Privacy Statement

Napoleon Home - Mobile Application

Data Protection Declaration

We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our application. Personal data is all data with which you can be personally identified.

The joint controller in charge of data processing on this website and mobile application, within the meaning of the General Data Protection Regulation (GDPR), is:

The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

Wolf Steel Ltd. (“Napoleon”, “we”, “us”, or “our”) provides a software platform to end-users (hereinafter, “you” or “your”) to connect their products with the cloud. Napoleon recognizes that your privacy is important, and we take it seriously. This privacy policy does not apply to the products of our business partners or to any third party, even if their websites are linked to our website, or if their offerings are used in connection with our products.

This privacy policy describes Napoleon’s privacy practices as it relates to the use of our products and services, as well as your choices regarding use, access and correction of personal information.

We may change this policy from time to time. We advise you to regularly check this page for updates, so you will be fully informed.

Children's Privacy

Protecting the privacy of young children is especially important to us. Our products are not directed at individuals, and particularly any individuals under the age of sixteen (16), and we request that these individuals do not provide any personal information to us. We do not knowingly collect personal information from anyone under the age of sixteen (16) unless we first obtain permission from that child's parent or legal guardian. If we become aware that we have collected personal information from anyone under the age of sixteen (16) without permission from that child’s parent or legal guardian, we will take steps to remove that information immediately.

Information Collected From Use of Our Napoleon Home Products

Information is collected through a cloud platform and through services associated with the internet of things and device management. Information collection and storage is done through a third party, Ayla Networks Inc. (“Ayla Networks”). If you request that personal information, be deleted from the systems, Napoleon will ensure such information is deleted in accordance with applicable regulations and when Napoleon confirms that the request is valid. Deleting information from our systems may mean that your device may no longer connect to a cloud and may no longer function as advertised.

For a device to connect to the Napoleon Home Platform, a user will need to provide an email address, country, approximate location, and password – this is the only information that we require to enable connection to your product. Once a device registers to connect to our cloud platform, we will have access to the approximate location (based on the IP address) and Wi-Fi network name of the IoT connected device. We may have access to other personal information, depending on the optional fields that are provided by you. Third parties that Ayla Networks contracts with may have access to such information. In these cases, Ayla Network agreements require these third parties to act in accordance with relevant privacy laws.

This table provides an example of information that may be collected by using our products. 

Information collected:

• Email address
• IP address
• Wi-Fi network name
• Napoleon connected devices
• Approximate location of Napoleon connected devices
• Device and Sensor Data
  • Temperature readings
  • Power level
  • Tank weight
  • Other sensor values necessary for device operation.
• Functional Data
  • The change in a device setting or function such as target temperature, alerts, timers, schedules, temperature unit, etc.

Optional information:

• First name
• Last name
• Any relevant information you choose to share with Napoleon

Data processing is carried out in accordance with Art. 6 (1) point of GDPR based on our legitimate interest in improving the stability and functionality of our products and applications. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

We will provide you with specific information about data collected if you request and upon our verification of the request. 

Data Storage, Volume and Frequency

Each device usage session generates small datasets, typically ranging from 0.5 MB to 10 MB.

• Data generation occurs both continuously and periodically, depending on context:
• Continuous: Sensor data while the device is in active use (e.g., temperature readings).
• Periodic: Data collected at regular intervals while idle, or external information such as weather data.
• Data is stored on the device temporarily and stored remotely for a duration ranging from a minimum of 30 days to a maximum of 3 years. Data is in JSON/CSV formats and in servers located within Canada, the EEA or in jurisdictions ensuring equivalent data protection guarantees.
• Deleting an account directly on Napoleon Home deletes the user’s personal information and links to any device data. The device may continue generating data for operational use and will only transmit data if connected to the internet. After account deletion, data generated by the device is no longer associated with any user or account, and therefore constitutes non-personal, operational data outside the scope of GDPR.

We will provide you with specific information about data collected if you request and upon our verification of the request. You may request a copy of the data generated via account tools or customer support.

Your Choices About Your Information

You can make changes to the information sent through our products, including the deletion of personal information, by emailing [email protected] or [email protected]. We will make the changes as requested once we have confirmed that the request is valid but note that these changes may affect the functionality of the connected device. Please note that we may deny your request to delete personal information if we need to maintain such information in order to (1) complete a transaction that began before we received the deletion request; (2) detect any security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for these activities; (3) debug products and to identify and repair errors that impair functionality of our cloud platform; (4) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law; (5) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.); (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent; or (7) comply with a legal obligation; (8) Comply with GDPR laws and regulations.

We may keep certain information in an aggregated or anonymized form that does not personally identify you and cannot be connected to you. We will keep information that is required to be retained under law.

How Your Information Is Used

We may use your personal information:

1. To create an account if you register with us.
2. To provide our products and services.
3. To provide support in connection with the use of our products.
4. To respond to inquiries, including by law enforcement or other authorities.
5. To send you important information and notices regarding our products and services, changes to agreement terms, changes to policies and other administrative matters.
6. To understand product usage for the purpose of continuous product improvements.

Except to the extent prohibited by law, we may store and back-up personal information within databases located within and outside Canada and the EU.

Sharing Information

We use information that is sent to us to provide our services. We do not sell personal information collected. We might use third parties to improve or assist in the provision of our services, and they might receive personal information, such as an IP address and contact information. 

Rights, Questions and Complaints

Regarding personal data applicable to you which we have stored, you have, amongst others, the following rights:

• The right to be informed of the nature of the personal data and the way we use it.
• The right to access it.
• The right to correct any errors therein.
• The right to cause us to erase it, subject to any legal obligations we have.
• The right to retract permissions given.
• The right to object to certain kinds of (automated) processing and decision making.

If you wish to exercise one of these rights or have questions or complaints about this policy, please contact us at the coordinates indicated at the top of this policy. If your wish is to exercise a right, please clearly demonstrate your identity.