Emlid Privacy Policy

Last updated: August 24, 2020

1. Introduction

At Emlid, we are committed to ensuring that your personal information is protected and never misused. We process personal data about you in accordance with applicable local law and this privacy policy.

We do not sell your personal information to anyone and only share it as outlined in this privacy policy or when you ask us to.

Our privacy policy explains what personal information we collect, why we collect it, how we use it, the control you have over your personal information, and the procedures we have in place to protect your personal information. It applies to the personal information we collect through:

1.1. Websites

1.2. Emlid apps (Apple App Store, Google Play Store)

(hereinafter – “Websites and Apps”).

1.3. Emlid сloud services (hereinafter – “Сloud Services”).

Additionally, we may collect personal data through our connected products (explained in more detail below), and in-person at our Emlid retail stores or stands and events.

By sharing your personal information with us and by continuing to use our Websites and Apps, connected products, and Сloud Services you confirm that you have read and understood the terms of this privacy policy. We take responsibility for the personal information we collect about you, and we aim to be transparent about how we handle it and give you control over it.

In this privacy policy, when we refer to “Emlid”, “us”, “we”, or “our”, we mean the Emlid group company (in particular, Emlid Limited which has its registered address at 4/F Enterprise Building, 228-238 Queen’s Road Central, Hong Kong) or companies which provide you with the Emlid websites, apps, or connected products or which are responsible for stores, stands, or events in your country. Information on which Emlid group company or companies are primarily responsible for any personal information collected about you is available in the contacts at the end of this privacy policy titled “14. Contacting us about Privacy Policy”. In this privacy policy, when we refer to the “Emlid Group”, we mean all Emlid group companies.

We address privacy issues seriously and are always available at privacy@emlid.com for any inquiries concerning your privacy.

2. Privacy principles

Privacy policies can be complicated. We have tried to make ours as clear and as accessible as possible. To help, we have also summarized how we handle your personal information at Emlid in our privacy principles below. These principles demonstrate our commitment to protecting your privacy and handling your personal information in the right way, and as you would expect it to be handled.

At Emlid we:

  • will only ask for or collect the personal information we need to provide and improve the service, products, and experiences our customers expect;
  • give you control over the personal information we hold about you to ensure it is accurate and meets your expectation, and we are always available at privacy@emlid.com for any inquiries concerning your privacy;
  • make sure your personal information is always secure and protected;
  • are fair and transparent about how we use the personal information we hold;
  • only ever use your personal information for the purpose that you trusted us to use it for;
  • will not sell your personal information and only share it as outlined in our privacy policy or when you ask us to;
  • respect your choices and will inform you if there are important changes that affect your personal information or how we use it;
  • take responsibility for the personal information that we hold about you.

3. What personal data we collect

We are not interested in collecting every personal detail about you. Our main reason for collecting your personal information is to provide and improve the service and products.

Personal information is defined slightly differently across the world. To guarantee your privacy and the protection of your information, we define it as any information that could be used to identify you or another individual directly or indirectly.

We collect personal information about you in a number of different ways. In this section, we explain the different ways we collect personal information about you and the ways in which that information will be used. For more detail on how we use your personal information, please see the section titled “4. How we use your personal information”.

3.1. Information you share with us

We collect personal information that you share with us when you contact us or interact with us through our Websites and Apps, email, phone, in person at our stores, stands and events, or otherwise.

For example, you will provide information to us when you contact our customer service teams, place an order, use a warranty, connect through an Emlid app.

Through these interactions, you may share with us: your name, address, e-mail address, contact number, and payment information. In some circumstances, we will need that information to be able to provide you with a product or service that you have asked for; for example, we need your payment information when you buy a product, your address to deliver it to you or to issue an invoice, or to find your previous orders.

If you share details of other people with us (for example, if you have bought an Emlid product for that other person or if you register another person for an Emlid app), then you will need to check with that person that they are happy for you to share their personal information with us, and for us to use it in accordance with this privacy policy.

We use this information in the GDPR-compliant services:

We do not have access to your full payment information. Payment is processed by the GDPR-compliant online payment services: PayPal and Stripe. Check their privacy policy pages to see how they can handle your Personal Information:

3.1.1. Information from Cloud Services

As a special case, we would like to draw your attention to the data we collect from Cloud Services. We collect personal information that you share with us if you use our Cloud Service.

Once you agree and want to use our Cloud Services, you allow us to store and process the data from Websites and Apps, Emlid products, your settings, project data, enabled subscriptions, services you use, possible integrations. You will also start sharing with us information about you and Emlid products and apps you use (for example, device model, country, firmware version, latest uptime).

Also, we will collect device data: crash reports and system logs, firmware versions of internal components, device configurations, battery performance statistics, how often users access certain features, RTK engine positioning statistics; and runtime data: crash reports and system logs, how often users access certain features, approximate user portrait geography, receiver models, correction formats, messages, usage lengths, etc.

If we introduce more new services, we may start collecting more analytical info on how our services are used.

3.2. Information from Emlid products and apps

As well as the personal information you share with us about yourself and your Emlid product, we may collect and handle some information directly from your Emlid connected products and Emlid apps. A connected product is an Emlid product that is “smart”, internet-enabled, or operated through an Emlid app.

Upon your consent, we want to be able to monitor your use of our Emlid connected products and Emlid apps to maximize the efficiency of our products and for statistical purposes. In such case, we will collect information about your use of our connected products (for example, when they are used and for how long, firmware version, operating time since the last launch, configuration, battery statistics, function usage statistics, measurement quality statistics), their responsiveness and any errors (or potential errors) with them.

Additionally, we would like to draw your attention to the fact that we could accidentally receive some additional personal information about you from the crash report related to our products. We will not be using, sharing, or processing such pieces of personal information anyhow. Please note that the risk of the above case is extremely low.

The purpose of collecting this data is to perform analysis and to help us better identify the usage flows around our products to maximize the efficiency of our products. We use the following services for that:

3.3. Information from your online interactions

If you are using a mobile device and shopping with us online or browsing our website, we may collect your IP address or other device identifiers, browser type and version, time zone setting, browser plug-in types, and versions, operating system and platform, and other portable device information.

We use this information so that we can see how well our websites and apps are working, how they are used, and what users look at most.

We also collect and handle information about how you engage with our promotional campaigns and advertising online, outside of our own websites (for example, on Google, YouTube, and social media). We use Google Analytics and Yandex Metrica for website analytics. The collected information is used to track and monitor the use of the Website. This information can be used by Google and Yandex to contextualize and personalize web ads of their advertising networks.

That information is, predominantly, collected through our use of cookies and similar technologies.

3.4. Cookies

We use cookies to recognize your browser and, if you have a registered account, associate it with your registered account. You will be prompted about the usage of cookies on the website when you visit it for the first time. You can disable cookies in your web browser settings, except cookies, which are mandatory to enable you to use our Websites and Apps.

In addition, we use cookies for website analytics.

Some cookies that we use at Emlid will collect personal information about you. Any personal information that is collected will be used in accordance with this privacy policy. By continuing to use our Websites and Apps, you accept that cookies will be set on your device.

3.5. Email communications

We will be sending support communications emails to you if you are a user of our products or services.

When you subscribe to our newsletters, you enter your name and email address. We use them to send you our marketing emails if you are fine with that. We also use email tracking to monitor and analyze click and open rates. This helps us to improve our newsletter content. You can opt-out of the subscription anytime by clicking the link in an email bottom.

Our email marketing platform is MailChimp. To see how they can handle your personal information, check the MailChimp privacy policy page.

3.6. Social media and Emlid forum

We like interacting with you on social media. You may use social media to contact us about your Emlid products or to let people know what you think about your Emlid product. We review publicly available social media and online sites to get a better understanding of what people are saying about us and our products, technology, and services and to assist customers who prefer to contact us through social media.

The information we collect from social media and online sites, including Facebook, YouTube, Twitter, Pinterest, Line, and Snapchat, sometimes includes personal information that has been put online and is publically available. We make sure any information we use is properly credited to its source or is made anonymous.

These online and social media sites typically have their own privacy policies explaining how they use and share your personal information. You should carefully review those privacy policies before you use these sites to make sure that you are happy with how your personal information is being collected and shared.

Additionally, we use our forum to get a better understanding of what people are saying about us. When you are registering on our forum, you enter your name and email address. Your email address will be verified by an email containing a unique link. If that link is visited, we know that you control the email address.

When you are registered and posting, we record the IP address that the post originated from. We also may retain server logs, which include the IP address of every request to our server.

We also use external authorization software on our forum. It stores your email address and uses it for authorizing you on our forum. To find out more about their use of information, please refer to Auth0 Privacy Policy.

3.7. Information we collect at our stores, stands, and events

You may share personal information with us when you visit us in person at our stores, stands and events; such as your name, contact details, and payment information (see the section above titled “Information you share with us”).

If you have Wi-Fi or Bluetooth enabled on your phone (or another device) when you visit us at our stores, stands and events, we may also collect limited personal information through your device.

4. How we use your personal information

Our main reason for collecting and using your personal information is to provide and improve the service and products.

4.1. Information you share with us

We use the personal information you share with us in the following ways:

  • to provide, manage and coordinate the purchase, delivery, and any required after-sales care of your products;
  • to respond to your queries and requests;
  • to communicate with you;
  • to provide services and support for our products;
  • to enable us to identify where service and product improvements can be made;
  • to provide updates to you about any changes to Emlid’s policies, terms and conditions. and any other matters which we may need to tell you;
  • to document, monitor and record the lifecycle of our products;
  • to tell you about our other products and services (if you explicitly agree with that); and
  • to provide you with essential service updates about your Emlid products.

4.1.1. Information from Cloud Services

There is some additional specific regarding Cloud Services. The essence of the Сloud Services is data exchange between different devices and access to data from different devices. All this data is required for Cloud Services to function and for us to improve and administer its work.

4.2. Information from Emlid products

We use the information we collect from Emlid products, by itself and sometimes in combination with other personal information that we collect about you, in the following ways:

  • to monitor the performance and stability of our products so that we can optimize their performance;
  • to provide updates and services to our connected products (including updates and upgrades to the software in the product and the app that connects to it);
  • to improve our products, technology, and services generally; and
  • to send you more relevant and interesting marketing communications (if you agree with that).

We also want to be able to monitor your use of our connected products, so that we can:

  • customize and improve the way that we engage with you in the future (for example, by showing you products and offers online that we think you might like).

You have the right to object to our monitoring of your use of our connected products and apps for these purposes unless we can process it as our legitimate interest.

4.3. Information from your online interactions

We use the personal information from your online interactions, by itself and in combination with other personal information that we collect about you to identify any part of our Websites or Apps that aren’t working as well as they should be, so that we can fix things and make our Websites and Apps better for you and other users.

We also want to be able to monitor your use of our Websites and Apps, and how you engage with our promotional campaigns and advertising online, so that we can:

  • customize and improve the way that you shop with us in future (for example, by showing you products and offers that we think you might like); and
  • send you more relevant and interesting marketing communications (as long as you are happy for us to do so);
  • detect and prevent fraud;
  • keep our Websites and Apps, products and IT systems secure;
  • produce analytics, user profiles, reports, and targeted advertising;
  • to respond to online queries through the web-enabled chat services on our Websites and Apps.

Emlid does not take any decisions involving the use of algorithms or profiling that significantly affects you. You have the right to object to our monitoring of your use of our Websites and Apps, and how you engage with our promotional campaigns and advertising online for these purposes unless we have a legitimate interest in doing certain data processing.

4.4. Other potential uses of your personal information

We use your personal information:

  • to assist in any disputes, claims or investigations relating to your Emlid product or warranty matters;
  • to detect and prevent fraudulent transactions;
  • to comply with our legal obligations.; and
  • for general statistical analysis on an anonymous basis.

5. What are our legal justifications for processing data

Data protection and privacy laws usually require us to have a legal basis or lawful grounds for handling personal information. Broadly, that means that we have to have a legal justification for handling your personal information. For the most part, we need to handle your personal information to be able to:

  • provide you with the products or services that you have asked for; and
  • for our products, Websites and Apps to be able to work properly and to do all the things that you expect them to.

We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data when you make an order for products and services. The same ground we use when you want to use Cloud Services, as a part of the performing Terms of Services for Cloud Services. Sometimes, our use of your personal information is not strictly necessary for us to be able to provide you with our products and services, or for them to work properly. In those circumstances, we have what’s called a “legitimate interest” in handling your personal information; our “legitimate interest” may be to:

  • detect and prevent fraud;
  • keep our websites, apps, products and IT systems secure;
  • ensure that our own processes, procedures, and systems are as efficient as possible;
  • analyze and enhance the information that we collect;
  • determine the effectiveness of our promotional campaigns and advertising; and
  • customize and improve the way that you shop and engage with us in the future.

Where we rely on our legitimate interests, we will always make sure that we find the balance between these interests and your rights.

In some cases, we will use your personal data because it is necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency).

Finally, there will be certain personal information that you share with us which we specify as being optional (for example, to send you advertising and marketing communications or to monitor your use of the Emlid products, Websites and Apps). We will ask you to provide consent for such data processing to confirm that you are agreeing to our use of your information in that way. You can ask us to delete that information at any time by emailing at privacy@emlid.com.

No matter the location, we collect explicit consent from all users in order to send our marketing emails. To join the subscribers’ list you should give us your consent to receive such a newsletter. You can opt-out of receiving marketing emails at any time by clicking the “unsubscribe” link found within our emails and changing your contact preferences.

6. What personal information Emlid shares with third parties

6.1. Sharing within the Emlid Group

Most of Emlid’s processes, procedures, and systems are shared across the Emlid Group, which means that we need to share your personal information between us. We make sure that access to your personal information is limited to those of our staff who need it, and that all staff understands how and why we protect your personal information.

6.2. Third-party service providers

We share your personal information with certain third-party service providers. They only have access to the personal information they need to perform those services. They are required to keep your personal information confidential and may not use it other than as we ask them to and always in accordance with this privacy policy. Those third-party service providers fall into the following categories:

  • certain distributors who help us to sell our products in certain countries;
  • those helping us to deliver products to you;
  • third parties that help us with mailing services, product service and repairs, processing product purchases, financial services, audit services, administrative services, IT technologies (e.g., data storage), security services and insurance claims; and
  • third parties that help us to provide services and responses to you.

6.3. Third parties that help us with our advertising and marketing

We want to make sure that our advertising and marketing is relevant and interesting to you and our other customers. That means that we work with third parties to help us to understand how well our online advertising works, or to reach people who are more interested in Emlid products. They do this by setting cookies on our website (more information on this can be found in our cookies policy).

We will also share limited personal information with:

  • social media platforms (such as Facebook), who serve our advertising on their platforms; and
  • third party data providers and analytics companies who perform data matching and/or data analysis on our behalf.

6.4. Other third parties

We share certain personal information with third parties who help us to detect and prevent fraudulent transactions. The information we share with those third parties includes some of the information that you share with us (such as your contact details and information about the transaction), and some of the information from your online interactions (such as the IP address of your device). That information is used to determine whether a transaction could be fraudulent. They are responsible for their use of your personal information and will use it for the purposes set out in their privacy policy.

We will also share your personal information if we are required to do so by law, including in response to a legal process, such as a court order or subpoena, or to comply with other national, state, provincial or local laws.

If you would like more information on how we share your personal information, please email at privacy@emlid.com.

7. External links

You can sometimes find links to other sites on the website. These third-party sites have their own privacy policies. We have no responsibility or liability for the content and activities of these linked sites.

Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

8. How long we keep your personal information

We only keep your personal information for as long as we need to, to be able to use it for the reasons given in this privacy policy, and for as long as we are required to keep it by law. The actual period for which we store your personal information will vary depending on the type of personal information and how it is used. For example, when you buy a product from us, we will store information about you and your purchase for at least the term of your warranty or guarantee.

9. Your rights

Consistent with applicable law, you may exercise any of the rights described in this section before us. See here for information on data subject rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking further action on your request.

9.1. Managing Your Information.

You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

9.2. Rectification of inaccurate or incomplete information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Emlid app, or another tool).

9.3. Data access and portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

9.4. Data retention and erasure

We generally 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. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

  • we may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention, and enhancing safety.
  • we may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
  • information you have shared with others (e.g., reviews, forum postings) may continue to be publicly visible on the Emlid platforms, even after your account is canceled. However, the attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database but are disassociated from personal identifiers.
  • because we maintain the Emlid Websites and Apps 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.

9.5. Withdrawing consent and restriction of processing

If we are processing your personal information based on your consent, you may withdraw your consent at any time by changing your account settings or by sending an email at privacy@emlid.com. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

9.6. Objection to processing

In some jurisdictions, applicable law may entitle you to require Emlid not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, Emlid 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 Emlid to cease processing your data for these direct marketing purposes by sending an email at privacy@emlid.com.

10. How we protect your personal information

We are committed to protecting your personal information. We use appropriate technical and organizational measures, including encryption, to protect your personal information and privacy, and review those regularly. We protect your personal information using a combination of physical and IT security controls, including access controls that restrict and manage the way in which your personal information and data are processed, managed, and handled. We also ensure that our staff is adequately trained in protecting your personal information. Our procedures mean that we may occasionally request proof of identity before we share your personal information with you.

In the unlikely event that we do suffer a security breach which compromises our protection of your personal information and we need to let you know about it, we will do so.

11. Transfer of your personal data

We may need to transfer your personal data to other countries, in the following circumstances:

  • where you have requested a service which is fulfilled by one of our group companies which sit outside of your country; or
  • where we work with a supplier that processes some of its personal data outside of your country.

Foreign countries may not have the same data protection laws as yours, and so your personal data may not be subject to the same protections. However, in such cases, we will take efforts to make sure that any transfer of your personal data to countries outside of yours is subject to appropriate safeguards and under the guiding principles set out in this privacy policy.

In any case, our transfer, storage, and handling of your personal information will continue to be governed by this privacy policy. If you would like further information about the global handling of your personal information, please contact us at privacy@emlid.com.

12. Children

Emlid’s Websites and Apps, Cloud Services, and products are not directed at children. We do not knowingly collect any personal information from children.

If you are a child, please do not attempt to become a registered user of our Websites and Apps, Cloud Services, or products or otherwise provide us with any personal information. If we learn that we have inadvertently obtained personal information from a child, we will delete that information as soon as possible.

If you are aware of a child who has provided their personal information to us, please contact us at privacy@emlid.com.

13. Updates to Privacy Policy

We may need to change this page from time to time in order to address new issues and reflect changes on the Websites. We will post those changes here so that you will always know what information we gather, how we might use that information, and whether we will disclose that information to anyone.

14. Contacting us about Privacy Policy

We address privacy issues seriously and are always available at privacy@emlid.com for any inquiries concerning your privacy.