Effective from: 11th December 2023.
1. Our contact details
Our website, products, software and services are operated by LightFi Limited, a limited company registered in England under company number 10212060.
- Registered address: 27 Old Gloucester Street, London, England, WC1N 3AX
- Phone: +44 7434 636 908
- Email: contact@lightfi.io
2. What does this Privacy Policy cover?
When you use our Site, Products, Software or Services LightFi Limited will process your personal data. This Privacy Policy applies only to your use of our Site, and any Products or Services delivered through our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
3. What is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What type of data we collect and for what purpose?
LightFi Limited provides sensors (the “Sensors”) that monitor occupancy and indoor air quality and are designed to enable control of your building’s Heating, Ventilation and Air Conditioning (HVAC) equipment. We also provide a mobile application (our “App”) and a web dashboard (the “Portal”) that is designed to work together with our Sensors. To get the full functionality of our Service, we require that you set up an account. Our Service may also include making recommendations to you to improve energy efficiency and/or indoor air quality.
Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, for the purposes also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data. Most of the personal information we process is provided to us directly by you for one of the following purposes:
| Data Type | Purpose |
|---|---|
| Your name, email address, username and password when you setup an account. | Administration of your user account. The processing purpose is based on contractual necessity. We need this information to identify our users and provide them access to a user account with their own credentials to provide our Service. |
| Sensor data, including air measurements of indoor air quality and occupancy. | As part of our Service, we collect Sensor data to measure air quality and occupancy, and analyse such data to provide our Service. We may also receive data about the Sensor, such its location (e.g., longitude and latitude, and/or street address), a UID assigned to each of our Sensors, and the name and/or type of Sensor (e.g., Alpine). We may associate that information with your account information. We collect this information under the processing purpose of contractual necessity as it is required for us to provide our Service to you. |
| App and Portal data collection. As part of our Service, we collect data about our App and the mobile device where our App is installed, and the device used to access our Portal. For example, we will collect the type of mobile device (e.g, Android) the operating system of your mobile device, the IP address, the general location if location services are enabled on the mobile device for our App, and a UID for your mobile device. | We collect this information under the processing purpose of contractual necessity as it is required for us to provide our Service to you. |
| Name, telephone number and email address collected in connection with support enquiries. | The processing purpose is based on the legitimate interest of helping you with your enquiry. |
| Your name, phone number and email address when you enquire about our services or sign up to our newsletter on our Site. | Sending out marketing materials, such as newsletters, brochures and information regarding our activities. The processing purpose is based on either your consent (where required by law) or the legitimate interest of helping you better understand Our Products & Services. |
| Curriculum Vitae when you apply for employment with us. | The recruitment of employment and consulting. The processing of data is based on your given consent. |
| We use cookies when you visit our public web pages to obtain information regarding the use of our web pages. No cookies are used on our Portal. | You can read more about cookies and which cookies we use here. The processing of cookies is based on the commercial interest of adjusting our web pages for the benefit of users. We ensure your data protection by only using this information for statistical purposes. In these statistics it is not possible to identify you as an individual. |
5. How and where we process your personal data?
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation. We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
LightFi Limited uses data processors to collect, store or in other ways process data on our behalf. In such cases we have concluded data processing agreements to ensure the information security in all segments of the data processing. We currently use the following data processors:
- Amazon Web Services: Data about you is processed in London, UK, by Amazon Web Services to handle your user account and handling the name, location and data of your Sensor(s). The processing is required for us to provide our Service to you. Data is stored in London UK.
- PostHog: Data about you is processed in the EU by PostHog to provide customer support and product analytics. The processing is based on our legitimate commercial interest in processing these data for this purpose.
- Hubspot: Data about you is processed by Hubspot to provide you with our newsletter. The processing is based on our legitimate commercial interest in processing these data for this purpose.
- Privateemail: is LightFi Limited email provider. Data about you will be processed here when you contact us for general communication and support.
Your personal data might be transferred to countries outside the UK and the European Economic Area (third countries) in order to provide you our Servces and where we use external services. We always make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data. Transfer to third countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the Data Protection Legislation.
6. How long do we store your personal data?
We only store your personal data for as long as necessary for the purpose the data was collected for. This means that personal data collection based on your consent will be deleted if you withdraw your consent unless we are required to retain all or part of the data under applicable law. Data processed for the purpose of our newsletter will for instance be deleted after withdrawal of your consent.
Personal data we process in the performance of a contract with you will be deleted when the contract is implemented and all obligations pursuant to the contract have been implemented. Personal data related to your user account, including location data, is retained until you delete your account, after such time the data is aggregated and may be stored for up to five years.
7. Do we share your personal data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exception. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Additionally, LightFi Limited works with resellers and other companies. If you purchase our Products and/or Services from a reseller or other company, they may have access to the Sensor data. We will notify you via email when you setup your account that a reseller from whom you’ve purchased our Services or Products may be able to view the information collected by your Sensors(s). We contractually require that any resellers that have access to your personal data only use that personal information to address issues related to energy efficiency and/or air quality and/or occupancy, including offering products and services to you to help you remedy any identified issues. Please note that any data they receive regarding your Sensors and/or use of our Service is subject to the reseller’s privacy policy, not ours. We strongly recommend that you carefully review their privacy policy.
8. Your data protection rights
Under data protection law, you have the following rights, which we will always work to uphold:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at contact@lightfi.io if you wish to make a request.
9. How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at contact@lightfi.io.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk