Hombli, its affiliates and subsidiaries (“we”, “us”, “our”, “Hombli”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

We respect the privacy of our website visitors, and app users, in particular their rights regarding the automatic processing of personal data. We have therefore formulated and implemented a policy on complete transparency with our customers regarding the processing of personal data, its purpose(s) and the possibilities to exercise your legal rights in the best possible way.

If you require any additional information about the protection of personal data, please visit the website of the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): https://autoriteitpersoonsgegevens.nl/nl.

With the continued visit of our website and mobile application you accept these terms of use and you accept the use of cookies and other tracking systems, unless we have provided for another method of accepting cookies on our website.

The current available version of this privacy policy is the only version that applies while visiting our website and app until a new version replaces the current version.

Article 1 – Definitions

1. Website (hereinafter: “Website”) www.hombli.com
2. Hombli Application (hereinafter: ”Hombli App”)
3. Personal Data: information that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.
4. Smart Devices: refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.
5. Apps: refers to the Hombli mobile applications that provide end users remote control to Smart Devices and with the ability to connect to the supplier IoT Platform.
6. Party responsible for processing personal data (hereinafter: “the controller”): Avanca International BV, established at Maanweg 174, 2516 AB Den Haag, The Netherlands, Chamber of Commerce number: 27359105.

Article 2 – Access to the website and Hombli App

Access to and use of the website are strictly personal. You will refrain from using the data and information of this website for your own commercial, political or advertising purposes, as well as for any commercial offers, in particular unsolicited electronic offers.

Article 3 – Website and Hombli App content

All brands, images, texts, comments, illustrations (animated) images, video images, sounds and all the technical applications that can be used to operate this website and more generally all the components used on this website, are protected by the laws on intellectual property. Any reproduction, repetition, use or modification, by any means whatsoever, of all or just part of it, including technical applications, without the prior written permission of the controller, is strictly prohibited. The fact that the controller may not take immediate action against any infringement, cannot be considered as a tacit consent, nor of a waiver of any right to prosecute the infringing party.

Article 4 – Management of the website and Hombli App

For the purpose of proper management of the site, the controller may at any time:

• suspend, interrupt, reduce or decline the access to the website for a particular category of visitors
• delete all information that may disrupt the functioning of the website or conflicts with national or international laws or is contrary to internet etiquette
• make the website and/or Hombli App temporarily unavailable in order to perform updates

Article 5 – Collection of data

1. When you visit the website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the website, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
2. When you make a purchase or attempt to make a purchase through the website, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit/debit card numbers and other related billing information), email address, and phone number.  We refer to this information as “Order Information.”
3. In order to provide our Hombli App services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services. Accordingly, we provide you the option to use the app without registering for an account.
   1. Information You Voluntarily Provide Us:
      Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.
      Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.
   2. Information We Collect Automatically:
      Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
      Log Information: When you use our app, the system and exception log may be uploaded.
      Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as robot cleaner and weather services. When using the Hombli App, there are various scenarios that may require your geo-location. However if you do not wish to share that information you may always decline the pop-up on your screen.
   3. Smart Devices Related Information:
      Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
      Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example, smart cameras may report images or videos captured by it.

Article 6 – Purposes and legal basis for processing Personal Data

The purpose for which we may process information about you are as follows:

1. Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased.
2. Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage.
3. Support: When you encounter problems with your device, and contact us through the help center,
4. Communicate with you;
5. Screen our orders for potential risk or fraud;
6. When in line with the preferences you have shared with us, provide you with newsletters, advertising or other information relating to our products or services. You can opt-out to receive our newsletter at any time.
7. Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain; and
8. If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

 Article 7 – Third Party Services

The Hombli App may contain features to websites and services provided by third parties. If you click on a link to a third party site, you will be taken to websites we do not control. Any information you provide on third-party sites or services may be provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Hombli App. This policy does not apply to the privacy practices of that website. Read the privacy policy of other websites carefully. We are not responsible for these third party sites or services to which links or access are provided through the Hombli App.

Article 8 – Your rights regarding information

1. Pursuant to Article 13 paragraph 2 sub b GDPR each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of his personal data, as well as the right to object to the processing and the right to data portability.
2. You can exercise these rights by contacting us at [email protected].
3. Each request must be accompanied by a copy of a valid ID, on which you put your signature and state the address where we can contact you.
4. Within one month of the submitted request, you will receive an answer from us.
5. Depending on the complexity and the number of the requests this period may be extended to two months.

Article 9 – Legal obligations

1. In case of infringement of any law or regulation, of which a visitor is suspected and for which the authorities require the personal data collected by the collector, they will be provided to them after an explicit and reasoned request of those authorities, after which these personal data do not fall anymore under the protection of the provisions of this Privacy policy.
2. If any information is necessary in order to obtain access to certain features of the website, the controller will indicate the mandatory nature of this information when requesting these data.

Article 10 – Collected data

1. Your personal data will not be used by our partners for commercial purposes.
2. If you encounter any personal data from other data subjects while visiting our website, you are to refrain from collection, any unauthorized use or any other act that constitutes an infringement of the privacy of the data subject(s) in question. The collector is not responsible in these circumstances.

Article 11 – Data retention

The collected data are used and retained for the duration determined by law. We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Article 12 – Cookies

1. A cookie is a small text file placed on the hard drive of your electronic device upon visiting our website. A cookie contains data so you can be recognized as a visitor when you are visiting our website. It enables us to adjust to your needs and it facilitates you to log in on our website. When you visit our website, we inform you about the use of cookies. By continuing to use our website you accept its use, unless we ask permission by other means. Your consent is valid for a period of thirteen months.
2. We use the following types of cookies on our website:
   • Functional cookies: like session and login cookies to collect session and login information.
   • Anonymised Analytic cookies: to obtain information regarding the visits to our website, like numbers of visitors, popular pages and topics. In this way we can adjust our communication and information to the needs of our visitors. We cannot see who visits our sites or from which personal device the visit has taken place.
   • Tracking Cookies: like advertising cookies that are intended to show relevant advertisements. By using these cookies we may deduce your personal interests. Thus (other) organisations may show you targeted advertisements when you visit their website. Tracking cookies make profiling possible and treat categories of people differently when targeting advertisements. Tracking cookies usually process personal data.
3. Specifically, we use the following cookies on our website:
   • Facebook (tracking cookie)
   • Google Adwords (tracking cookie)
4. When you visit our website, cookies from the controller and / or third parties may be installed on your equipment.
5. For more information about using, managing and deleting cookies for each electronic device, we invite you to consult the following link:  https://autoriteitpersoonsgegevens.nl/nl/onderwerpen/internet-telefoon-tv-en-post / cookies # faq

Article 13 – Responsibilities

1. The controller is not liable for any failure, disturbances, difficulties or interruptions in the functioning of the website or the App, causing the (temporary) inaccessibility of the website or of any of its functionalities. You, yourself, are responsible for the way you seek connection to our website. You need to take all appropriate steps to protect your equipment and data against hazards such as virus attacks on the Internet. Furthermore, you are responsible for which websites you visit and what information you seek.
2. The controller is not liable for any legal proceedings taken against you:
   • because of the use of the website or services accessible via the Internet
   • for violating the terms of this privacy policy
3. The controller is not liable for any damages that incur to you or third parties or your equipment, as a result of your connection to or use of the website and you will refrain from any subsequent (legal) action against the controller.
4. If the controller is involved in a dispute because of your (ab)use of this website, he is entitled to (re)claim all subsequent damages from you.

Article 14 – Applicable Law

These conditions are governed by Dutch law. The court in the district where the collector has its place of business has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.

Article 15 – Contact

For questions, product information or information about the website itself, please contact: [email protected].

 29 March 2021