Oasis Privacy Policy

Oasis offers advanced smart lighting solutions designed to create a comfortable, customizable home environment. Our smart lights seamlessly connect to the Oasis mobile application (the “App”), giving users to easy control and personalize their lighting experience.

This Privacy Policy describes how Mixtiles Ltd. d/b/a Oasis (“Oasis”, “we”, “our” or “us”) collects, stores, uses and disclose personal data of individuals (“you”, “your”) who (i) purchase Oasis smart lights (“Customer(s)”), (ii) use the Oasis App (“User(s)”), and (iii) visit our website (the “Site” and collectively with the App, the “Services”) and interact with our online ads and content, surveys, emails or other communications under our control (“Prospect(s)”).

Specifically, this Privacy Policy describes our practices regarding -

1. Data Collection
2. Data Uses & Business Purposes
3. Data Location
4. Data Retention
5. Data Disclosure
6. Cookies and Tracking Technologies
7. Communications
8. Data Security
9. Your Privacy Rights
10. Opt-Out of Sale/Sharing/Targeted Advertising
11. Additional Information and Contact Details

Privacy is important to us, and we are strongly committed to transparency and fairness in our data processing activities. Please read this Privacy Policy carefully and make sure that you fully understand and agree to our practices.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. However, please keep in mind that without it, we may not be able to provide you with the full range of our Services or deliver the best user experience when interacting with them. If you prefer not to share your personal data or have it processed by us, please refrain from providing it, visiting or interacting with our Site, our using our Services. You may also submit a request to exercise your rights as explained in Section 9 below.

Data Collection

When we use the term “personal data” (or personal information under certain data protection laws such as the California Consumer Privacy Act (CCPA)) in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. It does not include aggregated, de-identified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Specifically, in the last twelve months, we have collected the following categories of personal data:

We may obtain the categories of personal information listed above from the following categories of sources:

• Directly from you: you may provide us with personal data when you choose to use our Services, make a purchase through our Services, request information from us or contact us for any other reason, including via email or through our chat.
• Data automatically collected or generated: when you interact with or use our Services, we may collect certain technical data about your device (such as your operating system, IP address, device identifier, browsing history, purchase history etc.). We collect or generate such data either independently or with the help of our Service Providers (defined below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 6 below).
• Data received from third party services: our Services may be used in connection with third party services. If you use our Services with or through such third parties, we may receive personal data about you from such third parties. For example, if you use voice assistants to control your Oasis smart light, we may collect data such as control commands from the voice assistant, device status, and interaction logs to provide you with the requested functionality. Please note that when you directly engage with such third-party services, any aspect of that engagement that is not directly related to our Services and directed by Oasis is beyond the scope of Oasis’ Terms of Service (“Terms”) and this Privacy Policy, and their own terms and privacy policies will govern your use of those services.

Please note that we use analytics tools (including Google Analytics) to collect data about the use of Services such as how often you visit or use the Services, which pages they visit and when, and which website, ad or e-mail message brought them there. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

Data Uses & Business Purposes

We use your personal data as described in Section 1 as necessary for the performance of the Services (“Performance of a Contract”); to comply with our legal and contractual obligations (“Legal Obligations”); and to support our legitimate interests in maintaining and improving our Services, e.g., understanding how our Services are used and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing assistance and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with (“Legitimate Interests”).

If you reside or are using the Services in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for the processing of personal data as described in this Privacy Policy (either in general, based on the types of personal data you expect or elect to process or have processed by us or via the Service, or due to the nature of such processing) (“Consent”), your acceptance of our Terms and of this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, unless the applicable law requires a different form of consent. If you wish to withdraw such consent, please contact us at [email protected].

Specifically, we collected and used personal data in the last twelve months for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

Data Location

We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States, Israel, European Union, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Mixtiles and its affiliates and Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction from which such data originated.

Mixtiles Ltd. is headquartered in Israel, a jurisdiction which is considered by the European Commission, the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner, to be offering an adequate level of protection for personal data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the EEA, the UK and Switzerland to Israel on this basis.

For data transfers from the EU, the UK, or Switzerland to countries that are not considered to be offering an adequate level of data protection by the relevant data protection authority, we and the relevant data exporters and importers enter into Standard Contractual Clauses (“SCCs”). You can obtain a copy by contacting us as indicated in Section 11 below.

Data Retention

We may retain your personal data for as long as it is reasonably necessary to provide you with the ability to use our Services, shop and offerings and to maintain and expand our relationship; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of such personal data, the purposes for which we process your personal data and whether those purposes can be achieved through other means, as well as applicable legal requirements.

Please note that unless required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.

Please also note that we do not retain your payment information, it is transferred directly to the relevant Service Provider. We only retain a token of such payment information (which cannot be used to reidentify it) and the chosen payment method, as it is required for your continuous payment of our Services subscriptions.

If you would like to request the deletion of your personal data held by us or have any questions about our data retention policy, please contact us at [email protected].

Data Disclosure

We may disclose your personal data in the following instances:

Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.

Service Providers: we may engage selected third-part companies and individuals to perform services complementary to our own (“Service Providers”). Such Service Providers include hosting services, data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail and communication distribution, marketing and monitoring services, session or activity recording services, performance measurement, social and advertising networks, customer relation management systems, and our legal, compliance and financial advisors. These Service Providers may have access to some or all of your personal data processed by us, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Service Integration: you may choose to connect your Oasis smart light with voice assistants (such as Alexa, Google Home or Apple HomeKit) supported by our Services. Such service providers may receive and transmit certain data related to your Oasis smart light to enable control functionality. Please note that these third-party providers process your data under their own terms and privacy policy and we are not responsible for their privacy practices. Therefore, we encourage you to carefully review their terms and privacy policies for more information.

Sharing your Feedback or Recommendations: if you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Services. If you wish to remove your public review, please contact us at [email protected].

Protecting Rights and Safety: we may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Mixtiles, any of our Customers, Users, Prospects, or any members of the general public.

Mixtiles Subsidiaries and Affiliated Companies; Change of Control: we share personal data internally within our group companies (including, but not limited to, Mixtiles B.V. (NE), Mixtiles USA, Inc. (USA) and Mixtiles Ltd. (IL)), for the purposes described in this Privacy Policy. In addition, should Mixtiles or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of its assets, or will be found eligible for a governmental grant, your personal data may be shared (to the extent necessary and customary) with the parties involved in such an event. If we believe that such event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

Additional Sharing: we may share your personal data in additional manners, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

In the preceding twelve months, we have disclosed the following categories of personal data listed in Section 1 above: identifiers, customer records information, commercial information, internet or other similar network activity, geolocation data, and inferences.

When we disclose personal data for a purpose listed above, we enter into a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract.

Cookies and Tracking Technologies

Our Services utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order to provide and monitor our Services, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser tab or window. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. You may opt in to or opt out from the use of optional cookies through the “Your Privacy Choices” feature available on our website, depending on your location and activity on our Services, as applicable.

Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

In order to delete cookies or to change your settings through your browser, the following links may be helpful:

• Internet Explorer
• Google Chrome
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android
• Opera

If you are primarily concerned about third-party Cookies generated by advertisers, and you live in the USA, Canada, or Europe, you can also opt-out of the collection of your data by our advertising partners who participate in the Digital Advertising Alliance. Opt-out by visiting:

• US: www.aboutads.info/choices (for US users)
• Canada: www.youradchoices.ca/choices (for Canadian users)
• EU: https://youronlinechoices.eu/ (for European users)
• UK: https://www.youronlinechoices.com/uk/your-ad-choices

We also use the web analytics tool Google Analytics. This tool helps us understand users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.

Please also note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt out, so an additional opt-out will be necessary to prevent additional tracking.

Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.

Communications

We engage in service and promotional communications, through social media, e-mail, phone, surveys, SMS and notifications.

Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of order summaries and shipping updates, to inform you of changes or updates to our Services, billing issues, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use.

Promotional Communications: we may send you messages and notifications about new features, additional offerings, events and special opportunities, and any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications via SMS, notifications or e-mail, you may notify us at any time by e-mailing us at [email protected] or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions contained in the promotional communications you receive.

Data Security

In order to protect your personal data held with us, we maintain procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. We use sound industry-standard physical, procedural and technical security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.

Your Privacy Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at [email protected] if you wish to exercise your privacy rights under any applicable law, including the EU or UK GDPR, the CCPA or similar US States privacy laws.

Such rights may include (to the extent available to you under the laws which apply to you) the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with us, or to restrict or object to such data processing (including, for US States residents, the right to direct us not to “sell” or “share” your personal information, or process it for “targeted advertising” as explained in Section 10 below), or to obtain a copy or port such personal data, or the right to equal services and prices (e.g. freedom from discrimination). Please note that these rights are not absolute and may be subject to various exclusions and exceptions under applicable laws. Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.

To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf.  The authorized agent may submit a request to exercise these rights by emailing us.

Please be advised that deleting your personal data stored with us will adversely affect your use of our Services.

When you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may ask you to provide certain information to confirm your identity and ensure that we disclose personal data to the right person, or to better understand the nature and scope of your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, or proof of request fulfillment), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.

Opt-Out of Sale/Sharing/Targeted Advertising

Under some US data protection laws, our disclosure of certain internet activity and device information to third parties through cookies may be considered a “sale” or “sharing” of personal information, or processing of personal information for “targeted advertising” (as such terms are defined in applicable data protection laws). We do so in pursuit of the business and commercial purposes described in Section 2 above.

For the purposes of the CCPA, in the last twelve months we have "sold" or "shared" internet or other electronic network activity information, geolocation data, commercial information, and inferences data with our analytics and advertising partners. We have not knowingly sold or shared personal information of children under the age of 16.

California

In California, we only activate cookies that may result in a “sale” and/or “sharing” of your personal information if you have directed us to do so by activating such cookies and storing them on your device. By default, these cookies will be disabled.

Should you wish to opt in to the use of such cookies, you may click the “Your Privacy Choices” link in the menu or the footer of our website, and turn on the toggle for “Allow Sale and Sharing of Personal Information” button, then click the “OK” button.

To the extent the opt-in activation of such cookies is considered a “sale” or “sharing” of your personal information under the CCPA, you may exercise your right to opt out again at any time by turning off the toggle. You may also set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party advertising cookies.

Other US States

You may opt out of all cookies that may result in a “sale” and/or processing of personal information for “targeted advertising” in the following ways:

• Click the “Your Privacy Choices” link (available in the menu and the footer of our website), then turn on the toggle for “Opt-out of Sale and Targeted Advertising”, then click “OK”. You can opt in again at any time by clicking on "Your Privacy Choices" and turning off the toggle.
• Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising or other cookies (instructions on how to download and use GPC are available here).

Please note: If you visit us from a different device or browser, or clear cookies, then you need to return to this screen to re-select your preferences.

Additional Information and Contact Details

Updates and amendments: we may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External links: while our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention and to read the privacy policies and terms of each and every website and service you visit. This Privacy Policy applies only to our Services.

Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a child is using the Services, we will attempt to prohibit and block such use and to promptly delete any personal data stored with us which we deem to relate to such child. If you believe that we might have any such data, please contact us at [email protected].

Data Protection Officer: we have appointed PrivacyTeam Ltd. as our Data Protection Officer (DPO), for monitoring and advising on Mixtiles’ ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by us, please contact our DPO at [email protected].

EU Representative: Mixtiles B.V has been designated as Mixtiles’ representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Mixtiles B.V. may be contacted only on matters related to the processing of personal data of EU residents. To make such an inquiry, please send an email to [email protected] or contact Mixtiles B.V. by post at Stranwinskylaan 613, 1077 XX Amsterdam, the Netherlands. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

UK Representative: Dr. Andreas Maetzler (https://gdpr-rep.eu/) has been designated as Mixtiles’ representative for the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Inquiries regarding our UK privacy practices may be sent by e-mail to [email protected] or by post to Prighter (Attn: Mixtiles) at: Kemp House 160 City Road, EC1V 2NX, London, United Kingdom.

US Privacy Matters: if you have any inquiries regarding our US privacy practices or would like to exercise your rights under any applicable US state privacy laws, you can contact us by email at [email protected] or by post at: Mixtiles US Inc., 1313 N. Market Street, Suite 1000, Wilmington, DE 19801.

Questions, Concerns or Complaints: if you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by us, you can contact us at [email protected].

For the purposes of Israel’s Protection of Privacy Law, Mixtiles Ltd. is responsible for the personal data processed in connection with our Services, and may be contacted at [email protected].

Last updated: February, 2025.