Privacy Notice 

 

Welcome to Themo! 

Themo is owned and operated by Smart Load Solutions OÜ. 

Themo values your privacy and the protection of your personal data. This privacy policy describes what information we collect from you, how we collect it, how we use it, how we obtain your consent, how long we keep it in our databases and, if necessary, with whom we share it. 

By using the platform, you are accepting the practices described in this privacy policy. The use of the platform is also subject to our terms and conditions. In this privacy policy the words “platform” refer to the Themo mobile application and the Themo website together, "we", "us", "our", and "Themo", refers to Smart Load Solutions, and "you", and "user", refers to you, the Themo user. 

This privacy policy may change from time to time. Your continued use of the platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.  

This privacy policy has been developed and is maintained in accordance with all applicable national and international laws and regulations on privacy and data protection and, specifically, with the General Data Protection Regulation (GDPR - European regulation). 

 

1. GENERAL INFORMATION

The personal data of the users that are collected and processed through the platform: 

  • Themo mobile application (Available on Google Play and App Store) 
  • Themo web application 

Will be under responsibility and in charge of: 

  • Smart Load Solutions - Themo. 
  • Email: info@themo.io 

 

2. HOW WE OBTAIN YOUR CONSENT

By using the Themo platform and its products and services, you consent to the collection, use and processing of your personal data in accordance with this Privacy Policy and in compliance with applicable data protection regulations, including, but not limited to, the General Data Protection Regulation (GDPR) and any relevant national privacy legislation. 

You provide your express consent by doing any of the following: 

  • Visiting Themo's website and browsing its content. 
  • Downloading and installing the mobile application from the Google Play Store or the App Store. 
  • Registering as a user on the platform and providing personal information to create an account. 
  • Using the functionalities available on the platform, including connecting and managing devices, monitoring electricity consumption and receiving heating schedules.
  • Subscribe to our newsletter to receive communications, updates and promotions related to our products and services. 
  • Communicate with us through the contact details provided on the platform, either by email, web form or any other customer service channel. 

The legal basis for the processing of your personal data is based on: 

  • The consent of the user, given when carrying out any of the activities listed above. You may withdraw your consent at any time by following the procedures indicated in this Privacy Policy. 
  • The execution of an agreement, when the processing of your data is necessary for the provision of the services contracted through the platform. 
  • Compliance with legal obligations, in cases where Themo must retain or process certain user data in accordance with applicable legislation. 
  • The legitimate interest of Themo, in those cases in which data processing is necessary for the improvement of the platform, the security of the systems or the efficient provision of services, always guaranteeing the protection of your fundamental rights and freedoms. 

 

3. TYPES OF DATA COLLECTED


When using the Themo platform and its products and services, different types of data may be collected depending on the activity carried out by the user. This data may be provided directly by the user when interacting with the platform or may be collected automatically using technological tools. 

3.1. Personal Data:
Themo may collect personal information that the user voluntarily provides when interacting with the platform, including, but not limited to: 

  • Full name.
  • Email address. 
  • Telephone number. 

3.2. User Registration Data:
When the user creates an account on the platform, the following data may be collected for profile management and service provision: 

  • User email and password. 
  • Account settings preferences. 
  • Account access history. 

3.3. Usage Data:
When using the platform, Themo collects information about how the user interacts with the available devices and services, including: 

  • Configuration of the device connected to the platform. 
  • Electricity consumption history. 
  • Location of the added device. 
  • Activity within mobile application, such as functions used and frequency of use. 

3.4. Automatically Collected Data:
When the user visits the Themo website, downloads the application or uses it, certain data may be collected automatically, such as: 

  • IP address of the device used. 
  • Browser type and operating system. 
  • Unique device and user identifiers. 
  • Date, time and duration of the visit or use of the platform. 
  • Application performance data and errors. 

3.5. Analytical Data:
Themo uses analysis tools to improve the performance of the platform and the user experience. This data may include: 

  • Information about user behavior within the website and the application. 
  • Pages visited and time spent in each section. 
  • Interaction with elements of the platform, such as buttons or links. 
  • Aggregated and anonymized trend data and usage patterns. 

3.6. Contact Data:
When the user communicates with Themo through the available contact channels, data such as the following may be collected: 

  • Name and identification data provided in the query. 
  • Email address and telephone number. 
  • Messages sent through contact forms, email or other customer service channels. 

 

4. HOW LONG WE KEEP YOUR DATA

The personal data provided by users through the platform will be kept for the time necessary to fulfill the legitimate purposes described in section 5 of this policy and/or until the user stops using our services and the platform, closes the user account, uninstalls the application or requests the deletion of their data. Themo may retain personal data for a longer period provided that the user has given consent to such processing, as long as such consent is not withdrawn. In addition, Themo may be obliged to retain personal data for a longer period if required to do so in order to comply with a legal obligation or by order of an authority. Once the retention period has expired, the personal data will be deleted. Therefore, the right of access, the right of deletion, the right of rectification and the right of data portability cannot be asserted after the retention period has expired. 

 

5. HOW WE USE YOUR INFORMATION (LEGITIMATE PURPOSES) 

Themo collects and processes user data with the aim of providing, improving and optimizing its products and services. The legitimate purposes of data collection depend on the type of information collected and the activity carried out by the user within the platform. 

5.1. Personal Data:
The personal data provided by the user is collected and processed for the following purposes: 

  • To allow the identification of the user within the platform. 
  • To facilitate communication with the user in relation to their account, technical support and queries. 
  • To send relevant information about the use of the platform and its services. 

5.2. User Registration Data:
Registration data is necessary to: 

  • Create and manage the user's account on the platform. 
  • Allow access to Themo's web and mobile application. 
  • To personalize the user experience within the platform. 
  • To protect the user's account through authentication and security mechanisms. 

5.3. Usage Data:
Themo collects information on the use of the platform in order to: 

  • Allow the connection and control of devices linked to the platform. 
  • Analyze electricity consumption and provide optimization recommendations. 
  • Improve the efficiency of the services offered to users. 
  • Detect and correct errors or technical problems on the platform. 

5.4. Automatically Collected Data:
This data is processed to: 

  • Ensure the security of the platform and prevent unauthorized access. 
  • Optimize the performance of the website and the mobile application. 
  • Adapt the user interface according to the device and user preferences.
  • Diagnose and solve technical problems related to the functionality of the platform. 

5.5. Analytical Data:
Analytics data is used for the following purposes: 

  • To understand how users interact with the platform. 
  • To evaluate the effectiveness of functionalities and optimize the user experience. 
  • To develop improvements and new functions within the platform. 
  • To carry out studies of trends and usage patterns in an aggregated and anonymized way. 

5.6. Contact Data:
The data provided in communications with Themo is used to:

  • Respond to queries, support requests and complaints. 
  • Provide technical assistance and improve the quality of service. 
  • Inform the user about updates, maintenance of the platform or changes in the services. 
  • Send informative and promotional materials, provided that the user has given their consent to receive them.  

 

6. HOW WE SHARE INFORMATION

The personal information of our customers and users is an important and fundamental part of our platform. Under no circumstances will we sell or share information with third parties that has not been previously authorized by the user or owner of the personal data. We share user information only and exclusively as described below. 

Third-Party Service Providers. We use third-party services to perform certain functions on our platform. Some of these functions and services include: hosting the mobile application in the application stores (App Store and Google Play), hosting the website, data storage services, sending emails, and performing tracking and analysis functions on the platform. 

These third-party services and tools may have access to personal information needed to perform their functions, but may not use that information for other purposes. Information shared with these third-party services will be treated and stored in accordance with their respective privacy policies and our privacy policy.  

Notifications and communications: Themo can send automatic notifications through the application, and communications by email to keep users informed about updates, activities, and other relevant aspects of the platform. For this purpose, users' contact details, such as their email address, may be shared with third-party services specializing in sending automatic notifications and emails. 

Users have the option of managing notifications through their user account settings, where they can enable or disable notifications according to their preferences. In the case of emails, they can also choose not to receive additional communications by using the “unsubscribe” option available in certain emails. 

Themo undertakes to use contact details only for purposes related to the activities of the platform and to ensure that any third-party services managing such communications comply with applicable data protection and confidentiality regulations. Users can contact Themo if they need additional help managing their notification or communication preferences. 

Business Transfers. In the event that Themo creates, merges with, or is acquired by another entity, your information will most likely be transferred. Themo will email you or place a prominent notice on our platform before your information becomes subject to another privacy policy. 

Protection of Themo and others. We release personal information when we believe release is appropriate to comply with the law, enforce or apply our Terms and conditions and other agreements, or protect the rights, property, or safety of Themo, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. 

With Your Consent. Other than as set out above, you will receive notice when personally identifiable information about you might go to third parties, and you will have an opportunity to choose not to share the information. 

 

7. PROTECTING YOUR INFORMATION

We grant access to your personal information only to those outside persons or services that have a legitimate need to know it and in accordance with our privacy policy. We adhere to industry-recognized security standards to protect your personal information, both during transmission and in storage. However, it is important to note that no method of transmission over the Internet or electronic storage is foolproof and 100% secure. Therefore, while we at Themo strive to implement commercially viable data protection methods, we cannot ensure absolute security of your personal information. We undertake not to sell, distribute or transfer your personal data to unauthorized third parties, unless we have your explicit consent or are required by law to do so. 

 

8. DATA BREACH NOTIFICATIONS

In the event of a security breach that compromises the confidentiality of our users' personal data, Themo undertakes to notify those affected in a timely manner. This notification will be made through the means of contact that have been provided by the user on our platform. We will take all reasonable measures to protect the information and remedy any situation that jeopardizes the security of your data. 

 

9. INTERNATIONAL DATA TRANSFER

Themo may transfer users' personal data outside Europe or their country of origin due to the use of hosting, storage and processing services provided by third parties that operate servers located in different countries. These transfers are necessary to ensure the continuous functioning of the platform and to provide an efficient user experience. Although Themo is based in Estonia, the technological infrastructure used may involve data being stored or processed in jurisdictions with data protection laws that differ from those in Europe or your home country. 

Themo is committed to ensuring that all international transfers of personal data comply with applicable data protection regulations, including appropriate security measures to safeguard user information. This includes, but is not limited to, the implementation of standard contractual clauses, the assessment of the adequacy of data protection in the receiving country, and compliance with applicable privacy regulations in third-party services. 

By using Themo, users consent to the transfer, storage and processing of their data on servers located outside their country of residence, recognizing that such transfers are necessary for the operation of the platform. Themo undertakes to take all reasonable measures to protect the integrity and security of personal data during such international transfers.  

 

10. RIGHTS 

Users who provide information through our platform, as data subjects and data owners, have the right to access, rectify, download or delete their information, as well as to restrict and object to certain processing of their information. While some of these rights apply generally, others apply only in certain limited circumstances. We describe these rights below: 

  • Access and portability: to access and know what information is stored in our servers, you can send us your request through our contact information. 
  • Rectify, Restrict, Limit and/or Delete: You can also rectify, restrict, limit or delete much of your information. 
  • Right to be informed: Users of our platform will be informed, upon request, about what data we collect, how it is used, how long it is retained and whether it is shared with third parties. 
  • Object: When we process your information based on our legitimate interests as explained above, or in the public interest, you may object to this processing in certain circumstances. In such cases, we will stop processing your information unless we have compelling legitimate reasons to continue processing it or where it is necessary for legal reasons. 
  • Revoke consent: Where you have previously given your consent, such as to allow us to process and store your personal information, you have the right to revoke your consent to the processing and storage of your information at any time. For example, you may withdraw your consent by updating your settings. In certain cases, we may continue to process your information after you have withdrawn your consent if we have a legal basis for doing so or if your withdrawal of consent was limited to certain processing activities. 
  • Complaint: If you wish to file a complaint about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority. Users can exercise all these rights by contacting us through the contact information or the contact page. 
  • Rights related to automated decision-making, including profiling: users may request that we provide a copy of the automated processing activities we conduct if they believe that data is being unlawfully processed. 

Users or holders of personal data provided through the platform may exercise these rights over their personal data at any time and without limitation by sending their request through our contact information or contact form. The request to exercise their rights will be attended and answered within a maximum period of 10 working days. 

 

11. CHILDREN’S ONLINE PRIVACY PROTECTION 

We comply with the requirements of national and international data protection regulations regarding the protection of personal data of minors. We do not collect any information from children under the age of 13 (minimum age allowed to collect and process information without parental or legal guardian consent). If we become aware that a child under the age of 13 has provided us with personal information, we will take steps to delete such information. 

 

12. THIRD PARTIES

Except as otherwise expressly included in this privacy policy, this document addresses only the use and disclosure of information that Themo collects from you. If you disclose your information to third parties, whether other users or third parties, different rules may apply to their use or disclosure of the information you disclose to them. Themo does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. Themo is not responsible for the privacy or security practices of other websites, platforms or services, including those linked from our platform. Please review the privacy policies of any third-party websites, platforms or services you access through the Themo platform. 

 

13. CHANGES TO PRIVACY POLICY

We reserve the right to change our privacy policy at any time. Changes will be promptly notified to our users through any electronic means and posted on the platform. Your continued use of our platform following such changes will signify your acceptance of the changes. 

 

14. CONTACT US

If you have questions or concerns about these privacy policy and the handling and security of your data, please contact us through our contact information below: 

Smart Load Solutions OÜ - Themo. 

Email: info@themo.io