innogy SE and data protection

version 2.2, valid from 17/5/2018

1 General

At innogy SE (“innogy”) we take the protection of your personal data very seriously. Your privacy is important to us. We process your personal data for the purposes specified below in accordance with the applicable statutory data protection requirements.

Via our app, the web portal and the SmartHome platform we enable you to control your SmartHome-compatible devices and connect them with one another. It is also possible to purchase and use new products and services. To enable us to offer you new products and services we integrate other partners who also need access to specific data in order to provide these products and services, e.g. if you access your user account via a voice control system (such as Amazon “Alexa”) or if you contact a partner’s service hotline and need help with your SmartHome-compatible devices. innogy will also share specific data with partners who have specialised in developing innovative products and services for SmartHome. In this context innogy ensures that where it is not necessary these partners cannot establish any connection to you personally through using the data.

For the purposes of this data protection information, personal data refers to all information that establishes a connection to you personally. In particular, relevant personal data are data that are collected online via the app or website (e.g. cookie or tracking data, user IDs, IP addresses) and your personal data (e.g. name, address, contact details, information about your living circumstances), data from your SmartHome devices (e.g. your controller ID, heating/lighting control data, information on safety equipment used, system configuration data, photos and videos, information on energy consumption), advertising and sales data (i.e. insights from customer data analyses).

You can find out how we use these data below. We have divided our data protection information into chapters to provide a better overview.

2 Responsible entity and contact

innogy SE, Opernplatz 1, 45128 Essen, Germany, tel. +49 (0) 800 1234060, fax +49 (0) 800 1234090, e-mail smarthome.service@innogy.com, is responsible for processing your personal data.

If you have any questions or comments about data protection at innogy (for example about accessing or updating your personal data) you can also contact our data protection officer (datenschutz@innogy.com) quoting the keywords “data protection”.

3 General information on visiting our website and using our app

3.1 Log files

innogy records data and information via an automated system each time the app and website are accessed. These are stored in the server’s log files. These are files which log processes that run on a computer or network system.

The following data are collected in this context:

  • Information on the browser type and the version used
  • User’s operating system
  • User’s internet service provider
  • User’s IP address
  • Date and time of access
  • Websites via which the user’s system accesses our website (referrers)
  • Websites the user’s system accesses via our website.
  • User name

Processing the IP address serves to protect against and trace hackers and cyber attacks. Processing the other data serves the purposes of delivering the content of our website, ensuring the functionality of our information technology systems, optimising our website and safeguarding the functionality of the website. In this process the data in the log files are always stored separately from other personal data of users.

This processing of your aforementioned data is necessary for the purposes of the legitimate interests pursued by innogy and is justified by a balance of interests in favour of innogy. innogy has a legitimate interest in ensuring that the websites and the services offered there function from a technical perspective. Your legitimate interest in your aforementioned data not being used for this purpose does not override this legitimate interest of innogy, as innogy uses these data in an appropriate manner in accordance with the processing purpose described, uses only your IP address as an identifying characteristic when doing so and you also benefit from the functionality of the websites.

Your personal data are erased after no longer than 2 months, except if innogy is legally required to retain them or retention is justified on legal grounds.

3.2 Web analysis and web optimisation using cookies and tracking pixel

We use cookies and tracking technologies on our website and in the app. These serve the purposes of optimising our app and website and enhancing services, as well as marketing purposes. The technologies and their functionality are explained below.

If you open our app or visit our website we will store information on your smartphone/tablet/computer in the form of a “cookie” that we will automatically recognise on your next visit. Cookies are text files that are stored in the internet browser or that the internet browser stores on the user’s computer system. If a user accesses a website a cookie may be stored on the user’s operating system. This cookie contains a distinctive character string that allows unique identification of the browser if the website is accessed again.

Using cookies helps us to offer you full use of our website. Cookies help us to make your visit to our website as convenient as possible. Cookies enable us, for example, to tailor a website to your interests or save your user name so that you do not need to re-enter it every time you visit.

We also use tracking pixels on our website. Tracking pixels are small graphics on websites that allow log files to be recorded and analysed. The tracking pixels write information into the cookie file in the user’s browser when they visit the website. Using pixels enables us to show you targeted information and content.

Please note that cookies and pixels (hereinafter referred to only as “cookies”) that are necessary for technical reasons must be used to maintain the functionality of our website.

innogy uses cookies from the following categories:

3.2.1 Necessary cookies

Necessary cookies serve to ensure the faultless technical operation of our app and website. For example, they ensure the stability of the app and website, offer secure login and save the progress of your order, your login details and your settings.

In this process the following data are stored in the cookies and transmitted to innogy:

  • Language settings
  • Items in the shopping basket
  • Login information
  • Search terms

Technical measures are taken to pseudonymise the user data collected in this way so that it is no longer possible to attribute the data to the users. The data are not stored together with other personal data. When you access our websites or open our app an info banner will inform you about the use of cookies for analytical purposes and refer you to this data protection information. In this context information will also be provided on how to prevent cookies from being stored in your browser settings.

This processing of your aforementioned data is necessary for the purposes of the legitimate interests pursued by innogy and is justified by a balance of interests in favour of innogy. Some functions of our website cannot be offered without such use. These require the browser to be recognised even after leaving the site. innogy also has a legitimate interest in processing your aforementioned data to that effect, namely to promote the sale of its own products through the functional operation of its own websites. Your legitimate interest in your aforementioned data not being used for this purpose does not override this legitimate interest of innogy, as innogy uses these data in an appropriate manner in accordance with the processing purpose described and you can prevent cookies from being stored.

You have the right to object at any time to the processing of your data on the basis of a balance of interests on grounds relating to your particular situation. See Section 10.

3.2.2 Analytical cookies

We also use cookies on our website and in the app that allow the user’s surfing behaviour to be analysed. Analytical cookies enable us to analyse the website and the app so that we can measure and improve their performance. Analytical cookies are, for example:

  • etracker: We use the “etracker” from etracker GmbH in the online help. We will not use the data collected in this manner to identify you personally without your express consent or combine these data with your personal data.
  • Google Analytics: We use “Google Analytics” from Google LLC, Mountain View, California, USA in the online help. We will not use the data collected in this manner to identify you personally without your express consent or combine this data with your personal data. We use cookies to create statistical profiles. These are not attributable to individuals, but only to groups. They are used to analyse visitor and click behaviour as well as the demographic characteristics of website visitors. You can opt out of the use of cookies here: https://tools.google.com/dlpage/gaoptout?hl=en.

In this process the following data are stored in the cookies and transmitted to innogy and the respective provider:

  • Frequency of page views
  • Utilisation of website functions
  • Aborted actions or errors
  • Pages and menus accessed

In this context we also use cookies for remarketing. By using the cookies we can subsequently ascertain, on an anonymised basis, the points at which you aborted your visit to the website and the products you were interested in. This helps us to make the website more interesting. 

You have the right to object at any time to the processing of your data on the basis of a balance of interests on grounds relating to your particular situation. See Section 10. You can most easily change the settings relating to etracker analysis here (https://www.etracker.de).

3.2.3 Duration of storage

We store the information transmitted to us via cookies for a period of [three months] after collection; it is subsequently erased automatically.

4 Specific online-based offers

4.1 Our app

You can register with innogy’s app by providing personal data. In this case the data (e.g. name, address, user name, e-mail address and telephone number) are transmitted to innogy.

Your IP address as well as the date and time of registration are also stored during registration. The aim of this is to prevent misuse of the services. The data are not shared with third parties unless there is a legal obligation to share them. This processing of the IP address, date and time is necessary for the purposes of the legitimate interests pursued by innogy and is justified by a balance of interests in favour of innogy. innogy also has a legitimate interest in processing your aforementioned data for the purpose of registration, namely in order to facilitate the handling of your request or order or to facilitate further communication and structure the customer relationship. Your legitimate interest in your aforementioned data not being used for this purpose does not override this legitimate interest of innogy, as innogy uses these data in an appropriate manner in accordance with the processing purpose described and you can expect such use of your data by proceeding with registration, proceed with this voluntarily and also benefit from this due to processes running more smoothly. 

If you delete the app on your smartphone, the information stored on your smartphone will also be erased accordingly. To delete your user account please send an e-mail quoting the keywords “Delete user account” and specifying your user name, last name and first name to smarthome.service@innogy.com. It is important here that you provide the data as you entered them at the time of registering with us.

Your data will be blocked rather than erased if innogy is required to retain your personal data in accordance with commercial retention periods or other legal provisions.

This processing of the data you specified during registration is necessary for the performance of your contract.

4.2 Web portal

You can also set up your SmartHome central unit via a web portal and use it to integrate and manage your devices. The web portal also enables you to configure your SmartHome and clearly view all the information on a dashboard. You can register for this personalised area.

In this case the data in the relevant input screen (in particular, name, address, user name, e-mail address and telephone number) are transmitted to innogy.

Your IP address as well as the date and time of registration are also stored during registration. The aim of this is to prevent misuse of the services. This processing of these aforementioned data is necessary for the purposes of the legitimate interests pursued by innogy and is justified by a balance of interests in favour of innogy. innogy also has a legitimate interest in processing your aforementioned data for the purpose of registration, namely in order to facilitate the handling of your request or to facilitate further communication and structure the customer relationship. Your legitimate interest in your aforementioned data not being used for this purpose does not override this legitimate interest of innogy, as innogy uses these data in an appropriate manner in accordance with the processing purpose described and you can expect such use of your data by proceeding with registration, proceed with this voluntarily and also benefit from this due to processes running more smoothly.

The data collected for registration are erased if the registration is cancelled or modified on our websites.

4.3 Newsletter

You can subscribe to a free newsletter in the app and on the web portal. The data from the input screen are transmitted to us during registration for the newsletter (e-mail address, telephone number). The following data are also collected during registration:

  • IP address of the accessing computer
  • Date and time of registration

Your e-mail address is collected for the purpose of delivering the newsletter. Collection of other personal data during the registration process serves to prevent misuse of the services or of the e-mail address used.

In order to process the data for sending the newsletter your consent is obtained as part of the registration process and reference made to this data protection information. The legal basis for this processing of your personal data is your consent to this.

You have the right to withdraw consent with effect for the future at any time without affecting the lawfulness of processing based on consent before its withdrawal.

If you provide your e-mail address in connection with purchasing goods or services on our website we may subsequently use it to send a newsletter for direct marketing of our own similar goods or services. The legal basis for this processing of your personal data is Section 7 (3) of the German Act Against Unfair Competition (UWG). You can object to this direct marketing at any time without stating reasons. See Section 10.

You can cancel your subscription to the newsletter at any time by clicking on the relevant link in the respective newsletter.

The data collected during registration for the newsletter are stored for as long as the newsletter subscription is active.

4.4 Methods of establishing contact

innogy processes your personal data for the purpose of establishing contact. Contact forms that can be used to establish contact electronically are available on our websites. Alternatively, you can contact us using the contact details specified under Section 2.

If you contact us via one of these channels, the personal data voluntarily transmitted by you will be stored automatically. Storing the data serves the purposes of handling your request, establishing contact with you or, with your consent, marketing purposes.

This processing of your aforementioned data is necessary for the purposes of the legitimate interests pursued by innogy and is justified by a balance of interests in favour of innogy. innogy has a legitimate interest in offering you a platform for establishing contact and communicating with us easily. Your legitimate interest in your aforementioned data not being used for this purpose does not override this legitimate interest of innogy, as it is also in your interest that we process your request for contact and respond to it. The other personal data processed during the sending process serve to prevent misuse of the contact form and safeguard the security of our information technology systems.

Your personal data are automatically erased [3 months] after your request for contact has been answered and there is no justification for retaining them (such as an existing customer relationship) or statutory retention periods.

5 Advertising by post and e-mail

If you have provided your contact details to us, innogy uses your name and address to send you product information on energy products from innogy (e.g. energy generation and supply, energy efficiency, electromobility and other energy-related benefits and services) and in future also telecommunication products or services from innogy (e.g. telephone and internet). If you are an existing customer who has already purchased or used goods or services from innogy, innogy also uses the e-mail address you provided when doing so to send you product information on similar goods or services unless you have objected to this.

In order to address advertising to you we share your name and address with third parties and processors (e.g. dispatch service providers, media agencies) who process them in order to prepare advertising material and send it to you.

This processing of your aforementioned data is necessary for the purposes of the legitimate interests pursued by innogy and is justified by a balance of interests in favour of innogy. innogy cannot send any direct marketing to you without using these data. innogy also has a legitimate interest in processing your aforementioned data for the purpose of direct marketing of innogy products that are tailored to you, namely to promote the sale of its own products. Your legitimate interest in your aforementioned data not being used for this purpose does not override this legitimate interest of innogy, as innogy uses this data in an appropriate manner in accordance with the processing purpose described and also does not use any sensitive data from your customer relationship with innogy in order to do so. Furthermore, the use of your data for advertising purposes constitutes processing that you can expect in existing contractual relationships or after having expressed an interest in products or services from innogy so that no nuisance can be assumed as a result of the direct marketing. In addition, innogy only uses your aforementioned data for the direct marketing of innogy products if you have not objected to this.

innogy further ensures via the communication channels selected for advertising (post and in the case of self-promotion for existing customers also e-mail) that these cause you the least disturbance possible.

6 Postal advertising on behalf of and by third parti

If you have provided your contact details to us, innogy also uses your name and address as part of its promotional approach to send you product information on products and services from third parties (e.g. companies in the innogy Group, business partners who offer similar products).

This processing is justified by a balance of interests in favour of innogy. As explained above, innogy has a legitimate interest in sending you direct marketing. This also includes direct marketing for third-party products and services. Firstly, the transmission of third-party advertising in connection with innogy’s own advertising may also increase your interest in these products, which leads to an increase in sales for innogy and the third party. Secondly, innogy has a financial interest in granting third parties this opportunity to participate in advertising. As is the case with its own direct marketing for innogy products, your interest in your data not being used for such third-party advertising purposes is secondary; this is primarily due to the low level of nuisance resulting from postal advertising and your right to object to such use of your data.

If you have previously granted consent for this, third parties (see Section 9) will also offer you their own products and services directly. In this case innogy shares the data covered by this consent (e.g. contact details) with third parties, for example with service providers and device manufacturers, so that they can send you offers for SmartHome-compatible devices and services.

7 Market research and opinion polling

If you have provided your contact details to us, innogy also shares your name and address with market research and opinion polling institutes to enable them to conduct surveys on its behalf. The market research and opinion polling institutes work on behalf of and in accordance with the instructions of innogy. These surveys provide us with an overview as regards the transparency and quality of our products, services and communications and enable us to structure and design them to meet your requirements.

This processing is justified by a balance of interests in favour of innogy. innogy has a legitimate interest in processing your data for the purpose of market research and opinion polling, namely to improve the products and services it offers and thereby to promote the sale of its own products, potentially also in connection with third-party products. This enables innogy to ascertain your level of acceptance and satisfaction with the products and services offered by innogy and to evaluate and analyse your interests so as to be able to offer you products and services that are tailored even better to your requirements in the future. Furthermore, the use of your data for market research and opinion polling constitutes processing that you can expect in existing contractual relationships or after having expressed an interest in products or services from innogy. Your data are used only for the aforementioned purposes, which – unless you have objected – are also in your interest.

Market research and opinion polling will only be conducted by a means other than by post if you have granted us specific consent to use your data in this way.

If you no longer wish to participate in customer surveys you can object to this using the contact addresses specified in Section 2.

8 Data analyses (profiling)

We use evaluation tools to enable us to send you targeted information on products and services, i.e. including as part of direct marketing. innogy will analyse your personal data (e.g. configuration data, operating and status information about integrated devices and energy consumption data) and enhance it with publicly accessible and purchased socio-demographic data. innogy would like to use this to approach you with individual, tailored offers from innogy and innogy partners. The legal basis for this is a balance of interests in favour of innogy and its partners. innogy and its partners have a legitimate interest in aligning advertising as closely as possible with the recipient’s interests and in improving products and services from both innogy as well as the innogy Group and innogy partners in order to promote the sale of its own products. Furthermore, innogy and its partners have a legitimate interesting in avoiding the use of misdirected advertising material. This overrides your legitimate interests, as this way only advertising aligned with your interests is directed to you and you are protected against indiscriminate advertising and thus affected as little as possible by promotional approaches.

In order to evaluate and analyse customer interests your data (e.g. energy consumption data, operating and status information about integrated devices, scenarios you have programmed) are also shared in anonymised and pseudonymised form within the innogy Group (see Section 9) as well as in anonymised or, where not otherwise technically possible, in pseudonymised form with innogy partners who sell similar products (see Section 9 for general definition of innogy partners). Anonymised means that your personal data are retrospectively processed in such a way that they cannot or can no longer be identified. Pseudonymised means that your personal data cannot be attributed to you as a data subject without the use of additional information. This additional information is kept separately by innogy and is subject to technical and organisational measures to ensure that third parties cannot attribute the data to you.

The data are analysed for the purpose of improving and developing intelligent and innovative services and products.

The sharing and analysis of exclusively anonymised and pseudonymised data by other companies within the innogy Group can also be based on a balance of interests in favour of innogy. The legitimate interest of innogy lies in exchanging general information on specified customer groups with other companies in order to be able to improve products and services as a result. Your data are transferred exclusively in anonymised and pseudonymised form in order to take account of and protect your interests in the best manner possible. The data derived from the data analysis are only used for the aforementioned purposes, which – unless you have objected – are also in your interest. These data will not be processed or shared in any other way.

9 Recipients of your personal data

9.1 Third parties and processors

Your personal data are also used by other companies acting on behalf of innogy (“processors”) or acting in connection with business partners of innogy (“third parties”). This may include companies within the innogy Group (“innogy Group”) as well as external companies and partners (“innogy partners”). Possible recipients of your data are insurance companies, manufacturers of SmartHome-compatible devices, security companies, call centres, marketing and media agencies, market research institutes, social media companies, IT service providers, consultants or consulting companies specialising in data analysis, logistics companies, service providers for onsite installations, service providers for invoicing and payment activities, companies involved in the use of cookies and tracking pixels and other service and cooperation partners.

For details, please refer to the detailed descriptions of the types of data processing in this data protection information.

The processors mentioned in this data protection information have been commissioned by innogy SE and required to comply with the level of data protection and data security employed at innogy SE. Among other things, this requirement specifies that service providers may only receive those data that they need in order to perform their respective contracts.

9.2 Recipients outside the European Union (EU)

innogy arranges for individual services and tasks to be performed by carefully selected, contracted service providers that are headquartered outside the European Economic Area (“third country”), e.g. IT service providers. In such cases the data are transmitted to a third country. Where legally required in order to ensure an appropriate level of protection for your data, innogy employs guarantees meeting the statutory requirements to ensure an appropriate level of data protection; this includes, for example, EU standard contracts. You can request further information and be provided with copies of the relevant agreements at any time.

10 Your rights

In accordance with the statutory provisions (including any applicable restrictions under the GDPR and/or new Federal Data Protection Act (BDSG)) you can assert the following rights against us:

10.1 Access

You have the right in accordance with the provisions of Article 15 GDPR (where applicable with the restrictions under Section 34 BDSG (new)) to obtain access from us to the information we are storing about you.

10.2 Rectification

In accordance with Article 16 GDPR and at your request we will rectify the data stored about you if they are inaccurate or erroneous.

10.3 Erasure

If you wish, we will erase your data in accordance with the principles of Article 17 GDPR unless other statutory regulations (e.g. statutory retention requirements or the restrictions under Section 35 BDSG (new)) or an overriding interest on our part (e.g. to defend our rights and claims) or other reasons under Article 17 GDPR preclude this.

10.4 Restriction

You can request that we restrict the processing of your data, taking into account the requirements of Article 18 GDPR.

10.5 Data transfer

In accordance with the requirements of Article 20 GDPR you also have the right to receive your data in a structured, commonly used and machine-readable format or to transmit them to a third party.

10.6 Complaint

You are furthermore entitled to complain to a data protection supervisory authority (Article 77 GDPR). You can contact the supervisory authority responsible for innogy as follows:

Landesamt für Informationssicherheit und Datenschutz Nordrhein-Westfalen

PO Box 20 04 44

40102 Düsseldorf
Germany

(www.ldi.nrw.de).

You are welcome to contact our data protection officer first.

10.7 Objection

You can also lodge an objection to the processing of your data in accordance with Article 21 GDPR (please see box for further information).

To exercise these rights you can contact us using one of the contact methods specified in Section 2.

Information on your right to object under Article 21 GDPR

You have the right to object at any time to the processing of your data based on Article 6 (1) f GDPR (data processing on the basis of a balance of interests) or Article 6 (1) e GDPR (data processing in the public interest) on grounds relating to your particular situation. This also applies to any profiling within the meaning of Article 4 no. 4 GDPR based on this provision.

If you lodge an objection we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

We also process your personal data for direct marketing purposes. If you do not wish to receive any advertising you have the right to object to this at any time; this includes profiling to the extent that it is related to such direct marketing. We will comply with this objection in the future.

The objection does not have to be submitted in any specific form and if possible should be directed to:

innogy SE, Opernplatz 1, 45128 Essen, Germany, tel. +49 (0) 800 1234060, fax +49 (0) 800 1234090, e-mail smarthome.service@innogy.com

PREVIOUS VERSIONS

innogy and data protection

Version 2.1, valid from 19/04/2017

The security of your personal data is important to us. This is why our web-based activities are conducted in accordance with the laws on data protection and data security. You can find out what information we may collect and how we use that information below.

I. Definitions within data protection conditions

  • Platform partner: Platform partners are partners of innogy SE that integrate their components or services into innogy’s SmartHome services and are involved in the further development and maintenance of the SmartHome platform of innogy SE. 
  • PI partner: API partners are partners of innogy SE that develop applications, portals and apps into which users can themselves integrate the innogy SmartHome solution if they wish to do so. When integration takes place, responsibility for personal data is transferred to the API partner. Please note the relevant data protection conditions of the API partner.
  • Service provider: Carefully selected and contracted service providers (in accordance with Section 11 Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG)) and service partners (in accordance with Section 11 BDSG) that perform tasks and services for innogy SE and IT service providers for client and hosting services.
  • System user: The main user of the SmartHome services from innogy SE.
  • Joint user: User also created by the system user.
  • Other partner: Carefully selected further partners of innogy SE, known as data partners, that retain data in highly pseudonymised or (where possible) anonymised form and process this data for analysis and another commercial purposes. Personal data (e.g. name, address) is shared only if you have given your express consent.

II. Personal data

The fundamental principle by which innogy SE is guided is that the protection of your personal data is of the utmost importance. We therefore do not collect or process any personal data via our websites or devices connected to the SmartHome services without your consent. You alone decide whether or not you want to provide such data, for instance during a registration process, in response to a survey, during installation/configuration etc. As a general rule, we use your personal data to answer your queries, process your order, for system maintenance and configuration or to provide you with access to special information or offers, for example via e-mail newsletters. innogy SE may arrange for individual tasks and services to be performed by carefully selected, contracted service providers and platform partners that are headquartered inside and outside the EU/EEA where this is necessary for the performance of the contract, the provision of our services or to develop and maintain the SmartHome services from innogy SE. With that in mind, data protection agreements that comply with the relevant legal requirements are concluded with the contracting parties in order to ensure an appropriate level of data protection. innogy SE passes on personal data to API partners if you have voluntarily integrated their systems yourself and have consented to your information being shared. Please note the relevant data protection conditions of the API partner in question. Your personal information is shared with other partners – for example for advertising purposes – only if you have expressly consented to that information being shared. You will be duly informed when this situation arises and asked for your express consent. Any unnecessary data will be deleted immediately if no longer required for business purposes or due to any other legal provisions.

III. Storage of access logging data

Every time a file is requested from our internet presence, access data is saved. Each data record comprises:

  • Anonymised IP address
  • The page from which the file was requested
  • The name of the file requested
  • The date and time of the request
  • The data quantity transferred
  • The access status (file transferred, file not found etc.)
  • A description of the type of web browser used
  • The operating system used by the requester
  • The requesting domain
  • Number of visits
  • Pages and menus called up

The data we store is used solely for statistical purposes and to maintain, protect and improve our services, to develop new services and to protect innogy SmartHome and our users.

IV. Cookies

If you visit our website or use the innogy SmartHome app, we may store information on your computer in the form of a “cookie” that will be automatically recognised on your next visit, e.g. for the language you initially selected in the app. Cookies enable us, for example, to tailor a website to your interests or save your user name so that you do not need to re-enter it every time you visit. If you do not want us to recognise your computer, please configure your internet browser in such a way that cookies are deleted from your hard drive, all cookies are blocked or you receive a warning before a cookie is saved.

V. Information on web analysis

Data entered on this website may be collected and saved using technology supplied by etracker GmbH (www.etracker.com) for marketing and optimisation purposes. This information can be used to generate user profiles stored under a pseudonym. Cookies may be used for this purpose. Cookies are small text files that are saved locally in the cache of the website visitor’s internet browser. The cookies enable the recognition of the internet browser. The data collected using the etracker technology will not be used to identify the website visitor or be combined with personal data stored under a pseudonym profile without the express consent of the individual concerned. You can opt out of the future collection and storage of your personal information at any time.

VI. Device activity logging

innogy SE and its contracted service providers will log the activities of your devices unless you deactivate this function for all devices or specific devices via the SmartHome user interface. The activity logging covers all the activities of the device as well as physical readings such as the room temperature, air humidity etc., and saves this information in a log file that you can access.

(1) Access by system user / joint user
The log files are accessible only to you and to those people to whom you have granted access (joint users). Joint users are people who you as the main user (system user) have personally invited to have shared access to the system following its installation and whose identity you must also personally verify manually after their registration (e.g. family members). You can remove their access at any time.

(2) Access by innogy SE and platform partners
The device activities recorded are used by innogy SE and platform partners to offer you personal analyses and added-value services within the SmartHome user software (for example, energy-saving tips or mould protection warnings based on the use of your device, the device settings, the values measured by the device etc.). 
In addition, innogy SE will also analyse the device activities recorded – in so far as possible anonymously and using pseudonyms – in order, for example, to identify device faults and failures as well as their possible causes on the basis of usage patterns.

(3) Sharing with API partners
Device activities recorded will be shared with API partners only if you have voluntarily integrated their systems yourself and have consented to your information being shared. Please note the relevant data protection conditions of the API partner.

(4) Sharing with other partners
Device activities recorded will be shared with other partners – for example for advertising purposes – in anonymised form only and only if you have expressly consented to that information being shared. You will be duly informed when this situation arises and asked for your express consent.

(5) Deactivating logging and deletion
If the logging function is deactivated, the log files recorded up to that point are deleted. Don’t forget to tell the people affected by this logging activity (e.g. the people who live in your household) about this function.

VII. Saving and processing of camera images

When you use the SmartHome camera service, SmartHome will save the camera images taken by you using the SmartHome system with your other data in the innogy data centre.

(1) Access by system user / joint user
The camera images are accessible only to you and to those people to whom you have granted access to the innogy data centre (joint users, see above for definition).

(2) Access by innogy SE and platform partners
innogy SE and platform partners will not access this data.

(3) Sharing with API partners
Camera images will be shared with API partners only if you have voluntarily integrated their systems yourself and have consented to your information being shared. Please note the relevant data protection conditions of the API partner.

(4) Sharing with other partners
innogy SE and platform partners will not communicate camera images to unauthorised third parties or other partners or provide them with access to such images.

(5) Deletion and information on camera images
You can delete the camera images that have been recorded and saved at any time via the user software. Don’t forget to tell the people affected by the camera recordings (e.g. the people who live in your household) about this function! Remember to observe the legal provisions in force regarding the installation location and coverage of cameras (in particular in private and public areas and buildings).

VIII. Saving and processing of energy data

When you use the SmartHome energy services (Power Control, Power Control Solar, Energy Control), SmartHome will save the energy and performance data recorded by the corresponding system hardware to your electricity meter. This energy data is presented for your information in the form of graphs and tables within the SmartHome user interface.

(1) Access by system user / joint user
The energy data is accessible only to you and to those people to whom you have granted access (joint users, see above for definition).

(2) Access by innogy SE and platform partners
The energy data saved is also used by innogy SE and platform partners to offer you personal analyses and added-value services within the SmartHome user software (for example, energy-saving tips, electrical equipment, base load information, suggestion of and adherence to monthly advance payment plans).

You also have the option of entering the commercial data specified in your energy supply contract into the user software (for example, the costs per kWh, basic charges, advance payment plans etc.) in order to tailor those analyses and added-value services to your particular circumstances. In addition, innogy SE will also analyse the data – in so far as possible anonymously and using pseudonyms – in order, for example, to develop further products within the SmartHome range.

(3) Sharing with API partners
Energy data saved will be shared with API partners only if you have voluntarily integrated their systems yourself and have consented to your information being shared. Please note the relevant data protection conditions of the API partner.

(4) Sharing with other partners
Energy data saved will be shared with other partners – for example for advertising purposes – only if you have expressly consented to that information being shared. You will be duly informed when this situation arises and asked for your express consent.

(5) Deletion and downloading of data
You can download or delete the energy data saved at any time via the user software. Don’t forget to tell the people affected by the saving of energy data (e.g. the people who live in your household) about this function!

IX. Collection and processing of living circumstances data

When the system is first commissioned, SmartHome gives you the option to enter data relating to your living circumstances (location of the installation, dwelling type, i.e. house / flat, number of people in the household, number of floors, floor space within the dwelling) in addition to the data required in order to manage your user account (e.g. e-mail address, first name, surname, password etc.).

The entry of this data is optional and can be skipped and amended or deleted at a later date in the user software.

(1) Access by system user / joint user
The living circumstances data collected is accessible only to you and to those people to whom you have granted access (joint users, see above for definition).

(2) Access by innogy SE and platform partners
This additional information is used to offer you more specific analyses and added-value services within the SmartHome user software that are tailored to your personal circumstances (for example, energy-saving tips including comparisons with appropriate average households, sunrise and sunset times for the specific location, weather data for the specific location etc.). innogy SE and platform partners will analyse the data – in so far as possible anonymously and using pseudonyms – in order, for example, to develop further products within the SmartHome range.

(3) Sharing with API partners
Living circumstances data will be shared with API partners only if you have voluntarily integrated their systems yourself and have consented to your information being shared. Please note the relevant data protection conditions of the API partner.

(4) Sharing with other partners
Living circumstances data will be shared with other partners – for example for advertising purposes – in anonymous form only and only if you have expressly consented to that information being shared. You will be duly informed when this situation arises and asked for your express consent.

X. System configuration, log files

The SmartHome system automatically creates the system configurations required for the operation of the system, such as – for example – device names and room allocations, operating scenarios etc., and stores those configurations securely on the SmartHome central unit as well as in the SmartHome user interface app on your smartphone or tablet. The system configuration is also saved in the innogy data centre and is used only if you yourself initiate data recovery.

Your central unit and the SmartHome app each register a log file. The configuration of the central unit is saved in a system information file.

Control commands transferred from your central unit and communications between your central unit and your devices are encrypted.

(1) Access by system user / joint user
Access by you for data recovery is secured. Any such data recovery is initiated by you.

(2) Access by innogy SE
innogy SE analyses and reviews the settings of your central unit and control commands created when a connection is established via the innogy data centre in order to guarantee the availability of the SmartHome solution in the event of a malfunction or if technical problems occur.

(3) Access by platform partners
Platform partners will only access the system if required to analyse and rectify faults.

(4) Sharing with API partners
System configurations and log files will be shared with API partners only if you have voluntarily integrated their systems yourself and have consented to your information being shared. Please note the relevant data protection conditions of the API partner.

(5) Sharing with other partners
Information is not shared with other partners.

(6) Deletion of data
System configurations and log files are promptly deleted if, for example, old scenarios are replaced with new ones or if no longer required for business purposes.

XI. Links to other websites

innogy websites contain links to other websites. innogy is not responsible for the data protection strategies or the content of these other websites.

XII. Children – questions and comments

Children should not provide personal data on innogy websites without the consent of a parent or guardian. innogy advises parents and guardians to teach their children how to handle personal data safely and responsibly on the internet. However, innogy will not knowingly collect the personal data of children or in any way use such data or disclose it to third parties without authorisation.

XIII. Changes to our data protection conditions

We reserve the right to make changes to our security and data protection measures if required due to technical development. In such cases, we will also update our data protection information. Therefore, please make sure to read the latest version of our data protection conditions for our innogy SmartHome services.

innogy SE, Dortmund, 19/04/2017


Version 2.0, valid from 01/09/2016

The security of your personal data, such as your name, address, telephone number and e-mail address, is important to us. This is why our web-based activities are conducted in accordance with the laws on data protection and data security. You can find out what information we may collect and how we use that information below.

Personal data

The fundamental principle by which innogy is guided is that the protection of your personal data is of the utmost importance. We therefore do not collect any personal data via our websites without your consent. You alone decide whether or not you want to provide such data, for instance during a registration process, in response to a survey etc. As a general rule, we use your personal data to answer your queries, process your order or provide you with access to special information or offers, for example via e-mail newsletters.

innogy may arrange for individual tasks and services to be performed by carefully-selected, contracted service providers that are headquartered outside the EU/EEA. With that in mind, data protection agreements that comply with the relevant legal requirements are concluded with the contracting parties in order to ensure an appropriate level of data protection.

Your personal information is shared with third parties (for example, for system operations involving SmartHome platform partners or for advertising purposes), where this is necessary for the performance of the contract and the provision of our services, or for any other purposes, only if you have given your express consent to the sharing of that information. You will be duly informed when this situation arises.

Any unnecessary data will be deleted immediately.

No personal data

Some information that cannot be traced back to a particular person (e.g. the internet browser and operating system used; the domain name of the website from which the user was directed; the number of visits, average visit duration, aborted actions and errors; the pages and menus accessed) is occasionally collected automatically (i.e. not as part of a registration process) when you use our SmartHome services. The information collected in the course of supplying our services is used to provide, maintain, protect and improve our services, to develop new services and to protect SmartHome and our users.

Information on web analysis

Data entered on the system login page may be collected and saved using technology supplied by etracker GmbH (www.etracker.com) for marketing and optimisation purposes. This information can be used to generate user profiles stored under a pseudonym. Cookies may be used for this purpose. Cookies are small text files that are saved locally in the cache of the website visitor's Internet browser. The cookies enable the recognition of the Internet browser. The data collected using the etracker technology will not be used to identify the website visitor or be combined with personal data stored under a pseudonym profile without the express consent of the individual concerned. You can opt out of the future collection and storage of your personal information at any time: go to https://www.etracker.com/de/datenschutz.html and click on the button "Bitte schließen Sie mich von der etracker Zählung aus" ["Please stop etracker recording my data"].

Device activity logging

innogy and its contracted service providers will log the activities of your devices unless you deactivate this function for all devices or specific devices via the SmartHome user interface. The log files are accessible only to you and to those people to whom you have granted access (joint users). Joint users are people who you as the main user (system owner) have personally invited to have shared access to the system following its installation and whose identity you must also personally verify manually after their registration (e.g. family members). You can remove their access at any time. innogy will not communicate log files to unauthorised third parties or provide them with access to such files. The activity logging covers all the activities of the device as well as physical readings such as the room temperature, air humidity etc., and saves this information in a log file that you can access. The device activities recorded are used by innogy to offer you personal analyses and added-value services within the SmartHome user software (for example, energy-saving tips or mould protection warnings based on the use of your device, the device settings, the values measured by the device etc.). In addition, innogy will also analyse the data – in so far as possible anonymously and using pseudonyms – in order, for example, to identify device faults and failures as well as their possible causes on the basis of usage patterns. If the logging function is deactivated, the log files recorded up to that point are deleted. Don't forget to tell the people affected by this logging activity (e.g. the people who live in your household) about this function!

Saving and processing of camera images

When you use the SmartHome camera service, SmartHome will save the camera images taken by you using the SmartHome system in the innogy data centre. The camera images are accessible only to you and to those people to whom you have granted access to the innogy data centre (joint users, see above for definition). innogy will not communicate camera images to unauthorised third parties or provide them with access to such images. You can delete the camera images that have been recorded and saved at any time via the user software. Don't forget to tell the people affected by the camera recordings (e.g. the people who live in your household) about this function! Remember to observe the legal provisions in force regarding the installation location and coverage of cameras (in particular in private and public areas and buildings).

Saving and processing of energy data

When you use the SmartHome energy services (Power Control, Power Control Solar, Energy Control), SmartHome will save the energy and performance data recorded by the corresponding system hardware to your electricity meter. This energy data is presented for your information in the form of graphs and tables within the SmartHome user interface. The energy data recorded is also used by innogy to offer you personal analyses and added-value services within the SmartHome user software (for example, energy-saving tips, base load information, suggestion of and adherence to monthly advance payment plans). You also have the option of entering the commercial data specified in your energy supply contract into the user software (for example, the costs per kWh, basic charges, advance payment plans etc.) in order to tailor those analyses and added-value services to your particular circumstances. In addition, innogy will also analyse the data – in so far as possible anonymously and using pseudonyms – in order, for example, to develop further products within the SmartHome range. The energy data is accessible only to you and to those people to whom you have granted access (joint users, see above for definition). . You can download or delete the energy data saved at any time via the user software. Don't forget to tell the people affected by the saving of energy data (e.g. the people who live in your household) about this function!

Collection and processing of living circumstances data

When the system is first commissioned, SmartHome gives you the option to enter data relating to your living circumstances (location of the installation, dwelling type, i.e. house / flat, number of people in the household, number of floors, floor space within the dwelling) in addition to the data required in order to manage your user account (e.g. e-mail address, first name, surname, password etc.). This additional information is used to offer you more specific analyses and added-value services within the SmartHome user software that are tailored to your personal circumstances (for example, energy-saving tips including comparisons with appropriate average households, sunrise and sunset times for the specific location, weather data for the specific location etc.). In addition, innogy will also analyse the data – in so far as possible anonymously and using pseudonyms – in order, for example, to develop further products within the SmartHome range. The entry of this data is optional and can be skipped, amended at a later date in the user software or deleted. The living circumstances data collected is accessible only to you and to those people to whom you have granted access (joint users, see above for definition). innogy will not communicate living circumstances data to unauthorised third parties or provide them with access to such data.

System configuration, log files

The SmartHome system automatically creates the system configurations required for the operation of the system, such as – for example – device names and room allocations, operating scenarios etc., and stores those configurations securely on the SmartHome central unit as well as in the SmartHome user interface app on your smartphone or tablet. The system configuration is also saved in the data centre and is used only if you yourself initiate data recovery.

SmartHome will not exploit or analyse the settings of your central unit. The control commands created when a connection is established via the innogy data centre are saved only up until they have been performed.

Control commands transferred from your central unit and communications between your central unit and your devices are encrypted. SmartHome will not use any control commands in order to analyse them.

Your central unit and the SmartHome app each register a log file. The configuration of the central unit is saved in a system information file. If a technical problem occurs, you can send the log files and system information file to the SmartHome Service for the problem to be analysed. All employees who carry out problem analysis are obliged to observe data secrecy. The log files or system information file sent by you will be used for problem analysis only and will be saved only for the duration of the troubleshooting.

SmartHome cannot access the log files or system information file saved in your central unit at any time.

Your central unit reports the online status, logged-in users and the status of the software and hardware (of the central unit) to the data centre. The purpose of this communication is solely to meet the requirements relating to the security and operation of the central unit.

Links to other websites

innogy websites contain links to other websites. innogy is not responsible for the data protection strategies or the content of these other websites.

Questions and comments

If you have any questions or comments about data protection at innogy (for example about viewing or updating your personal data), please contact us quoting the keywords "data protection" via Datenschutz@innogy.com. The further development of the Internet has an impact on our data protection strategy. We will announce any changes on this page in good time.

Children

Children should not provide personal data on innogy websites or to SmartHome services without the consent of a parent or guardian. innogy advises parents and guardians to teach their children how to handle personal data safely and responsibly on the Internet. However, innogy will not knowingly collect the personal data of children or in any way use such data or disclose it to third parties without authorisation.

Security

innogy takes precautions to guarantee the security of your personal data. Your information is conscientiously protected against loss, destruction, falsification, manipulation and unauthorised access or disclosure.

innogy SE, Dortmund, 01/09/2016