Privacy Policy for Smart+Cool Products and Services

This Privacy Policy for Concepcion-Carrier Air Conditioning Company ("CCAC") Products and Services (“Privacy Policy”) describes information that CCAC and its subsidiaries and affiliates (collectively, “CCAC”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address, physical address, or billing information, or other data that can be reasonably used to infer this information). This policy outlines the information related to the operation of CCAC's products and services, including the Smartcool™ Smartplug. In this policy, the expression “CCAC Products” also includes our Web Apps, Mobile Apps, and Subscription Services.

Our Commitment:

  • We will be transparent about the different types of information we collect and how we use them.
  • We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide CCAC’s Products and Services, and to do so only when we think they will provide you with a welcome additional service.
  • We will use best-in-class practices to keep your data safe and protect the CCAC Products from unauthorized access.

Your Consent:

Consent to data collection and processing. By using CCAC Products, you agree to allow us to collect and process information as described in this Privacy Policy. Consent to international data transfers. Your personal information may be collected, processed and stored by CCAC or its service providers in countries other than the Philippines. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country.

What information does the Smartcool™ Smartplug collect?

It collects:

  • Setup information you provide
  • Electrical data from the Smartcool Smartplug sensors
  • Direct adjustments to the appliance, such as power state
  • Technical information from the Smartplug

Setup information you provide: When you install the Smartcool Smartplug, you’ll be asked several questions to identify the appliance being connected to the Smartcool Smartplug, such as appliance type and model, and the physical location (street, city, province and country) and room location. This information will help you identify the appliance being controlled by the Smartcool Smartplug, while allowing us to provide context to data generated by the Smartplug. Electrical data from the Smartcool Smartplug sensors: We collect data from sensors built into the Smartcool Smartplug. This includes incoming voltage, current, and instantaneous power (watts). This information drives the analytics used in the mobile application, to allow you to monitor energy consumption.

Direct adjustments to the device: When you use the mobile application to control the power state of the connected appliance, this information is used by our network to pass on the instruction to the Smartcool SmartPlug, allowing you to remotely control the device.

Technical information from the device: In order to ensure that your Smartcool Smartplug and our CCAC IOT infrastructure remains secure and reliable, we record information such as the Smartcool Smartplug serial number and model, the mobile application software version, and location based information about both the Smartplug and your mobile application usage.

How does my CCAC Product or account interact with third parties?

Currently, our products do not interact with any third party hardware or software. If this changes in the future, we’ll ask your permission before sharing any information to a third party.

What additional information does CCAC collect and store when a user connects a CCAC Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your CCAC Product to our Services, or to access your CCAC Product over the Internet from a computer, a smartphone or a tablet, you will need to connect it to your Wi-Fi network. During setup, the CCAC Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device, along with your IP address, so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with CCAC servers and download software updates.

Once connected to your Wi-Fi network, your CCAC Product regularly sends the data described in this Privacy Policy (excluding your Wi-Fi password) to CCAC to provide you with the Services.

Email Addresses: When you create a CCAC account (with or without using a Facebook account), we collect and store your email address. From that point forward, your email address is used for communications from CCAC.

Facebook Accounts: When you create a CCAC account with a Facebook account, we only collect and store the information disclosed during authorization of the Facebook account, such as your name, email address and date of birth. This information will only be used to maintain the integrity of your account, and to validate your identity when interacting with our customer support services. You may directly control these permissions with the privacy and security settings of your Facebook account, at any time.

Bluetooth data: Bluetooth-enabled CCAC Products (such as Smartcool Smartplug) may broadcast an identifying signal wirelessly. This is used to connect with your Bluetooth-enabled devices (such as a smartphone or tablet) in order to deliver features such as setup.

How does CCAC use the information it collects?

We use this information to provide, develop and improve CCAC Products and services, including to make assessments and recommendations about products, safety, or energy use. We may use your contact details to send you this information, or to ask you to participate in surveys about your CCAC use, and to send you other communications from CCAC.

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, CCAC may process your personal information on servers that are not in your home country.

In what circumstances does CCAC share my information?

Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of CCAC Products and services without asking you first. We do not rent, broker, or sell our customer lists.

The following are the limited situations where we may share personal information:

With your consent: We may share personal information when we have your consent. One example of this would be if you invite another user to access the Products on your account as an additional authorized user. Another example is if you sign up for programs offered by our partners (e.g., energy or insurance companies); if you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device.

For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers for technical problems.These technicians (as well as CCAC employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-CCAC purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video data.

As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy Policy in place at the time of its collection.

For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, we may disclose information in response to legal process and we may disclose information in response to lawful requests by public authorities in the Philippines and other countries for the purposes of law enforcement and national security.

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. This information may also be shared with other users to help them better understand their energy usage compared to others in the CCAC community, raise awareness about safety issues, or help us generally improve our system. We may also share non-personal information with our partners, for example, if they are interested in providing demand-response services or other incentive programs. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

What choices do I have and how can I delete my personal information?

CCAC generally stores your personal information on CCAC’s servers until you delete or edit it, or for as long as you remain a CCAC customer in order to provide you with CCAC Products. When you choose to delete your account, we only retain anonymized information (meaning, information that cannot identify you) for historical and statistical purposes.

As described above, some information is processed and stored directly on the CCAC device. All personal information is encrypted as it is transmitted to CCAC and cannot easily be accessed.

You can delete the information on the CCAC device by resetting it to the defaults through the Factory Default Reset feature described in the User Manual.

Can the Privacy Policy be changed?

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes on the website or by contacting you.

If you have any questions, please contact us at dpo@ccac.com.ph