PRIVACY POLICY

Last updated: April 2026

1. Scope of application

This Privacy Policy governs the use of the Pulse Installa mobile application, available for Android and iOS, intended exclusively for professional clients of Legrand Care (installers, technicians, or authorized personnel) for the installation, provisioning, and technical configuration of Legrand Care devices.

The application is not designed to be used by end users, dependents, or family members.

2. Data Controller

LEGRAND GROUP ESPAÑA S.L. with NIF B08272064 and registered office at Hierro 56, 28850 Torrejón de Ardoz (Madrid), will act as data processor, being the owner of the Pulse INSTALLA, and treating the information in accordance with the privacy policy established below.

DPO (Data Security Protection Officer): es-tor-sm-protecciondatos@legrandgroup.es (LEGRAND GROUP ESPAÑA, S.L.), Telephone +34 91 649 61 10.

LEGRAND GROUP ESPAÑA S.L develops technological solutions for telecare services and equipment for domiciliary and residential environments, acting as a technology provider for professional clients.

3. Categories of Personal data processed

Pulse INSTALLA processes a limited amount of personal data related to professional users only.

3.1. Professional User Data

The application processes a limited and strictly necessary set of personal data related to the professional user:

a) Email address

Purpose: User identification during the login process.

Processing: The email address is transmitted to the Legrand Care backend only during login.

Storage on the device: Not stored locally.

Retention: Not retained within the application.

b) Authentication token (API token)

Purpose: Maintain the user session and authenticate communications with the backend.

Processing: Technical session token, not reusable for other purposes.

Storage:

iOS: System Keychain.

Android: Encrypted Shared Preferences using Android Keystore.

Retention: Until logout or a maximum of 1 hour.

c) Email address

Purpose: Multi‑factor authentication (MFA) and delivery of one‑time passwords (OTP) via SMS to securely authenticate access to the application.

Processing: The phone number is provided directly by the professional user during MFA setup and is used exclusively to send authentication codes during the login process.

Storage on the device: Not stored locally in the device. Stored in the authentication and identity management service used by Legrand Care

Retention: Retained while the professional user account remains active or while SMS‑based multi‑factor authentication is enabled.

3.2. End User / Third-Party Data

Pulse INSTALLA does not process personal data of end users of the devices (such as dependent persons).

The application manages technical configuration parameters only, without access to:

• personal data
• health data
• contact information
• or any identifying information related to the end user

5. App permissions

NFC (Android and iOS)

Purpose: Read device NFC tags to retrieve technical identifiers (e.g., serial number).

Personal data: No personal data is accessed or stored.

Camera (Android and iOS)

Purpose: Scan QR codes to retrieve device serial numbers.

Permission: Requested when first used.

Personal data: Images are not captured or stored.

Bluetooth (Android and iOS)

Purpose: Discover, connect to and provision Legrand Care devices via Bluetooth Low Energy (BLE).

Personal data: No.

Location (Android only)

Purpose: Required by the Android operating system to allow Bluetooth scanning.

Processing: The application does not collect, store or transmit location data.

6. Purpose of processing

Personal data is processed exclusively to:

• Authenticate professional users.
• Secure user sessions.
• Enable installation and configuration of Legrand Care devices.
• Ensure secure communication with backend systems.

Data is not used for advertising, profiling, analytics or marketing purposes.

7. Legal basis

Processing is based on:

• Article 6(1)(b) GDPR – performance of a contract (B2B relationship).
• Article 6(1)(f) GDPR – legitimate interest in securing the application and systems.

8. Data sharing

• No personal data is shared with third parties.
• No data is sold or used for commercial purposes.
• Data may be processed by authorized service providers acting as data processors under contractual obligations.

9. International data transfers

No international transfers of personal data are performed through this application.

10. Data security

Legrand Care implements appropriate technical and organizational security measures, including:

• Encrypted storage of authentication tokens.
• Secure communication channels.
• Access controls to prevent unauthorized access.

11. User rights

Professional users may exercise their rights under applicable data protection laws, including access, rectification, erasure, restriction or objection and data portability (where applicable).

Requests can be sent to: es-tor-sm-protecciondatos@legrandgroup.es

12. Changes to this policy

Legrand Care reserves the right to update this Privacy Policy to reflect legal, technical, or functional changes to the application.

Any significant changes will be duly communicated through appropriate channels.

The latest version will always be available at this URL

13. Applicable Law

This Privacy Policy is governed by:

• Regulation (EU) 2016/679 (GDPR).
• Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), where applicable.