Privacy Statement for Andersen Products and Services

Policy active as of May 23, 2018.

At Andersen, we take your privacy seriously.

This Privacy Statement for Andersen Products and Services (“Privacy Statement”) describes information that Andersen Labs, Inc. and its subsidiaries and affiliates (collectively, “Andersen”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).

This document focuses on information related to the operation of Andersen products and services, including the Andersen Konnect, Andersen Service and other products from Andersen (collectively, “Andersen Products”). In this Privacy Statement, the expression “Andersen Products” also includes our Web Apps, Mobile Apps, and Subscription Services as defined in our Terms of Service.

We provide additional details about how we collect and use information from our public web sites in our Privacy Policy for Andersen Web Sites.

Our Pledge:

  1. We will be transparent about the different types of information we collect and how we use them.
  2. We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide Andersen’s Products, and to do so only when we think they will provide you with a welcome additional service.
  3. We will use best-in-class data security tools to keep your data safe and protect the Andersen Products from unauthorized access.

Your Permission: Permission for data collection and processing. By using Andersen Products, you agree to allow us to collect and process information as described in this Privacy Statement.

What information does the Andersen Konnect chargepoint collect?

The Andersen Konnect chargepoint collects:

  • Setup information you provide
  • Environmental data from the Andersen Chargepoint sensors
  • Charging usage information
  • Technical information from the device

Setup information you provide: When you install the Andersen Konnect Chargepoint, you’ll be asked several questions in order to help us create your Andersen ID account.
For example, we’ll ask for information like whether your chargepoint is located in a home or a business, or like your home address or postal/ZIP code. This information helps us to customize your experience by, for example, retrieving weather information for your neighborhood or by enabling switch the behavior of Andersen products at you home when you leave and when you come back. In addition, the Andersen Chargepoint pulls information directly from your electrical system to learn its capabilities

Environmental data from the Andersen Learning Chargepoint’s sensors: We collect data from several sensors built into the Andersen Learning Chargepoint. These sensors collect data such as temperature, power usage, active charge time.

Charging usage information: Every time your system turns on and off, Andersen records the time and duration during which your system was on in order to offer you features such as usage history.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with the Andersen Learning Chargepoint, we record your Andersen Learning Chargepoint model and serial number, software version, and technical information such as battery charge level.

What information does Andersen Protect collect?

Andersen Protect collects:

  • Setup information you provide
  • Technical information from the device

Setup information you provide: When you install Andersen Protect, you’ll be asked for information like your home address or postal/ZIP code as well as where in your home you’re installing it. This information helps to customize your experience by, for example, enabling Andersen Protect to inform you where an event is occurring, or to better schedule features like Sound Check to run during certain hours of the day.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with Andersen Konnect, we record your Andersen Konnect model and serial number, software version, and technical information such as sensor status, Wi-Fi connectivity.

What information is shared among multiple connected Andersen Products?

If you have multiple Andersen Products interfacing with one another, the products will share certain information with each other, such as data on whether vehicles are charging, energy usage data and temperature data. This sharing may occur locally among connected devices (both Andersen and third-party devices). Sharing can also occur between Andersen Products and your mobile device or application, or among Andersen’s servers.

Andersen offers a lock feature that uses the information collected from your Andersen Products and, if you enable it, the location of a paired phone, to determine whether the charge point is in use.

What additional information does Andersen collect and store when a user connects a Andersen Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your Andersen Product to our Services, or to access your Andersen Product over the Internet from a computer, a smartphone or a tablet, you will need to connect it to your Wi-Fi network. During setup, the Andersen Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device, along with your IP address, so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with Andersen servers and download software updates.

Once connected to your Wi-Fi network, your Andersen Product regularly sends the data described in this Privacy Statement (excluding your Wi-Fi password) to Andersen to provide you with the Services.

Additional Authorized Users: Andersen may provide you with the ability to enable additional authorized users to access your account. If you do so, the additional authorized users may control and view all of your devices, content, and Works with Andersen connections. Invited users may also add additional authorized users to your account, so be careful to add only those you trust. An invited user must have or create a Andersen account, and information about invited users (like email address, name or changes to product settings) will be stored with your account.

Email Addresses: When you create a Andersen account, we collect and store your email address. From that point forward, your email address is used for communications from Andersen. In addition, Andersen may provide you with the ability to enable individuals to access your account as additional authorized users, or to invite other individuals such as friends or family to share access to your content such as recorded video footage. We will ask you for the email address of any such individuals and automatically send an email invitation on your behalf. Andersen stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation services.

Basic Profile Information: Your account allows you to provide certain basic profile information like your name and profile photo. Names and profile photos may be shown to others in connection with the Services. In addition, if you download the Andersen Konnect Mobile App, we may collect and store your mobile device identifiers (such as IDFA, AAID, or other device identifiers).

Mobile location data: You may choose to enable features like Lock Assist or device pairing. If you do this, you’ll be asked for permission to share location data from your mobile device. If you grant this permission, the Andersen app uses standard location services built into iOS and Android. This data may be processed or combined with data from other products to enhance features like Home & Away.

How does Andersen use the information it collects?

We use this information to provide, develop and improve Andersen Products and services, including to make assessments and recommendations about products, safety, or energy use. We may use your contact details to send you this information, or to ask you to participate in surveys about your Andersen use, and to send you other communications from Andersen.

We may also use this information in a non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated user information about the number of active chargepoint users in a particular state to help us decide what energy companies might be good partners.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, Andersen may process your personal information on servers that are not in your home country.

In general for purposes of applicable law (e.g., GDPR), Andersen is a controller of the information collected in connection with the Products and Services. However, in the case of “Video and audio signals and data” and “Facial recognition to enable Familiar Face Alerts feature” you are the controller of these data and Andersen is a processor.

Our legal bases for processing information

If European data protection law applies to the processing of your information, we process your information for the purposes described in this Privacy Statement, based on the following legal grounds:

When we’re providing a product or service

We process your data to provide and support a product or service you’ve asked for under a contract, including but not limited to delivering our Terms of Service.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:

  • offering and improving Andersen Products and services
  • developing new products and features
  • understanding how people use our products and services
  • performing research that improves our services for our users and benefits the public
  • sending you direct marketing and other communications from Andersen
  • protecting against harm to the rights, property, and safety of Andersen, our users, and the public
  • detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
  • maintaining and improving the integrity of our computing systems, and protecting our users’ data security
  • enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re complying with legal obligations

We process your data when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.

With your consent We ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at anytime.

In what circumstances does Andersen share my information?

Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of Andersen Products and services without asking you first. Period. We do not rent or sell our customer lists. The following are the limited situations where we may share personal information:

  • With your permission: We may share personal information when we have your permission. One example of this would be if you invite another user to access the Products on your account as an additional authorized user. Another example is if you sign up for programs offered by our partners (e.g., energy or insurance companies); if you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device. If you connect third-party devices and services to your Andersen Products through the Works with Andersen program, you are shown information about any proposed exchange of data. Andersen or the third party will request your consent to these exchanges on your behalf and you can change your mind at any time. When you use third-party products and services integrated with the Andersen Products, their own terms and privacy policies will govern your use of those products and services.
  • For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage,including helping to answer your questions. They may also assist with monitoring our servers for technical problems.
 These technicians (as well as Andersen employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Andersen purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video data.
  • As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.
  • For legal reasons: We will share personal information with third parties if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable government request; (ii) enforce Andersen policies or contracts, including investigation of potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) protect against harm to the rights, property or safety of Andersen, our users or the public as required or permitted by law.

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about energy use or elevated carbon monoxide levels in the home. This information may also be shared with other users to help them better understand their energy usage compared to others in the Andersen community, raise awareness about safety issues, or help us generally improve our system. We may also share non-personal information with our partners, for example, if they are interested in providing demand-response services or other incentive programs. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

If you select an outside party for the purchase, installation or service of your Andersen device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a Andersen Learning Chargepoint from a retailer, the retailer may collect personal information as part of the transaction. Or the party that installed the device may retain information that you provided to them to assist them in servicing the device if needed. Always check the privacy policies for any company that collects your personal information.

What choices do I have and how can I delete my personal information?

Andersen generally stores your personal information on Andersen’s servers until you delete or edit it, or for as long as you remain a Andersen customer in order to provide you with Andersen Products. In addition, Andersen may store your personal information to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

As described above, some information is processed and stored directly on the Andersen device. Personal information from Andersen devices is encrypted while it is being transmitted to Andersen.

You can delete the information on the Andersen device by resetting it to the defaults (using Reset in the Settings menu).

You can access, amend or delete your personal information from Andersen’s servers through the controls in your account. Andersen customers can also request their Andersen data by visiting https://andersen-ev.com/privacy-policy/.

Individual Rights in the European Economic Area.

If you are located in the European Economic Area, you may seek confirmation regarding whether Andersen is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to Andersen’s processing of your personal information at any time. However doing so may impact your use of the Products and Services.

If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by Andersen, you may do so, as applicable, through controls in the Andersen application or by contacting Andersen. To protect your privacy, Andersen will endeavor to take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information. Learn more at Andersen.com/privacy.

Minors

Only individuals aged 18 and older are permitted to act as Owners of Andersen Accounts. Authorised Users must be over the age of 13 (or equivalent minimum age in the jurisdiction where they reside) and may use the Products and Services under the supervision of a parent or legal guardian and only if they agree to be bound by these Terms on your behalf. Andersen Products and Services do not knowingly collect or store any personal information from anyone under the age of 13.

Can the Privacy Statement be changed?

Please note that this Privacy Statement may change from time to time. We will provide notice of any changes on the website or by contacting you.

How can I contact Andersen?

For users please contact Andersen at 6th Floor, Aldgate Tower, 2 Leman Street, London E1 8FA

If you have any questions, you may submit an inquiry to our Data Protection Office, led by our Data Protection Officer, by emailing contact@andersen-ev.com