Last Updated: Jan 2020

This Privacy Policy explains how we collect, use, process, and share
your information, including personal information, in conjunction with
your access to and use of the Olisto Platform.

When this policy mentions “Olisto,” “we,” “us,” or “our,” the Olisto
B.V. company, registered in Amsterdam-Duivendrecht, The Netherlands and
providing services under the Olisto brand, which is responsible for your
information under this Privacy Policy (the “Data Controller”).

This Privacy Policy may be changed over time. The users of the Olisto App (“Data subjects“)
are advised to regularly review the Privacy Policy and Terms for
possible changes. If we make changes we will provide additional notice,
such as via email or through the Services.

1. What information we collect from you

We must collect certain personal information about you to be able to
provide you with our services. Without it some or more of the Olisto
services will not be available to you. You provide us with some types of
information, and we also collect information about you automatically.

1.1 Information you provide us

We collect your email address when you create an account with us. We
use your email in order to verify that the Account belongs to you, after
you create an account with us, or whenever we need to do so afterward,
for example when you’ve lost access to your account. You can also
provide us with your location information (city), in order to be able to
use more personalized Trigg conditions in certain Triggs.

When you use our services, namely: when you connect channels to your
account and start creating/saving Triggs, we collect information on what
these channels and Triggs are. When you connect one or more of the
external channels to your account, we collect that information in order
for you to be able to create or/and save Triggs and Trigg bundles (more
information about collecting information from external channels in
1.3.2).

When you decide to use the Olisto forum, we collect some personal
information from you. Namely, your email address, your username, and you
may or may not provide us with your name and/or full name.

1.2 Information we automatically collect from your use of the Olisto App and Website

When you use Olisto’s Services, we automatically collect certain
information, including personal information, about services you link
your Olisto Account to and how you use them. This information is
necessary for the execution of the Triggs, and as a result to enable us to
provide and improve Olisto’s Services and functionalities.

1.2.1 Olisto’s App Device information:

  • Device attributes: information such as operating system and hardware version, browser information
  • Identifier: unique identifiers (only unique for our iOS app)
  • Device signals (the names of Wi-Fi access points used in Triggs, currently connected Wi-Fi networks)
  • Data from device settings – information you allow
    us to see via device settings you turn on (geofence location, camera,
    push notifications, app foreground and background tracking)
  • Network and connections (location history for users with Android device)

1.2.2 Usage information:

We gather information on how you interact with the Website and the
App, such as the pages/screens you view, inspiration Triggs you save and
enable, details of the conditions and actions you set for the Triggs,
and other actions you perform in the Olisto App.

1.2.3 Log Data

We automatically collect log data and device information when you
access and use the Olisto App. That information, among others, may
include the Internet Protocol (IP) address, access dates and times,
crash data, cookie data.

1.2.4 Cookies and similar technologies

We use cookies. A cookie is a small data file that is transferred to
your computer or mobile device. We use both session-based and persistent
cookies on the Olisto Website, as well as third-party cookies like
Google Analytics. The main purpose of using cookies is to provide a
personalized experience. We do ask for your consent for allowing usage of
the cookies on the Website. For more information on our use of these
technologies, see our Cookie Policy.

1.3 Information we collect from third parties

In order to provide you with extended services of our product, we
collect some information from our third-party partners: such as Facebook
login, our Channel Partners, and support tools.

1.3.1 Information from Facebook login

If you log in or create your Olisto Account with a Facebook login, we
will receive information from Facebook, such as your registration and
your profile information. This information includes your id, your first
name, last name, your email, and is controlled by Facebook as authorized
by you via your privacy settings on Facebook. We store that information
for the personalization of the app and to assist support requests.

1.3.2 Information from external channels and integrations

After you create an Account with Olisto, you may decide to connect
the third-party services represented by the channels in the app (e.g.
Philips Hue, Eneco Toon). The information that we collect
from these partners may include information needed to make the actions
or conditions for the particular service work. We don’t collect
additional personal information about you from these third parties.

Olisto offers its services to be used through the products of some of
its partners (in Integration). If you are using Olisto’s services in
this way, Olisto may receive some of your personal information (device
information, information on created/saved Triggs, connected channels).
Olisto will receive and process any information that is required to make
the Integration work, such as relevant events generated by the
Partners’ products, list of devices or other items used with the
partners’ products, and Triggs used with the partners’ products. Where
possible, the user can pick which pieces of information may or may not
be passed from the partner to Olisto.

2. How we use the information we collect

We use, store, and process information, including personal
information, about you to understand, improve, and develop the Olisto
services, as well as to create and maintain a safe environment for you to
use our services.

Provide, Improve, and Develop the Olisto Platform.

  • Enable you to access and use the Olisto platform (App and Website)
  • Operate, protect, improve, and optimize the Olisto platform and experience, such as performing analytics and conducting research
  • Send you support messages, product updates, marketing offers, newsletters, and alerts

Create and maintain a safe environment

  • Verify the information provided by users such as to verify the account on Olisto with users’ email).
  • Comply with our legal obligations.
  • Resolve any disputes with any of our Members and enforce our agreements with third parties.
  • Enforce our Terms of Service and other policies.
  • Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

3. How we share the information we collect

You provide consent to us to share some of your personal information
when you decide to share Triggs with your friends and family. To provide
some of our Services we also share some information with our partners
and third-party services.

3.1 People you share your Triggs with

You may decide to share some of your Triggs by the use of the
public link. When you share a Trigg, we don’t disclose any additional
personal information apart from the information in the Trigg you include
when you decide to publicly share the Trigg. It is your responsibility
to control the information you share in the Triggs publicly or directly
to other people.

3.2 Measurement and Analytics services

In order for us to understand and have a clear picture of how the
Olisto App and the Website are being used by our users and for marketing
purposes, we make use of several analytics tools. Most of these tools
are third-party services that we do share certain anonymized information
with about how you use the App and the Website. That is, the
screens/webpages you visit, how long you stay there, how many Triggs you
use, etc. We do not share information about your name, email address,
and other individually identifiable information about you.

3.3 Subsidiaries, Employees, and Independent Contractors

We may disclose information about you to our subsidiaries, our
employees, and individuals who are our independent contractors that need
to know the information in order to help us provide our services or to
process the information on our behalf. We require our subsidiaries,
employees, and independent contractors to follow this Privacy Policy for
personal information that we share with them.

3.4 Customer support related services

In order to provide you with timely and extensive customer support,
we make use of the tools like Intercom, Mailchimp, and Zapier with which
we do share information about your location, the channels you connect,
the number of Triggs you use, your email, the chats and conversations
you have with us by means of these tools. We do not share additional
personal information with these tools.

3.5 Aggregated and De-Identified Information

We may share information that has been aggregated or reasonably
anonymized so that the information could not reasonably be used to
identify you. For example, we may publish aggregated statistics about
the use of our services.

4. Age limitations

We don’t intend our services for children below 16 years old. If you
find out that a child under 16 has provided us with personal information
without consent, please contact us.

5. Changes to this Privacy Policy

Olisto may change this Privacy Policy from time to time. Laws,
regulations and industry standards evolve, which may make those changes
necessary, or we may make changes to our business. We will post the
changes to this page and encourage you to review our Privacy Policy to
stay informed. If we make changes we will provide additional notice,
such as via email or through the Services. If you disagree with the
changes to this Privacy Policy, you should deactivate your Services
account.

6. Your rights

You are entitled to any of the rights described in this section and
may request their execution through contacting our Customer support by
sending an email to help@olisto.com.

6.1 Managing Your Information.

You may access and update some of your information through your
Account settings. If you have chosen to connect your Olisto Account to a
third-party application(s), external Olisto channels like Toon,
WoonVeilig, KlikAanKilkUit you can change the status of your connection
by disabling/enabling the channels in your App Profile. You are
responsible for keeping your personal information up-to-date.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete
personal information concerning you (and which you cannot update
yourself within your Olisto Account).

6.3 Data Access and Portability.

You may request copies of your personal information held by us. We
will provide this in a structured and machine-readable format of your
personal data you provided to us.

6.4 Data Retention and Erasure.

We retain your personal information for as long as is necessary for
the performance of the contract between you and us and to comply with
our legal obligations. If you no longer want us to use your information
to provide the Olisto App and services to you, you can delete your
account and all your personal information will be deleted within the
following 30 days. Please note that if you request the erasure of your
personal information:

  • We may retain and use your personal information to the extent
    necessary to comply with our legal obligations. For example, Olisto may
    keep some of your information for tax, legal reporting, and auditing
    obligations.
  • Because we maintain the Olisto Platform to protect from accidental
    or malicious loss and destruction, residual copies of your personal
    information may not be removed from our backup systems for a limited
    period of time.

6.5 Withdrawing Consent and Restriction of Processing.

You may withdraw your consent to the processing of your personal information at any time by sending an email
to Olisto specifying which consent you are withdrawing. Please note
that the withdrawal of your consent does not affect the lawfulness of
any processing activities based on such consent before its withdrawal.

You possess the right to limit the ways in which we use your personal
information, in particular where (1) you contest the accuracy of your
personal information; (2) the processing is unlawful and you oppose the
erasure of your personal information; (3) we no longer need to process
your personal information, but you require the information for legal
claims; or (4) you have objected to the processing (Section 6.6) and
pending the verification of whether the legitimate grounds of Olisto
override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require
Olisto not to process your personal information for certain specific
purposes where such processing is based on legitimate interest. If you
object to such processing Olisto will no longer process your personal
information for these purposes unless we can demonstrate compelling
legitimate grounds for such processing or such processing is required
for the establishment, exercise, or defense of legal claims.

Where your personal information is processed for direct marketing
purposes, you may, at any time ask Olisto to cease processing your data
for these direct marketing purposes by sending an e-mail to help@olisto.com.

7. Security

Your personal data are treated strictly confidential and Olisto has
taken the appropriate technical and organizational security measures
against loss or unlawful processing of this data. For this purpose we
use several security techniques including secure servers and encryption,
as well as physical safeguard of the locations where data are stored.

If you know or have reason to believe that your Olisto Account
credentials have been lost, stolen, misappropriated, or otherwise
compromised or in case of any actual or suspected unauthorized use of
your Olisto Account, please contact us following the instructions in the
Contact Us section below.

8. Contact us

If you have any questions or complaints about Olisto’s Privacy Policy or Olisto’s information handling practices, you may email us or contact us at:

Olisto B.V.

Entrada 100, 1114 AA, Amsterdam-Duivendrecht, the Netherlands

+31202441759