My Water Privacy Policy

October 9, 2019 (ver. 2.0)
We at ORBITAL SYSTEMS (“Orbital”) consider security and integrity to be part of our company DNA. It’s our obligation as controller of our customers’ personal data to inform our customers, both prospects and purchasing, about how and why we process their personal data. We commit to respect the personal data of individuals in the same manner as we respect individuals themselves, be they our employees, customers, vendors or any other party that we interact with.
THE PERSONAL DATA & HOW WE MANAGE IT

We process personal data in respect of two categories of data subjects, namely, prospect customers and buying customers. Also, we collect two different types of data, namely;

• Customer data. Customer data is the data you provide us with when signing up on the waiting list or that is connected to your account and any other data created due to your use of our product and services, e.g. invoice data etc.

The customer data is collected by us when:

• you communicate with us during the process of becoming a customer, for example when you contact us via e-mail for information or sign up for our newsletter or waiting lists;
• you sign up to our services in app or web;
• you visit our website as we collect cookies (See our Cookie policy on page 7)
• Shower data. Shower data is the data produced by the product that we supplied you when in use. The shower data is only technical and does not include any personal data of any sort, meaning that we cannot see who used the product when, just that it was used.

Shower data enables us to deliver notifications and statistics to you via web or/and app. Also, the data may be used for development purposes to help us improve the product. As well as for marketing, sales and business decision purposes. For example, we will aggregate behaviour data (of the product) to help us study shower habits. We may publish these trends. Note that shower data does not contain information about you. This is data about filter status, sensors, temperature etc. This is specific for the units we provide, and not considered personal data.

We never save data longer than we need. Some data is discarded directly, others are stored for a long time depending on the data and our legal requirements.
For example, a buying customer’s personal data is saved no longer than 24 months after the termination of the contract. Exceptions do apply to such information that must be stored by law, e.g. the Swedish Accounting Act (Sw: Bokföringslagen).
Personal data is also saved for billing purposes. In the case of unpaid invoices, the personal data is saved until the claim is settled. When the invoice is paid, the data is deleted after 24 months if not required by law that it is stored for a longer period.
Please see the tables below for more detailed information. Do note that we will not process your personal data for any other purposes than listed below. If additional processing would be needed, we will inform you and ask for further consent or explain on what legal basis we process your personal data.

Prospect customers
We collect data about you when you sign up on our waiting list to purchase one of our products to contact you when we launch in your country, share news and updates, and/or let you know when the product you are interested in is in stock.

Customers
We collect data about you when you sign up as a customer and use our services. The data is collected to fulfil our obligations under the agreement with you, give you a good experience and improve our services.

Certain data processing is based on your approval, so-called consent. If the processing is based on consent, you can always decide not to agree to certain processing activities or purposes, and you can withdraw your consent at any time.
Note: In order to provide services and products, we need to process and manage your data. You are not obliged to submit your data to us. If you choose not to do so, it is not certain that we can provide all of our products and services to you.

We share your data with a number of partners in order to provide our services to you. Orbital also uses databases and software suppliers to handle communication with you in the best possible manner. We always enter into a binding agreement with all external parties that includes a duty of confidentiality and require them to comply with the requirements of applicable legislation regarding processing and transfer of personal data. In this way, we guarantee the security and confidentiality of your personal data.

Orbital may transfer your personal data to countries outside the EU/EEA in order to provide our services to you. Any such transfer will always be done in a secure and legal manner. Orbital may transfer your personal data to such countries only when we have entered into an agreement with another company and the agreement includes either so called Binding Corporate Rules or Standard Contractual Clauses which comply with EU Commission guidelines, or when the country that we transfer your personal data to has been approved by the EU Commission to have an adequate level of protection.

Security of data comes first in everything we do. Security features are built into all of our products, services, and infrastructure to keep data protected at every layer. We invest in teams and technology to continually improve that security, protecting not only our operations, but your business and data as well.
In the unlikely event that we lose control of your personal data and this data is of a sensitive nature we will inform you without undue delay, and no later than 72 hours after we have become aware of the incident.

It is our obligation to only process personal data which are correct, relevant and necessary with regards to the purposes of the processing, and you are entitled to control that this is the case. Orbital is responsible for that your personal data is processed in accordance with existing legislation.
We will, on your request or on our own initiative, correct, de-identify, erase or complement data which are detected to be inaccurate, incomplete or misleading.
You as an individual have a number of rights under existing legislation. You have the right to:

• Gain access to your personal data.
• We will, on your request, provide information regarding which of your personal data we are processing as quickly as possible.
• You are also entitled to obtain a copy of the personal data which is being processed.
• Orbital may refuse you access to the personal data if your request is manifestly unfounded, clearly abusive or if the personal data cannot be disclosed by access due to requirements in other legislation.
• The register with your personal data will be provided free of charge. However, Orbital has the right to charge a reasonable fee for administrative costs arising out of request of additional copies or if the request is manifestly unfounded or clearly abusive.
• Demand rectification of your personal data.
• We will, on your request, rectify the inaccurate or incomplete information that we are processing about you as quickly as possible.
• Demand erasure of your personal data.
• We will erase your personal data on your request as quickly as possible from when we received your message if they are no longer necessary for the purpose for which they were collected or if the processing was based on your consent.
• Please note that we cannot erase your personal data if we still have a legal basis for continuing the processing. If that is the case, we will cease with the processing of the personal data that is possible to erase and is corresponding to your request and inform you of the legal basis and the relevant purpose of the continued processing.
• Demand limitation of processing.
• You have a right to mark your personal data in order for it to only be processed for certain limited purposes. You can inter alia demand limitation when you consider that your personal data are inaccurate, and you have demanded rectification according to the above. Whilst the time when the personal data’s correctness is investigated, the processing of it will be limited.
• We will inform you if the investigation results in that the processing shall be limited. We will make sure that necessary rectifications or erasure of personal data and limitation of processing of personal data also is made by the companies to which Orbital have disclosed your personal data.
• Demand data portability.
• You have a right to, under certain circumstances, receive and transmit your personal data in a structured, commonly used and machine-readable format to another controller. Contact us if you wish to know more!
• Object to processing of personal data which is being done with the support of a balancing test.
• You can object to the processing if it is based on a balancing of interest test. If you object to such processing, we will only continue to process your personal data if there are eligible reasons to the processing which outweighs your interest. We will inform you of the reasons if that is the case.
• Demand that we cease to process your personal data for direct marketing.
• You always have a right to object against direct marketing by sending an e-mail to contact@orbital-systems.com When we have received your objection, we will cease to process the personal data for such marketing purpose.
• Complain on our processing of your personal data and compliance with the law to the Swedish Data Protection Authority.
• You are entitled to complain on the processing that we perform on your personal data to the Data Protection Authority if you think that we are in breach of the Privacy Policy, do not fulfil your rights or in any other way are acting contrary to existing law.

If you wish to make use of any of your rights above, please feel free to contact us. Our contact details can be found below.

Sometimes we may come to do changes in the privacy policy. We will send you a message if we do major changes by use of appropriate means, e.g. by sending a message by e-mail, inform via a pop-up in the app/on the web, or send a SMS message to you.
In some event, we will inform you in advance, and your continued use of the webpage and/or app after the changes will constitute your acceptance of the changes. Therefore, we kindly advise you to ensure that you read all such messages carefully.