RAK Hotspot Privacy Notice

Data controller

Data Protection Officer (DPO)

To onboard a RAK Light Hotspot to the Helium network, you will need to set up the hotspot through local (web) interface, use the Application to onboard gateway either by using the deep link and input the necessary information by yourself or by scanning a QR code shown on the web interface from gateway. To be able to scan the QR code, the Application will need the camera permission of your cellphone.

By inputting information or scanning the QR code on the web interface, the Application will collect and process your Information. Please note that we do not keep a database to store the Information.

a. Wallet Address

The wallet address is your public blockchain address associated with your Wallet (the “Wallet Address”), and is required to securely link your Hotspot to the Helium network and ensure all earnings generated by your Hotspot are credited to your account.

The Wallet Address is a unique set of numbers and letters assigned to you by the Helium Blockchain Network. Please note that the Wallet Address is publicly available within the Helium Blockchain Network to any person.

We collect and send your Wallet Address to Helium Blockchain Network to onboard your Hotspot to Helium Blockchain network. The legal basis for the processing of your Wallet Address is performance of a contract with you, i.e., to let you onboard your Hotspot.

b. Hotspot Address

Each Hotspot has a unique address (identificator) assigned to it by the Helium Blockchain Network (the “Hotspot Address”). The Hotspot Address is necessary for the Helium Blockchain Network to identify each Hotspot connected to it and properly maintain the interaction of the Hotspot with the Helium Blockchain Network.

When you onboard the Hotspot within the Application, the Hotspot Address will be sent to the Helium Blockchain Network. Please note that we do not control the Helium Blockchain Network, and are not responsible for their privacy practices. When you leave the Application, we encourage you to read the respective privacy policy/notice/statement of the Helium Blockchain Network.

The legal basis for the processing of the Hotspot Address is performance of a contract with you, i.e., to let you use the Application and onboard your Hotspot to the Helium network.

c. Location

To properly onboard a Hotspot to the Application, you shall provide the location (longitude, latitude) of the respective Hotspot (the “Location”). The Location is necessary due to the nature of the Helium Blockchain Network, which is a “proof-of-coverage” blockchain that requires to know the precise Location of each onboarded Hotspot.

You may enter the Location either manually (by personally typing the address of the Hotspot) or by using the geolocation data of your device. In the latter case, the Application will request your permission to use the geolocation data of your device; if you do not provide such permission, you will only be able to enter the Location manually.

If you use the geolocation data of your device, the Application will use the services provided by Mapbox. Such services are operated by Mapbox, Inc. registered at 740 15th Street NW, 5th Floor, Washington DC 20005, United States.

In this case, the Location may be transferred to Mapbox pursuant to this Data Processing Agreement. For more information, please review Mapbox Privacy Documentation. Note that competent US state authorities may have access to the personal data collected via Mapbox.

When you onboard a Hotspot, we will process the Location and associate it with the respective Hotspot Address. The Application will transfer the Location to the Helium Blockchain Network, as it is necessary for the proper functioning of the Hotspot and its interaction with the Helium Blockchain Network. Please note that the Location will be permanently available within the Helium Blockchain Network and it is literally impossible to either delete or change it. You may always update the Location, however, the previous location will still be stored within the Helium Blockchain Network.

Please note that the Location must be associated with the address of the appropriate Hotspot, not necessarily with your personal location or the location of your residence.

The legal basis for the processing of the Location is the performance of a contract with you, i.e., to let you use the Application to onboard your Hotspot to the Helium Network.

We process the Location only during the period when you are onboarding your Hotspot to the Helium Network. Accordingly, we do not process the Location if you do not use the Application for example when you close the Application. Please note that the Location will be permanently stored within the Helium Blockchain Network.

d. Antenna and Height

You will be asked to submit antenna and height details for your Hotspot during the Antenna Setup procedure of the Application, including Antenna Type, TX/RX Gain, and Height (the ‘Antenna and Height’).

The Antenna Type represents the type of antenna, e.g. RAK Antenna, custom antenna, etc.

TX/RX Gain represents the gain of the antenna when is sending (TX Gain) or receiving (RX Gain), defined in decibels (dB).

Height represents the height of the deployment of the antenna, e.g. the approximate height of the roof (if the antenna is deployed on the roof) or apartment building (if the antenna is deployed in the apartment building).

The legal basis for the processing of the Antenna and Height is the performance of a contract with you, i.e., to let you use the Application to onboard your Hotspot to the Helium Network. The Antenna and Height are requested by Helium to be saved on the blockchain, calculate, or estimate the coverage of the antenna, and to perform Proof of Coverage (PoC) challenges based on the estimated coverage.

e. Support

You may contact us via support@rakwireless.com (‘Support Email Address’). When you contact us or submit a request, you may provide us with certain additional personal information. Such information may include your email address or any other personal information that you choose to provide to us (the ‘Support Data’).

This data is necessary to address your issue, answer your request, contact you back, or address you properly, where, and as applicable depending on the type of personal information. The legal basis for processing such data — our legitimate interest in assisting you with your request regarding the Application.

f. Analytics

We use Sentry within the Application. Sentry is the error and performance monitoring software offered by Functional Software, Inc. Sentry provides us with information about crashes and malfunctions in the Application. In case of malfunction or failure, the following information is transmitted:

• information about the device and the browser, such as Sentry device ID, model and device type, screen parameters, name and version of the operating system, and settings of the device (e.g., language);
• version and functionality of the Application;
• date, time and time zone of the crash event;
• place in the Application where the crash happened.

With the aforementioned information, we do not intend to identify you as an individual, however, according to the applicable data protection legislation, it may be considered personal data.

We use Sentry to improve the Application and ensure its stability. The legal basis for processing the data collected via Sentry is our legitimate interest. Information collected with Sentry is stored during 90 days from the date when the malfunction took place.

For more information regarding the data processing by Sentry, please refer to Sentry’s Privacy Policy.

We do not record any of the Information in database.

We only share your Information in the two circumstances, which are all third-party solutions related to or integrated within the Application:

(a) Helium Blockchain Network, when you use the Application to onboard your Hotspot;

Please note that certain data will be publicly available within the Helium Blockchain Network, as described in section “Your Information and Blockchain” above.

(b) Sentry, when you use the Application and a crash takes place.

Except the Support Data, we do not store your Information in data base. Once the Information is collected, the Information will be stored in the cache before it is sent to the Helium Blockchain Network. As a nature for cache, the data will be deleted once the Information has been sent out to Helium Blockchain.

Support Data is processed for the period of one (1) year following your contact with the Support Email Address. The data is stored in Frankfurt, Europe.

According to the applicable data protection legislation, you may have the following data protection rights:

1. Right to access:

You can request access to your personal data that we store about you. Among others, you may ask us regarding:

• the purposes for collecting personal information about you;
• categories of personal information concerned;
• who receives your personal information or categories of such recipients;
• how long we are going to store the information about you and if not possible criteria to determine the storage period;
• when your personal information was obtained not from you directly, the source where it came from;
• the existence of either profiling activities or automated decision making based on your personal information. Where such activities are performed, we should also inform you about the importance, and expected consequences of them;
• a copy of your personal information processing. For such requests further, we may charge you with a reasonable fee. We generally provide users with an electronic copy of their personal information unless they request otherwise.

2. right to rectification:

You have the right to correct inaccurate (for example, old or incorrect) personal information related to you.

3. right to erasure or the right to be forgotten:

You have, under certain circumstances, the right to request the erasure of your personal information. Please note, that this right only applies to the data available at the time of request and is not applicable to future data.

• Request to the erasure of personal information is possible when:
• personal information is no longer needed for the purposes it was primarily collected or processed;
• when you have already withdrawn your consent for processing your personal data, and we do not have other legal ground to process it;
• when your personal data is processed under legitimate interest and you object to such legal ground. Moreover, there is no overriding legitimate interest to proceed with processing of your personal data;
• your personal information was unlawfully processed;
• when your personal data must be erased due to legal obligation.

4. right to restrict processing:

You may request us to stop processing your personal information when:

• you have reasonable doubts that your information is accurate, and we are verifying the accuracy of such information;
• your personal information was unlawfully processed;
• the purpose of your personal information collection no longer exists, but you wish to store it longer to defend a legal claim.

Moreover, you may request us to stop processing your personal data while we are working on a rectification request or request to object to the processing of your personal information.

5. right to data portability:

You have the right to obtain from us and further reuse your personal data for your own purposes within other services. You will also be able to transfer your personal information from one IT environment to another in a safe and secure way, when certain conditions apply, such as:

• the processing is based on your consent or needed for the performance of a contract with you;
• the processing is made only electronically, without any paper-based files included.

6. right to object:

You have the right to object to the processing of your personal information at any time. This allows you to prevent us from (stop) processing your personal information. This right applies only when one of the following conditions are met:

• your personal information is used for direct marketing purposes;
• the processing is based on our legitimate interest;
• we are performing tasks carried out for the public interest or by governmental authority;
• your personal information was processed for either research or statistical purposes.

7. right not to be subject to automated decision making and profiling:

Currently, neither we nor the Website uses your personal data for profiling or decisions made solely by automated means.

8. right to lodge a complaint with a supervisory authority:

You have a right to lodge a complaint with a data protection authority in a country you either reside, permanently live, work, or in a country where data protection infringement takes place.

Please note that the above data rights are about personal data, since this Application does not collect any personal data from you, and will delete all information collected from you once your Hotspot has onboarded to the Helium Network, you could not ask us to access to your information we have collected etc. because we do not store it.