4. What Personal Information We Collect and How We Collect It. We do not currently require you to provide Personal Information in order to have access to general information available on the Site. But, we do receive and/or collect Personal Information from you in the following ways:
4.1. ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available, by sending an email to an email address that we provide, you are required to provide us with certain information such as your name and email address (and your Company name and website) including information as free text that you choose to include about your reasons for contacting us. We do ask that you do not include any Personal Information in this free text field.
4.2. Subscription Information. The Site allows you to subscribe to our mailing list to receive information and updates about our current products and services including future product and services releases, IoT news and other general marketing content. For this purpose, we collect your name and email address.
4.3. Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track user’s movement around the Site, and gather demographic information.
4.4. Cookies and Other Tracking Technologies. Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to operate and make our Site available and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. You can learn more about cookies on the Internet Advertising Bureau’s website: http://www.allaboutcookies.org.
5. The Way We Use Personal Information. If you submit or we collect Personal Information through the Site, then we may use such Personal Information in the following ways:
5.1. Contact Us.
• We use the information that you voluntarily provide us to respond to your queries. We do ask that you do not provide us with unnecessary Personal Information. If you have purchased a product directly from us, or through a third party and then contacted us, we will combine your Contact Us information with other information we have about you from other sources in relation to your product purchase.
• We process this data on the basis of a legitimate interest and as necessary to perform a contract with you or take steps, at your request, to enter into a contract.
• If you do not provide us with this information, we cannot respond to your queries.
• For this purpose, we use third party service providers who provide the communication infrastructure and interface for this purpose and who will have access to and store your Personal Information, including e-commerce and CRM platforms, and communication services including online chat, video and email services.
• We will retain this information for no longer than the applicable periods described in the section below “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.
• If you subscribe to our mailing list on the Site, we will use your name and email address to send you information and updates about our current products and services including future product and services releases, IoT news and other general marketing content.
• We process this data on the basis of your consent (for subscribing to our mailing list).
• Please note that you have the right to object at any time to the processing of your Personal Information for such purposes and to withdraw your consent for such processing. You can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will find on all email marketing messages we send you. Alternatively, you can contact us at [email protected] Please note that even if you opt out of receiving all direct marketing emails, we may still send you a response to a “Contact Us” request.
• If we see through our records that you have expressed interest in our products or services in the past, or have actually purchased our products and services, or you just have left your details through our mailing list, we will retain this information until you object to the processing of your Personal Information for this purpose.
• For marketing purposes, we use third party email marketing and e-commerce platforms who will have access to your name and email address to assist us in providing direct marketing to you.
5.3. Use of the Site.
• We use Log Files and Cookies and Other Tracking Technologies, including IP address to operate, monitor and analyze the Site and provide you with certain features and functionalities on the Site.
• We will process this information on the basis of a legitimate interest in being able to provide and improve the functionalities of, and product and services offered to you from, the Site.
• We will retain this information for two (2) years.
• With respect to Cookies and Other Tracking Technologies, to opt-out of providing this information to Securithings, please see section headed “Opting-Out of Cookies”.
• For this purpose, we use website analytics service providers who will have access to your Personal Information.
5.4. Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.
• We use your Personal Information to take action in case of a dispute involving you in connection with your use of the Site and to enforce the terms and conditions applicable to the Site. We also use your Personal Information to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities, tax reporting and auditing requirements), to protect against harm to the rights, property or safety of Securithings, our users, yourself or the public, and to protect against detect, prevent, or otherwise address fraud or security issues.
• For this purpose, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Securithings users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose.
• We will retain this Personal Information for the amount of time as required by law to fulfill the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
5.5. As a general note, for each of the purposes set forth above, we also use the following service providers which are required to fulfill each individual purpose:
• In order to communicate with each other for this purpose, we also use various communication tools such as email and online messaging platforms to communicate with each other.
• The data we use is hosted, managed and backed-up with third party technology vendors we use to provide us with a service.
6. Additional Ways We Share your Personal Information.
6.3. In the event Securithings goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your Personal Information will be among the assets transferred.
7. Transferring Personal Information From and Outside of the European Union. We will take appropriate steps to ensure that transfers of your Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end, if we as the data controller share your information with our corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission) or EU – US Privacy Shield certification. We will provide further information on the means to ensure an adequate level of data protection on request.
8. Use of Anonymous Information. We may use Anonymous Information or disclose it to third party service providers in order to improve our Site and enhance your experience with the Site. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Site.
9. Your Rights. The following rights (which may be subject to certain exemptions or derogations), shall apply to users of the Site:
• You have a right to access Personal Information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
• You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
• If you no longer want us to use your Personal Information, you can request that we erase your Personal Information. Please note that if you request the erasure of your Personal Information, we will not be able to respond to your queries or provide you with features and functionalities of the Site. We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention, and enhancing safety. For example, if we suspend the use by a user for fraud or safety reasons, we may retain certain information about that user to prevent them from using the Site in the future. We may also retain and use your Personal Information to the extent necessary to comply with our legal obligations, including for tax, legal reporting and auditing obligations. Also, because we maintain the Site to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.
• You have a right to restrict the processing of your Personal Information subject to applicable laws.
• Where you have provided your consent to the processing of your Personal Information by Securithings you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
• You have a right to object to our use of your Personal Information for marketing purposes. To object to Marketing, please see the “Marketing” Section above. For opting out of cookies, please see the section “Opting Out of Cookies” section.
• You have a right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of Personal Information transferred to another data controller in a structured, commonly used and machine-readable format.
• You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
• You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us at [email protected] Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
10. Opting Out of Cookies. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
11. Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Site but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
13. Children’s Privacy. The Site is not structured to attract children under the age of 13 years. If we learn that we have collected Personal Information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at [email protected]
15. Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
17. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] Please note that we are only required to respond to one request per customer each year.
18. Our California Do Not Track Notice. We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Site.
19. Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
Last updated: July 8, 2018