Effective date: 4 September 2026
1. About this Privacy Policy
This Privacy Policy explains how Electronic Modular Services Limited (“EMS”, “we”, “us” or “our”) handles personal data in connection with the SmartCell Services mobile application (Android package identifier uk.co.emsgroup.smartcell), website, backend systems and notification services (together, the “Service”). It applies to the Android and iOS versions of the application.
SmartCell Services is published on Google Play under the developer name “EMS WIRELESS”. This is the app-store display name and is not a separate legal entity or trading name. EMS is a member of the Kidde Global Solutions (“KGS”) group of companies.
2. Who is responsible for your personal data?
Electronic Modular Services Limited is responsible for the personal data described in this Privacy Policy to the extent that it determines why and how that personal data is processed.
Electronic Modular Services Limited is a company registered in England and Wales under company number 00917296. Its registered office is at Technology House, Herne Bay West Trading Estate, Sea Street, Herne Bay, Kent CT6 8JZ, United Kingdom.
In some cases, the organisation that provides your SmartCell Services account (for example, your employer, installer, service provider or building operator) determines who may use the Service, which sites or panels are connected and which notifications are sent. That organisation may therefore be a separate controller of certain personal data, and EMS may process certain information on its behalf. You should also refer to that organisation’s privacy information and contact it if your request concerns its use of the Service.
Privacy enquiries may be sent to [email protected]. Technical support and account deletion requests may also be sent to [email protected].
3. Personal data we process
Depending on how the Service is configured and used, we may process the following categories of personal data:
1. Account and access data, including user login details, account status, permissions and the organisation associated with the account.
2. Contact and notification data, including a user’s name, email address, telephone number and other notification contact details.
3. Panel and site information linked to the user, including identifiers and details relating to the relevant SmartCell panel or monitored site. Site information is personal data only where it identifies or can reasonably be linked to an individual.
4. Panel event and status information, including event type, status and time information associated with a user, panel or site.
5. Notification preferences, including the notifications selected by the user or configured by an authorised administrator and the chosen delivery channel.
6. A Firebase Cloud Messaging push token used to deliver push notifications to the user’s device. The application does not collect a persistent device identifier for advertising purposes.
7. Email and SMS notification records, including records relating to the sending or delivery of notifications where those channels are configured.
8. Support and request information, including information provided when contacting technical support or exercising data protection rights.
Technical and audit data. The application records user actions in an audit log. The SmartCell Services website and API infrastructure also records client IP addresses and standard technical request information, including the date and time, requested URL or URI, query string where applicable, HTTP method, status or error information, user agent and referrer where available. These records are used to operate, secure, troubleshoot and audit the Service. The application does not collect location data, analytics data, crash reports or persistent device identifiers and requests notification permission only.
4. How we obtain personal data
We may obtain personal data directly from you when you use the Service or contact support; from an authorised administrator of your employer, installer, service provider, customer organisation or building operator; automatically from the SmartCell panel, backend systems and notification services when the Service is used; and from service providers that support the delivery, security and operation of the Service.
Users cannot self-register or create their own SmartCell Services accounts within the mobile application. Accounts are created and managed by authorised administrators.
5. Why we use personal data and our legal bases
Providing and administering the Service
We use account, contact, panel/site, event/status and preference information to authenticate users, provide access to the Service, connect users to the relevant panels or sites and administer accounts. We rely on our legitimate interests in providing and managing the Service and, where the user is directly party to a contract with EMS, on the necessity of processing for that contract.
Sending operational notifications
We use contact details, notification preferences, event/status information and push tokens to deliver push, email or SMS notifications selected by the user or configured by an authorised administrator. We rely on our legitimate interests and those of our customers in operating the Service and delivering requested safety-related and service notifications. These notifications are operational and are not used for advertising.
Support and account management
We use account, contact and support information to respond to enquiries, investigate technical issues, verify and complete deletion requests and maintain appropriate service records. We rely on our legitimate interests in supporting the Service and on compliance with applicable legal obligations where relevant.
Security, misuse prevention and legal compliance
We may use relevant account, technical and service information to protect the Service, investigate suspected misuse, establish or defend legal claims and comply with applicable law or requests from competent authorities. We rely on our legitimate interests in maintaining a secure and reliable service and, where applicable, on compliance with legal obligations.
We do not use personal data collected through the Service for behavioural advertising. The Service does not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.
6. Who we share personal data with
We may share personal data only where necessary for the purposes described in this Privacy Policy, including with:
1. The organisation that provides or administers your account and its authorised administrators.
2. Other KGS group companies and authorised personnel who support the operation, administration, security or compliance of the Service.
3. Rackspace infrastructure used to host the SmartCell Services backend, production MySQL database and daily server images and snapshots in the United Kingdom.
4. Google Firebase Cloud Messaging, which is used to deliver push notifications.
5. Twilio and IntelliSMS, where configured, which are used to deliver SMS notifications.
6. Professional advisers, auditors, insurers, regulators, courts, law-enforcement bodies or other competent authorities where disclosure is reasonably necessary or legally required.
Email notifications are sent from [email protected] using an IIS SMTP service hosted on the SmartCell Services server and configured for direct delivery; no separate smarthost relay provider is currently used. Service providers are required to protect personal data and may use it only for the relevant service purposes, subject to their applicable contractual and legal obligations. We do not sell personal data or share it for third-party behavioural advertising.
7. International data transfers
The SmartCell Services backend and production MySQL database are hosted on Rackspace server infrastructure located in the United Kingdom. Daily server images and snapshots used for recovery are also stored in the United Kingdom. Personal data may be accessed or processed outside the United Kingdom where this is necessary for service operation, support or the use of the service providers identified above.
Authorised operational and support access may occur from the United Kingdom, France, Spain, the Netherlands, Germany, Belgium, Poland, Denmark, Italy, Portugal and Sweden. Based on the information currently available, no additional operational or support access locations are known. Service providers identified above may process limited personal data in other countries in accordance with their service arrangements. Where personal data is transferred outside the United Kingdom or European Economic Area, as applicable, EMS takes steps to ensure an appropriate level of protection, including, where required, by relying on an applicable adequacy regulation or decision or appropriate contractual safeguards such as the UK International Data Transfer Agreement or UK Addendum and the European Commission’s Standard Contractual Clauses. Information about applicable safeguards may be requested at [email protected].
8. How long we keep personal data
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including operation of the Service, support, security, audit and compliance with legal obligations. The following periods or objective criteria apply:
| Data category | Retention period or criterion |
|---|---|
| Account, contact and notification preference data | Retained while the account or relevant Service remains active. Following a valid and verified deletion request, deletion is normally completed within two business days, subject to the exceptions described below. |
| Panel/site and event/status information | Retained while the relevant account or Service remains active and thereafter only as necessary for service operation, support, security, audit, legal compliance or an active matter. |
| Firebase push notification tokens | Retained for up to 365 days and refreshed when the user logs in. Associated token records are removed when the user account is deleted. |
| Email and SMS notification records | Retained while the relevant account or Service remains active and thereafter only for as long as reasonably necessary for service operation, support, security, audit or legal and compliance purposes. |
| Support and deletion-request records | Retained for as long as reasonably necessary to respond to the request, evidence its handling, meet legal and compliance obligations, and establish or defend legal claims. |
| Server images and snapshots | Daily Rackspace server images and snapshots are retained for seven days and are then removed. Data deleted from the active system may remain recoverable from a pre-deletion image until that seven-day period expires. |
| Technical and audit logs | Retained while needed for service operation, troubleshooting, security, audit or legal purposes, including active investigations, support matters or legal obligations. No fixed period currently applies. |
We may retain limited information for longer where required by law, necessary to establish or defend legal claims, needed for security or fraud prevention, or required to preserve information that belongs to the relevant customer organisation rather than to the individual user. Where information remains temporarily in a server image or snapshot following deletion, it will not be restored to active use except where necessary for disaster recovery, security or legal compliance and will be removed when the applicable seven-day retention period expires.
9. Security
EMS uses administrative, organisational and technical measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, disclosure or access. Data is encrypted in transit between the mobile application and the SmartCell Services backend using
HTTPS/TLS. The mobile application does not contain production database credentials, and production MySQL connection details are loaded from encrypted server-side configuration. Access to account deletion and administration functions is restricted to authorised personnel.
10. Account and data deletion
SmartCell Services does not allow users to create their own accounts within the mobile application. Accounts are created and managed by authorised administrators. If you wish to request deletion of your account and associated personal data, contact SmartCell Technical
Support at [email protected]. You may also contact [email protected] for assistance with a data protection request.
We may ask for information reasonably necessary to verify the request and protect the account from unauthorised deletion. Once a valid request has been verified, Support will normally remove the user account from the active SmartCell Services backend and web portal within two business days. Associated Firebase push notification token records are removed when the account is deleted. Other personal data linked to the account will be deleted or anonymised where required and technically applicable, subject to the exceptions described below.
Some information may be retained where required by law, needed for security, audit or the establishment or defence of legal claims, forms part of records controlled by the customer organisation, or remains temporarily in a server image or snapshot. Data deleted from the active system may remain recoverable from a pre-deletion image until the applicable seven-day retention period expires. We will explain any material limitation applicable to a request.
11. Your data protection rights
Depending on the circumstances and the law applicable to you, you may have the right to request access to your personal data, correction of inaccurate data, deletion, restriction of processing, data portability and information about applicable international transfer safeguards. You may also have the right to object to processing based on legitimate interests and to withdraw consent at any time where processing is based on consent. Withdrawal of consent does not affect processing carried out before withdrawal.
RIGHT TO OBJECT: You have the right to object, on grounds relating to your particular situation, to processing based on our legitimate interests. We will stop that processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is required for legal claims.
To exercise your rights, contact [email protected]. We may need to verify your identity and, where another organisation is responsible for the relevant processing, may refer your request to that organisation or assist it in responding. Data protection rights are not absolute and may be subject to legal conditions and exemptions.
12. Complaints
If you have concerns, please contact [email protected]. You may also complain to the UK Information Commissioner’s Office (ICO) or, where applicable, to the data protection supervisory authority in the country in which you live or work.
ICO website: Make a complaint to the ICO | Telephone: 0303 123 1113
13. Children
The Service is intended for authorised professional users and is not directed to children.
14. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to the Service, our data handling practices or legal requirements. The current version and effective date will be available through the application and on the public webpage linked from the relevant app-store listing. We will provide additional notice where required by law.
15. Contact details
Controller: Electronic Modular Services Limited (company number 00917296)
Registered office: Technology House, Herne Bay West Trading Estate, Sea Street, Herne Bay, Kent CT6 8JZ, United Kingdom
Privacy and rights requests: [email protected] | Technical support and deletion requests: [email protected]