Introduction

This privacy policy is designed to assist you in understanding how we collect, use, and process personal data on behalf of users that engage with the Homey website application (the “Platform”). Some of these users are part of a company providing services to the Platform (an “Organisation”), for example, introducing other users or completing services for users introduced to the Platform.

Information Collected

We collect different types of personal data from our Platform. Users and Organisations may provide personal data to us through the Platform in various ways, such as during registration, through communications, or when uploading content within the Platform.

Account registration: Basic account information that you or your Organisation provide to us when setting up a user account consists of your name and corporate email address. Other information includes your language, subscription or notification preferences, privileges assigned in the Platform, your role or job title within your Organisation, and dates such as your work anniversary or birthday.

Other optional information: You may optionally choose to provide your mobile phone number (if you wish to enable SMS notifications) and add other information about yourself, such as a photo or birthday, to your profile.

Platform content: You can provide information to the Platform, including information that will invite other users or information about other users that will allow us to advertise a range of services to this user in the future, or use the Platform to send emails or other communications. The Platform may make your contact information available to other users through current and future features that may include a user directory, messaging features, or other similar services.

Metrics, maintenance, and analytics: When you access or use the Platform, we may collect certain information automatically about your device and your use of the Platform. This will include IP addresses, browser types, log files, and other information regarding your system and connection. We collect information about how you access and use the Platform, such as which pages are viewed, when the profile was registered, and which portions of the Platform are used. We also collect metrics related to the number of users you have invited, platform engagement, and the speed and/or nature of communication you conduct through the Platform. This information is collected automatically through various commonly used information-gathering technologies, including cookies and web beacons. Some of these cookies and web beacons can be turned off through your website browser; however, on a mobile device, including our mobile apps, you may not be able to turn them off.

Use of Information

In general, Homey is the controller and your Organisation is the processor. As part of our legitimate interests to provide, operate, and maintain the Platform, we use information in the following ways:

• Manage the Platform, system administration, and account management: The Platform’s administrative tools allow Homey’s employees involved in the support and maintenance of the Platform to view content in a network to troubleshoot specific issues, maintain and improve the Platform, or perform other Platform-related functions, or as may be required by law. We also use third-party analytics services for our web and mobile applications for quality assurance, product interaction analysis, product improvement, and trouble-shooting.

• Process and complete transactions: This includes billing to a designated contact at an Organisation.

• Handle Organisation and users’ inquiries and support requests: Provide information and access to resources or services that they have requested from us.

• Compile aggregated data: This may be about the operation and use of the Platform and to better understand the preferences of Organisations and users.

• Conduct quality-assurance: Carry out research and development to improve our products and services.

• Send Organisations and users communications: This includes technical alerts, reports, updates, security notifications, and other service-related communications according to their notification preferences.

• Contact relevant business contacts at your Organisations: We may contact the designated contact person at an Organisation, which may also include marketing messages related to new product features, promotions, or other information about our products or services; however, you can opt-out of receiving these communications at any time.

• Investigate and prevent fraud: Unauthorised access or use of the Platform, breaches of terms and policies, and other wrongful behaviour will be investigated to prevent fraud.

• Enforce our agreements, and as required by applicable law.

When you download and use our mobile app to access the Platform, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.

Information We Share

We will only share and disclose your information transparently with other users that have a legitimate interest in access to the relevant data and with third parties where we feel there is a likely benefit or interest to the user from the third party providing its services. Examples include:

• Between users that are part of the same Organisation: We will share information with users that are within your Organisation. In most instances, this will include information you provide on other users you have invited to the Platform and the details collected on them for the provision of quotes for services that are available through the Platform.

• With other users within the Platform: We will share information with other users that have a legitimate interest in access to this data to complete their role in a service that has been instructed via the Platform. Some of these users may be service providers that use the information specifically to provide quotes for services they offer within the Platform.

• Other third-party service providers: They may have access to your data to assist in the provision of the Platform service and other business-related functions such as cloud storage, mobile phone push data, email provisioning, and usage analytics.

• To law enforcement authorities, government agencies, or judicial courts: We may be required to disclose data that we handle in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, in connection with the sale, transfer, merger, bankruptcy, restructuring, or other reorganisation of our business; to protect or defend our rights, interests, or property, or that of third parties; to investigate any wrongdoing in connection with our website, our Platform, or our services; in connection with a warrant, discovery, or other legal order; or to protect the vital interests of an individual.

With your consent: We may share other information with third parties when we have your consent to do so.

Third Party Websites and Services

Our Platform may contain links to other websites and services that are outside our control and are not covered by this policy.

We are not responsible for the content, security, or privacy practices employed by other websites or services that interface with the Platform. If you access other websites or services using the links provided, you will use them in accordance with their privacy policy, which may differ from ours. If you do not wish these third parties to process your personal data, please do not click on these links or access these services via the Platform. We are not responsible for the content, security, or privacy practices employed by other websites or services.

Our Security

We are committed to processing your data in a secure manner by putting in place specific technical and organisational measures to prevent the personal data we hold from being accidentally or deliberately compromised.

We conduct information risk assessments and ensure that our staff understand the importance of protecting personal data. We include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors that process personal data on our behalf so that they also ensure appropriate technical and organisational measures to protect the data. We also integrate privacy in the design of our projects that involve the use of personal data to secure the information and implement the aforementioned principles.

Your Choices

If you are located in the EEA, UK, or Switzerland, you have certain privacy rights recognised under the General Data Protection Regulation (GDPR), such as the right to request access to information, rectification, or erasure.

We control the information collected when you interact with the Platform, and accordingly, are responsible for attending to your data privacy rights and defining the legal grounds for the processing. To that end, we will support in completing the following actions:

Right to access and correct your personal data: You and your Organisation may access or correct information you have uploaded to the Platform by using the tools within the Platform. If you do not see the tools within the Platform, you should contact Homey via the contact details below. Changes on the Platform take immediate effect across the Platform, but data will be retained by us in our backup systems for a commercially reasonable amount of time.

Account closure and right of erasure: If you would like to stop using the Platform, you should contact Homey via the contact details below. Similarly, if you stop working for or with the Organisation, the Organisation may request to suspend your user account and/or may request to delete any information associated with your user account on the Platform. In addition, you can also request Homey to:

• Account closure and delete identifiable information: In general, account closure means that your name and other identifiable information (including your photo, if provided) will be deleted and not available to us or other users, your Organisation, or other users of the Platform – your name will be changed to an “anonymous user”.

• Deletion of information: Please note that information you submit or create in relation to particular transactions or other users may remain on the Platform and be accessible even if you deactivate or terminate your account.

Right of objection and restriction: You have the opportunity to elect whether you would like to receive certain correspondences from us or opt out of Homey’s promotional emails. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, transactions, and communications related to the Platform, unless your account is deleted.

Dispute Resolution Procedure

If you believe that we are not complying with our privacy policy, or have any issue or concern, you can submit a complaint with us and we will respond to you within 45 days. To that end, please contact us in writing using the details below and provide your identification and contact details, name and related Organisation (if applicable), and a complete explanation of your concern.

Data Retention

We will retain information collected and as required by applicable law, unless we specifically receive a request from you or your Organisation to delete your data. We will delete all personal data stored in our servers and backups within 90 days unless required to be kept for other regulatory or legal reasons.

Privacy Rights

We are committed to collecting and processing personal data responsibly and in compliance with applicable data protection laws in the United Kingdom. Our goal is to apply data protection standards based on internationally accepted data protection principles, ensuring effective protection of personal data we process. In addition to upholding your rights under the GDPR, we will consider other applicable data privacy laws and comply where necessary. We reserve the right to evaluate any request against the governing data privacy law.

Cookies

The Platform uses technologies such as cookies for proper functionality and analytical purposes.

Cookies are small data files placed on your computer or mobile device when you visit a website or use online services. Cookies are widely used by website owners to make their websites and services work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Homey) are called “first-party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and when it visits certain other websites.

We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons for our Platform to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us to enhance the experience on our Platform. Third parties serve cookies through our Platform for analytics, performance, and functionality. The specific types of first-party and third-party cookies and the purposes they perform are described in the table below:

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links. You can set or amend your web browser controls to accept or refuse first-party and/or third-party cookies. If you choose to reject cookies, you may still use our Platform, though your access to some functionality and areas of our site may be restricted.

The means by which you can refuse cookies through your web browser controls vary from browser to browser. Therefore, you should visit your browser’s help menu for more information. Here are the current relevant information pages for the main browsers:

• Microsoft Internet Explorer:

  • http://www.microsoft.com/info/cookies.htm

• Google Chrome:

  • https://support.google.com/accounts/answer/61416

• Mozilla Firefox:

  • http://www.mozilla.org/projects/security/pki/psm/help_21/using_priv_help.html

• Apple Safari:

  • Blocks cookies by default and accepts cookies only from your current domain. To change, click Safari, Preferences, Security, and choose your preference.

We gather certain information automatically to analyse trends in the aggregate and administer the Platform. This information may include your Internet Protocol (IP) address, device identification, your browser header (browser type, operating system and related information), and other items that correlate to your IP address, including but not limited to location, Internet service provider, and mobile carrier. We use this information to record the pages and files you view and the actions you take on the Platform. We also use this information to analyse overall usage trends and improve the Platform.

Web Storage (also known as local storage, DOM storage, Flash Cookies, website data) may be used on our website in a similar manner to cookies (for example, to enhance your experience by storing your user preferences and settings). You can manage these settings via your browser’s settings, similar to cookies.

To communicate with our Data Protection Officer, please email hello@homey.co.uk.