Smart-me AG (hereinafter “smart-me”) respects the privacy of every person who uses the smart-me devices, visits the smart-me website, or uses the smart-me cloud functions. If you use smart-me services, you entrust us with your data. You can use this data in a variety of ways—to monitor, visualize, control, and bill energy flows. By agreeing to this privacy policy, you consent to your meter data being stored and processed in the smart-me cloud. In this privacy policy, you will learn what data we collect, for what purposes we collect it, and how we use the collected data. The security of your data is therefore our top priority. Our privacy policy explains:

  • How We Protect Your Data
  • What information we collect and why
  • How We Use This Information
  • The options we offer, including how information can be accessed and how it can be updated.

The protection of your data is important to smart-me , and we therefore ask you—whether you are a new or long-time user—to take the time to familiarize yourself with our practices. If you have any questions, please contact us.

How We Protect Your Data

Encryption

Every access to your data in the smart-me cloud is SSL (TLS) encrypted. All access attempts are logged and analyzed. Passwords and other sensitive data are stored only in encrypted form. All connections between the devices (meters, modules, electric charging stations, and gateways) and the smart-me cloud are encrypted. Each device has its own unique key (128-bit). AES is used as the encryption algorithm.

Help ensure even greater security for your data by encrypting your Wi-Fi network with a strong password.

Access Security

The measurement data from the user’s various devices (e.g., electricity meters) is recorded in the smart-me cloud and further processed in anonymized form. The user also has the option of making their measurement data visible to other users. The smart-me servers are located in secure data centers in Switzerland and are accessible only to authorized personnel.

Information We Collect

We collect information to provide better services to all of our users—from determining basic details such as the language you speak to more complex details such as energy consumption (electricity, water, gas, heat). We collect information in the following ways:

Visiting the smart-me websites

You can visit our website without having to provide any personal information. We store your access data without linking it to you personally.

Log data

However, when you access content provided by smart-me, we collect and store certain data in server logs. These logs include, among other things:

Details about how you have used our services, such as the pages you have visited on smart-me.com

IP address

Data on device events such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request, and the referral URL

Location-related information

Local storage: We may collect and store information (including personal data) locally on your device using mechanisms such as your browser's web storage (including HTML5) and application data caches.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store data when you access a smart-me service. This may also include cookies or similar technologies used to identify your browser or device. You can prevent cookies from being installed by adjusting your browser settings accordingly; however, please note that in this case, you may not be able to use all features of this website to their full extent.

Analysis

To enable statistical analysis of user behavior, smart-me uses analytics services and tracking technologies provided by Google, Mountain View, California, United States. The data collected in this way are anonymized. Only information about how smart-me products are used—such as page views and loading times—is recorded; personal data, customer-identifying information, or content are never collected. The data collected in this way are used exclusively for troubleshooting and to optimize the customer experience. The information generated is typically transmitted to and stored by Google on servers in Europe (to enable performance comparisons). You can find more information about Google’s privacy policy here.

Cloudflare

To secure the smart-me server and optimize loading times, CloudFlare is used as a CDN (“Content Delivery Network”). Therefore, all requests are automatically routed through the CloudFlare server and aggregated into statistics that cannot be disabled. According to the company, the collected raw data is typically deleted within 4 hours, or after 3 days at the latest. Here you will find information about the data collected there and about security and data protection at CloudFlare. CloudFlare also operates within the framework of the Privacy Shield Agreement between the EU and the U.S.

Contact forms

If you use the contact and registration forms available on our website, you should not enter any sensitive or particularly sensitive data. Information transmitted over the Internet (such as online forms) and content received online may, under certain circumstances, be transmitted via third-party networks and be visible to everyone.

Use of the smart-me web portal and the smart-me app

Data You Share With Us

To use the smart-me cloud services, you must first create a smart-me account. To do so, we ask you to provide personal information. At a minimum, your email address will be saved.

Data we receive as a result of your use of our services

Device-related information: The meter data recorded in your smart-me account (electricity, water, gas, heat, etc.) are stored in association with the email address you provided.

By using the smart-me cloud services, which require your consent to this privacy policy, you also agree that smart-me may notify you of any new features, changes, restrictions, or modifications necessary for the proper operation and effective use of the portal Extensions. You may withdraw your consent at any time.

Customers of service providers who use smart-me

If your smart-me account is managed on your behalf by an energy billing service provider, the billing service provider and the sales partners who provide customer service for your organization have access to the information on your smart-me account (including your email address and your meter data). Your meter data can and will be viewed by the entity that generates the energy bill. In any case, the total energy consumption is recorded by the entity that generates the energy bill at the end of the billing period. This is done in accordance with our instructions and in compliance with our privacy policy and other appropriate confidentiality and security measures.

Your utility or energy service provider may offer the following option:

  • View statistics related to your account
  • block or terminate access to your account
  • access or store data stored as part of your account
  • To receive information from your account in order to comply with applicable laws, regulations, or procedural law, or to comply with an enforceable official order
  • Limit your ability to delete or edit data or privacy settings

For more information, please refer to the privacy policy of your utility or energy service provider.

If you would like to prevent your energy billing center from viewing your energy data in detail, please contact smart-me and your billing center. Under certain circumstances (e.g., due to contractual obligations within a self-consumption community), a suitable alternative solution for billing your energy data must be found.

General business software

We process the data you provide solely to fulfill and process your order, as well as for the purpose of using the smart-me cloud, for advisory services, for advertising and market research for our own purposes, and to tailor our services to your needs. Your personal data will only be collected for specified, clear, and legitimate purposes and will not be stored longer than necessary.

Emails

In every email from us, you have the option to unsubscribe from further product information or emails. Exceptions include emails that are necessary for the customer relationship or its termination, such as updates to our terms and conditions. We use systems from Mailchimp Inc., Atlanta, Georgia, United States, to send emails. Your first name, last name, country, language, company, and, if necessary, information about your customer segment are transmitted to Mailchimp for processing. You can find more information about Mailchimp’s privacy policy here.

Transactional emails (such as order confirmations) are sent via the U.S. service provider SendGrid. Using a specialized service provider is necessary to ensure the delivery of these emails and, if possible, to reduce the likelihood that they will be classified as “spam.” An adequate level of data protection is guaranteed at all times. SendGrid does not store any message content—only data necessary for sending emails—and the storage period is limited. You can learn more about SendGrid’s data protection guidelines here.

Enterprise Resource Systems

In order to use third-party technical or organizational services that we need for our business operations, personal data may be stored in third-party systems. For example, last name, first name, company, language, address, information on the customer segment, and bank details may be stored in our business software provided by bexio AG, Rapperswil, Switzerland. You can find more information about bexio AG’s privacy policy here.

Customer Support

smart-me uses systems provided by Freshworks Inc., San Mateo, California, United States, to provide customer support. To ensure that smart-me can assist you as effectively as possible, the following information is stored exclusively for the purpose of providing support services: last name, first name, company, shipping address, email address, serial number, product type, language, and phone number. smart-me stores the correspondence between you and our customer support team, regardless of how we communicate with you (phone, email, etc.). This is done so that we can better assist you with future inquiries. Questions submitted via the Apple App Store, the Google App Store, or social media (such as LinkedIn or similar platforms) also generate a Freshworks ticket and are saved. The data collected in this manner is stored in accordance with applicable data protection regulations. You can find more information here.

Payments

We process payments through Stripe and PayPal, among others. In this regard, your data will be shared with them. As part of the payment process through PayPal, you will be redirected to the PayPal website. You will only enter your sensitive information on the payment provider’s website, where a secure connection is established. You can learn more about the security of payment transactions from PayPal or Stripe.

Google Workspace

We use business tools from Google Workspace (Google, Mountain View, California, United States). We also store personal data in it, such as email addresses. You can find out more about Google Workspace's privacy policy here.

Access and update your personal information

Whenever you use our services, we aim to provide you with access to your personal data. If this data is incorrect, we will make every effort to give you the opportunity to quickly update or delete it—unless we need to retain this data for legitimate business or legal purposes.

We strive to provide our services in a way that protects data from accidental or intentional destruction. For this reason, we may not immediately delete remaining copies of data that you have deleted from our services from our active servers, and we do not remove this data from our backup systems. Please contact us by mail or email if you would like to request information about, correction of, blocking of, or deletion of your stored data free of charge.

Safeguarding the public interest

We will disclose personal data to companies, organizations, or individuals outside of smart-me if we can reasonably believe that access to this data, or its use, storage, or disclosure, is reasonably necessary in order to

  • Comply with any applicable law, regulation, or legal process, or comply with an enforceable government order
  • Enforce applicable Terms of Use, including investigating possible violations involving fraud, security flaws, or technical issues, and detecting, preventing, or otherwise combating
  • To protect the rights, property, or safety of smart-me, our users, or the public from harm, to the extent permitted or required by law

In the event of a corporate restructuring

If smart-me is involved in a business combination, a company acquisition, or a sale of assets, we will continue to ensure the confidentiality of all personal data and will notify the affected users before any personal data is transferred or becomes subject to a different privacy policy.

Scope of the Privacy Policy

Our privacy policy applies to all services offered by smart-me and its affiliated companies, including eCarUp. This date

This privacy policy does not apply to services for which separate privacy policies apply and which do not include this privacy policy.

Our privacy policy does not apply to services offered by other companies or individuals that may include smart-me services or other websites linked to our services. Our privacy policy does not cover the handling of information by other companies or organizations that advertise our services.

Working with Regulators

We regularly verify compliance with our privacy policy. Your customer data will be stored, processed, and disclosed in accordance with the relevant provisions of Swiss law (Federal Data Protection Act), the Federal Data Protection Act (BDG), and the EU General Data Protection Regulation (GDPR). The responsible supervisory authority is the Federal Data Protection and Information Commissioner.

Changes

Our privacy policy may change from time to time. We will not restrict your rights under this privacy policy without your express consent. We will publish all changes to the privacy policy on this page. If the changes are material, we will provide an even clearer notification (including, for certain services, an email notification of the changes to the privacy policy). We will also keep older versions of this privacy policy in an archive for your reference.

 

Data Protection Officer

smart-me AG

9 Lettenstrasse

CH-6343 Rotkreuz

Switzerland

Legally represented by Management: David Eberli

Phone: +41 41 511 09 99, email: [email protected]

Archives

July 11, 2021

Data Protection Statement

smart-me AG (hereinafter “smart-me”) respects the privacy of every person who uses the smart-me device, visits the smart-me website, or uses smart-me cloud functions. When you use smart-me services, you entrust us with your data. You can use your data in a number of different ways—to monitor, visualize, control, and bill for energy supply. By consenting to this Data Protection Declaration, you agree to your meter data being stored and processed in the smart-me cloud. This Data Protection Declaration outlines the data we collect, the purposes for which we collect it, and how we use the collected data. The security of your data is our highest priority. Our Data Protection Declaration explains:

  • How We Protect Your Data
  • What information we collect and why
  • How We Use This Information
  • The options we offer, including ways to access information and how it can be updated.

smart-me We care about protecting your data, so whether you are a new or long-time customer, we ask that you take the time to familiarize yourself with our practices—and if you still have questions, please contact us.

1 How We Protect Your Data

1.1 Encryption

All access to your data in the smart-me cloud is SSL (TLS) encrypted. All access attempts are logged and analyzed. Passwords and other sensitive data are stored only in encrypted form. All connections between devices (meters, modules, and gateways) and the smart-me cloud are encrypted. Each device has its own unique key (128-bit). AES is used as the encryption algorithm. Help make your data even more secure by encrypting your Wi-Fi network with a strong password.

1.2 Access Protection

The measurement data from the user’s various devices (e.g., electricity meter) is collected in the smart-me Cloud and processed in anonymized form. Users also have the option of making measurement data visible to all users. The smart-me servers are located in secure data centers in Switzerland and are accessible only to authorized personnel.

2 Information We Collect

We collect information to provide better services to all our users—from basic information, such as the language you speak, to more complex areas, such as energy consumption (electricity, water, gas, heat). We collect information in the following ways:

2.1 Visiting the smart-me website

You can visit our website without having to provide any personal information. The access data we store does not contain any references to individual users.

2.2 Log Data

When you retrieve content provided by smart-me, we capture and store certain data in server logs. These logs contain information such as:

  • Details about how you use our services, such as the pages you visit on smart-me.com
  • IP address
  • Data on device events such as crashes, system activity, hardware settings, browser type, browser language, the time and date of your query, and the referral URL

2.3 Location-specific information

Local storage: We may collect information (including personal data) locally on your device using mechanisms such as your browser’s web storage (including HTML5) and application data caches. Cookies and similar technologies: We and our partners use various technologies to collect and store data when you use a smart-me service. These may include cookies or similar technologies that can be used to identify your browser or device. You can configure your browser to block all cookies, including those associated with our services, or you can choose to receive an alert whenever we set a cookie. However, please note that many of our services may not function properly if you have disabled cookies. For example, we will be unable to save your preferred language settings.

2.4 Google Analytics

We also use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies,” which are text files stored on your computer that enable analysis of your use of the website. The information generated by the cookie regarding your use of our website (including your IP address) is transmitted to a Google server in the United States and stored there. Google uses this information to evaluate your use of the website, to compile reports on website activity for the website operator, and to provide other services related to website and internet usage. Google may also transfer this information to third parties if required by law or if such third parties process this data on Google’s behalf. Google will never associate your IP address with other Google data. You can prevent the installation of cookies by changing your browser settings; however, please be aware that in this case, you may not be able to fully use all the features of this website.

2.5 Cloudflare

To safeguard the smart-me server and optimize loading time, Cloudflare is used as a CDN (“content delivery network”). This means that all requests to the server are automatically routed through the Cloudflare server and aggregated into statistics; this feature cannot be disabled. The collected raw data is generally deleted within 4 hours, and no later than 3 days. Here you can find information about the data collected and Cloudflare’s security and privacy policies. Cloudflare also operates within the framework of the Privacy Shield Agreement between the EU and the U.S.

3 Using the " smart-me " energy management system

3.1 Data You Share With Us

To use smart-me cloud services, you must first set up a smart-me account. To do this, we ask you to provide some personal information. At a minimum, this will include your email address, which is stored.

3.2 Data we receive based on your use of our services

Device-related information: The meter data (electricity, water, gas, heat, etc.) recorded in your smart-me account is stored in association with the email address you provide. By using smart-me cloud services that require your consent to this Data Protection Declaration, you further consent to smart-me informing you of any new features, changes, restrictions, or enhancements necessary for the proper operation and effective use of the portal. You may revoke your consent at any time.

4 How We Use the Information We Collect

We process the data you share solely to fulfill and process your order, as well as for purposes related to the use of the smart-me cloud, to provide advice, for our own advertising and market research purposes, and to tailor our services to customer needs. Once your contract has been fulfilled and paid in full, your data is blocked from any further use and deleted upon the expiration of any time limits related to our fiscal and commercial law obligations, unless you have given your express consent for the further use of your data. Your personal data is collected only for defined, clear, and lawful purposes and is not retained in a personalized form for longer than necessary. If you have an smart-me account, we share your account name and your meter data with your billing service provider as long as there is a valid agreement between you and your billing service provider regarding the billing of energy consumption. If you contact smart-me, we will record your communication in order to assist you in resolving any issues you may have. Information regarding your use of our services, including details about upcoming changes and improvements, will be sent to your email address. Before using your information for any purpose other than those defined in this Privacy Policy, we will request your consent.

4.1 Accessing and Updating Your Personal Data

Whenever you use our services, we always strive to provide you with access to your personal data. If this data is incorrect, we strive to give you the opportunity to update it promptly or to have it removed, unless we are required to retain this data for legitimate business or legal purposes. We strive to make our services available in a way that protects data from accidental or intentional destruction. For this reason, we may not immediately delete any remaining copies of data on our services that you have deleted from our servers, nor will we remove this data from our backup systems.

4.2 Information You Share with Others

Our service allows you to share information with others, particularly for the purpose of billing your energy consumption. We do not share personal data with companies, organizations, or individuals outside of smart-me, except in the following circumstances: your personal data will be transferred to third parties or otherwise disclosed if this is necessary for the purposes of contract fulfillment—in particular, the transmission of meter data to service providers—or if you have provided your prior, express consent. However, in these cases, the scope of the data transferred is limited to the minimum necessary.

4.3 Payments

We process payments through Stripe and PayPal. Your data is transferred to these service providers for payment purposes. When you pay with PayPal, you will be redirected to the PayPal website during the transaction. You enter your confidential data only on the payment service provider’s page, which uses a secure connection. For more information about the security of payment transactions through these services, please contact PayPal or Stripe.

4.4 Customers of energy cost billing services (who use smart-me)

If your smart-me account is managed on your behalf by an energy billing service provider, the service provider and the operational partner responsible for customer service within your organization will have access to the information in your smart-me account (including your email address and meter data). Your meter data can be and will be viewed by the person who generates the energy bill. In each case, the energy bill will be generated based on your total energy usage. This is carried out in accordance with our instructions and in compliance with our Privacy Policy as well as other relevant confidentiality and security measures. Your energy cost billing service provider also has the option to:

  • View statistics related to your account
  • Block or terminate access to your account
  • Access or store data saved as part of your account
  • Receive data from your account in order to comply with applicable laws, regulations, and procedural law, or to comply with an enforceable official order
  • Restrict your ability to delete or process data or data protection settings
  • Please refer to the privacy policy of your energy cost service provider for more information.

If you wish to prevent your detailed energy data from being viewed by your energy billing center, please visit smart-me and contact your billing center. In some cases (for example, due to a contractual relationship with a private consumption community), we will need to find an alternative solution for billing your energy data.

4.5 Safeguarding the Public Interest

We will transfer personal data to companies, organizations, or individuals outside of smart-me if we can reasonably believe that access to this data, or the use, storage, or transfer of this data, is reasonably necessary to

  • To comply with applicable laws, regulations, or procedural law, or to comply with an enforceable official order
  • Enforce relevant terms of use, including investigating possible fraud or security vulnerabilities, or to disclose, prevent, or otherwise address technical issues
  • Protect the rights, property, or security of smart-me, our users, or the public from harm to the extent permitted or required by law

4.6 Market Research

We may also share non-personal data with the public or our partners, such as publishers, advertisers, or affiliated websites. For example, we may publish information to illustrate trends in overall usage.

4.7 In the event of corporate restructuring

If smart-me becomes subject to a corporate merger, acquisition, or disposal of assets, we will continue to ensure the confidentiality of any personal data and will notify affected users before personal data is transferred or becomes subject to a different privacy policy.

5 Scope of the Privacy Policy

Our Privacy Policy applies to all services offered by smart-me and its affiliated companies, including eCarUp. This Privacy Policy does not apply to services governed by separate privacy policies that do not incorporate this Privacy Policy. Our Privacy Policy does not apply to services offered by other companies or individuals that may include smart-me services, or other websites linked to our services. Our Privacy Policy does not extend to the handling of information by other companies or organizations that acquire our services.

6 Compliance with Regulations and Cooperation with Regulatory Authorities

We regularly monitor compliance with our Data Protection Statement. Your customer data will be stored, processed, and transferred in accordance with the relevant provisions of Swiss law (Federal Data Protection Act) and the EU’s General Data Protection Regulation (GDPR). The relevant supervisory authority is the Federal Data Protection and Information Commissioner. You have the right to request, free of charge, access to, correction of, restriction of processing, and, if necessary, deletion of your stored data at any time. Please contact us or send us your concerns by mail or email. Your stored personal data will be deleted if you revoke your consent to its storage, if your information is no longer necessary to fulfill the purpose for which it was stored, or if its storage is unlawful for other legal reasons.

7 Changes

Our Privacy Policy may change from time to time. We will not restrict your rights under this Privacy Policy without your express consent. We will publish any changes to the Data Protection Declaration on this site. If the changes are significant, we will provide an even clearer notification (including an email notification of changes to the Data Protection Declaration for certain services). In addition, we will keep older versions of this privacy policy in an archive where you can access them. Responsibility for data protection lies with smart-me AG, Lettenstrasse 9, 6343 Rotkreuz, Switzerland,

represented by management:

David Eberli, tel: +41 41 511 09 99, email: info(at)smart-me.com