Privacy Policy – HERZ clever&smart App

Effective date: September 15, 2025

HERZ Armaturen Ges.m.b.H. (“HERZ,” “we,” “us”) respects your privacy. This Privacy Policy explains what data the HERZ clever&smart App processes, for what purposes, on what legal basis, and how you can exercise your rights.

Data Processed in the App

• Account data (email address)
  • Purpose: To create and manage your account and enable remote access to devices.
  • Legal basis: Art. 6(1)(b) GDPR (contract).
  • Retention: Until the account is deleted.
  • Sharing: With service providers for hosting and support.
• Diagnostics (crash logs, performance data, error events)
  • Purpose: To ensure and improve reliability.
  • Processing: Stored locally on the device; only transmitted if the user explicitly sends the data to support via email.
  • Legal basis: Art. 6(1)(b) GDPR.
• App activity (non-content events such as onboarding steps, feature toggles)
  • Purpose: To provide core functionality and troubleshoot issues.
  • Processing: Stored locally; only transmitted if the user explicitly sends the data to support.
  • Legal basis: Art. 6(1)(b) GDPR.
• Nearby devices / Local network / Wi-Fi
  • Purpose: To detect and connect to HERZ devices within the local network.
  • Note: Data remains on the device, except where remote access is explicitly used.
  • Legal basis: Art. 6(1)(b) GDPR.
• Location
  • Purpose: The App does not collect location data.
  • Exception: The operating system may require approximate location permission for Bluetooth/Wi-Fi onboarding. In such cases, location data is not stored or shared.
  • Legal basis: Art. 6(1)(b) GDPR.
• Advertising
  • No advertising.
  • No sale of personal data.

Third-Party Processors

We use external service providers to host and manage accounts. These providers act only under contract and with appropriate safeguards (including Standard Contractual Clauses for transfers outside the EEA).

Account and Data Deletion

• In-App:
  Settings → My Account → Delete account.
• Web:
  https://www.sorel.de/delete_account.php — submit a deletion request without reinstalling the App.

After verification, we delete the account and associated personal data automatically, unless retention is required by law. Deletion happens immediately.

Your Rights

Under GDPR, you have the right to:

• Access your stored data,
• Rectify inaccurate data,
• Erase your data,
• Restrict processing,
• Data portability,
• Object to certain processing.

If processing is based on consent, you may withdraw consent at any time with effect for the future.

You may lodge a complaint with the Austrian Data Protection Authority.

Security

We apply appropriate technical and organizational measures in line with Art. 32 GDPR to protect your data against loss, misuse, and unauthorized access.

Changes

We may update this Privacy Policy from time to time. The latest version with a new effective date will always be available in the App or at the published URL.