Owner Confidentiality Notice

At Greta, we are committed to providing you with the security that your personal data is protected and never misused.

This privacy notice explains what personal data we collect, why we collect it, how we use it, the control you have over your personal data and the procedures we have implemented to protect it.

Who is responsible for your personal data?

Greta is responsible for the personal data we hold about you. We are a international organisation, present in many countries.

In this notice, when we refer to "Greta", "we", "us", "new" or "our", we mean Greta Technologies LLC and its affiliates who provide you with Greta connected websites, applications or products or who are responsible for stores, stands or events in your country.

How to contact us

Information about the Greta company that holds primary responsibility for the personal data collected about you and also how you can contact us is available on the Contact page.

Personal data we collect about you.

It is not necessary for us to collect all personal details about you. Our primary reason for collecting your personal data is to provide and improve the services, products and experiences you and our customers expect from us.

Personal data has slightly different definitions worldwide. To ensure the privacy and protection of your information, we define it as any information that could be used to identify you or another person.

We collect personal data about you in a variety of ways, including:

Information you communicate to us via our website or apps, by email or phone, in person at our stores, booths and events or otherwise.
Information from your products Greta connected - products that are 'smart' or 'intelligent', enabled by the internet.
Information from your online interactions through cookies and similar tracking technologies
Information from your communications (such as emails and live chats, and information about how you have engaged with the emails and app communications we have sent you.
Publicly available information from your interactions with us on social media or from posts about us
Information from our shops, stalls and/or events - such as CCTV footage, videos and photographs.
Information obtained through the Bluetooth or WiFi connection of your smart device when you visit our stores - such as your location.
Information from third party data providers to whom you have granted permission to share your data.

Categories		Example
Personal data		Name, email address, delivery address, IP address, cookie ID, login information and information about your device (e.g. ID or IMEI number).
Order information		Order number, Product(s) purchased, payment information, delivery records.
Internet activity		Information from online tracking technologies (e.g., cookies that indicate which areas of our website you spent more time on than others)
Geolocation data		If you connect to Greta Wi-Fi in one of our stores, we will know that your smart device is in our store at that moment. Greta uses location services for connectivity to allow pairing a Greta product with our app via Bluetooth or WiFi. Please note that Greta does not collect location data as a result of this connection.
Preference data		Information such as your marketing options, home, allergies and interests, and what appeals to you most about Greta (e.g., through your account. Greta or in response to voluntary surveys or through the Greta app).

If you share your details with us with other people (for example, if you have purchased a Greta product for another person or if you register another person for the Greta app), then you will need to check with that person whether they agree to share their personal data with us and use it through this privacy notice.

Also, Greta websites, apps and products are not aimed at children. Where we knowingly collect and process children's data, appropriate information about such processing will be provided at the time of collection. At the time of data collection, the consent of the parent and/or legal guardian will be obtained as required.

How and why we use your personal data

Our primary reason for collecting and using your personal data is to provide and improve the services, products and experiences you expect from us. This section details how we use the data we collect directly from you or indirectly from third parties, such as our retail partners.

Please refer to us for further information on how we collect personal data.

In order to provide you with our products and/or services Greta needs your personal data for ordering, payment processing and product delivery coordination.

This processing includes:

managing and coordinating the purchase, delivery and after-sales service of your products (as required);
respond to your questions and requests (through various channels, such as online, in person, by phone, posting, live chat and SMS);
documenting, monitoring and recording the lifecycle of our products, including product inventory management; and
to contact you when certain products or models are about to be returned to stock.

In order to provide support for the products and/or services you have purchased on a regular basis, we use your personal data to provide you with assistance with Greta products you own. If you have a connected product, please visit the website for information specific to your product.

We do this by monitoring the performance of your product and sending you relevant product support communications. You can opt out of these activities at any time; see the section below entitled "Monitoring methods and your options".

If you have the MyGreta app, we monitor the performance and stability of your product, which allows us to:

To optimise its performance and your experience with the product: in particular, we want to be able to identify when there may be a problem with your product, so that we can inform you as soon as possible (sometimes we can do this before the problem becomes apparent); and
we provide updates and services for our connected products (which includes updates and upgrades for the software in the product and the application that connects to it).

If we send you product support communications, this allows us to:

we offer you useful information about your product. Greta or about the Greta service you use, for example:
- essential product support updates;
- reminder messages on how to perform maintenance operations for optimal performance;
- notifications for recommended updates or upgrades to your application or software that we believe will improve the performance of your product.;
- information on how and where to get help from Greta experts if you need assistance;
- information about your guarantee. Greta; and
- notifications of any important safety announcements or product recalls; and
to provide an enhanced owner experience through new technologies such as our mobile apps.

As part of these activities, we combine different categories of personal data that we collect about you. For example, we combine personal data resulting from your online interactions, information you communicate to us, or information obtained from Greta products, for profiling and statistical analysis of the popularity of our products, your behavior when using our website or applications, or how our products are used.

In order to improve our products, services and customer experience we collect personal data to gain insight into areas where we can make improvements to our products, services and customer experience. We collect this personal data from your connected products, through the Greta Link app or directly from you through your online feedback and interactions.

If you have the Greta Link application installed, we monitor your use of our connected products for the following purposes:

to improve our products, technology and services in general; and
to monitor your use of our connected products so that we can optimize their performance and your experience of using them.

Our customers are at the heart of everything we do. To ensure we provide the best possible service, we process your feedback and preferences by:

customer satisfaction surveys, to enable us to identify where improvements can be made to our services and products, and to enable us to improve your experience if you need assistance from one of our experts; and
your online interactions, independently and in combination with other personal data we collect about you, to identify any part of our websites or apps that is not working properly, so that we can remedy the situation and make our websites and apps better for you and other users.

Greta uses the best available technology to process and protect your data, which includes, in limited cases, the use of artificial intelligence (such as machine learning). For example, we use artificial intelligence technology in the real-time chat function on our website to provide answers to frequently asked questions without having to wait for a customer service agent to become available.

Please note that Greta does not make any decisions involving the use of algorithms or profiles that would significantly or legally affect you.

How long do we keep your data?

We keep your personal data only for as long as necessary to use it for the purposes set out in this privacy notice and for as long as we are required to keep it by law.

The actual period we store your personal data will vary depending on the type of personal data and how it is used. For example, when you buy a product from us, we will store information about you and your purchase for at least the duration of your warranty.

To keep you informed

We like to keep you informed, whether it's about the latest product announcements, offers for owners, opportunities to test new Greta products or upcoming events.

Ultimately, we want to make sure you are happy with the communications you receive from us. We do this either by giving you the opportunity to opt-out (e.g. service emails) or by asking you to subscribe (e.g. consent to marketing emails). See the section entitled "Your orders and choices" for further information.

analysing and improving the information we collect;
creating user profiles, reports and targeted advertising;
including you only in selected marketing campaigns and certain event invitation lists.
measuring the effectiveness of our promotional and advertising campaigns; and
personalize and improve the way you shop and interact with us in the future (for example, by linking what you see on our site to topics you have previously been interested in).

To promote Greta, our products and services, we often organise Greta events in a variety of locations, such as Greta stores or other shopping centres. By participating in these events, your personal data may be collected:

as part of photographs or footage taken for publication on social networks, for the creation of promotional material or for archiving purposes;
by our experts and stylists, for sharing on social media or in promotional materials; and/or
to set up an appointment with one of our experts.

To protect Greta and our customers Greta may process some of the personal data you provide for the following additional purposes:

to detect and prevent criminal activity, including fraud;
to maintain the security of our websites, applications, products and IT systems;
to provide assistance in the event of disputes, claims or investigations related to your product or warranty. Greta;
to comply with our legal obligations; and/or
to provide you with updates on significant changes to Greta's policies, terms and conditions and any other matters we may need to inform you about;

What is our justification for handling your personal data in this way?

Data protection and privacy laws in some countries require us to have what is called a "lawful basis" or "legitimate ground" for processing personal data. In general, this means that we must have a legal justification for processing your personal data.

To process your data, we will mainly use the following legal grounds:

Contract - for example, we need to process your delivery and payment details in order to provide you with the product you have purchased
Consent - for example, we will send you marketing communications if you have given your consent
Legitimate interests - for example, we will process your order information to detect fraudulent activity and protect Greta and our customers.

In some situations, it may be necessary for us to process your personal data in a certain way in order to fulfil our legal obligations; for example, if a regulator or law enforcement authority asks us for your personal data.

The ultimate reason why we process your personal data in the way we do is to be able to directly or indirectly improve our products, services and also your overall experience of Greta. Regardless of our justification for handling your personal data, we ensure that we take steps to honour our commitment to protect your privacy.

Sharing and transferring your personal data

Most importantly, we will never sell your personal data to anyone and will only share it as described in this privacy notice or when you request us to do so.

Sharing within the Greta Group

Most of Greta's processes, procedures and systems are shared within the Greta Group, which means that we have to share your personal data with each other. We make sure that access to your personal data is limited to our employees who need it and that all our employees understand how and why we protect your personal data. Transfers of personal data between Greta entities (including those outside the EEA) are governed by the Greta Group-wide Agreement.

Sharing with third parties

We share your personal data with certain external service providers. They only have access to the personal data they need to provide those services. For example, order and delivery details will be shared with our courier companies. They are obliged to maintain the confidentiality of your personal data and must not use it in any way other than as requested and must also always act in accordance with this privacy notice.

Third parties providing services fall into the following categories:

distributors who help us sell our products in certain countries;
those who help us deliver products to you;
Those who help us provide you with relevant and interesting communications (e.g. social media platforms, analytics companies, marketing and advertising agencies);
Third parties who help us with shipping services, service and repair operations for products, processing product purchases, financial services, audit services, administrative services, IT technologies (e.g. data storage), security services and compensation claims; and
third parties who help us provide services and responses to you.

We share certain personal data with third parties to help us detect and prevent unlawful activities (such as fraudulent transactions). The information we share with those third parties includes some of the information you share with us (such as your contact information and transaction information) and some of the information that results from your online interactions (such as the IP address of your device). This information is used to determine whether a transaction may be fraudulent. One of the external companies we use to help us identify and prevent fraudulent transactions is Riskified; it is responsible for the use of your personal data and will use it for the purposes set out in its privacy notice.

We will also share your personal data if we are required to do so by law, including in response to a legal action, such as a court order or subpoena, or to comply with other national, state, provincial or local laws.

Also, in the process of purchasing a Greta product, you may interact with a third party who will be independently responsible for the personal data you provide. For example, if you purchase a Greta product under a funding agreement, that agreement will be entered into directly with that third party and you should read their separate privacy notice(s).

Data transfers, storage and global handling of your personal data

The relevant company or companies within the Greta Group will collect personal data from you in the country in which you reside. We, together with third parties to whom we transfer your personal data, host, then store and process that information in Romania, European Economic Area (EEA) countries or any country outside the EEA, including those specified on the Contacts page.

We will ensure that any transfers of your personal data from one country to another comply with the data protection and privacy laws that apply to us.

In particular, European data protection laws include specific rules on the transfer of personal data outside the EEA. When transferring personal data outside the EEA, we will:

include standard contractual data protection clauses approved by the European Commission for the transfer of personal data outside the EEA in our contracts with those third parties; and.
ensure that the country in which your personal data will be processed has been deemed "adequate" by the European Commission; or.
Ensure that a risk assessment has been carried out for the transfer of data.

However, the transfer, storage and handling of your personal data will continue to be governed by this privacy notice.

Interaction of connected products with third-party products

We may add functionality to some of our connected products that allows your product to interact with third party products. Greta to interact with certain third-party products you have in your home (such as Amazon Echo, also known as Alexa, etc.). This functionality allows you to take full advantage of the features of a "smart home". However, products will only interact if you want them to, by enabling the relevant functionality.

If you choose to allow your Greta connected product to interact with a third party product, certain information (including potential personal data) will need to be shared with the third party product and the relevant third party provider. In general, we will need to communicate a unique reference number to connect the two products, as well as information about your product and how you use it. We share only the minimum amount of personal data we need to allow the two products to interact. The details of how the external entity uses your personal data (and any personal data it collects through its own product) are set out in the third party privacy notice. You should carefully review the privacy notice(s) of external entities before using their products and before connecting them with your Greta connected product. You can prevent the Greta connected product from sharing information with the third party product at any time by disabling the connection between the two.

Links to third-party sites

We provide links to other websites that are not operated and controlled by Greta. We have no control over the content of these websites and are not responsible for their content or for the manner in which third parties responsible for them collect and use your personal data. We do not endorse or make any representations about third party websites.

Third party websites usually have their own privacy notices that explain how they use and share your personal data. You should review these privacy notices carefully before using these websites to ensure that you agree with how your personal data is collected and shared.

Control methods and your options.

To the extent possible, we give you control over the personal data we collect about you to ensure that it is accurate and reflects your preferences. You have the right to access, update and amend the personal data we hold about you; you can do this in relation to some of your personal data in your account Greta.

We will only send you marketing communications when you have indicated that you agree to do so. If you have previously indicated that you would like us to contact you ("opt-in"), but would like to change or update how we do so, you can update your preferences:

By contacting Greta Customer Service and indicating that you would like to change or update the way we contact you;

Logging into your account on our website and changing your preferences and information.

In certain circumstances, you also have the right to ask us:

to stop the use of your personal data for certain purposes;
limit or restrict the use of your personal data;
delete or remove personal data about you; or
disclose your personal data to an external service provider.

For example, you have the right to object to the monitoring of your use of our connected product websites and applications, and how you interact with our promotional campaigns and online advertising.

Please note that these rights do not always apply and there are certain exceptions to them.

If you or an entity authorized to act on your behalf wishes to exercise any of your rights in relation to your personal data, please send an email to privacy@greta.eu or call your local Greta center using the information on the Contacts page. We will send you a link to our privacy portal, using the contact details you provide, where you will be invited to provide additional information about your request and receive further details about how we will process this request.

We will also need to confirm your identity before we can process certain requests. We may not be able to respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request on behalf of someone else.

We will inform you if the law in your country allows us to impose a fee to provide you with access to your personal data or to exercise any of your other rights in relation to your personal data. You will not be subject to any discrimination because you have exercised any of your rights.

How do we protect your personal data?

We are committed to protecting your personal data. We apply appropriate technical and organisational measures, including encryption, to protect your personal data and privacy, and review them regularly. We protect your personal data by applying a combination of physical and IT security controls, including access controls, that restrict and manage how your personal data and data in general is processed, managed and handled. We also ensure that our staff are adequately trained in protecting your personal data. Our procedures involve occasionally requesting documents to prove your identity before we disclose your personal data to you.

If we have given you (or if you have chosen) a password that allows you to access a portal or an account, you are responsible for keeping the password confidential. Please do not share your password with anyone.

In the unlikely event that we encounter a security breach that compromises the protection of your personal data and we need to notify you about it, we will do so.

Changes to this Privacy Notice

We will periodically review and update this privacy notice. This privacy notice was last reviewed and updated in January 2024. If we change our privacy notice in a way that significantly affects how we process personal data we hold about you, we will also ask you to confirm that you accept these changes by the most appropriate method (for example, by email or by a notice on our website).

Translations of this Privacy Notice

This privacy notice has been translated from English into the official language of several countries. We have done this to ensure that the notice is clear and accessible to all users. If there are any contradictions or inconsistencies between the translated versions of this Privacy Notice, the English language version will prevail.