SmartThings Privacy Notice

Effective Date: May 4, 2021

At Samsung Electronics Co., Ltd. (“Samsung”), we know how important privacy is to our customers. Samsung is the data controller for SmartThings. The Data Controller Representative of Samsung in Turkey is “Samsung Electronics Istanbul Pazarlama ve Ticaret Ltd. Şti.”. We created this Privacy Notice (“KVKK Notification Text”) to make sure you understand how we collect and use your personal information.

• within the framework of the purpose for which they are required to be processed and as relevant, limited, and proportionate to such purpose,
• by preserving the accuracy and the most up-to-date state of such personal data as they have been provided to Samsung by you or otherwise,
• and by complying with the conditions stipulated in the KVKK.

With this KVKK Notification Text (Obligation to Inform Text), it has been aimed to continue and develop the activities carried out by Samsung in accordance with the principles contained in the KVKK.

Our Samsung Privacy Policy at https://account.samsung.com/membership/terms/privacypolicy also applies to your use of SmartThings. Our Privacy Policy contains more information about how we use your data. It also includes information about your rights and how to contact us. Please read our Privacy Policy in addition to this KVKK Notification Text. However, this KVKK Notification Text shall always prevail over the Privacy Policy in relation to how we use your information for SmartThings.

WHAT INFORMATION DO WE COLLECT?

Samsung shall process your personal data for the purposes and legal grounds specified in this KVKK Notification Text. If there is any change in the purpose for which your personal data are processed or in the legal grounds thereof, this KVKK Notification Text shall be updated and re-published by Samsung.

Through SmartThings, Samsung obtains and maintains information about you in various ways. Your personal data are collected through electronic media, via all kinds of information, documents and certificates you have submitted to Samsung and collected through the application, both before and after the establishment of the contractual relationship and during such contractual relationship.

Information You Provide Directly

• Your Account Information: SmartThings will collect your account information, which is necessary to initiate and provide the SmartThings service to you. This will include information such as your name, Samsung account ID, email address, mailing address and phone number, username and password. Your account information will not only include the information that you enter in the SmartThings app to create a Samsung account, but also the account information in apps from third-party service partners which you allow to access SmartThings.

Information About Your Use of SmartThings

In addition to the information you provide, we will collect information about your use of our SmartThings through software on your devices and by other means. We will collect:

• App Usage Information: we will collect your usage information created during your use of the SmartThings app, such as app logs, groups, rules and location names, and other configuration information.

• Home IoT Device Information: As SmartThings may consist of several sets of home appliances, sensors, SmartThings hubs, smart bulbs, products, home monitoring cameras and other devices connected to SmartThings (“Home IoT Devices”), SmartThings will also collect usage information related to your Home IoT Devices, such as Home IoT Device model, name, group name or nickname, location name and other settings assigned to the device, event and event settings (for example, if you set up a schedule reminder to display on your Home IoT Device), the network connection information and the surrounding network environment information, device country code, device network operator, OS version, IP address and IMEI, sensor and configuration data, error and malfunction logs, device identifier (e.g. ICCID) and the device and automation name. The main purpose for processing such information is to provide the service you have requested (though it may also be used for data analysis and to enable us to provide customised marketing communications, where you have given us your separate consent). Examples relating to the use of your information to provide you with the service are set out below. For example, when you use a motion sensor, SmartThings will collect the information detected by the sensor such as logs which indicate movement in your home, that the lights have been automatically turned on or off, or if there is unexpected movement in your home to enable an alert to be sent. SmartThings will also collect the usage/settings information of home appliances connected to SmartThings, if you turn on these features. For example, the temperature information inside your refrigerator, the time information which shows how long you have used the air conditioner, and other information about the functions you have selected will be collected not only to display the device/appliance status through your app, but also to understand your use of Home IoT Devices and so that we can continue to improve the our services. In addition to the previous personal data, we will collect your dump logs, which are files in which the technical errors of your devices are listed. These dump logs will only be used to provide you with the technical assistance you need and to improve the SmartThings app and Home IoT Devices.

• Video and Audio Clips Recorded by the Home Monitoring Camera: If you connect video or audio recording devices to SmartThings, SmartThings will collect the video or audio clips recorded by such device, based on your choices, to provide the service you request in the SmartThings app.

• Images, video clips: If you choose to share your images or video clips (not recorded by the Home Monitoring Camera) stored on your device with other SmartThings users or devices, SmartThings will collect the images and video clips.

• Voice Information: If you use voice commands to control SmartThings, information about your conversations, including voice commands, will relayed through SmartThings servers to process your command.

• Location Information: If you consent to the collection and use of location data, your geolocation data is collected to provide the service or feature that requires location information. If you wish to stop processing your location information, you can turn it off in the SmartThings settings.

• Smart TV Information: If you connect a Samsung Smart TV to SmartThings, information about the Smart TV content you purchase, including voucher or gift card numbers and information that lets you set reminders and calendar notifications on your Smart TV will be collected.

• SmartThings Cooking Information: If you use SmartThings Cooking, we will collect information about your use of SmartThings Cooking, including your favorite ingredients and cuisines, dietary preferences, and cooking experience, and information you receive from Family Hub such as responses, answers and content. Any information you enter into SmartThings Cooking will override the existing information in your Family Hub. For example, if you input your dietary preferences through SmartThings Cooking, your Family Hub will be updated to include those dietary preferences. You can add, remove, or change your dietary preferences using either SmartThings Cooking or Family Hub.

We will also collect information about your Smart TV and other devices which you add to and connect with the SmartThings app and the SmartThings Hub, and your use of these devices in ways that we will describe to you at the time of collection or otherwise with your separate consent.

We also may collect other information about you, your devices and apps, and your use of SmartThings in ways that we describe to you at the time of collection or otherwise with your consent.

HOW DO WE USE YOUR INFORMATION?

We use the information collected for the following purposes:

• to identify and authenticate you;
• to enable you to control your Home IoT Devices in the SmartThings app;
• to provide services or features you request in the SmartThings app;
• to respond to your requests and questions, and to communicate with you about SmartThings;
• to provide assistance when you request technical support for the SmartThings app or Home IoT Devices and other maintenance services;
• to provide you with remote maintenance service for errors related to Home IoT Devices connected to SmartThings if you contact a customer service center;
• to link your account information or otherwise interact with selected apps, devices, features and services of third-party service partners;
• to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products, services and SmartThings; analyzing our products and services, aggregating and anonymizing data and performing data analytics and performing accounting, auditing and other internal functions);
• to provide customized recommendations related to Home IoT Devices and other useful services or features;
• if you turn on Customization Service in your Samsung account, to use data collected through the SmartThings app for the purposes herein. You can learn more about our Customization Service by going here;
• if you have a Samsung Smart TV, to (i) enable you to purchase Smart TV digital content, (ii) provide a history of purchased Smart TV digital content, (iii) let you set reminders for Smart TV digital content, and (iv) enable you to receive calendar notifications on your Samsung Smart TV;
• where you have separately consented to receive marketing communications from us when you create your Samsung Account, we may combine information about your device and the Home IOT Devices which you connect to SmartThings, with data which we have collected about you from other sources, in particular your Samsung Account, to provide you with more relevant marketing;
• to comply with laws, regulatory obligations, and legal processes; and
• to protect the rights, property and/or security of Samsung Electronics, or any of our affiliates, business partners and/or customers.

Samsung processes personal information for the purposes described above. Samsung’s legal basis to process personal information is outlined below:

Your personal data are processed being limited to the use of the related service/platform; in compliance with the legislation in force and the Law on Protection of Personal Data; by automated or non-automated methods;

• based on your explicit consent given in sign-up stage for Samsung Account, for the purposes of sending commercial electronic messages to you, customizing and offering our products and services according to your satisfaction, usage habits and needs, and carrying out other sales and marketing activities;
• based on Article 5, paragraph 2 of the KVKK, sub-paragraph c), which stipulates ‘if it is necessary to process personal data of contractual parties, provided that such processing is directly related to the establishment or performance of the contract’, and sub-paragraph f) thereof, which stipulates ‘if it is mandatory to process personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not violated’:
  • for all collection purposes stated above other than sending commercial electronic messages to you, customizing and offering our products and services according to your satisfaction, usage habits and needs, and carrying out other sales and marketing activities;

and may be updated in line with our obligations arising from the legislation and the company policies.

Your personal data shall be kept for a reasonable period of time until the purpose for which they are processed ceases to exist or until the end of the legal time period specified in the relevant legislation, and in any case until the expiry of the statute of limitations.

WHO DO WE SHARE YOUR INFORMATION WITH?

The procedures and principles to be applicable to personal data transfers are set forth in Articles 8 and 9 of the KVKK, and the personal data of the data subject may be transferred to third parties in Turkey and/or abroad.

We will disclose your information internally within our business and to the following entities, but only for the purposes described above.

• Affiliates: other Samsung Electronics Group companies which we control or own, such as affiliates who help us improve SmartThings by analyzing and evaluating your data;
• Business partners: partners who we work together with to provide you with SmartThings, such as third-party products or services that you can connect to SmartThings so you can control those products or services. These business partners control and manage your personal information;
• Service providers: carefully selected companies that provide services for or on behalf of us, such as cloud platform providers who maintain data on our behalf. These providers are also committed to protecting your information;
• Other parties when required by law or as necessary to protect SmartThings: for example, it may be necessary by law, legal process, or court order from governmental authorities to disclose your information. They may also seek your information from us for the purposes of law enforcement, national security, anti-terrorism, or other issues that are related to public security;
• Other parties in connection with corporate transactions: We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of bankruptcy; and
• Other parties with your consent or at your direction: in addition to the disclosures described in this KVKK Notification Text, we may share information about you with third parties when you separately consent to or request such sharing.

HOW LONG DO WE RETAIN YOUR INFORMATION AND WHERE DOES IT GO?

How long your data will be retained depends on the legal basis relied upon to process your data. For example, data we process to perform our contract with you requires us to keep the data throughout the time you use SmartThings. As long as you are an active user of SmartThings, we will retain and process this data. Data such as your account information and device information and identifiers fall into this category.

Data we process to promote our business interests, such as your usage of SmartThings, is only kept for as long as needed for the purposes for which it was collected. For example, this data may be collected to perform analytics so we can develop improvements to SmartThings, or we may process data to keep a record of inquiries you made through or about SmartThings to improve your customer service experience.

In addition, we may also process your data based on your consent. If you withdraw your consent, we will continue to process data collected prior to your withdrawal until the purposes for which such data was collected have been achieved.

Please note, although we aim to retain your data for the time period described above, your data may be processed longer pursuant to applicable law. For example, if a specific statute mandates we require a certain piece of data, we comply and retain that data until the required retention period expires.

As long as your data is retained by us your data will always be subject to appropriate safeguards.

Your use of SmartThings will involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, countries in the European Economic Area, the Republic of Korea, United States, Canada, India, and the Philippines. All international data transfers are subject to legal requirements to ensure that your personal information is processed safely and as you would expect.

YOUR RIGHTS UNDER KVKK

Data Subject’s Rights under KVKK

In accordance with Article 11 of the KVKK, you may apply to Samsung and make requests on the following issues about your personal data:

1. Learning whether or not your personal data have been processed,
2. Obtaining information on the procedure, if your personal data have been processed,
3. Learning the purpose for which your personal data have been processed and whether or not they are used in line with such purpose,
4. Obtaining information about third parties to whom your personal data are transferred within Turkey or abroad,
5. Requesting correction of your personal data if they have been processed incompletely or inaccurately and requesting the notification of third parties to whom your personal data are transferred of the correction made in this respect,
6. Requesting deletion, destruction, or anonymization of your personal data if the reasons for which they are processed no longer exist and requesting the notification of third parties to whom your personal data are transferred of such deletion, destruction, or anonymization procedure,
7. Objecting to the occurrence of a result which is detrimental to you as a result of analyzing of your processed personal data exclusively through automatic systems,
8. Requesting indemnification for your damages which are caused by unlawful processing of your personal data.

Samsung or our Data Controller Representative shall receive and evaluate the data subject requests through the “Samsung Electronics Co., Ltd. Data Subject Application Form” available on https://www.samsung.com/tr/info/kvkk/. Samsung or our Data Controller Representative shall conclude your application free of charge in accordance with Article 13 of the KVKK according to the nature of the request, and within 30 (thirty) days at the latest. If the request is rejected, the reason(s) for rejection shall be notified to you in writing or electronically together with the relevant grounds.

Your Other Rights

In addition to the Related Person Rights requests that are specified in 5.1 and which you can submit to Samsung or Data Controller Representative, rights below also have been offered and automated by Samsung for your use.

• Examining your data that we collect (specific to the relevant application)
• Deleting your data on Samsung apps and services (specific to the relevant application)

You can access the relevant rights on https://privacy.samsung.com/#/. Samsung reserves the right to change the scope of these rights.

UPDATES TO THIS KVKK Notification Text

This KVKK Notification Text may be updated to let you know about changes in how we collect and process your information in SmartThings or changes in related laws. The date when the document was last updated is shown at the top of this KVKK Notification Text. You may access the most up-to-date version of this KVKK Notification Text by going in the SmartThings settings > About SmartThings > Privacy Notice