Milex Smart Privacy Policy

Homemark (PTY) Ltd. and its Affiliates (as hereinafter defined) (“we”, “us”, “our”, or “Homemark”) are committed to protecting your privacy. Milex Smart Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data (as hereinafter defined) we process through your use of our products and services (collectively, the “Services”), for instance, the Milex Smart Mobile Application (the “App”)

Before you start using the Services, please carefully read this Policy which details our purposes for collecting and processing your Personal Data, as well as how we use, store, share and transfer your Personal Data. In this Policy, you will also find ways to exercise your rights to access, update, delete or protect your Personal Data.  

If you have any questions regarding this Policy, please do not hesitate to contact us via

Homemark Customer Service Department: 011 444 8800 or info@milex.co.za

You are not obliged to provide us with your Personal Data (as defined below). However, we may be unable to provide you with certain products and/or Services if you decline to provide such data.

 Definitions

In this Policy:

Affiliate means any company, firm or legal entity that:

(1) is directly or indirectly controlled by Homemark; or

(2) directly or indirectly controls Homemark; or

(3) jointly with Homemark, controls the same company; or

(4) is, directly or indirectly, under common control of the same company as Homemark. Affiliates shall include, without limitation, Homemark’s parent companies, subsidiaries, and such subsidiaries under common control of the same parent company as Homemark.

Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone or from that information and other information we have access to about that individual.  

Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information, etc. according to various data protection laws and regulations. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collect personal sensitive data about you.

Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with a human-machine interface and the ability to transmit data that connect wirelessly to a network, including smart home appliances, smart wearable devices, smart air cleaning devices, etc.

1. What Personal Data Do We Collect?

In order to provide the Services to you, we will ask you to provide the necessary Personal Data that is required to provide those Services. If you do not provide your Personal Data, we may not be able to provide you with the Services.

1) Information You Voluntarily Provide to Us

• Registered Account Data: When you register an account with us, we may collect your account name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with the Services, we may further collect your nickname, country code, language preference or time zone information into your account.

If you authorise login to the Services with a third party account, we will obtain from such third party your account information (such as portrait, nickname, region etc.) which may be bound with your Milex account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentation agreed with such third parties regarding sharing personal information, in processing your Personal Data.

However, if the Services you request or purchase are based on your account, please go to the registration/login page for guidance.

• Feedback: When using feedback and suggestion features in the Services, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

Information based on additional functions:

In order to offer you more convenient and higher-quality Services with optimised user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use the basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:

Additional functions based on location information:

When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing them with your Smart Devices. Also, we may collect information about your
a) real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Device, or
b) non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaners and weather service.

Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details. You may disable the collection and use of your location information by managing the device level settings, upon which we will cease to collect and use your location information. 

You may opt out of the use of location information: "My - Setting - Privacy Right Setting - Switch on/off Location Information"

Additional services based on camera:

You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.

You may opt out of the use of camera permission: "My - Setting - Privacy Right Setting - Switch on/off Camera"

Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):

You can use this function to upload your photos/pictures/videos after turning on the photo album permission, so as to realise functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.

You may opt-out of the using of photo album permission: "My - Setting - Privacy Right Setting - Switch on/off Photo Album"

Additional services related to microphone-based service:

You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognize your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App.

You may opt out of the use of microphone permission: "My - Setting - Privacy Right Setting - Switch on/off Microphone"

Additional services based on storage permission (Android):

The purpose is to ensure the stable operation of the App by utilising the storage permission. After you give or indicate permission to read/write your mobile device’s storage, we will access pictures, files, crash log information and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.

You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switch on/off Storage"

Additional services based on Notification permission:

The reason why we ask you for permission is to send you notifications about using the products or services, especially if you have purchased security services and you require an alert or message so that you can capture the real-time status.

You may opt-out the using of App notifications: "My - Message Center - Setting - Switch on/off Notifications"

Additional services based on Alert Window permission：

If you choose to bind a camera in the App and you require the App to display the real-time image of the camera in a separate window.

You may opt out of the use of navigation information: "My - Setting - Privacy Right Setting - Switch on/off Alert Window".

Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning on the permission, including control of the Smart Device, acquiring device status, device discovery, and device network configuration. In these functions, we will communicate with terminal devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display the device status on the home page and Smart device panel; perform device control on the home page and device panel; we would use it on the home page and the add device page for discovering equipment, equipment distribution network.

You may opt out of the use of Bluetooth via "My - Settings - Privacy Setting - Disable/Enable Bluetooth permission".

Additional services based on HomeKit permission (iOS):

You can enable related functions after enabling HomeKit permissions, including discovering Smart Device, enabling Smart Device network configuration, controlling Smart Device, and checking device status. Among these functions, we will process data with the "Home“ App that comes with the iOS system through HomeKit. Please be aware that even if you have agreed to enable the HomeKit permission, we will only use it in these scenarios: on the home page, to discover HomeKit devices, HomeKit device network configuration; in "Settings - HomeKit" for discovering HomeKit devices, HomeKit device network configuration.

You may opt out of the use of Homekit permission via "My - Settings - Privacy Settings-Turn off/on HomeKit permission".

Additional services based on HealthKit (iOS):

You can proactively enable related functions after enabling HealthKit permission, including statistics on weight, height, running, and swimming. In these functions, we will exchange data with the health-related functionalities that come with the iOS system through HealthKit. Please be aware that even if you have agreed to enable HealthKit permission, we will only use them in these scenarios: when you use the health-related Smart Device, such as body fat scales, bracelets, watch and consent to use the HealthKit, the data reported by the Smart Device will be transferred to HealthKit.

You may opt out of the use of HealthKit permission via "My - Settings - Privacy Settings - Turn off/on HealthKit permission".

Please note that if you turn on any permission, you authorise us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as a cancellation of the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect the previous collection and use of information based on your authorization.

2) Information We Collect Automatically

• Mobile Device Information: When you interact with our Services, in order to provide and maintain the common operation of our Services, improve and optimise our Service, and protect your account security as well, we automatically collect mobile device information, such as mobile device model number, IP address, wireless connection information, the type and version of the operating system, application version number, push notification identifier, log files, and mobile network information. Meanwhile, we will collect your software version number. In order to ensure the security of the operating environment or to provide services, we will collect information about the installed mobile applications and other software you use.
• Usage Data: During your interaction with our websites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usages of our websites and Services.
• Log Information: When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, preferred language setting, operating system version, and date or time of access, so that we can facilitate and accurately identify problems and help you solve them in a timely manner.

Please note that one cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate or desensitise such information.

3) Smart Devices Related Information:

When you use a Smart device, we will collect some basic and pre-embedded information about the Smart Device and the information generated during your use of the Smart Device.

• Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
• Information collected during the process of connecting to a Smart Device: Based on the type of Smart Device you need to connect, whether the Smart Device is connected via Wi-Fi, via Wi-Fi after establishing a local connection via Bluetooth, Bluetooth or via Zig-bee, we will collect the Mac address of the smart device.
• Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with the Services, we may collect different information reported by your Smart Devices. The following information reported by the Smart Device only applies when you use them:
• When you voluntarily use a smart camera (IPC service) and connect to the Milex platform: When you connect a doorbell camera, a door lock, or a smart surveillance camera through Milex service to monitor the security of your residence, during the process, the device may capture the images if it recognizes someone or an object is moving around, and then provide you playback of related surveillance content. At this time, we will automatically encrypt the captured image and save it locally on the device. When you actively choose and successfully purchase a cloud storage service, the smart camera will upload the pictures or video files you have taken to the cloud for further storage so that you can review them on the App. We will keep your information based on the cloud storage service you purchase. When you choose to delete the picture in advance in the Milex Smart App, you can delete it in the message centre and if you need to delete a video on the App, the cloud will respond to delete immediately the video files you stored in the cloud service.

2. Purposes and Legal Basis for Processing Personal Data

The purpose for which we may process information about you is as follows:

• Provide You Services: We process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our
• Improve Our Services: We process your mobile device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyse the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our User Agreement.
• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, policies and/or other administrative information. At the same time, we will also send you notifications related to the services you have purchased, such as alert services. You can check the “App Notification” in the App ("Me > Message Center > Setting > Notification Setting”) to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such a purpose. The legal basis for this processing is to perform our contract with you according to our User Agreement.
• Data Analysis: In order to analyse the usage of the products we provide and improve your user experience, we will analyse the data you provide us,
  a) we need to check your problems when you encounter any malfunctions during the usage of the product, under such circumstances, you may not be able to opt-out because it is highly related to your functionalities and quality of using our product and service, and
  b) analyse data about how you interface with the product or under particular scenarios so that you can better enjoy the convenience brought by our Services, under such circumstances, if you do not agree to data analysis of your data, you can enter the privacy settings of Milex Smart App (“My > Settings > Privacy Settings > Data Analysis”) to opt-out your selection. The legal basis for such processing is based on your consent.
• Marketing Communication and Personalization: We may process your account data, usage data, and device information to personalise product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and inviting you to participate in surveys relating to your use of the Services. If you do not allow us to process your Personal Data for personalization, you may opt out when you enter the App, or by changing your preferences in “Privacy Settings” (“Me> Settings > Privacy Settings > Personalization”) in the App. The legal basis for this processing is your consent.
• Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

1. a) comply with a legal obligation, process or request;
   b) enforce our User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;
   c) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or
   d) detect, prevent or otherwise address security, fraud or technical issues. prevent or otherwise address security, fraud or technical issues.

If there is any change in the purposes for processing your Personal Data, we will inform you with a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

3. Who do We Share Personal Data with?

At Homemark, we only share Personal Data in ways that we tell you about. Without your consent, we will not disclose your Personal Data to third-party companies, organisations, or individuals except in the following cases:

• To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
• To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our websites and Services.
• To subsidiaries or affiliates within our corporate family for the purpose of regular business activities based on our instructions and in compliance with applicable law, this Privacy Policy and other appropriate confidentiality and security measures.
• To an affiliate or other third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, and choices you may have regarding your Personal Data.
• As we believe in good faith that access to, or use preservation, or disclosure of the information is reasonably necessary or appropriate to

(a)Comply with applicable law, regulation, legal process, or lawful governmental request;

(b)Enforce our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof;

(c) Protect our operation and business systems;

(d)Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law;

(e)Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.

Except for the third parties mentioned above, we only disclose your Personal Data to other third parties with your consent.

Data Transfer

Milex operates globally, and Personal Data may be transferred, stored and processed outside of the country or region where it was initially collected. Also, the applicable laws in the countries and regions where we operate may differ from the laws applicable to your country of residence. Under the Personal Data Protection framework and in order to facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live.

We protect Personal Data in accordance with this Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws.

If you would like further details on the safeguards we have in place under the data transfer, you can contact us directly as described in this Privacy Policy.

Data Subject Rights

We respect your rights and control over your Personal Data.

Response Fee Timeframe: You do not have to pay any fee for executing your personal rights. Subject to applicable data protection laws in relevant jurisdictions, your request for privacy rights will be fulfilled within 15 business days, or within 30 calendar days due to different response requirements.

If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may exercise any of the following rights:

• Right of Access: Request access to the Personal Data that we process about you via "Me - Setting - Privacy Policy Management - Export Personal Information";
• Right of Rectification: Request us to correct inaccurate or incomplete Personal Data about you:

1) Modify your account number (email address or phone number) via "Me - Setting - Account and Security - Change your Account";

2) Modify the nickname and/or time zone via "Me - Personal Information";

• Right of Deletion: Request to delete of Personal Data about you via "Me - Setting - Account and Security - Delete Account", when you confirm the deletion of your account, your Personal Data will be deleted accordingly.
• Right of Restriction of Processing Personal Data: Request to restrict, temporarily or permanently, on our processing of some or all Personal Data about you via "Me-FAQ & Feedback", or send over the email request to info@milex.co.za
• Right of Opt-out/Objection: Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests, please kindly check the following "consent withdraw" section.

1) For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notification settings and other related functions;

2) You may opt out the non-marketing communication through “Me > Message Center > Notification Settings” or “Me > Settings > Privacy Settings > Notification" to manage your selection;

3) You may opt-out of the data analysis features through “Me > Settings > Privacy Settings”;

4) You may opt-out of the Personalization feature through “Me > Settings > Privacy Settings > Personalization”;

5) Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected;

6) If you previously agreed to associate your Milex Smart account with a third-party service, such as a health platform, please unbind it on the third-party platform.

When you withdraw your consent we may not be able to continue to provide you with certain products or services correspondingly. However, the withdrawal of your consent will not affect the processing of personal information based on your consent before the withdrawal.

If you have more questions please do not hesitate to contact info@milex.co.za  to elaborate on your privacy rights.

Security Measures

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Homemark provides various security strategies to effectively ensure the data security of users and devices.

• As for device access, proprietary algorithms are employed to ensure data isolation, access authentication, and application for authorization.
• As for data communication, communication using security algorithms and transmission encryption protocols and commercial-level information encryption transmission based on dynamic keys are supported.
• As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing info@milex.co.za

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Policy unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data.

• For as long as you require us to fulfil the products and services you request from us as defined in the ;
• Personal Data will no longer be retained when you request to remove your Personal Data, we will accordingly complete the task.

When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Children’s Privacy

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information.

Changes to this Policy

We may update this Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our practices or this Policy, please contact us as follows:

Homemark (PTY) Ltd.

Email: info@milex.co.za