RUDOLPH is committed to the privacy and security of your personal information. This document, referred to as the Privacy Policy, describes our practices regarding the personal data we process through individual use of the RUDOLPH by Resfri Ar App on mobile devices, and its communication with our compatible products and equipment. This set of operations is called the CONNECTIVITY SERVICE.

The RUDOLPH by Resfri Ar App is owned and managed by RUDOLPH Usinados SK s.r.o., a business entity registered under (IČO) 36 582 514, headquartered at Radlinského 17/B, 1280, ZIP Code 052 01, Spišská Nová Ves in Slovakia. 

Through this policy, our goals are to:

  1. Inform you which personal data we process;

  2. Explain the purposes of this processing and how we safeguard your privacy;

  3. Clarify your rights and choices as a data subject.

For the purposes of this policy, RUDOLPH is primarily considered the DATA CONTROLLER, holding decision-making authority over data processing.

If you have any questions during your relationship with RUDOLPH, please feel free to contact us at: [email protected] 

KEY DEFINITIONS

  • APP: The RUDOLPH by Resfri Ar App, developed and published by RUDOLPH on the official Google Play Store and Apple App Store.

  • PERSONAL DATA: Information relating to a natural person that can identify them individually or in context with other data accessible by RUDOLPH.

  • PURPOSE: The reason or goal behind the use of your personal data.

  • LEGAL BASIS: Grounds that justify the processing of data under the General Data Protection Law (GDPR).

  • DATA SUBJECT: You – the individual to whom the personal data refers.

  • PROCESSING: Any operation involving your personal data, such as collection, storage, classification or deletion.

  • CONNECTIVITY SERVICE: Features enabled through wireless communication between user-owned computing devices and RUDOLPH-manufactured products compatible with the data operation and transmission technology.

YOUR RIGHTS UNDER THIS POLICY

In accordance with applicable law, RUDOLPH ensures you the following rights regarding the processing of your data:

  • Confirmation of whether we process your personal data;

  • Access to the data being processed;

  • Correction of incomplete, inaccurate, or outdated data;

  • Data portability upon request;

  • Information on the option to withhold consent and consequences of refusal;

  • Information on data sharing practices;

  • The ability to revoke consent or request the deletion of data processed under that legal basis.

You may also object to the processing of your personal data in certain situations, particularly when the processing is not legally or contractually required. These rights may be limited where fulfilling your request would infringe on the rights of third parties or RUDOLPH, or if we are legally obligated to retain the data.

The exercise of these rights may affect access to the APP and its features, including special offers, promotions, technical support and warranty benefits linked to the CONNECTIVITY SERVICE.

You can exercise your rights by contacting: [email protected]

WHAT INFORMATION WE COLLECT AND HOW WE USE IT

Upon optional purchase, the latest generation of our refrigerators includes built-in devices that store technical data on equipment performance and enable access to the CONNECTIVITY SERVICES via the RUDOLPH by Resfri Ar App. In general, this data is stored within the product and is not accessible to RUDOLPH or others without physical access.

During normal use of the RUDOLPH by Resfri Ar App and its interaction with compatible products, you may create a user profile. Through this profile, we may collect:

  • Device-related data (e.g., model, IMEI or unique identifiers, MAC/IP address, operating system and version);

  • App usage and interaction data;

  • Precise or approximate location data (e.g., city code, region, mobile network, coordinates, time zone, language);

  • Information about the connected product (e.g., serial number, ownership, purchase date and location);

  • Registration data (e.g., name, birthdate, phone number, email, login credentials).

We may also process non-personal information not directly or indirectly associated with individuals, such as:

  • Device-specific usage data (e.g., operating hours, faults, performance diagnostics);

  • Statistical and monitoring data (e.g., session duration, feature usage);

  • Events and logs related to app errors or failures.

Some features may require your permission to access storage, notifications, location, Bluetooth, NFC or mobile data. Granting or denying these permissions may impact the availability or functionality of certain services.

WHY AND HOW WE USE YOUR INFORMATION

Devices with CONNECTIVITY features may periodically transmit operational data to us via the internet. This requires the installation of the RUDOLPH by Resfri Ar App and your consent to these terms.

We use technical, statistical and personal data for the following purposes:

  • To create and manage your account or user profile;

  • To enable access and remote control of our compatible products;

  • To improve the quality and security of our products and services;

  • To maintain relationships with customers and partners;

  • To manage and validate product warranties;

  • To provide software updates;

  • To conduct research and product development;

  • To generate market presence analytics;

  • To respond to inquiries and support requests;

  • To send notifications and targeted promotions (with proper consent);

  • To produce statistics and behavioural patterns for a personalised experience;

  • To comply with legal or regulatory obligations, or defend RUDOLPH’s rights;

  • To cooperate with court orders or government authorities;

  • For any other legitimate interest, provided it benefits you and aligns with the law.

SECURITY, STORAGE AND SHARING OF PERSONAL DATA

All data collected is stored in secure, controlled environments. Information transmitted via the CONNECTIVITY SERVICE is encrypted and transferred securely.

Internally, RUDOLPH respects legal data processing principles and adopts technical and administrative measures to prevent unauthorized access, loss or alteration of data.

Once the data’s purpose is fulfilled, it is deleted or anonymised. You may also request deletion at any time, except where retention is legally required (e.g., for audit or tax compliance) or justified by our legitimate business interests.

Due to the structure of the Internet, some data may be processed on servers located outside Brazil. If international data transfer occurs, RUDOLPH ensures adequate protection, contractual safeguards, and compliance with Brazilian legislation.

In certain cases, RUDOLPH may share your personal data with:

  • Judicial, regulatory or government authorities;

  • Other companies within our corporate group;

  • Carefully selected third-party service providers;

  • Authorised technical support partners.

Third-party access is limited to the stated purposes and contractually bound to comply with this policy and data protection laws.

CHILDREN’S DATA

The RUDOLPH by Resfri Ar App is not intended for users under 18 years of age. Users under this age cannot register. If we become aware that we have unintentionally collected data from a minor, we will delete such data and may deactivate the associated account.

GENERAL PROVISIONS

We are continuously improving our services. As such, our data processing practices may change over time, and this Privacy Policy may be updated. Changes become effective once published on our website.

This and other documents governing the relationship between RUDOLPH and USERS shall be interpreted according to European law. The competent court will be Spišská Nová Ves in Slovakia or, in the case of consumer relations, the USER’s local jurisdiction.

CONTACT US

If you have any questions about this Privacy Policy or wish to communicate regarding personal data, contact us at:
 📧 [email protected]
 📧 Data Protection Officer (DPO): [email protected]