Privacy Statement for ScentAir Products and Services
This Privacy Statement for ScentAir Products and Services (“Privacy Statement”) describes information that ScentAir Technologies, LLC, and its subsidiaries and affiliates (collectively, “ScentAir”) 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).
As used herein, “ScentAir servers” or “ScentAir’s cloud-based servers” includes the server environments operated by our contracted third-party vendors.
- We will be transparent about the different types of information we collect and how we use them.
- We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide ScentAir’s Products, and to do so only when we think they will provide you with a welcome additional service.
- We will use best-in-class data security tools to keep your data safe and protect the ScentAir connected Products from unauthorized access.
Your Permission: Permission for data collection and processing. By using ScentAir Products, you agree to allow us to collect and process information as described in this Privacy Statement.
International data transfers. Your personal information may be collected, processed and stored by ScentAir or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using ScentAir Products in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, you agree to the transfer of your personal data to the United States and other countries where ScentAir operates.
What information does ScentAir collect?
ScentConnect Products collect:
- Settings information
- Data from the device’s oil volume sensors
- Direct adjustments to the device
- Usage information
- Technical information from the device
Setup information you provide and ScentAir records: When we install a ScentConnect device (the “device”), we’ll use a few pieces of information to create an initial device profile and program of settings that will keep your space optimally scented. For example, we’ll enter the time zone of the installation location, as well as where the device is located in your facility and/or HVAC system.
Data from the device’s sensors: We collect data from oil volume sensors built into the device, as well as ambient temperature, HVAC duct pressure, power to the device, details about operation of the pump and pump run hours. This helps ScentAir ensure a consistent and efficient scenting experience.
Direct adjustments to the device: If you change settings like scent intensity or scheduling on the ScentAir device, it records that information and shares it back to ScentAir so that we can optimize your scenting experience.
Usage information: Every time your system turns on and off, ScentAir records the time and duration during which your system was on in order to offer you features such as usage history and otherwise optimize your scenting experience.
Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with the ScentAir device, we record the model and serial number, software version, and technical information about the device’s performance.
What information is shared among multiple connected ScentAir Products and with ScentAir?
If you have multiple ScentAir Products interfacing with one another, the products may share certain information with each other, such as data on scenting schedules, scent intensity and oil volumes. This sharing may occur locally among connected devices (both ScentAir and third-party devices). Sharing can also occur between your mobile device or application and ScentAir’s cloud-based servers.
Wi-Fi Network Information: To connect your ScentAir Product to our Services, or to access your ScentAir Product over the Internet from a computer, a smartphone or a tablet, you may need to connect it to your Wi-Fi network. During setup, the ScentAir 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 ScentAir servers and download software updates.
Once connected to your Wi-Fi network, your ScentAir Product regularly sends the data described in this Privacy Statement (excluding your Wi-Fi password) to ScentAir to provide you with the Services.
Additional Authorized Users: ScentAir 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 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 ScentAir 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 an account on My Account (https://myaccount.scentair.com) (a “ScentAir account” or “account”), we collect and store your email address. In addition, ScentAir may provide you with the ability to enable individuals to access your account as additional authorized users. We will ask you for the email address of any such individuals and may automatically send an email invitation on your behalf. ScentAir stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our services.
Basic Profile Information: Your account allows you to provide certain basic profile information like your name and contact information. Profile information may be shown to others in connection with the Services. In addition, if you download the ScentAir Mobile App, we may collect and store your mobile device identifiers (such as IDFA, AAID, or other device identifiers).
Additional Authorized Users: ScentAir 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 and account content. 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 ScentAir account, and information about invited users (like email address, name or changes to product settings) will be stored with your account.
Mobile location data: You may choose to enable features where you’ll be asked for permission to share location data from your mobile device. If you grant this permission, the ScentAir 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 provided by ScentAir.
Bluetooth data: Bluetooth-enabled ScentAir Products, if applicable, may broadcast an identifying signal wirelessly. This is used to connect with your Bluetooth-enabled devices (such as a smartphone or tablet) in order to deliver features.
How does ScentAir use the information it collects?
We use this information to provide, develop and improve ScentAir Products and services, including to make assessments and recommendations about products and their performance. We may use your contact details to send you this information, or to ask you to participate in surveys about your ScentAir use, and to send you other communications from ScentAir.
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 may use aggregated user information about the number of active ScentAir users in a particular state, or the number of scent diffusion devices per user location.
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 network and through broadband networks or the Internet to our servers. Depending on your location and type of data, ScentAir may process your personal information on servers that are not in your home country.
In general for purposes of applicable law (e.g., GDPR), ScentAir is a controller of the information collected in connection with the Products and Services.
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 ScentAir 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 ScentAir
- protecting against harm to the rights, property, and safety of ScentAir, 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.
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 ScentAir share my information?
Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of ScentAir 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.
- 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 ScentAir 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-ScentAir purposes.
- 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 ScentAir 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 ScentAir, 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 fragrance oil useage and scent diffusion levels in the spaces our Products are used. This information may also be shared with other users to help them better understand their fragrance oil usage compared to others in the ScentAir community, or help us generally improve our system. We may also share non-personal information with our partners. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.
What choices do I have and how can I delete my personal information?
ScentAir generally stores your personal information on ScentAir’s servers until you delete or edit it, or for as long as you remain a ScentAir customer in order to provide you with ScentAir Products. In addition, ScentAir may store your personal information for a reasonable period of time after you are a ScentAir customer 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 ScentAir device. This does not include personal information.
ScentAir customers can also request their ScentAir data by visiting www.scentair.com/legal/privacy or by emailing email@example.com.
Individual Rights in the European Economic Area.
If you are located in the European Economic Area, you may seek confirmation regarding whether ScentAir 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 ScentAir’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 ScentAir, you may do so, as applicable, through controls in the ScentAir application or by contacting ScentAir. To protect your privacy, ScentAir will endeavor to take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
Only individuals aged 18 and older are permitted to act as Owners or Authorized Users of ScentAir Accounts. ScentAir Products and Services do not knowingly collect or store any personal information from anyone under the age of 18.
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 ScentAir?
For users in the United States and other countries outside of the European Economic Area:
SCENTAIR TECHNOLOGIES, LLC
3810 SHUTTERFLY ROAD, SUITE 900
CHARLOTTE, NC USA
For users in the European Economic Area:
SCENTAIR FRANCE PARC D’ACTIVITES DU CASSE 2 16 RUE JEAN MONNET 31240 SAINT JEAN
For users in France : Conformément à la loi « Informatique et Libertés » N° 78-17 du 6 Janvier 1978, vous bénéficiez d’un droit d’accès, de rectification et d’opposition que vous pouvez exercer en vous adressant à :
SCENTAIR FRANCE PARC D’ACTIVITES DU CASSE 2 16 RUE JEAN MONNET 31240 SAINT JEAN
If you have any questions, you may submit an inquiry to our Data Protection Committee by emailing firstname.lastname@example.org.
Last Updated: [8 January 2019]