Tewke Privacy Policy

PRIVACY POLICY

This privacy policy sets out how Tewke Limited, a company incorporated under English law under the number 11775040 and whose registered office is 93 Southwark Street, London SE1 0HX (“Tewke”, and also referred to as “we”, “us” or “our” in this privacy policy), uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can [view the full version of the privacy policy here https://tewke.com/privacy-policy/

1. IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)

2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)

3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)

4. HOW WE USE YOUR PERSONAL DATA (paragraph 4)

5. DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)

6. INTERNATIONAL TRANSFERS (paragraph 6)

7. DATA SECURITY (paragraph 7)

8. DATA RETENTION (paragraph 8)

9. YOUR LEGAL RIGHTS (paragraph 9)

10. CONTACT DETAILS (paragraph 10)

11. COMPLAINTS (paragraph 11)

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 12)

13. THIRD PARTY LINKS (paragraph 13)

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how Tewke collects and uses your personal data through your use of this website, including any data you may provide when you register an account with us, sign up to our newsletter, purchase a product or service, take part in a competitionor register to attend an event.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Tewke is the controller and responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

2. Types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data: includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data: includes billing address, delivery address, email address and telephone numbers.
Financial Data: includes bank account and payment card details.
Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
Delivery Information:information relating to the delivery of our products to you.
Tewke Profile Data: when you download and use our mobile apps, you will be asked to register with us and create a profile. Your profile detailsinclude your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Device Data: information about smartphones, mobiles, computers or other electronic devices you connect to our products, website or mobile apps, such as the details about the type of device (which can include unique device identifying numbers), its operating system, the browser you use and applications on the device that connect to our products. It can also include details of your internet service provider, mobile network and your IP address.
Records of your discussions with us, including our customer support team (such as call recordings, webchat and emails:when you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our customer service team, use any in-app messaging feature, post or comment on our Tewke community webpages or contact us through social media such as through Instagram or our Facebook page. We may also monitor and record our phone calls with you to make sure we are living up to the standards we want, as well as relevant laws and regulations.
How you use Tewke products: we will collect information about how you and, where you share access, others are using Tewke products in your home and their performance, what devices are connected to them and how those devices are being used with the Tewke products. For example, this includes information that any other smart devices you connect to your Tewke device about room temperatures, temperature settings, heating schedules, lighting use and schedules, when contact sensors show doors or windows are open or closed, when motion sensors detect movement, water flow events and water temperature, when smartplugs are on or off, and energy usage.
Usage Data: includes information about how you interact with and use our website, our mobile apps, and Tewke products.
Home Profile Data: we will collect information regarding the type and size of home you live in, and if you have smart meters, the data from them.
Location Data: we will collect information about your exact location (including your postcode where our products are in use) when you choose to share that with us and motion information from the motion sensors in your Tewke products that detect movement in your home. For example, you may set up your mobile app to send you a reminder to turn off your lights when you are out of the house, and to do this you will need to share the location of your mobile device with us.
Marketing and Communications Data:includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

You are not required to provide any of the personal information described above to us. However, if you do not do so, you may not be able to use our products and services, or the functionality of our products and services may be reduced.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey;
register to attend an event; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Device Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. We may also receive Device Data about you if you visit other websites employing our cookies.Please see our cookie policy https://tewke.com/cookies-policy/ for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below [DELETE OR ADD TO THIS LIST AS APPROPRIATE]:
Device Data is collected from the following parties:
analytics providers [such as Google based outside the UK];
advertising networks [such as [NAME] based [inside OR outside] the UK]; and
search information providers [such as [NAME] based [inside OR outside] the UK].
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services [such as Recharge Group (CG Services B.V.), Gorgias Inc, Klaviyo Ltd and Shopify International Limited based [inside OR outside] the UK].
Identity and Contact Data is collected from data brokers or aggregators [such as [NAME] based [inside OR outside] the UK].
Identity and Contact Data is collected from publicly available sources [such as Companies House and the Electoral Register based inside the UK].
Other companies’ apps and products provide us with information when you connect them to Tewke products and approve their sharing of personal data with us. For example, if you connect to Amazon Alexa or Google Home, we will receive your information about how you use those apps with our Tewke products.
[ANY OTHER WAYS YOU COLLECT PERSONAL DATA].

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

[AMEND, DELETE OR ADD TO THIS TABLE AS APPROPRIATE]

Purpose/Use	Type of data	Legal basis
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
To carry out market research through your voluntary participation in surveys		Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY]
Investigating misuse of your account	All the personal information we collect	Necessary for the performance of a contract and for the legitimate interest of operating our business
Transfer of Tewke devices to new owner / Tewke customer where those devices have been left in a property after an existing customer has moved out. This involves restoring the device to its factory settings and deleting any data held on the device before it can be transferred to a new owner / customer	The data that may have been stored on the device could include information about the devices that were previously connected to the device, as well as any actions that those devices were asked to perform.	For the legitimate interest of ensuring that devices can be reused to minimise waste.

Direct marketing

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Tewke via [EMAIL, SMS, TELEPHONE, POST] OR You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view in terms of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time [by following the opt-out links within any marketing communication sent to you or by contacting us [LINK] (or through any other opt-out mechanism we might make available).

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations, for product/service warranty registration, appointment reminders, updates to applicable terms and conditions, or checking that your contact details are still correct.

For more information about the cookies we use and how to change your cookie preferences, please see https://tewke.com/cookies-policy/

Service notifications

Our mobile apps will send service notifications directly to your smartphone or device through the app when we have something important or interesting to make you aware of or you have asked to be notified about certain events relating to your Tewke products, e.g. to remind you that your lights are on.

Depending on the service you choose, you may also receive these notifications by text message or email depending on your preferences.

You can turn off service notifications at any time through the app, your smartphone system settings or your online account.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

Internal Third Parties as set out in the [LINK].
External Third Parties as set out in the [LINK].
[Specific third parties [listed in the table Purposes for which we will use your personal data above OR such as [SPECIFIC THIRD PARTIES]].]
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

[IF NO TRANSFERS OUT OF UK OCCUR:] [We do not transfer your personal data outside the UK].

[IF PERSONAL DATA IS TRANSFERRED OUTSIDE THE UK TO SERVICE PROVIDERS]:

[We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place [DELETE AS APPLICABLE]:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, [INSERT NAMES OF COUNTRIES AND RELEVANT ADEQUACY REGULATIONS]. .OR
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the [International Data Transfer Agreement] [OR] [The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers]. To obtain a copy of these contractual safeguards, please contact us at [insert contact email address or link to Contact details (paragraph 10). For further details, see [ ].] OR
[INSERT DETAILS OF ANY OTHER TRANSFER MECHANISMS, E.G. A BESPOKE CONTRACT AUTHORISED BY THE ICO OR AN APPROVED CODE OF CONDUCT OR CERTIFICATION SCHEME AND INSERT DETAILS OF HOW TO OBTAIN A COPY OF THE MECHANISM].

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data’s accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, [please contact us [see Contact details (paragraph 10)] OR [SPECIFIC DETAILS OF WHO TO CONTACT FOR SUBJECT ACCESS RIGHTS]].

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: [DETAILS]
Postal address: [DETAILS]

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [DATE]. [Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Tewke Mobile Application

Any users holding an account with the Tewke mobile application downloaded via the AppStore or Google Play Store can request that their account be deleted and user data wiped from our database. To request account deletion send an email request to contact@tewke.com