Privacy Statement

Napoleon Home - Mobile Application

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 update this privacy policy from time to time.

Children's Privacy

Protecting the privacy of young children is especially important to us. Our products are not directed to individuals, and in particular any individuals under the age of thirteen (13), 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 thirteen (13) 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 thirteen (13) 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.

In order for a device to connect to the Napoleon Home Platform, a user will need to provide an email, country, and password – this is the only information that we require to enable connection to your product. Once a device connects 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 through the use of our products. 

Information collected:

  • Email address
  • Password
  • Power status
  • IP address
  • Wi-Fi network name
  • Data sent from device, such as temperature
  • The change in a device setting or function

Optional information:

  • First name
  • Last name

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

Your choices about your information

You can make changes to the information sent through our products, including the deletion of personal information, by calling Napoleon at +1 (866)-820-8686. 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. 

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 product 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 of the United States.

Sharing information

We use information that is sent to us in order 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.