These Terms are an agreement between you and Imperial College of Science, Technology and Medicine, a University incorporated by Royal Charter in the United Kingdom whose address is at South Kensington Campus, Exhibition Road, London SW7 2AZ (“Imperial”). When these Terms refer to “our”, “us” or “we”, they refer to Imperial.
Imperial is a partner in the POWBAL research project studying consumer energy use and has developed the POWBAL application (“the POWBAL App”). The POWBAL App enables participants in the POWBAL research project to configure and operate a smart power plug (“the POWBAL Plug”) that connects via the participants’ home WIFI connection to the internet. The POWBAL Plug allows remote switching-off of electrical devices connected to the plug as well as the measurement of those devices’ power consumption. It also allows participants to override remote switch-offs of the POWBAL Plug by Imperial.
Imperial College of Science, Technology and Medicine., its affiliates and subsidiaries (“we”, “us”, “our”, “Imperial”) are committed to protecting your privacy. This Privacy Statement (“Statement”) describes our practices in connection with information privacy on personal data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”) including the POWBAL App developed by the POWBAL research project in which Imperial is a partner.
In this Privacy Notice, “Personal Data” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual. “Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, etc. “Apps” refers to those mobile applications developed by POWBAL that provide end users remote control to Smart Devices and the ability to connect to the POWBAL Web Platform.
In order to provide our services to you, we will ask you to provide the necessary personal data that is required to provide those services. If you do not provide this data, we may not be able to provide you with our products or services.
All current participants in the POWBAL program have provided their consent to participate via our consent survey, which is presently hosted on the Qualtrics survey platform. The consent process asks that the participants read a project information sheet prior to checking five consent boxes that confirm that participants: (i) have read the information sheet and asked any questions they may have, (ii) understand that participation is voluntary and they can withdraw at any time without consequences, (iii) understand that they will be asked to use a smart plug that can be remotely switched off and on, that we may observe electricity usage, and that that they give permission for us to use this data and to contact them via the email address they provide; (iv) understand the compensation arrangements, and (v) agree to take part and allow the research team to switch off their plugs briefly from time to time.
Account or profile data: When you register an account with us, we may collect your name and contact details, such as your email address, mailing address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect and integrate your nickname, profile picture, country code, language preference, or time zone information into your account.
Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number, and your feedback content to address your problems and solve device failures on a timely basis.
Device information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
Data usage: During your interaction with POWBAL’s Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
Location information: We may collect information about your real-time precise or non-precise geo-location when you use our specific products or services.
Smart devices related information: When you use Smart Devices that are connected to our Services, depending on the capability of your Smart Devices, we may collect certain types of your usage data in order to provide services you have requested or purchased.
Basic information of smart devices: The basic information may include device name, device id, online status, activation time, firmware, and upgrade information.
Information reported by smart devices: When you use our products we may collect different information reported by your devices. For example, the POWBAL smart plug will collect electricity consumption data.
Lottery related information: If you consent to participate in our lottery, or contest; you may be able to win rewards in the form of e-vouchers. As such we will collect data about your energy consumption through the POWBAL Plug so that we may include you in our rewards programme.
The purpose for which we may process information about you are as follows:
Improve Our Services: We process your device information, usage data, location information, and Smart Device related information to continually review and upgrade the functions and safety of our Products, to develop and improve our Products and Services, to analyse the efficiency of our operations, and to prevent fraudulent or inappropriate usage.
Conduct academic research and provide insight: We will analyse POWBAL user data to provide high level insights into the behaviour of energy consumers. Any data that may be shared with open or restricted access (e.g. using the UK Data Service) for the purposes of research replication will be de-identified.
Marketing Communication: We may process your personal data to provide marketing and promotional materials to you on our Products and Services where you have consented. If we do, each communication we send you will contain instructions permitting you to opt out of receiving future communications of that nature. Additionally, if you consent to participate in our lottery, or other promotions, we may use your personal data to manage such activities.
Personalisation: We process your account and profile data, usage data, device information to personalise product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products.
Legal Compliance: We may process your personal data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We respect your rights and control over your personal data. You may exercise any of the following rights by emailing us at email@example.com. You do not have to pay a fee and we will aim to respond you within one calendar month. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your personal information deleted from our database or otherwise let us know what limitations you would like to put on our use of your personal information. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes. You may: • Request access to the personal data that we process about you; • Request that we correct inaccurate or incomplete personal information about you; • Request deletion of personal data about you; • Request restrictions, temporarily or permanently, on our processing of some or all personal data about you; • Request transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and • Opt out or object to our use of personal data about you where our use is based on your consent or our legitimate interests.
Withdrawal Criteria You may choose to withdraw from the study at any time without penalty or consequences of any kind. If you decide to withdraw from the study, you must immediately notify us by emailing firstname.lastname@example.org. If you choose withdraw from the study, you will be asked if we may still use your personal data. If you choose to withdraw your consent to utilize this data, we will delete your personal data from our files.
POWBAL provides various security strategies to effectively ensure data security of user and device. As for device access, POWBAL employs strong passwords and encryption keys to ensure data isolation, and access authentication. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by emailing email@example.com. All the data published for academic research will be anonymised and meticulously de-identified.
We process your personal data for the minimum period necessary (and no longer than 7 years) for the purposes set out in this Privacy Notice, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your personal data, and after the retention period ends, we will destroy your personal data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your personal data.
We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes, we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
This policy is formulated in accordance with the laws of England & Wales.
If you have any questions about our practices or this Privacy Notice, you may contact us at firstname.lastname@example.org or at our postal address below. If you wish to raise a complaint on how we have handled your personal data please contact Imperial College London’s Data Protection Officer via email at email@example.com, via telephone on 020 7594 3502 and via post at Imperial College London, Data Protection Officer, Faculty Building Level 4, London SW7 2AZ.
If you are not satisfied with our response or believe we are processing your personal data in a way that is not lawful you can complain to the Information Commissioner’s Office (ICO). The ICO does recommend that you seek to resolve matters with the data controller (us) first before involving the regulator.
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