SecuFirst
PRIVACY STATEMENT
Protecting the personal privacy of every customer and vendor is a crucial
part of gaining and keeping your trust in SecuFirst (the “Company”, “we”, “us”). As a
global organization, we strive to provide a high level of privacy protection
across all of our businesses and services and to deploy consistent, rigorous
policies and procedures.
This privacy statement (the “Statement”) serves as our commitment to you
to protect the security and privacy of your personal data, and covers the
following areas of privacy concerns:
1.
The types of data we
collect from you
2.
When we collect your data
3.
How we use and process your
data
4.
Our legal basis for
processing your data
5.
When and to whom we share
your data
6.
For how long we retain your
data
7.
When and to whom we
transfer your data across country borders
8.
Whether and how we carry
out profiling using your data
9.
The security measures we
take to protect your data
10. Your rights over your data
11. The choices you have over how your data is collected and used by us
12. Who to contact and what to do if you wish to discuss with us about your
data and your rights
This Statement does not apply to third-party applications, products,
services, websites or social media features that may be accessed through links
that we provide on our websites and interfaces. Accessing those links may
result in the collection of information about you by a third party. We do not control or endorse those third-party
websites or their privacy practices. We
encourage you to review the privacy policies of such third parties before
interacting with them.
Your privacy is of utmost importance to us in servicing you. Our products and services are rendered to you
on the basis of your understanding of your data privacy rights.
Please read this Statement carefully. When visiting our website and using
our services that link to or reference this Statement, you agree to be bound by
the terms and conditions of this Statement.
Your personal data
– what is it?
Personal data relates to a living individual who can be identified from
that data. Identification can be by the data alone or in conjunction with any
other data in the data controller’s possession or likely to come into such
possession. The processing of your personal data is governed by applicable
privacy laws.
What roles do we play in processing
your data?
We are the data controller with respect to processing your data (contact
details below). This means that we decide how your personal data is processed
and for what purposes. We know that you
care how data about you is used and shared, and we appreciate your trust that
we will do so carefully and sensibly.
When are your personal data
collected?
Some of your data can, in
particular, be collected by us:
·
whenever
you become our customer;
·
whenever
you use our services and products;
·
whenever
you contact us via the various channels we offer you;
Our collection of personal
data
The personal data we collect include any and all data you provide to us when
you use our products and services. You can choose not to provide data to us, but
we may then not be able to service you where such services require processing
such data. We use the data that you
provide for fulfilling the purposes of the product and service such as making
the connection of the device and your mobile devices. Examples of the data we collect and store include: your e-mail address,
password, device setup utility if you wish to use email notification service.
How do we
process your personal
data?
We comply with our obligations under applicable privacy laws by keeping
personal data up to date; by storing and destroying it securely; by collecting and
retaining only the necessary data that we need to service you; by protecting
personal data from loss, misuse, unauthorized access and disclosure and by
ensuring that appropriate technical measures are in place to protect personal
data.
The processing operations we perform on your data cover automated and
non-automated means of collecting, recording, organizing, structuring, storing,
altering, retrieving, using, transmitting, disseminating or otherwise making
available, aligning or combining, restricting, and/or erasing your data.
We use your personal data for the following
purposes:
·
To
design and deliver our services and activities to you.
·
To maintain the integrity and safety of our data
technology systems that store and process your personal data.
·
To enforce or
defend our policies or contract with you.
·
To detect and
investigate data breaches, illegal activities, and fraud.
What do we do with
the information?
When
you start using our OMG
Pro APP, we ask you for permission to access your camera and microphone
in a pop-up so the camera can communicate with the device. If you do not grant
the permission, you will not be able to access these features. In this case,
however, you cannot use all the features of the OMG Pro APP.
If
you allow access to these data, the OMG Pro APP will only access these features to the extent
necessary to provide the functionality. The legal basis for granting access is
your consent, Art. 6 para. 1 lit. a GDPR. You can revoke the permission at any
time in the settings of the OMG
Pro APP.
The wireless IP cameras and the security gateway supports secure
communication with the WebRTC
streaming channel with encryption protection. This means that the
communication takes place directly from the camera to the OMG Pro APP, without interposing a server or cloud system. A storage of the data
does not take place on any part of the server.
We
need the following accesses for the following purposes:
1. Camera
To read the
QR code, the camera needs access to your device. However, no data is stored
here. In order to optimally protect the image data against unauthorized access
during transmission, the entire transmission is encrypted.
2.
Microphone
In order to
perform two-way audio communication from OMG Pro APP to wireless camera or wireless
video door phone, access to the microphone is required. No data is stored here.
3. Location
In order to
retrieve the Wi-Fi list for user to select the router for wireless Camera to connect
to, this option needs to be turned on. However, the app will not feedback or
store the history of the actual location of the smartphone.
4. Phone
In order to
retrieve the phone state so the server could decide if need to wake up the
phone when system is in sleep mode, this option needs to be turned on to send
the push notification when needed.
5.
Who can access the live Stream
or save videos and photos?
To access the
live stream or recorded videos and photos, user first will have to have the authorization to access the
camera device. To ensure that no unauthorized person can access the live
stream or recorded videos and photos, please do not provide account or password of the camera to
others. Due to the used peer-to-peer technology, only authorized users can
access the recordings. Neither our server nor the technical support is able to
access them.
What
is our lawful basis for processing your personal data?
In
general, the lawful basis for us to process your
personal data for the various types of processing performed on your
data (please refer to “How do we process
your personal data?” section
of this Statement) is, as applicable, processing based on your consent, as necessary for us to enter into and
to perform our contract with you, or as necessary to pursue
the legitimate interest of our Company or of third parties.
We will collect, process, and use the personal
data supplied by you only for the purposes communicated to you and will not
disclose your data to third parties except under the circumstances of data
disclosure described in the “Sharing your
personal data” section below.
Where we talk about our legitimate interest or that of third parties,
such legitimate interest can include:
·
Right to freedom of
expression or information, including in the media and the arts;
·
Prevention of fraud,
misuse of company IT systems, or money laundering;
·
Operation of a
whistleblowing scheme;
·
Physical security,
IT and network security;
·
Internal investigations;
and
· Proposed mergers and acquisitions
Necessity
to provide us data
You are not under any obligation to provide us
any personal data. As noted below, the
choice is yours. However, please note that without certain data from you, we
may not able to undertake some or all of our obligations to you under our
service contract with you, or adequately provide you with our full range of
services. If you would like to obtain
more detail about this, please contact us following the instructions in the “Contact Us” section below.
Sharing
your personal data
Your personal data will be treated as strictly
confidential, and will be shared only with the categories of data recipients
listed below. We will only share your
data with third parties outside of the Company with your consent, and you will
have an opportunity to choose for us not to share your data.
We may disclose your personal data to:
· our affiliated entities
within our global group of companies worldwide to provide you services such as
facilitating order processing and shipping, for internal administration
purposes, to detect and deal with data breaches, illegal activities, and fraud,
and to maintain the integrity of our information technology systems.
· governments and/or
government-affiliated institutions, courts, or law enforcement agencies, to
comply with our obligations under relevant laws and regulations, enforce or
defend our policies or contract with you, respond to claims, or in response to
a verified request relating to a government or criminal investigation or
suspected fraud or illegal activity that may expose us, you, or any other of
our customers to legal liability; provided that, if any law enforcement agency requests your data, we will attempt to
redirect the law enforcement agency to request that data directly from you, and
in such event, we may provide your basic contact information to the law
enforcement agency.
· third parties involved in
a legal proceeding, if they provide us with a court order or substantially
similar legal procedure requiring us to do so.
We may provide you
with opportunities to connect with third-party applications or services. If you
choose to use any such third-party applications or services, we may facilitate
sharing of your information with your consent. However, we do not control the
applications or services of those third parties or how they use your
information, and your use of such applications and services is not governed by this
Statement. Please review the terms and the privacy policies of those third
parties before using their applications or services.
How
long do we keep your personal data?
We keep your
personal data for no longer than reasonably necessary for the given purpose for
which your data is processed. If you
will provide us, or have provided us, consent for us to process your data, we
will process your data for no longer than your consent is effective. Notwithstanding the above, we may retain your
personal data as required by applicable laws and regulations, as necessary to assist
with any government and judicial investigations, to initiate or defend legal
claims or for the purpose of civil, criminal, or administrative proceedings. If none of the above grounds for us to keep
your data apply, we will delete and dispose of your data in a secure manner
according to our data protection policy.
Privacy
of data subjects under the age of 16
Our products and
services are not targeted to persons under the age of 16. We do not knowingly collect or process
personal data from persons under the age of 16.
Your
rights and your personal data
Unless subject to an
exemption under applicable privacy laws, you have the following rights with
respect to your personal data:
· The right to request a copy of your personal
data which we hold about
you.
· The right to request that we correct
any personal data if it is found to be inaccurate
or out of date.
· The right to request
to erase your personal data where it is no longer necessary for us to retain such
data, except we are not obliged to do so if we need to retain such data
in order to comply with a legal obligation or to establish, exercise, or defend
legal claims.
·
The right to withdraw your consent to the processing at
any time if we rely on your consent to process your data. This includes cases where you wish to opt out from marketing
communications that you receive from us.
· The right to request that we
provide you with your data and, where possible, to transmit that data directly to
another data controller, where the processing is based on your consent or is
necessary for the performance of a contract with you, and in either case, we process
the data by automated means.
· The right to restrict our processing of your personal data where you
believe such data to be inaccurate, our processing is unlawful; or that we no
longer need to process such data for a particular purpose unless we are not
able to delete the data due to a legal or other obligation, or because you do
not wish for us to delete it.
· The right to object to us
using your personal data, where the legal justification
for our processing of your personal data is our legitimate interest. We will
abide by your request unless we have compelling legitimate grounds for the
processing, which override your interests and rights, or if we need to continue
to process the data for the establishment, exercise, or defense of legal
claims.
·
The right to lodge a
complaint regarding our
processing of your data, with the competent authority where you reside or in which
your data is processed.
If you would like
to exercise any of the above rights, please do so by providing your request in
the “GDPR Support Page”
After receiving
your request, we will evaluate your request and inform you how we intend to
proceed on your request. Under certain
circumstances in accordance with applicable privacy laws and regulations, we
may withhold access to your data, or decline to modify, erase, port, or
restrict the processing of your data.
Please be advised
that if you exercise the rights to erase data, restrict, or object to our
processing, or to withdraw your consent, we may not be able to continue our
services to you if the necessary data is missing for processing.
Transfer,
Storage, and Processing of Data Abroad
As noted in the “Sharing your personal data” section of
this Statement, as a globally operating company, we may share your information
with our affiliate companies or third parties.
Please refer to the “Sharing your
personal data” section of this Statement for the recipients of your data
and the reasons for our provision of your data to them. Where such entities are
located in other countries and jurisdictions, we will therefore be transferring
your personal data outside of the European Economic Area. In making such data transfers, we make sure
to protect your personal data by applying the level of security required by the
applicable privacy laws. Where we
transfer your data to a country or jurisdiction that cannot guarantee the
required level of protection as required by applicable privacy laws, we have
enhanced our IT security measures and have entered into Standard Contractual
Clauses with the transferee to require security obligations on the transferee,
both of which are intended to increase the protection of your personal data.
Standard Contractual Clauses are one of a number of "appropriate
safeguards" under the applicable privacy laws that enable the transfer
of personal data concerning data subjects within the European Economic Area to
jurisdictions that have not been designated by the European Commission as
possessing an adequate level of data protection. You may request a copy of such Standard
Contractual Clauses from us, or inquire about transfers of your information, by
providing your request in the “GDPR Support Page”
Profiling
We currently do not
carry out any form of profiling, which is an automated processing of personal
data consisting of using your personal data to build a profile on you and
evaluate certain personal aspects concerning you, or to analyze or predict
aspects concerning you. If and when we decide to undertake any profiling using
your data, we will provide you with a prior explanation about what we intend to
do with your data and obtain your explicit written consent for us to do so, and
we will prior to such processing implement appropriate measures to safeguard your
rights, freedoms and legitimate interests.
Further
processing
If we wish to use
your personal data for a new purpose not covered by this Statement, then we
will provide you with a new notice explaining this new use prior to commencing such
further processing for a new purpose, setting out the relevant new purpose and
processing conditions. In such case, we
will find a lawful basis for further processing, and whenever necessary we will
seek your prior written consent to such further processing.
What
are your choices?
You have the choice
to allow us to collect and process your data. The collection and processing of your personal
data is neither a statutory nor a contractual requirement, although as noted
above, we will be unable to provide you with certain services without the data
necessary for such services purposes.
You can always
choose not to provide your data to us, although we may need such data to
process your requests, in which case we will inform you of our constraints.
To the extent that you
have consented to our processing of your data, you can choose to discontinue
our processing at any time.
You can choose to
request from us a copy of the personal data we store and process regarding
you.
You can choose to add
or update data that you have provided to us.
You can choose to
erase your data, or you may choose to restrict our processing of your data instead.
You can choose to
port your data to a third party under conditions stated above.
You can choose to
object to our processing of your data.
In summary, what we are allowed to do with your
data is, with limited exceptions under applicable privacy laws, up to you.
However, in the event that you choose for us not to further process your data,
such choice may affect the delivery of our obligations or services to you; in
this situation, we will inform you of our constraints.
JSW Pacific Corp