This Privacy Policy describes how TP-Link UK Ltd, a company registered in England and Wales (company number: 07205003) whose registered office is at Units 2 & 3 Riverview, Cardiff Road, Reading, Berks RG1 8EW (“we”, “us” and “our”) look after your personal data when you visit our website (https://uk.store.tapo.com/ - our “Site”) including when you purchase goods from our Site. We are the data controller and we are responsible for your personal data.

Our contact details are set out below under ‘Contact Details’

Collecting Personal

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose:shared with our processor Shopify.

Order

• Examples of Personal Information collected:name, billing address, shipping address, payment information (including payment card details, email address, and phone number).
• Purpose of collection:to provide products or services to you to fulfil our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

• Disclosure for a business purpose:shared with our processor Shopify.

Customer support information

• Examples of Personal Information collected:name, email address, and phone number.
• Purpose of collection:to provide customer support.
• Source of collection:collected from you.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Using Personal Information

We use your personal Information to provide our goods or services to you, which includes: offering products for sale, processing payments, shipping and fulfilment of your order, and keeping you up to date on new products, services, and offers.

• We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into, with you.
• Where it is necessary for our legitimate interests (or those of a third party such as a Third Party Provider) and your interests and fundamental rights do not override those interests.
• Where it is necessary to comply with a legal obligation, or to establish, exercise or defend legal claims.
• Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfil our contracts with you, as described above. For example:

• We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfilment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation and UK General Data Protection Regulation (“UK GDPR & DPA”), if you are a resident of the resident of UK, we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

After you close your account with us we will keep your personal information for a reasonable period to maintain our records and legal obligations to you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for scientific or historical research or statistical purposes, in which case we may use this information indefinitely without further notice to .

For more information on your right of erasure, please see the ‘Your rights’ section below.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and data protection legislation.

We have put in place procedures to deal with any actual or suspected personal data breach and will notify you and any applicable regulator of a breach where appropriate and in any event, where we are legally required to do so.

Automatic decision-making

If you are a resident of the UK, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

Your rights

GDPR

If you are a resident of the UK, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. 

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. 

Under certain circumstances, you have rights under data protection laws in relation to your personal information as following:

• Request access to your personal information.
• Request correction of your personal information.
• Request erasure of your personal information.
• Object to processing of your personal information.
• Request restriction of processing your personal information.
• Request transfer of your personal information.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details provided in paragraph 1 of this privacy policy.

Children's Privacy

Our Products and Services are not directed to, or intended for, individuals under the age of 16 and we do not knowingly collect personal information from individuals under the age of 16. If you believe that we have any such information, please notify us immediately and we will delete the information as quickly as possible.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. Historic versions can be obtained by contacting us.

Contact Details

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us at  contact us page.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.