Effective date: 1 Sept 2019
• Smarttrove Tech (located at Heritage One, Gurgaon, Haryana 122101, India) is the data controller including all the processing activities in relation to product support, product analysis and development activities.
THE INFORMATION WE COLLECT
We refer to these products and services collectively as the "Services".
We obtain information about you through the means discussed below when we provide the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.
STT collects a variety of information that you provide directly to us. For example, STT collects information from you through:
Information about you. While some of the Services may not require you to provide any information that can directly identify you by name, the specific types of information we collect will depend upon the Services you use, how you use them, and the information that you choose to provide. The types of data that we collect directly from you include:
Information about others. If you request that your STT purchase be delivered to someone other than yourself (such as a gift recipient), we use the information that you provide about the other person to fulfil the delivery.
STT ID. Some of our products and features will allow you or require you to create an account and establish a STT ID or Skyfly (the brand of STT) ID. This ID may allow you to sign in to a range of STT Services. It also enables STT to consolidate information collected across a range of STT products and services, which helps us provide you with a more seamless experience across our Services.
When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third-party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
Websites. When you use our websites, we collect and analyse information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services and upload or post content, error logs, and other similar information.
Connected STT products. If you connect your STT product (such as headphones or speakers) to the Internet or to a STT software or application, we may automatically receive information from the STT product about how you use the product. Such information includes:
STT mobile applications and software. When you use a STT mobile application or software, we automatically receive certain information about the mobile phone, tablet or computer used to access the application or software, including a mobile device identifier, IP address, operating system, version, Internet service provider, browser type, domain name and other similar information, whether and when you update the app and your connected STT products, date and time of use, and how you use the app, including time spent in different portions of the application, content accessed or downloaded (including stations played, playlists, artists, albums, songs or podcasts), and a list of systems and software applications.
Location information. When you use the Services, we and our service providers may automatically collect general location information (e.g. IP address, city/state and/or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user's general location (e.g. providing access to local radio stations).
We will ask your permission before collecting your precise GPS location information. In such instances, we will use your precise geo-location information to provide customised services, content, promotional offers and other information that may be of interest to you. We may also use this information to enable you to locate a lost or stolen device. If you no longer wish for us and our service providers to collect and use GPS location information, you may disable the location features on your device. Please see your device manufacturer settings. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services.
Collection of information across STT products, personal devices and applications.
Sometimes, we (or our service providers) may use the information we collect—for instance, usernames, IP addresses and unique mobile device identifiers—to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets or connected STT products), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt out of cross-device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
At STT retail locations or third-party retail locations that sell STT products, you may additionally have the ability to connect your personal devices to STT digital displays or to otherwise provide information about yourself through such displays. If you choose to connect to such displays or provide STT with information about yourself in this way, the types of information we collect include the type of phone you are using to initiate the connection (e.g. iOS7) and the name that you assigned to your phone (if any).
Similarly, if you connect your STT device to underlying platforms or content providers (e.g. Spotify or Amazon Echo and Alexa), such providers allow us and our service providers to have access to and store additional information about your interaction with those providers as it relates to use of the Services (e.g. to display your recently played Spotify playlist within STT connected products and mobile applications, understand how often you use Alexa to play music etc.). If you do not wish to have this information shared, do not initiate these connections.
When you "like" or "follow" us on Facebook, Instagram, Twitter or other social media sites, we may collect some information from you including your name, email address and any comments or content that you post that is relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
STT may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you with the STT brand and improve STT’s products, analytics and advertising.
HOW WE USE YOUR INFORMATION
Aggregate/anonymous data. We may aggregate and/or anonymise any information collected through the Services so that such information can no longer be linked to you or your device ("Aggregate/Anonymous Information"). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners and sponsors.
LEGAL BASES FOR USE OF YOUR INFORMATION
COOKIES AND SIMILAR TECHNOLOGIES
To collect the information in the "Information we automatically collect" section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
As we adopt additional technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g. Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including Flash cookies and local storage objects with the Flash management tools available at Adobe's website. Please note that by blocking, disabling or managing any or all cookies, you may not have access to certain features or offerings of the Services. For example, to complete a purchase on our websites, you will need to accept cookies sent by our sites.
ONLINE ANALYTICS AND ADVERTISING
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyse usage information through cookies and similar tools; engage in auditing, research or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on. We may also use Adobe Analytics to analyse and optimise the performance of our websites, advertising and content. Learn more about Adobe’s privacy practices and making choices regarding Adobe’s tracking activities.
If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites that you visit and other applications that you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties, whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone or other device to collect information about you as discussed above. We also allow other third parties (e.g. ad networks and ad servers such as Google Analytics) to serve tailored ads to you on the Services, other sites and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone or other device you use to access the Services. We sometimes provide our customer information (such as email addresses) to service providers, who may "match" this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.
Please note that if you exercise the opt-out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behaviour over time.
When using mobile applications from STT or others, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalised in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognise or respond to browser-initiated DNT signals.
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
STT will share your information in the following ways:
RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
DATA SUBJECT RIGHTS AND YOUR CHOICES
You have certain rights with respect to your information as further described in this section.
If you would like further information in relation to your legal rights under applicable law, the procedures to exercise any of your rights or if you would like to exercise any of them, please contact our Data Protection Officer using the information in the “STT contact information” section below at any time. Your local laws may permit you to request that we:
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law.
To place an order on our websites, you must have cookies enabled.
THIRD PARTY LINKS AND FEATURES
Please note that in providing services to you, STT may subcontract the processing of your data to, or otherwise share your data with, other members within the STT group, trusted service providers and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
HOW WE PROTECT YOUR INFORMATION
STT takes technical and organisational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through or on our Services or via the Internet and that any such transmission is at your own risk.
Where we have given you (or where you have chosen) a password which enables you to access to a STT account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The Services may contain careers sections that link to websites where you can apply for employment at STT. STT will use and share your information only for employment purposes, such as evaluating you for a job opportunity or communicating with you about your interests, and where sharing is required by law. If you have any questions about the handling of your employment application data, please contact us through one of the methods described below.
STT CONTACT INFORMATION
You may also contact our Data Protection Officer by using the email address above or by postal mail at the following address: A204, Heritage One, Sector 62, Gurgaon 122101, Haryana, India.