Introduction
SparkTek International PTE. LTD (hereinafter referred to as "we", “us", or "our") respects your privacy and is committed to protecting it through our compliance with this Mobile App Privacy Policy (the “Policy”). This Policy describes the types of
information we may collect or that you may provide to us when you download, install, register with, access or use the SecuCenter software application for mobile devices and tablets (the “App”), and our practices for collecting, using, maintaining, sharing, protecting and disclosing that information.
This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.
BY CHECKING THE CONSENT BOX FOR THIS POLICY AND THE TERMS OF USE OR USING OR ACCESSING THE APP, YOU (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS POLICY AND THE TERMS OF USE; (B) REPRESENT THAT YOU ARE 18 YEARS OF AGE OR OLDER; AND
(C) ACCEPT AND AGREE THAT YOU ARE LEGALLY BOUND BY THIS POLICY AND THE TERMS OF USE. IF YOU DO NOT AGREE TO THIS POLICY OR THE TERMS OF USE, DO NOT ACCESS OR USE THE APP AND DELETE IT FROM ALL OF YOUR MOBILE DEVICES AND TABLETS.
We may modify this Policy from time to time (see “Changes to Privacy Policy" below). If you have any issues regarding this Policy, please contact us at developer@sparktekintl.com.
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/her physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, telephone number, email address, physical address, profile photo, job department and position.
Personal Sensitive Information: it refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, etc., depending on the definition provided by applicable laws.
APP: it refers to SecuCenter.
Software Application: it refers to remote access to cameras and recorders for live view, play back and receive alerts.
We may process certain types of personal information you consent to provide to us， or when it is necessary to provide our services to you or under which is permitted by applicable laws. You have the right to choose whether or not to provide the information we have requested. However, we may not be able to provide you relevant services if
you reject to provide your personal information.
We have set out below, in a table format, a description of all the activities we plan to process your Personal Information, and the specific legal grounds we rely on.
Note that we may process your Personal Information for more than one legal ground depending on the specific purpose of the activities. If you need details about the specific legal grounds we rely on to process your Personal Information, please contact us at developer@sparktekintl.com.
Activity | Type of Personal Data | Processing Purposes | legal Grounds for Processing |
A. When You use APP | |||
When you sign up with SecuCenter for the first time | Email address; country or region; nickname; password (encrypted); profile photo; | To allow us complete your registration, communicate with you and administer your account. Profile photo may be uploaded from local photo album in your mobile phone on a voluntary basis if you desire to have a more personalized account, omission to do so, does not affect the running of SecuCenter. | Consent from you |
When you change the details you used for registration | Email address; country or region nickname; password (encrypted); profile photo; | To allow the changes you have requested for. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use other functions of SecuCenter. | Consent from you |
When you add Compatible Hardware | Hardware SN; Hardware model; Wi- Fi info; Hardware | To process your request to add a hardware to your account and allow | Consent from you |
Name; Hardware password (encrypted); Hardware time zone and DST status | configuration of your hardware. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of SecuCenter’s other functions. | ||
When you use Live View function which provides you a real- time video display | Hardware SN; Hardware IP; Hardware Port Information; (real time) Video Stream | To provide you with the basic services of video display through SecuCenter | Performance of a contract or consent from you |
When you use Playback and Video Recording functions | Hardware SN, Hardware’s Channel ID, Record Files Path, (real time) video stream | To store your history record and allow you view it | Performance of a contract or consent from you |
Mac address; IP | |||
address; Hardware | |||
SN; Hardware model; | |||
Hardware firmware | |||
version; Country | |||
When you activate and configure the settings of the added Compatible Hardware | information (via IP address); Hardware location (via IP); Date of Hardware register; Hardware channel information; | To allow activation of your Hardware and its registration with our server | Consent from you |
Hardware | |||
offline/online status; | |||
Hardware | |||
configuration | |||
information | |||
Cover image; | You can set device name, | ||
When you set | Hardware name; | change cover image, and | |
Hardware name and | Channel information; | view channel name, device | Consent from you |
cover image | Hardware model; | model and SN. The | |
Hardware SN | processing of such |
information is needed for us to allow the changes you have required for and to inform you about the details of the Hardware added on your SecuCenter. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of SecuCenter’s other functions. | |||
When you enter Hardware password or use the reset function | Hardware SN; original password (encrypted), email address | To allow you enhance the security of your Hardware by adding a password or reset your password. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of SecuCenter’s other functions. | Consent from you |
When you use Hardware Share function | Hardware SN; Email address | To allow you the sharing of your Hardware with another user of SecuCenter as requested by you. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of SecuCenter’s other functions. | Consent from you |
When you use Delete Hardware function | Hardware SN; Email and (or) telephone number | To allow the removal of the Hardware from your account on SecuCenter and matched accessory as you requested us for. Refusing to provide such | Consent from you |
information may only result in your being unable to use this function, but does not affect your normal use of SecuCenter’s other functions. | |||
When you receive notification | Hardware SN; Push notice ID/alarm snapshot | To send you alarm notifications and provide you the services you have requested. | Consent from you |
When you use SecuCenter’s cloud services to extend your storage capability | Hardware SN; messages and video record; Hardware channel information | To allow you use of the cloud storage service (either free or added value version). Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of SecuCenter’s other functions. | Consent from you |
When you de-register from SecuCenter and cease to use our service | Telephone number (only of customers who sign up with SecuCenter via their telephone number), and (or) Email. | To allow us to complete your deregistration, and to delete all your Personal Information collected by us during the period of your use of SecuCenter. | Performance of a contract or consent from you |
When you use hosting service for device trusteeship purpose | Email address and precise geographical location | To notify the administrator of hosting service the device and SecuCenter user, and allow the administrator to confirm the location of SecuCenter device. | Consent from you |
B. Other Processing and General Legal Grounds | |||
Except for the above processing activities, we may process your personal information to the extent that at least one of the following applies: | |||
Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.
Processing is necessary for compliance with a legal obligation.
C. Video and Audio Data | |
Processing is necessary in order to protect the vital interests of data subject or of another natural person.
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested.
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of data subject which require protection of personal data, in particular where the data subject is a child.
Other lawfulness of processing as specified in applicable laws.
video (and in some cases audio) recordings or live feeds or streams and still photographic images;
readings or data from physical or virtual sensors (to the extent offered by or included with Compatible Hardware and supported by the App), including motion detection sensors, event sensors, temperature sensors, window/door sensors, passive infrared sensors, water sensors, carbon dioxide sensors and ambient light sensors.
Unless otherwise restricted by applicable laws, we may disclose your Personal Information or other information which does not identify you in the following situations:
To any third parties after obtaining the explicit consent of you or other data subject corresponding to or associated with the Personal Information you collect, provide and upload.
To our subsidiaries and affiliates to deliver services or facilitate the provision of services to you.
To contractors, service providers, and other third parties we use to support our business or provide you services.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company about our App users is among the assets transferred.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To exercise our rights arising from any contracts entered into between you and us, including the App Terms and Conditions and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Other situations which is permitted or required by the applicable laws and regulations.
When you use the App, certain third parties such as the mobile device manufacturer or the mobile service provider may use automatic information collection technologies to process your Personal Information. We cannot control these third parties’ activities and we will not be liable for the third parties’ products or services in any event.
We shall take all appropriate physical, electronic and management security measures to prevent your Personal Information from accidental losses and from unauthorized access, use, alteration and disclosure. For instance, we shall use encryption technology to improve the security of Personal Information and trusted protection mechanisms to prevent Personal Information from being maliciously attacked.
We highly recommends you to use comprehensive and complex password in protecting the security of your account. We shall ensure the security and confidentiality of Personal Information you provide.
In the case of a personal information leakage and other personal information security incidents, we shall without undue delay and, where feasible, after having become aware of it, notify the Personal Information breach to you and/or the supervisory authority competent in accordance with the applicable laws and regulations via email, phone, push notification, announcement or any other feasible methods in a reasonable and effective way. We shall inform you including the basic situation and possible impact, the disposal measures that we has taken or will take and recommendations for risk mitigation, etc.
We will retain your Personal Information for no longer than it is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. To determine the appropriate retention period for Personal Information, we may consider the amount, nature and sensitivity of the Personal Information, the potential risk from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
The APP is not intended for children under 16 years of age, or equivalent minimum age in the relevant jurisdiction (refer to “Child” or “Children” below), and we does not knowingly collect Personal Information from Children.
Children shall obtain the consent of your parents or legal guardians (“Consent of Guardian”) and carefully read this Policy before using this APP.
If we acknowledge that the APP has collected or received Personal Information from a Child, without verification of Consent of Guardian, we will delete that Personal Information. If you believe we might have any Personal Information from or about a Child, please contact us at developer@sparktekintl.com.
Since we have established affiliates in different regions around the world and we may offer our services through the use of servers located in different countries. As such, your Personal Information might be transferred outside the region and country you use the APP, including to regions/countries outside the European Economic Area
(“EEA”) which might have different legal rules and might not offer an adequate level of protection as determined by the European Commission. However, we have taken the necessary measures to ensure that your Personal Information is processed in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy. Your Personal Information may be stored or processed in multiple countries, such as Singapore, America, and Germany. For the
purposes described in this Policy, your information may be transferred to these territories in accordance with applicable law.
Your legal rights to your Personal Information are set out below:
Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Information. This enables you to delete or remove your Personal Information by submitting your request to us through “Delete Account” at “Me” - “Account Management” - “Delete Account”. You also have the right to request us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we is required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on our legitimate interest (or that of a third party), and there is something about your particular situation that makes you want to object to processing on this ground as you believe it affects your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise,
or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For security reasons, we will take steps to authenticate your identity before providing access to your Personal Information. You also have the right to lodge a complaint with the relevant Data Protection Authority.
We reserve the right to modify this Privacy Policy from time to time in our sole discretion. If we made material modifications to the Privacy Policy, we will notify you sending you an in-App alert the first time you use the App after we make the change. The date this Privacy Policy was last revised is identified at the top of the page. All changes are effective immediately when we post them and apply to all access to and use of the App thereafter; provided, to the extent required by law, we will seek your affirmative consent prior to applying material modifications to this Privacy Policy on how we use or disclose Personal Information that we collected or received prior to the date of the modification. You are expected to check this Privacy Policy frequently, so you are aware of any modifications, as they are binding on you.
To ask questions or comment about this privacy policy and our privacy practices, contact us at developer@sparktekintl.com.
SparkTek International PTE. LTD