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RMI - Remote Monitoring Interface
PRIVACY POLICY
In compliance with the Personal Information Protection and Electronic Documents Act, SC 2000, c 5 (hereinafter the "PIPEDA"), Mitsubishi Electric Sales Canada Inc., with registered office at 4299 14th Avenue, Markham, Ontario Canada L3R 0J2, (hereinafter the "Company", "us" or " our"), is committed to protecting the privacy of users.
This privacy policy (the "Privacy Policy") is provided by the Company to inform users that we process Personal Information in compliance with PIPEDA within the context of providing the products and services referred to in the website dedicated to the RMI (hereinafter call the "Site") and the RMI App which can be downloaded, free of charge, to a mobile device from the Apple App Store and Google Play (the "App")
This Privacy Policy should be read carefully before browsing the Site and before using the App.
THE SERVICE (RMI SITE/APP)
The main purpose of the Site/App is to allow users, who have registered using the appropriate form, to access and to use the Company's RMI (Remote Monitoring Interface) services. Once registered, users can download the App to their mobile device and use the RMI services, not only through a web browser, but also directly from their device, accessing them with the same credentials used for the page dedicated to their services.
This Privacy Policy describes how the Company collects, uses and shares Personal Information obtained as a result of users registering at and using the Site.
Since the Company reserves the right to add new functionalities to or to remove any functionality from the Site/App and to modify the RMI services and/or products at any time, the Privacy Policy may be updated by the Company at any time and the Company will notify users of any changes made to it.
Since the Site/App can allow access to websites owned and operated by third parties, it should be noted that this Privacy Policy does not apply to such third-party websites and the Company is not responsible for such third parties for the protection of Personal Information.
PERSONAL INFORMATION
Personal Information processed : «personal information»: means any information relating to an identified or identifiable individual («individual»); an identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
Site Registration
To use the RMI services, the user must log in for the first time by using the link in the email sent by the Company following a request by the user to activate the RMI services. Once logged in, the user must enter his/her Personal Information in the registration form and choose a password for subsequent use. The user will also be asked to accept the RMI general terms and conditions of use as well as this Privacy Policy and, in this way, will become a registered user, able to use the RMI services including through the App. Registration can only be done via the Site.
Personal Information processed
The Company may collect the following Personal Information:
• the user's first name and last name,
• the user's domicile or residence address,
• the user's email address,
• details of the RMI services and/or products for which information is requested
• location
Data can be collected by the user voluntarily entering it on the Site/App during registration or, for example, when the user contacts the Company to request information about the RMI services and products. In the event that the user provides Personal Information concerning a third party, he/she must do whatever is necessary such that sending this Personal Information to the Company and the subsequent processing of it, for the purposes specified in this Privacy Policy, take place in compliance with applicable legislation. Therefore, for example, before providing the Company with Personal Information that concerns a third party, the user must inform the third party and must obtain their consent to their Personal Information being processed, if required by the aforementioned legislation.
Navigation data
Navigation data includes all data automatically collected through the Site and covers, for example, the types of actions performed by the user on the Site and how the user is using the Site. In addition, the Company may automatically record the user's IP address (i.e. the unique address that identifies the user's device on the internet), which is automatically recognised by our server. Navigation data is only used to obtain anonymous statistical information on how the Site is used and to monitor its proper functioning. Navigation data is deleted immediately after being processed. This data can also be used to ascertain responsibility in the event of a computer crime against the Site or to protect our rights.
Consumption data
The RMI system allows mobile remote management of the user's air conditioning and heating system.
It monitors the performance of equipment, programs functionalities, consults the performance, verifies system consumption and operating status.
1. The entity responsible for ensuring compliance is Mitsubishi Electric Sales Canada Inc., with registered office at 4299 14th Avenue, Markham, Ontario, Canada L3R 0J2, Attn: Cindy Carter, Privacy Officer, contactable via email at cindy.carter@mesca.ca
2. PURPOSE AND LEGAL BASIS OF PROCESSING
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PURPOSES |
LEGAL BASIS |
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A. The Company processes a user's Personal Information in order to allow the same to register with the Site/App and to use the RMI services/products purchased through the Site and/or the App and in order to respond to or to meet a request made by a user with reference to the RMI services/products including via the App's "help" section. |
The Company processes Personal Information for these purposes in order to execute a contract/service and/or pre-contractual measures adopted following a request from the user. |
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B. The Company processes a user's Personal Information in order to ensure that the Site and the App are up to date and meet the needs of users, to analyse, review and improve the RMI services/products on the Site/App, to provide a user-friendly Site/App browsing experience, to ensure compliance with the Site's/App's terms and conditions of use, the security of the Site/App and its users and to protect the Company's rights and assets. The information used for this purpose will remain strictly anonymous and will not be used to identify any user nor will it be aggregated with a user's Personal Information. |
The Company processes Personal Information for these purposes in order to pursue its legitimate interest in protecting its assets, its business, provided that the interests or the fundamental rights and freedoms of the individual are not overriding, taking into consideration the reasonable expectations of the individual based on his/her relationship with the controller |
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C. The Company processes a user's Personal Information in order to comply with domestic or international legal obligations or regulations. |
The Company processes Personal Information for these purposes in order to comply with a legal obligation. |
3. THE NATURE OF THE PROVISION OF THE PERSONAL INFORMATION AND THE CONSEQUENCES OF ANY REFUSAL TO PROVIDE IT
Providing data for the purposes referred to in points 2.A, 2.B and 2.C is necessary and if a user refuses to provide such data, it will be impossible for the Company to perform its contractual/service obligations and to provide the user with the functions, services and information requested as specified above.
4. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL INFORMATION
Personal Information will be sent to recipients who will process the data as processors and/or as individuals acting under the authority of the Company, for the purposes listed above.
Specifically, data will be sent to:
Companies in the Mitsubishi Electric Group . The Company communicates Personal Information concerning users to the subsidiaries, affiliates and parent companies of the Mitsubishi Electric Group, where necessary, to pursue the purposes described in this Privacy Policy.
Service providers . The Company shares user's Personal Information with service providers acting as processors or data controllers, in order to make using the service possible and/or in order to make receiving the services through the Site/App possible. By way of example, such recipients may include professionals who provide technical, commercial or administrative consultancy services to the Company in the pursuit of its activities and the purposes described in this Privacy Policy, companies that provide management or maintenance services for the IT infrastructure on which the Site/App is based.
The list of data processors is constantly updated and is available from the registered office indicated above.
Third parties in compliance with a legal obligation or to protect the Company's rights . Personal Information concerning users may be communicated to institutions, law enforcement agencies, judicial authorities, administrative authorities, regulatory or public security authorities, within the framework of legal or administrative proceedings, or in order to comply with a legal obligation or to protect our rights, including in a court of law.
5. PERSONAL INFORMATION OF MINORS
The Company does not intentionally collect nor store Personal Information concerning individuals under the age of 18, nor does it intentionally allow such minors to use the Site and/or the App.
People under the age of 18 are kindly requested not to register with the Site/App and not to provide any Personal Information.
6. TRANSFERRING DATA TO A COUNTRY OUTSIDE OF CANADA
The Company may need to transfer users' Personal Information to countries outside of Canada in order to provide services to users and to pursue the other purposes indicated in this Privacy Policy. Before transferring data outside of Canada, the Company will take appropriate precautions, including any contractual ones, as provided for by applicable privacy legislation, in order to ensure the protection, security and confidentiality of the Personal Information being transferred.
7. DATA RETENTION
The Company retains Personal Information concerning users for the time strictly necessary to provide the RMI services or to achieve the purposes for which this data was collected, or in compliance with legal obligations:
-for example, we retain the Personal Information needed to exercise our right of defence in the event of a legal dispute, such as the Personal Information relating to the provision of a service, for up to a maximum of 10 years from the date on which the service is terminated;
- data relating to notices will be kept for 6 months;
- accounting data will be kept for 24 months;
- if the App is not used for a period of 15 months, the Company will send an alert regarding the subsequent storage of Personal Information;
- Personal Information concerning users will, in any case, be kept for a maximum of 10 days following the termination of the service.
Once these terms expire, Personal Information will be deleted or rendered anonymous.
8. COOKIES
With regard to information concerning cookies, refer to the specific Cookies Policy https://www.mitsubishielectric.com/en/cookie-gateway/cookies.html
9. DATA SECURITY
The Company has adopted and will continue to adopt appropriate security measures to safeguard the confidentiality of users' Personal Information. However, due to the nature of the internet, continuous technological advances and other factors beyond our control, the security of data sent via the internet cannot be fully guaranteed. We cannot, therefore, ensure nor guarantee the security of the data and information that users send to us and users acknowledge and agree that sending data over the internet is at their own risk. Users are also advised to take appropriate precautions when using the Site and the App, such as, for example, keeping access credentials strictly confidential and changing them periodically.
10. CONTACT INFORMATION
Pursuant to PIPEDA, he user has the right to access the Personal Information that concerns him/her and that is held by the Company. To request information or seek clarification regarding this Privacy Policy, users may contact the Privacy Officer duly appointed by the Company at cindy.carter@mesca.ca.
Updated: 02.17.2021
