PRIVACY POLICY
SoHo by
Vantage Privacy
Policy
Last updated: 30/12/2021, 04:00pm
Effective date: 30/12/2021
Vantage Security and
subsidiaries (“we”, “us”, “our”, “Vantage Security ”) are committed
to protecting your privacy. This Home Security Privacy Policy (“Policy”)
describes our practices in connection with information protection on Personal
Data we process through your individual use of the following services,
products, and related mobile applications (collectively, the “Products”).
Before you use our Products, please
carefully read through this Policy and understand our purposes and practices of
collection, processing of your Personal Data, including how we use, store,
share and transfer Personal Data. In the Policy you will also find ways to
execute your rights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register
with yourPersonal Data, or if you start to use our Products and does
not expressly object to the contents of this Policy, we will consider that you
fully understand and agree with this Policy. If you have any question
r regarding this Policy, please do not hesitate to contact us
via:
Service Department: service@vantagesecurity.com
Privacy Office: B3, Bredon House 321, Tettenhall,
Wolverhampton, UK
For other branded mobile applications powered by Vantage
Security , our Clients control all the Personal Data collected through
our Products. We collect the information under the direction of our Clients and
the processing of such information shall be limited to the purpose of providing
the service for which our Clients has engaged us. If you are a customer of one
of our Clients and would no longer like to be contacted by one of our Clients
that use our service, please contact the Client that you interact with
directly.
Definitions
In this Policy, Personal
Data means information generated,
collected, recorded and/or stored, electronically or
otherwise, that can be used to identify an individual or reflect the
activity of an individual, either from that information alone, or from that
information and other information we have access to about that individual.
Personal
Sensitive Data includes personal biometric information,
communication records and contents, health information, transaction
information, and precise location information. When we collect Personal
Sensitive Data from you, we will generate an explicit notification for your
consent before we collection personal sensitive data about you.
Smart
Devices refers to those computing devices produced or
manufactured by hardware manufacturers, with human-machine interface and the
ability to transmit data that connect wirelessly to a network, including: smart
home appliances, smart wearable devices, smart air cleaning devices, etc.
What
Personal Data do We Collect
In order to provide our Products to you, we will ask
you to provide necessary Personal Data that is required to provide those
Products. If you do not provide your Personal Data, we may not be able to
provide you with the Products.
1.Information You Voluntarily Provice Us.
• Account or Profile Data: When you register an
account with us, we may collect your name and contact details, such as your
email address, phone number, user name, and log-in credentials. During your
interaction with our Products, we may further collect your nickname, profile
picture, country code, language preference or time zone information into your
account.
• Feedback: When using feedback and suggestion features
in our Products, we will collect your email address, mobile phone number and
your feedback content to address your problems and solve device failures on a
timely basis.
2.Information We Collect Automatically
• Device Information: When you interact with our
Product, we automatically collect device information, such as the MAC address
of your devices, IP address, wireless connection information, operating system
type and version, application version number, push notification identifier, log
files, and mobile network information.
• Usage Data: During your interaction with our Sites
and Services, we automatically collect usage data relating to visits, clicks,
downloads, messages sent/received, and other usage of our Sites and Services.
• Log Information: When you use our app, the system
and exception log may be uploaded.
Please note that one cannot
identify a specific individual by using Device Information or Log
Information alone. However, ifthese types of non-personal information,
combined with other information , may be used to identify a specific
individual, such non-personal information will be treated as Personal
Data. Unless we have obtained your consent or unless otherwise provided
by data protection laws and regulations, we will anonymize and
desensitize such non-personal information.
• Location Information: When you enable
location-basedfunctions through permission settings on your mobile
device, we will collect and process your location information
to enable certain functions, such aspairing with your Smart
Devices. Also, we may collect information about your real-time precise or
non-precise geo-location when you use certain Smart Devices or relevant
services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fence
feature on the Products, your location information will be generated and shared
with Google Map services. Please note that Google has corresponding data
protection measures, which you may refer to Google Data Protection Terms for
more details: https://privacy.google.com/businesses/gdprservices/.
You may reject such use of your location information by managing the permission
settings in the Products, upon which we will cease to collect and use your
location information. 3.Smart Devices Related Information
• Basic Information of Smart Devices: When you
connect your Smart Devices with our Products or Services, we may collect basic
information about your Smart Devices such as device name, device ID, online
status, activation time, firmware version, and upgrade information.
• Smart Device setting information: when you purchase
the security related products and set the name or description, for
example,such as a video doorbell, you name it "Welcome doorbell", as
well as information about changing the location where
the security product is pairing, and any adjustments to this setting.
• Information Reported by Smart Devices: Depending on
the different Smart Devices you elect to connect with our Products or Services,
we may collect different information reported by your Smart Devices. For
example, smart cameras may report images or videos captured by it.
Purposes
and Legal Basis for Processing Personal Data
The purposes for which we may process your personal
data about you are as follows:
• Provide You Services: We process your account and
profile data(including information about the community services), device
information, usage data, location information, and Smart Device related
information to provide you with our Products and Services that you have
requested or purchased. The legal basis for this processing is to perform our
contract with you according to our Terms of Use.;
• Improve Our Services: We process your device
information, usage data, location information and Smart Device related
information to ensure the functions and safety of our Products, to develop and
improve our Products and Services, to analyze the efficiency of our operations,
and to prevent and trace fraudulent or inappropriate usage. The legal basis for
this processing is to perform our contract with you according to our Terms of
Use;
• Non-marketing Communication: We process your
Personal Data to send you important information regarding the Services, changes
to our terms, conditions, and policies and/or other administrative information.
Because this information may be important, you may not opt-out of receiving
such communications. The legal basis for this processing is to perform our
contract with you according to our Terms of Use;
• Marketing Communication: We may process your
Personal Data to provide marketing and promotional materials to you on our
Products and Services. If we do so, each communication we send you will contain
instructions permitting you to opt-out of receiving future communications of
that nature. The legal basis for this processing is your consent. Additionally,
if you consent to participate in our lottery, contest or other promotions, we
may use your Personal Data to manage such activities;
• Personalization: We may process your account and
profile data, usage data, device information to personalize product design and
to provide you with services tailored for you, such as recommending and
displaying information and advertisements regarding products suited to you, and
to invite you to participate in surveys relating to your use of our Products.
The legal basis for this processing is your consent;
• Legal Compliance: We may process your Personal Data
as we believe to be necessary or appropriate: (a) to comply with applicable
laws and regulations; (b) to comply with legal process; (c) to respond to
requests from public and government authorities (d) to enforce our terms and
conditions; (e) to protect our operations, business and systems; (f) to protect
our rights, privacy, safety or property, and/or that of other users, including
you; and (g) to allow us to pursue available remedies or limit the damages that
we may sustain.
If there is any change in the purposes for processing
your personal data, we will inform such changes to you via email (specified in
your account)and/or a prominent notice on our website of such changes of
purposes, and choices you may have regarding your Personal Data.
Share,
Transfer, Disclose Personal Data
Data Sharing
At Your company name, we only share Personal
Data in ways that we tell you about. We may share your Personal Data under the
following circumstances:
1)Obtain your explicit consent or authorization in
the first place, or provide information to support for your dispute resolution
with other users in accordance with your formal request;
2)In accordance with relevant agreements we
contracted with you (including electronic agreements and corresponding Term of
Use) or other legal documents provided;
3)In accordance with applicable laws and regulations,
judicial procedures, and other mandatory administrative or judicial requests;
4)In order to comply with the law, execution orders,
or adhere to our Term of Use and other agreements, to the extent permitted by
laws and regulations, only by sharing Personal Data can protect the rights,
privacy, property or security from damage for Your company name, our
affiliates, partners, you or other Your company name users;
5)To protect our facilities, operations and systems
and to seek remedies available for this purpose or to limit the damages we may
need to provide;
6)Data sharing for the academic research;
7)Share Personal Data for the public interest in
compliance with laws and regulations.
• To subsidiaries or affiliates within our corporate
family, to carry out regular business activities. We will only share
necessary Personal Data for said purpose, and our affiliates will also be bound
by the this Privacy Policy. When they change the purposes of processing
Personal Data, we will obtain your explicit consent once again so that we can
further process your Personal Data.
• To our third-party service providers who perform
certain business-related functions for us, such as website hosting, data
analysis, payment and credit card processing, infrastructure provision, IT
services, customer support service, e-mail delivery services, and other similar
services to enable them to provide services to us. In this respect, we share
your Personal Data in a legitimate, necessary, specific and with defined
purposes, meanwhile, we only share your Personal Data which are required to
share. In the same time, the third-party service providers will not access to
exact Personal Data about you and have no right to use Personal Data for other
processing purposes which contracted with us.
• To our customers and other business partners who
provide you, directly or indirectly, with your Smart Devices, and/or networks
and systems through which you access and use our Sites and Services.
Except for the third parties described above, when we
decide to share your Personal Data, only your consent can authorize
us to proceed. The third parties we share Personal Data with, are required
to be bound with the Non-Disclosure-Agreement, as well as this Privacy Policy
to process Personal Data according to the defined instruction, security
measures and confidentiality.
Data Transfer
At Your company name, we only transfer
Personal Data in ways that we tell you about. We may transfer your Personal
Data with the following reasons:
1)Obtain your explicit consent or authorization in
the first place;
2)In accordance with applicable laws and regulations,
judicial procedures, and other mandatory administrative or judicial requests;
3)In accordance with relevant agreements we
contracted with you (including electronic agreements and corresponding Term of
Use) or other legal documents provided;
4)In the event of any reorganization, merger, sale,
joint venture, assignment, transfer or other disposition of all or any portion
of our business, assets or stock (including without limitation in connection
with any bankruptcy or similar proceedings). In such an event, you will be
notified via email and/or a prominent notice on our website of any change in
ownership, incompatible new uses of your Personal Data, and choices you may
have regarding your Personal Data. Under such circumstances, we will require
the third parties who have been transferred Personal Data comply with this
Privacy Policy, otherwise require them to obtain your consent and authorization
to process Personal Data.
Data Disclosure
We only disclose your Personal Data under the
following conditions and adopt industry-standard security measures:
1)Upon your request and through the way you consent,
we will disclose your Personal Data;
2)Where it is necessary to provide Personal Data in
accordance with laws and regulations, mandatory administrative enforcement or
judicial requirements, we may disclose Personal Data accordingly with the
defined types of data and way of disclosure. Under the premise of complying
with laws and regulations, when we receive the above request for disclosure of
Personal Data, we will require the corresponding valid legal documents,
subpoenas or investigation letters. To the extent permitted by laws and
regulations, the files we disclose are protected by encryption keys.
Security
Measures
We use commercially reasonable physical,
administrative, and technical safeguards to preserve the integrity and security
of your Personal Data, including but not limited to the following security
measures: establishing strict internal data management systems and processes,
encryption of Personal Data (including transmission, storage and processing),
desensitization of the data, segregation of employees roles and duties,
conducting security and privacy awareness training for our internal employees,
access control and monitoring, etc., to prevent leakage, illegal usage,
unauthorized access or infringement of Personal Data.
If you have reason to believe that your interaction
with us is no longer secure (for example, if you feel that the security of any
account you might have with us has been compromised), you could immediately
notify us of the problem by emailingYour company's contact information
If a security incident affects the security of your
account or Personal Data, we will promptly notify you through the email
address, phone number, or Notification Center, etc., that you provided to us, and
keep you informed of any suggestions to reduce or prevent related risks. When
necessary, we will immediately take appropriate remedial measures in accordance
with internal security response plan and report to the relevant authorities
accordingly.
Individual
Privacy Rights
We respect your rights and control over your Personal
Data. You may exercise any of the following rights:
nVia the “Me &rt; Personal Center (Portrait)
&rt; Account and Security” or via “Me &rt; FAQ&Feedback” in the
App;
nBy emailing us at Your company's contact
information
You do not have to pay a fee for executing your
personal rights. According to different data protection laws, your request of
personal rights will be handled within 15 business days, or within 30 calendar
days due to different response requirement.
If you decide to email us, please make clear what
information you would like to have changed in your request, whether you would
like to have your Personal Data deleted from our database or otherwise let us
know what limitations you would like to put on our use of your Personal Data.
Please note that we may ask you to verify your identity before taking further
action on your request, for security purposes.
You may:
nRequest access to the Personal Data that we process
about you;
nRequest that we correct inaccurate or incomplete
Personal Data about you;
nRequest deletion of Personal Data about you;
nRequest restrictions, temporarily or permanently, on
our processing of some or all Personal Data about you;
nRequest transfer of Personal Data to you or a third
party where we process the data based on your consent or a contract with you,
and where our processing is automated;
nOpt-out or object to our use of Personal Data about
you where our use is based on your consent or our legitimate interests.
•
Withdrawal of consent: We will exercise your privacy
right to withdraw consent through the following approaches:
1) For privacy permissions acquired through device
system settings, your consent can be withdrawn by changing device permissions,
including location, camera, photo album (picture library/video library),
microphone, Bluetooth settings, notifications and other related functions;
2) In the marketing communications that you agree to,
the information we send to you contains instructions that allow you to withdraw
your consent in accordance with the “unsubscribe” method described in the
information;
3) Unbind the Smart Device through the app, and the
information related to the Smart Device will not be collected;
4) By using product with the visitor mode, we will
not collect any personal data about you;
nWhen you withdraw your consent or authorization, we
may not be able to continue to provide you with the products or services
correspondingly. However, your withdrawal of your consent or authorization will
not affect the processing of personal information based on your consent before
the withdrawal.
About Delete of the Account: You can find the Delete
function through “Me &rt; Personal Center(Portrait) &rt; Account and
Security &rt; Delete Account”.
International
Transfer of Information Collected
Primarily, Your company name adheres to
Data Localization Requirement and Minimum Data shall involve International
Transfer, while in order to facilitate our operation, we may transfer, store
and process your Personal Data in jurisdictions other than where you live. Laws
in these countries may differ from the laws applicable to your country of
residence. When we do so, we will ensure that an adequate level of protection
is provided for the information by using the following approach:
Include but not limited to the agreement on the basis
of approved EU standard contractual clauses per GDPR Art. 46. For more
information, see
If you would like further detail on the safeguards we
have in place, you can contact us directly as described in this Privacy Policy.
Data
Retention
We process your Personal Data for the minimum period
necessary for the purposes set out in this Privacy Policy, unless there is a specific
legal requirement for us to keep the data for a longer retention period.
We determine the appropriate retention period based
on the amount, nature, and sensitivity of your Personal Data, and after the
retention period ends, we will destruct your Personal Data. When we are unable
to do so for technical reasons, we will ensure that appropriate measures are
put in place to prevent any further such use of your Personal Data.
Privacy
of Young Children
Protecting the privacy of young children is especially
important to us. According to the different data protection and privacy
regulations, the Services are not directed to individuals under the age of
eighteen (18), and we request that these individuals do not provide any
Personal Data to us. We do not knowingly collect Personal Data from anyone
under the age of eighteen (18) unless we first obtain permission from that
child’s parent or legal guardian. If we become aware that we have collected
Personal Data from anyone under the age of eighteen (18) without permission
from that child’s parent or legal guardian, we will take steps to remove that
information.
Changes
to the Privacy Policy
We may update this Privacy Policy to reflect changes
to our information practices, but at least on an annual basis. Without your
explicit consent, we will not undermine your privacy rights under this Privacy
Policy. For any regular updates, we will provide such information in the Policy
page, or Notification Center in the Application, or other appropriate channels.
We encourage you to periodically review this page for the latest information on
our privacy practices.
If we make any material changes we will notify you by
channels that you can easily access to, for instance, email or SMS (send to the
email address specified in your account) or by means of a notice on this
website prior to the change becoming effective.
Contact
Us
If you have any questions about our practices or this
Privacy Policy, please contact us as follows:
Vantage Security
Postal Mailing Address: B3, Bredon House 321, Tettenhall,
Wolverhampton, UK
Email: info@vantagesecurity.com
Name: Emily Parker
Email: info@vantagesecurity.com