Privacy Policy

1. General Provisions

1.1. This Privacy Policy (hereinafter referred to as the Policy) defines the principles for working with information of users of the CONNECT service (hereinafter referred to as the Service, CONNECT) and has been developed taking into account the provisions of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” and the current legislation of the Russian Federation.

1.2. This document establishes the relationship between the Service and individuals (hereinafter referred to as the User) interacting with the functionality through the official website connect.smartliving.ru.

1.3. Before using the Service, the User undertakes to thoroughly study the contents of this Policy and the terms of processing technical information.

1.4. The commencement of use of the Service confirms the User's full and unconditional acceptance of all terms of this Policy.

1.5. If the User has any objections to any provisions of this Policy, he/she must immediately cease interaction with the Service.

2. Definitions

2.1. Personal data – information directly or indirectly related to an identified or identifiable individual.

2.2. Processing of personal data is a set of operations with personal data carried out with or without the use of automated means, including accumulation, systematization, storage, modification, use, distribution, depersonalization, blocking and liquidation.

2.3. Automated processing – performing operations with data through the use of computing equipment and software.

2.4. User – a legally competent individual who uses the Service to store, process, and synchronize data from Smart Home devices and platforms.

2.5. Technical Device Identifier—a set of technical characteristics of the User's device, automatically transmitted upon connection to the Service: device name, operating system type, and operating system version. Used in conjunction with account credentials to link devices to a subscription.

3. Principles of personal data processing

3.1. The Service processes a limited amount of data necessary to provide services and operate the User's account.

3.2. The technical parameters to which the Service has access are:

The numeric Telegram ID (when using a Telegram bot), automatically provided by the relevant platform when the User interacts with the Service; technical identifiers of the User's devices: device name, operating system type, operating system version — automatically transmitted upon connection to the server; date and time of connection — for the purpose of technical monitoring of subscription activity.

3.3. The Service does not request, collect, or store the following categories of information: last name, first name, patronymic, contact information, residential or registration addresses, passport information, income information, or other personal information of Users.

3.4. The Service does not receive Users' payment information or bank card details. Financial transactions are processed through certified payment systems that comply with PCI DSS security standards.

4. Purposes of data processing

4.1. Technical identifiers are used by the Service exclusively for the following purposes:

Automatic authorization of the User in the system;

provision of access to cloud synchronization functionality; sending system notifications about the status of the active subscription and service expiration dates; technical identification of the User upon activation of paid tariff plans; functioning of the referral program and accrual of bonus funds; ensuring the operation of the technical support service; linking devices to a subscription: identification and accounting of devices connected within the framework of a single subscription, including control over the number of simultaneously used devices and management of additional device slots purchased by the User; collection of anonymized statistics on the use of the Service to improve the quality of the services provided.

4.2. Processing of user data

The Service stores and synchronizes data transmitted by the User's Smart Home platform.

Such data is processed solely for the purpose of providing the Service's functionality and is not used for marketing purposes.

5. Processing and storage conditions

5.1. Technical identifiers are stored in the Service's technical database solely to ensure the functioning of the authorization system, the operation of the User's account, and access to data synchronization services. Technical identifiers of devices are stored for the duration of the subscription and are subject to deletion no later than 30 (thirty) calendar days from the termination of the contractual relationship or at the User's request.

5.2. CONNECT guarantees that technical identifiers are not subject to transfer, sale, or provision to third parties, except in situations expressly provided for by the current legislation of the Russian Federation.

5.3. Upon termination of use of the Service, the User has the right to submit a request to delete their data from the technical database.

5.4. The Service uses a set of organizational and technical measures to protect stored information from unauthorized access, modification, or destruction.

6. Ensuring security

6.1. CONNECT implements a set of legal, organizational, and technical measures aimed at ensuring the protection of technical information from illegal or unintentional access, modification, blocking, copying, destruction, or distribution.

6.2. The security measures applied include, but are not limited to: database encryption, a system for restricting access to server equipment, periodic security checks of information systems, and the creation of backup copies of data.

6.3. Access to the technical databases of the Service is provided exclusively to authorized employees to the extent necessary to perform their official duties.

7. Rights of the data subject

7.1. The User has the right to receive comprehensive information regarding the processing of their technical data, except in cases established by federal law. The Service ensures that the requested information is provided in an accessible and understandable form.

7.2. The User has the right to request the Service to clarify, block, or delete technical information if it is determined to be out of date, incomplete, unreliable, illegally obtained, or there is no need to process it for the stated purposes.

7.3. If violations of the law are detected, the User has the right to contact the Service with a request to stop processing technical information.

7.4. The User may at any time request the cessation of processing, blocking, and deletion of technical information related to him, except in cases where further storage is required by the legislation of the Russian Federation.

7.5. To exercise these rights, the User shall submit a corresponding request via the feedback form on the official Website of the Service.

8. Transfer of data to third parties

8.1. The Service shall transfer technical information to third parties only in the following cases:

the presence of the User's written consent to carry out such actions;

the need to transfer the requested services to the User or to fulfill the concluded agreement; the presence of a legal requirement from authorized government agencies, presented in accordance with the procedure established by Russian legislation.

8.2. CONNECT does not transfer, sell or provide technical information for commercial purposes without the consent of the User.

9. Data storage

9.1. The technical information of Users shall be processed and stored for the period necessary to achieve the processing purposes established by this Policy, or for the period specified by applicable law, or for the duration of the contractual relationship between the Service and the User.

9.2. Upon expiration of the specified periods or upon the User’s corresponding request, technical information is subject to deletion or anonymization.

9.3. The Service reserves the right to continue storing anonymized statistical information for the purposes of analysis and improvement of the quality of services provided.

10. Policy Changes

10.1. CONNECT reserves the right to unilaterally amend and supplement this Policy, including, but not limited to, changes in applicable legislation, as well as modifications to the functionality or technology of the Service.

10.2. When making changes to this document, the date of its update is indicated. The updated version of the Policy becomes legally binding upon its publication on the Service's official website, unless a different procedure for entry into force is expressly specified in the new version.

10.3. The User is responsible for independently monitoring the current version of this Policy by periodically reviewing its contents.

10.4. Continued use of the Service after the publication of an updated version of the Policy constitutes the User's full and unconditional consent to the changes made.