We are proud to comply with the requirements of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR). GDPR is a comprehensive European data protection law that sets the new global standard regarding your personal information.
We offer services to our users, through our:
- Website chipolo.net (the “Website”);
- Website app.chipolo.net (the “Web app”);
- Website support.chipolo.net (the “Support Center”);
- Chipolo mobile application (the “Chipolo app”);
- Social media pages;
- Other associated services that we provide both online and offline.
Services listed above are collectively referred to as the “Services”.
About us
Chipolo d.o.o., Gabrsko 12, 1420 Trbovlje, Slovenia and its fully owned subsidiary Chipolo Inc, Schissel Smallberg 450 7th Ave #2710, NY 10123, USA are the responsible parties and data controllers with respect to personal information collected through the Services. If you want to exercise any of your rights in relation to our processing of your Personal Information, Chipolo d.o.o. shall be the responsible party.
Our primary goals in using your data and information are to create your account, provide Services to you, improve our Services, contact you, conduct marketing and research and create anonymous statistical reports for internal use.
Please note that the scope of this Privacy Policy is limited to information and data collected or received through your use of the Service. We are not responsible for the actions of third party individuals or companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any links to those sites do not constitute our sponsorship of, or affiliation with, those individuals or companies.
If you do not agree to these terms, please do not use the Service.
For general information and privacy questions please feel free to contact us via [email protected].
How we collect and use your information
In this Privacy Policy, the term "Personal Information" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, or, in certain circumstances, location information, an IP address or the unique identifier allocated to each Chipolo device. Specifically, we collect, process and use the following information from you, which may include Personal Information:
Placing an Order
Contact Information
When you place an order on our website, you’ll need to provide an email address, a first and last name, and a shipping and billing address and any other information you voluntarily give to us.
Additionally, for shipping to most parts of the world, we will require you to provide a contact phone number used for delivery purposes. This is a requirement from many delivery companies that we work with.
The contact information will be used to complete and fulfill the order and your personal information will be retained according to the Slovenian legislation (10 years for issued invoices).
Information Provided by You About Others
When providing personal information of another person, we rely upon you to obtain the consent necessary for us to process their personal information.
For sending Chipolos as a gift, the processing of the gift recipient's personal information you provide on the webpage (in the cart and during the checkout process) will be consistent with the description for processing Contact Information from the previous chapter and any other references to the Contact Information throughout our Privacy policy.
Information About You Provided by Others
If you received Chipolo as a gift directly from our webpage, someone else has provided your personal information to us to make it possible to send the package directly to you. The processing of your personal information will be (and was) strictly limited to the minimum required processing that we needed to do to ship the package to you and will be retained based on the requirements of our Slovenian legislation. Your personal information was shared with our shipping providers and external fulfillment partners (for US, Canadian and UK addresses) acting as data processors for us and in no way for their own use. No additional processing will be done on your personal information.
Payment Information
In order to complete your order on our website, you’ll need to provide payment information, such as your credit card, PayPal account, Apple Pay or Google Pay. This information is needed in order to process your order and is not stored on our servers, but servers of the listed 3rd party payment providers.
List of the available 3rd party payment providers that are available for use on our webpage with links to pages explaining their privacy policies:
Order Fulfillment
US and Canadian orders are fulfilled by our external warehousing and fulfillment partner Shipmonk and their network of delivery partners.
UK orders are fulfilled by our external warehousing and fulfillment partner Rapidpack and their network of delivery partners.
All other orders are shipped from Chipolo d.o.o. using one of the below delivery providers depending on the country and the shipping method selected:
We will share your shipping address with any of the companies listed in this chapter for the purposes of delivering the items you have ordered to your address.
Registration for the use of our Services
You can register for the use of our Services by manually creating a Chipolo account or by using an existing third party account, such as Apple, Google or Facebook, to create one.
When creating a Chipolo account, you’ll need to provide a display name, a valid email address and a password. You can choose whether or not your display name includes your first and/or last name.
When using an existing third party account, we obtain your profile information and your email address from this account. The information we get from third party providers often depends on your settings or their privacy policies, so be sure to check what those are.
We do not identify you personally to other users or make your account information available to any third parties in any way that could identify you without your prior consent.
Information from your use of our Services
Chipolo ID and name
When you activate Chipolo using the Chipolo app, that Chipolo’s unique identifier (or Chipolo ID) will be associated with your account. If you choose to name your Chipolo, this information will also be associated with your account.
Location Information
Chipolo is designed to tell you where your items are. In order to do that, it’s necessary to collect data about your location. We use the term “Location Information” to refer to the combined location data of your phone or device, and your Chipolo.
While the app is running on your device, it periodically transmits your Location Information (even while running in the background). This allows us to show you, on your map, the last place your Chipolo was seen by your device. It is one of the primary ways Chipolo helps you find your lost items.
We may also collect and update location information for your Chipolo(s) "anonymously" (i.e., we will not disclose your identity to the other user and not disclose the other user's identity to you) from other Chipolo users who are running the app within Bluetooth range of your device. We do this to provide you with the most recent and accurate location of your Chipolos, even if they are out of your devices’ Bluetooth range. The Location Information associated with your Chipolo(s) is never made available to these users.
If you use a computer, phone, or other device in relation to the Services, we use the IP address of that computer or device to determine an approximate location (only to the country level). We do this so that we can provide you with a better, more-personal experience.
We may also use your Location Information to promote the Services or provide you with personalized offers if you agree to such usage with separate consents. However, your Location Information is never shared with other users unless you choose to share it yourself through the use of the sharing features part of our Services.
Usage Information
These days, whenever you use a website, mobile application, or other internet service, there’s certain information that almost always gets created and recorded automatically. The same is true when you use our Services. We track how, and how often you use our Services. We also collect certain information that your mobile device sends when you use them for Services. This includes information such as your device’s model, operating system type and version, and the dates and times of your requests. We use this information to provide you with optimal Services and customer support, and to collect anonymous statistics that helps us understand our user base.
Activity Recognition (Physical Activity and Health Data)
Chipolo app uses activity recognition (physical activity recognition) features on your phone to help with triggering the Out of Range Alerts and to help keep the Chipolo app running in the background. In terms of Out of Range Alerts, this data is used to reduce the number of false alerts and to reduce the latency of the alerts.
Chipolo app never stores or sends your health data (collected via the activity recognition mechanisms on your mobile device) to the Chipolo servers or any 3rd party services. In other words - your health data collected via the Chipolo app never leaves your mobile device and we never see or process this data.
Information collected through Chipolo’s Support Services
We provide support services via live chat on our website, email request submissions, recorded inbound and outbound telephone calls and direct email. We collect Personal Information you may have to provide to our customer care team in the process. This includes, but is not limited to: your name, email address, phone number, and mailing address. In the absence of such data, we cannot provide you with Support Services. We may use and process your Personal Information, including Location information, to handle your support request and provide you with the best support possible, including quality assurance control.
As described in greater detail below, we may share this information (including Personal Information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy.
Purposes of Data Processing
We use information collected through our Service for purposes described in this Privacy Policy or disclosed to you in connection with our Service. For example, we may use your information to:
- Operate and Improve our Service:
- Fulfill your online orders and enable registration for the use of our Service;
- Understand you and your preferences to enhance and customize your experience and enjoyment using our Service;
- Respond to your comments and questions and provide support service;
- Send you Service related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
- Any other processing necessary for the performance of a contract with you.
- Ensure physical, network and information security and integrity:
- This is necessary for our legitimate interest of ensuring that our IT systems and networks are secure and uncompromised, including, for example, backup and archiving, preventing malware, viruses, bugs or other harmful code, preventing unauthorised access to our systems, and any form of attack on, or damage to, our IT systems and networks.
- Deliver marketing and promotional information:
- Communicate with you about our offers, promotions, rewards, upcoming events, and other news about our Services and products only upon your explicit consent.
- For statistical and research purposes:
- We will anonymize your data and use them for our legitimate interests of processing Personal Information for research purposes, including market research, better understanding of our respective customers, and tailoring our respective products and Services to their needs;
- Sharing aggregated data with business partners.
- For purposes of tracking your Location Information:
- We will always store your last known location to operate our Services;
- We will store your historical Location Information and use it for improving and personalizing our Services only upon your explicit consent.
- For compliance and legal purposes:
- Indicating possible criminal acts or threats to public security to a competent authority. This is necessary for our legitimate interest of promoting the success of our business, preventing crime, for compliance with a legal obligation to which we are subject;
- In connection with any legal or potential legal dispute or proceedings. This is necessary for our legitimate interest of promoting and ensuring the success of our business, resolving disputes and making such disclosures as are required by law or which we consider, acting reasonably, are required by law.
- For business or share sale purposes:
- In connection with disclosure requests and in the case of a business or share sale or sale or purchase of a business and/or assets, whether actual or potential. This is necessary for our legitimate interests of selling and/or ensuring and promoting the success of our business.
How we may share your Personal Information with third parties
We may share your data (including Personal Information) with our affiliates or Data Processing Partners, which are:
- IT Services and Infrastructure Providers
- Order Fulfillment Services
- Analytics Providers
- Marketing Platforms
- Third Party Advertising Providers
- Referral Program Partners
This list may change from time to time. We may share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of delivering our Services, displaying advertisements, conducting analysis and research and for measuring our Data Processing Partners’ advertising campaign performance.
The privacy policies of Data Processing Partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.
We cannot guarantee that the Data Processing Partners will adhere to the contractual obligations or acceptable business practices. We strive to protect the information provided to our Data Processing Partners. We have no direct control over their use of the collected information. Therefore you acknowledge that we are not liable for any third-party privacy breach and that our liability for Data Processing Partners is limited to the amount we are able to receive as indemnification from Data Processing Partners.
We may also release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
Rakuten advertising
We partner with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information are subject to the privacy policy located here: https://rakutenadvertising.com/legal-notices/services-privacy-policy/
Your rights:
https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/
Cookies and similar technologies
We and our analytics service providers use technologies such as cookies, scripts, advertising IDs and tags to identify a user's device and to remember things about your visit. For details please consult our Cookie Policy.
Your rights in relation to your data
You have the following rights in relation to your personal information, which you can exercise by writing to the following address [email protected]:
- To request access to your personal information and information related to our use and processing of your personal information;
- To request the correction or deletion of your personal information;
- To request that we restrict our use of your personal information if technically viable;
- To receive personal information which you have provided to us in a structured, commonly used and machine-readable format (e.g. an Excel spreadsheet) and the right to have that personal information transferred to another data controller (including a third party data controller);
- To object to the processing of your personal information for certain purposes (for further information, see the section below entitled “Your right to object to the processing of your personal information for certain purposes”);
- To withdraw your consent to our use of your personal information at any time where we rely on your consent to use or process that personal information. If you withdraw your consent, this will not affect the lawfulness of our use and processing of your personal information on the basis of your consent before the point in time when you withdraw your consent.
You also have the right to lodge a complaint with a supervisory authority, which, for the purposes of Slovenia, is the Information Commissioner, the contact details of which are available here: https://www.ip-rs.si
For further information about your rights in relation to your personal information, including certain limitations, which apply to some of those rights please see Articles 12 to 23 of the General Data Protection Regulation (GDPR), which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.
We will respond to your access request within a reasonable timeframe.
We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
Your right to object to the processing of your data for certain purposes
You have the following rights in relation to your personal information, which you may exercise in the same way as you may exercise the rights in the preceding section (Your rights in relation to your personal information):
- To object to us using or processing your personal information where we use or process it in order to carry out a task in the public interest, where we do so in the exercise of official authority or for our legitimate interests, including “profiling” (i.e. predicting your behaviour based on your personal information) based on any of these purposes;
- To object to us processing your personal information for direct marketing purposes (including any automated evaluation we make about you or any of your characteristics as a person, to the extent that it is related to such direct marketing).
You may also exercise your right to object to us using or processing your personal information for direct marketing purposes by:
- Clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions, which appear in your browser following your clicking on that link; or
- Sending an email to [email protected] asking that we stop sending you marketing communications.
Whenever you object to direct marketing from us by a different communication method to that of the marketing communications you have received from us, you must provide us with your name and sufficient information to enable us to identify you in relation to the communications you have received.
Security safeguards
We take appropriate technical and organisational measures to secure your personal information and to protect it against unauthorised or unlawful use or processing as well as against the accidental loss or destruction of, or damage to, your personal information, including:
- Only sharing and providing access to your personal information to the minimum extent necessary and subject to confidentiality restrictions;
- Training our employees about the importance of confidentiality and maintaining the privacy and security of your information;
- Committing to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities;
- Updating and testing our security technology on an ongoing basis;
- Using secure server providers to store your personal information;
- Requiring proof of identity from any individual who requests access to personal information.
Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Data retention
We retain your information:
- For as long as you have not deleted your account;
- For any legal obligation to continue to process your information, such as any record-keeping and tax obligations imposed by applicable law or whether we have any legal basis to continue to process your personal information, such as your consent;
- To retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
As indicated above we will store your information for no longer than necessary. When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at [email protected].
Our policy regarding children
We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of fourteen (14) or knowingly allow such persons to use our Services. If you are under 14, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 14 may provide any Personal Information. In the event that we learn that we have collected personal information from a child under age 14, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 14, please contact us at [email protected].
International transfer
We may transfer information that we collect about you to affiliated entities, or to Data Processing Partners across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.
When we transfer your personal information outside the European Economic Area, the country to which it is transferred will either be subject to an adequacy decision by the European Commission, or if not (or if we transfer your personal information to an international organisation), we will ensure that the transfer takes place on the basis of one or more of the following safeguards:
- Data protection policies adhered to by the data controller and other companies and entities within our corporate group from time to time, which comply with applicable laws, known as “binding corporate rules” or “BCRs”;
- Standard data protection clauses adopted by the European Commission or adopted by the Information Commissioner and approved by the European Commission in accordance with relevant law;
- A code or codes of conduct produced by an association or other body approved by the Information Commissioner;
- An approved certification mechanism (such as the EU-US Privacy Shield); or
- Where authorised by the Information Commissioner, contractual clauses between the data controller or processor and the data controller, processor or recipient of the personal information in the third country or international organisation.
Data protection officer
Our data protection officer is Vesna Stanković - ITLAW, legal consultancy, Vesna Stanković s.p., Kotnikova ulica 34, 1000 Ljubljana.
You can get in touch with our DPO at [email protected] or [email protected].
Changes to this Privacy Policy
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Website prior to the change becoming effective. We encourage you to periodically review our Website for the latest information on our privacy practices.
If you have any questions or concerns about our data privacy practices, or if you have any requests for resolving issues with your personal information, please contact us at [email protected]. Customer support is available in English language.
