PORTLANDFIR Smart Platform

Privacy Policy

Last updated: 9 January 2026

1. Who We Are

   This Privacy Policy explains how personal data is processed when you use the PORTLANDFIR Smart Platform.

   Data Controller: Two Design Investments Limited.

   Data Processor: JM Zengge Co., Ltd, acting on behalf of the Data Controller under a signed Data Processing Agreement (DPA).

2. What Data We Collect

   We may process the following personal data:

   • Email address and account credentials

   • Device identifiers and technical information

   • App usage and connectivity data

   We do not collect unnecessary personal data.

3. Why We Process Your Data

   Your data is processed to:

   • Create and manage your user account

   • Enable app and device functionality

   • Maintain security and system stability

   • Provide customer support

   3A. Location Data

   The App may request access to your device's location only when required for core app functionality, such as discovering, connecting to, or controlling nearby smart devices via Bluetooth or similar technologies.

   Location data is not used for tracking, advertising, profiling, or analytics purposes.

   We do not store or retain precise location data, and any access is limited strictly to what is necessary to enable device connectivity.

   Granting location permission is optional, and you may enable or disable it at any time through your device settings.

4. Legal Basis for Processing

   We process personal data based on:

   • Your consent

   • Performance of a contract (providing the App)

   • Compliance with legal obligations

5. Where Your Data Is Stored

   Your personal data is stored and processed exclusively on servers located within the European Union. We do not transfer personal data to servers outside the EU, including China or other regions.

6. Data Sharing

   Your data is processed by JM Zengge Co., Ltd solely on our behalf and under our instructions. We do not sell your personal data.

7. Data Retention

   We retain personal data only for as long as necessary to provide the service or to comply with legal obligations. You may request deletion of your account at any time.

8. Your GDPR Rights

   You have the right to:

   • Access your personal data

   • Request correction or deletion

   • Restrict or object to processing

   • Request data portability

   To exercise your rights, contact: info@portlandfir.com.
9. Security

   We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse.

10. Changes to This Policy

    We may update this Privacy Policy from time to time. Material changes will be communicated through the App.

11. Contact

    For privacy-related questions, contact: info@portlandfir.com.