPIENTS

Data shall only be transferred in the event of a legal obligation to group companies and third parties subcontracted by JCM. Regarding this last point, JCM hereby reports that it will internationally transfer data to providers located in countries that do not have regulations equivalent to European personal data processing regulations. Notwithstanding, JCM guarantees that it shall apply all guarantees and safeguards necessary to preserve user privacy in this data transfer. For more information, please contact the controller at : admin@jcm-tech.com.

7. STORAGE PERIODS

When the legal basis for processing is the user's consent, data shall be stored as long as said consent has not been withdrawn.

In any event, personal data shall be stored throughout the period of time during which the data controller may be held liable according to applicable law. If applicable, the data may be blocked until the pertinent prescription period has elapsed.

8. USER RIGHTS

You are hereby informed that you may exercise your rights, at any time, of accessing, correcting, deleting, limiting, opposing, and transferring your personal data as set forth in personal data protection regulations, by sending a written request to Pol. Ind. Sot dels Pradals C/Costa d’en Paratge, 6 B 08500 Vic (Barcelona, Spain), or to this email address: admin@jcm-tech.com.

Specifically, you may exercise the rights listed as follows:

Accessing your personal data.
Obtaining information on whether companies in the data controller's group are processing your personal data.
Rectifying inaccurate or incomplete data.
Requesting the deletion of personal data when, in addition to other reasons, they are not necessary for the purposes for which they were collected.
Exercising limitation for data processing when one of the conditions set forth in the data protection regulation is met.
Under certain circumstances and for reasons related to your particular situation in terms of data processing, interesting parties may oppose processing. In these cases, JCM shall cease processing your data, for compelling legal reasons, or to file or defend against possible claims.
Obtaining human intervention, to express your point of view and challenge automated decisions made by JCM, if applicable.
Requesting data portability.

In the event of disagreement in terms of how your data is processed, you may file a claim with the Spanish Data Protection Agency, the body that holds authority in this matter, located on Calle Jorge Juan, 6 (28001), Madrid (Spain) (www.aepd.es).

Annex: Service Functions

Date of last update: 27 March 2024.

1. ACCESS MANAGEMENT

Functions

Honoa provides the User with the possibility of remotely managing entrance and exit to all facilities connected to JCM Electronic Devices. This guarantees that the User can use the facilities at any time, provide access to authorised third parties, or block entrance to said establishments with no need to do so in person with a set of keys or remote control. However, using the Software does not impede the use of these mechanisms if the User requires them.

Within this section, JCM has provided two solutions for the User:

Local activation - If the user requires it, it is possible to open the door only with a BLE connection, provided that the User is near the pertinent JCM Electronic Device.
Remote activation - When the User wishes to open or close facilities remotely, they have this option provided that their mobile device and the JCM Electronic Device are connected to a WiFi network or mobile data via GSM.

Permissions

For the described functions, the following permissions are required:

Local activation (via BLE):

Android

lower than 12: location

if hands-free function is enabled, allow location ALWAYS

12 or later: nearby devices and location

if hands-free function is enabled, allow location ALWAYS

if hands-free function is enabled, allow location ALWAYS

Remote activation (via Internet):

Android

12 or later: nearby devices (even if not used)

BLE (even if not used)