Last Update: 20th May 2021
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Subscriber has engaged. Subscribers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable regulations and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information.
We collect information under the direction of our Subscribers and have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. If you are an individual who interacts with a Subscriber using our Services (such as a customer of one of our Subscribers) and would either like to amend your contact information or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.
By using the Services, you are accepting and consenting to the practices described in this policy, now and as amended by us.
What information does IIKSA collect?
We collect the following categories of information:
Information you give us
- Account and Registration Information: We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilise one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorise to log into and utilise our Services in connection with Your Account. We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
- Other Submissions: We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, requesting customer support, or otherwise communicating with us.
- Attendee Information: We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of IIKSA participates.
Information That We Collect From You on our Websites:
We may collect information such as zip code, area code, referrer URL, approximate location, and the time zone where our products and services are installed to provide our services and to assist you in case of troubleshooting.
Technical information from your network and devices:
We collect technical and diagnostic information about the devices in your network. For instance, we automatically collect the MAC address, maker name and model of your devices, up and down status, operating system version, unique device identifiers and the related software. We also collect real time operating status of your network and its connected devices (i.e. network speed, IP addresses, device event information such as disconnections, system activity, hardware settings, the date and time of your requests) and the related diagnostics information. We may process information from your devices so that we can send you alerts when something happens. We may also use this data as described below; for example, we may use the data in aggregated format for statistical and research purposes to show you how your network performance compares with other users in your area.
We may collect data from sensors or devices which may be present in your network, such as data on whether something in the room is moving, temperature data, and the occurrence of smoke or CO alarms in order to deliver such information to you or to security services during the use of our products and services.
Collaboration and remote connectivity data:
One of the features of IIKSA is to provide you, or people enabled by you, to remotely connect to your network via secure sessions. For example, you (or others you allow) could be accessing your home PC remotely via our Remote Desktop feature or you could login remotely into the configuration page of your router or any of your home devices. We do not view or access any of your devices remotely without prior authorization by you or from your support provider that has obtained your consent.
Information we may receive from other sources:
We may receive information about you if you use the Services. We work with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
How does IIKSA use the information it collects?
We may use the information we collect to provide, develop and improve our products and services, such as for:
- Providing you with products, services, or information you request, for example when you contact us for remote support and troubleshooting;
- Making assessments and recommendations about products, services and safety;
- Providing you with information our products and services or the required notices;
- Customizing your experience when using our products and services;
- Improving the products and services that we provide, such as by better tailoring our content to your needs and preferences;
- Internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- Delivering marketing communications about IIKSA-related services, products or promotions and to measure or understand the effectiveness of marketing. We may use service providers to send these messages on our behalf, but we do not share your email address with any other third parties without your permission; and
- Detecting, preventing, and responding to fraud, intellectual property infringement, violations of law, or other misuse of the products and services.
We may also combine or aggregate in anonymised or non-personally identifiable format any of the information collected through the use of the Services or elsewhere for any of these purposes and for research, statistical and business purposes.
Legal Basis for Processing (EEA only):
If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
In what circumstances does IIKSA share my data?
The following are the situations where we may share your data:
- We may share your personal information with any member of our group, which means our ultimate holding company and its subsidiaries (as defined in section 1159 of the UK Companies Act 2006).
- IIKSA partners and third party developers: We may share de-identified data for research, statistical, and business purposes. Additionally, to improve their software, hardware and services designed for use with our products and services, IIKSA may provide any such partner or third party developer with information that is relevant to that partner’s or developer’s software, hardware and/or services, as long as the diagnostic information is in a form that does not personally identify you.
- Business Transitions: If we are involved in a merger, acquisition or sale of all or a portion of our assets, your information may be transferred as part of that deal.
How do the Services interact with third parties?
When you choose to connect third-party products and services through IIKSA products and services, you are shown details about proposed exchange(s) of data between IIKSA products and services and the third party that is providing the products or service. In some cases, IIKSA Services or the third party will instead (or also) ask for permission to control the products that you have connected. IIKSA products and services may receive and process information from third parties, and some of this information may be associated or stored with your IIKSA account.
How and where does IIKSA process information?
IIKSA users residing in North America will have their information sent to IIKSA Cloud servers located in the United States when transmitting information in the United States.
IIKSA users residing in Europe and the rest of the world will have their information sent to IIKSA Cloud servers based in the European Union when transmitting information from outside of the United States.
How long does IIKSA save my data and how can I delete it?
IIKSA generally stores your data on IIKSA’s cloud servers for as long as you remain an IIKSA customer in order to provide you with IIKSA services and products and for legal compliance purposes. You can view and edit your information on the IIKSA web or mobile application. You can delete your personal data at any time by terminating your account or by writing to us at email@example.com. We may retain de-identified data indefinitely.
For personal information that we process on behalf of our Subscribers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.
How does IIKSA keep my information secure?
We take security seriously and care about the integrity of your data. We use administrative, physical, and technical safeguards to protect the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer). However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.
As per the organisational duties introduced by the General Data Protection Regulation (“GDPR”), we commit to reporting personal data breaches to the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, also those individuals will be informed without undue delay. We have appointed Silvio Di Crosta as Data Protection Officer of our organisation. If you have any questions about the security of your personal information, you can contact him at firstname.lastname@example.org.
What are my rights?
At IIKSA we take our users’ rights into the highest regard. For this purpose, we align ourselves to the most advanced privacy regulations available. When in it comes to your Personal Data, we recognise, and commit to respect and enforce, the following rights:
- The right to be informed: Upon request, we will provide you with information about whether we hold or process any of your personal information. To request this information please contact us at email@example.com.
- The right of access: As a user of our Services, you may access your personal data, at any time, by logging into the IIKSA Portal and accessing your profile section.
- The right to rectification: As a Subscriber of our Services, you may access and update or change your Account Information by editing them yourself from your profile area of the IIKSA Portal. A Data Subject who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days.
- The right to erasure: If you no longer wish to make use of our Services, you may erase your personal data from the Account area of the IIKSA Website. You may also exercise this right by making a request, in accordance with Data Protection Laws, by emailing firstname.lastname@example.org.
- The right to restrict or object processing: You retain the right to request us to refrain from or restrict our processing of your data for the purposes of marketing. To exercise such right, you may click the “unsubscribe” link in any non-transactional email or marketing email from us, update your preferences in your account, or contact us via email at email@example.com.
- The right to data portability: You retain, at all times, the right to exercise your right of having your Personal Data exported and transferred – in a safe way – to another provider of Services similar to ours. You may exercise this right by making a request, in accordance with Data Protection Laws, by emailing firstname.lastname@example.org. Any request related to your rights above will be handled within thirty (30) days from the moment we receive such request.
The Services are not directed to, nor do we knowingly collect information from, children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.
Updates to this Policy
If you have any questions, please contact us at email@example.com or write to:
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