Privacy Policy

Introduction

This Privacy Policy applies to following services:

The Controller of your personal data is AKUVOX (HK) NETWORKS CO., LIMITED (hereinafter referred to as ‘AKUVOX’, ’us’ or ’we’). AKUVOX takes your personal information very seriously and gives you control over your personal information. We use strong encryption technology to protect personal privacy, and employ strict policies to manage all data. Before using Akuvox services, you need to agree to this policy on how we collect, use, store and share your personal information. If you have any questions about this policy, please contact: support@akuvox.com. The main points of this privacy policy are as follows:

1.      We will explain the types of personal information we may collect and how  we may use it.

2.      We may collect some of your sensitive information after obtaining your consent. Refusing to provide this information will only make you unable to use the specific AKUVOX Services, but not other AKUVOX Services that affect your normal use of the Web Apps or Mobile Apps.

3.      You can access, correct, and delete your personal information through the channels listed in this guide. You can also withdraw consent, cancel your account, report complaints, and set privacy features.

4.      GDPR: On 25 May 2018, the General Data Protection Regulation (GDPR) went into effect in the European Union (EU). The GDPR seeks to create a harmonized data protection regulation framework across the EU and aims to give the control of personal data back to data subjects, while imposing rules on those hosting and processing this data, anywhere in the world. This new regulation impacts both organizations that conduct business in the EU, as well as businesses that maintain or process personal data of EU citizens. The protection of natural persons in relation to the processing of personal data is a fundamental right. Article 8(1) of the Charter of Fundamental Rights of the European Union (the ‘Charter’) and Article 16(1) of the Treaty on the Functioning of the European Union (TFEU) provide that everyone has the right to the protection of personal data concerning him or her.

If you want more detailed information, please read the corresponding chapter.

A. What Information We Collect

Personal information is collected by AKUVOX for the purpose of providing services under applicable laws.

“Personal information” shall have the same meaning as “personal data” and shall include any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, phone number and email address.

We will ask you to provide personal information that is necessary to provide ‘AKUVOX Services’ to you. If you do not provide your personal information, we may not be able to provide you with ‘AKUVOX Services’.

In the following part, we want you to understand the types of information we may collect when you use ‘AKUVOX Services’.

1.      Personal Information:

1)     When you sign up for Mobile Apps, Web Apps, you provide us with personal information that includes users’ names, phone numbers, emails, authentication information, device and mobile phone IP address information, device MAC address information, browser and mobile phone cookies, log information and other personal information based on your consent.

2)     During your use of AKUVOX Services, we will collect information about the AKUVOX Services you use and how you use them, such as system information that is generated when you use the MySmart App to make calls, monitor devices, capture visitor images, text messages, view call logs and subscribe to services.

2.      Non-Personal Information:

We may also collect other information that cannot identify a specific individual and is not personal information according to applicable local laws. This includes, but is not limited to, statistical data generated when you use Web Apps, Mobile Apps, anonymous device-related information, daily events, page visit events, page visit duration events, session events, network monitoring data such as request duration, number of requests and bad requests, and application crash events. This information is collected to improve AKUVOX Services we provide to you. When you use AKUVOX Products, logs used for optimized products may be collected. And for The type and amount of information collected depends on how you use AKUVOX Services.

B. Why We Collect the Information

1.      To maintain, improve, develop our products or provide services to you, such as delivery, verification, after sales and customer support;

2.      Data are used for authentication, customer service, security, archiving and backup purposes to ensure the security of AKUVOX Services we provide to you;

3.      For internal uses, such as data analysis, research and development of statistical information related to your use of Web Apps, Mobile Apps to better improve AKUVOX Services;

4.      Provide you with more flexible services;

5.      Perform software verification and upgrade services;

6.      Provide specific services required by users, which may involve the need of providing the information to our affiliates, third parties or other users;

7.      Other circumstances that do not violate any mandatory laws and regulations;

8.      Store and maintain information about you for our business operations (such as business statistics) or to fulfill legal obligations;

9.      For other purposes with your consent.

C. Your Privacy Rights

You have following rights when use AKUVOX services.

1.      Consenting or withdrawing your consent

You are free to withdraw your consent at any time. e.g. when use voice assistant feature on Products, and you can choose to enable or disable debug mode. If enabled, the voice data will be record under the local path of Products, you also have the right to choose to send or not send data to us.

2.      Managing, reviewing, updating and deleting your information

You can always review and update information after logging into Web Apps, Mobile Apps, for example, viewing logs in our MySmart App.

D. Retaining Your Information

We retain the data we collect for different periods of time depending on what it is and how we use it. We will describe the reasons why we hold onto different types of data for different periods of time.

1.      We set different retention timeframes for different types of data based on the reason of collection, for example, door release capture, motion capture and call capture. After the predetermined period of time, the data will be automatically deleted.

2.      Information retained until your Account is deleted

We keep some data to provide you with AKUVOX Services, for example, the MAC and IP of devices, call histories, system logs and end user account, installer account, distributor account or property manager account information, which are stored on our servers.

3.      Information retained for extended time periods for limited purposes

Sometimes business and legal requirements oblige us to retain certain information for an extended period of time for specific purposes. The reasons we might retain some data for a longer period of time include financial record-keeping and complying with legal or regulatory requirements.

E. Cookies and Similar Technologies

Cookies are small files containing strings of characters that are sent to your computer when you visit a website. When you visit a website again, cookies enable the website to recognize your browser. Cookies can also store user preferences and other information. You can reset your browser to reject all cookies or alert you when sending cookies. But without cookies, some website features or services may not work properly. Cookies and similar technologies are commonly used technologies on the Internet. When you use Web Apps, Mobile Apps, we may use these technologies to send cookies or anonymous identifiers to your device to collect and store information when you access and use Web Apps, Mobile Apps. We treat information collected through cookies and other technologies as non-personal information, unless your local laws treat Internet Protocol (IP) addresses or similar identifying marks as personal information. We use cookies and similar technologies for the following AKUVOX Services:

1.      To ensure the safe and efficient operation of AKUVOX Services

We may set authentication or security cookies or anonymous identifiers that help us confirm that you are securely logged into the service or may encounter illegal acts such as frauds. These technologies will also help us improve service efficiency and system login and response speed.

2.      To help you get an easier access experience

Using such technologies can help you avoid the steps and processes of repeatedly filling in personal information and entering search content via methods like one-click login and search history.

3.      For log file

Like most websites, we collect certain information and save it in log files. Such information may include Internet Protocol (IP) addresses, browser types, Internet service providers (ISPs), referrer / exit pages, operating systems, date / time stamps, and / or clickstream data. We do not associate automatically-collected log data with other information we collect.

4.      For mobile analysis

In Web Apps, Mobile Apps, we use mobile analytics software to better understand the functionality of our mobile software in your phone. This software may record information such as how often you use the application, events that occur within the application, cumulative usage, performance data, and data of where the application crash occurred. We do not associate the information stored in the analytics software with any personal information you submit in the Web Apps, Mobile Apps.

F. Protecting your personal information

All AKUVOX Services have built-in strong security features. We develop a strict information management policy, equipped with a professional technical team, and adopt a series of reasonable precautions to protect your personal information from unauthorized browsing, disclosure, abuse, alteration, destruction, and loss, including:

1.      Use encryption technology to ensure that your data remains private during transmission;

2.      Provide multiple security features to help you protect your account security;

3.      Review our collection, storage, and processing of information practices, including physical security measures, to prevent unauthorized people from accessing our systems.

G. Sharing your information

Normally, without your consent, we will not share personal information with any organizations or individuals other than AKUVOX. However, if it is necessary to collect your personal information in accordance with the mandatory requirements of local laws and regulations, we may collect and use your relevant personal information without obtaining your authorization. We do not sell any personal information to third parties.

H. Children’s privacy

AKUVOX does not intend that any AKUVOX Services will be accessed or used by children under the minimum age in the relevant jurisdiction and such use is prohibited. AKUVOX Services are designed and intended for adults. By using AKUVOX Services, you represent that you are at equal or above the minimum age in the relevant jurisdiction and understand that you must be at equal or above the minimum age in the relevant jurisdiction in order to create an account and purchase the products or services advertised through AKUVOX Services. If we obtain actual knowledge that an account is associated with a registered user who is under the minimum age in the relevant jurisdiction, we will promptly delete information associated with that account. If you are a parent or guardian of a child who is under the minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us, please contact us by email at support@akuvox.com. A parent or guardian of a child under the minimum age in the relevant jurisdiction may review and request the deletion of such child’s personal information as well as prohibit the use thereof.

I. Storage of information

We maintain Cloud servers in the USA, Singapore, Germany and China. Generally speaking, you will use the server closest to you. For example, if you are located in the European region, your personal information is stored in Germany. But it’s also possible that your information is processed on servers located outside of the country where you live. When processing that information for the purposes described in this Privacy Policy, for example providing customer services as per your request, our colleagues in China may access certain portion of your information (wherever you are located) in order to provide the requested services to you. We shall do so in accordance with applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You hereby agree to the transfer of the data and you have the right to be informed of the appropriate safeguards taken by AKUVOX for this transfer of your personal information.

J. Scope of application

1.      Our privacy policy applies to all services provided by AKUVOX (HK) NETWORKS CO., LTD (AKUVOX Services), but does not apply to services with independent privacy policies, such as products provided by third parties and service.

2.      Our privacy policy does not apply to products and services provided by third parties, such as products and services provided by third parties on the MySmart App, and other websites linked to in AKUVOX Services. These products, services , or websites will be regulated by an independent privacy policy. Please review the corresponding policy provisions separately.

K. Updates to this privacy policy

We may modify and update this privacy policy from time to time. We will post updates on the privacy policy in the Web Apps, Mobile Apps through notifications and other forms. You can visit the MySmart App(go to ‘My - Settings - About’), or visit AKUVOX website to check the latest version of the privacy policy. We will send you formal notifications of major changes (including, for certain services, email notifications of changes to our privacy policy).

L. Contact us

If you have any other questions or requirements regarding our use of your personal data, or need more information, you can contact us at support@akuvox.com Please provide your name (or nickname), preferred method of contact, the details of your request or comment along with any corresponding website links.

M. Appendix: key points of some articles in the GDPR

1.      Art. 5 GDPR Principles relating to processing of personal data

Personal data shall be:

1)     Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

2)     Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);

3)     Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’); accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

4)     Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);

5)     Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).

2.      Art. 8 GDPR Conditions applicable to child's consent in relation to information society services:

Where point (a) of Article 6(1) applies, in relation to the offer of information society services directly to a child, the processing of the personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child. Member States may provide by law for a lower age for those purposes provided that such lower age is not below 13 years. The controller shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child, taking into consideration available technology. Paragraph 1 shall not affect the general contract law of Member States such as the rules on the validity, formation or effect of a contract in relation to a child.

3.      Art. 16 GDPR Right to Rectification

1)     The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her.

2)     Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

4.      Art. 7 GDPR Conditions for consent

1)     Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data.

2)     If the data subject’s consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of this Regulation shall not be binding.

3)     The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.

4)     When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.

Suitable Recitals