Secure Afrique Privacy Policy
Last updated: July 8, 2021
Effective date: July 15, 2021
Secure Afrique and
subsidiaries (“we”, “us”, “our”, “Secure Afrique”) 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
your Personal 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:
For other branded mobile applications powered by Secure Afrique, 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 Provide 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, if these 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-based
functions through permission settings on your mobile device, we will collect
and process your location information to enable certain functions, such as pairing
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 Secure Afrique, 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 Secure Afrique, our affiliates, partners, you or other Secure Afrique 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 Secure Afrique, 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 emailing hello@secureafriq.com 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;
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, Secure Afrique 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:
Secure Afrique.
Postal Mailing Address: 78 Atlantic Blvd, Bakau, The
Gambia, West Africa.