Privacy Policy – Smart Systems

MEGAMAN^® operates Smart Home Systems and the corresponding INGENIUM^® Applications (“App”) and we are committed to respecting and protecting your data and your privacy. This policy informs you of how we collect, use and disclose personal data when you use the App and your rights in respect of that personal data.

We endeavour to be transparent about how we use any personal data we collect. By confirming your consent in the course of downloading and/or accessing and/or using any part of the App, you agree to the collection and use of personal data in accordance with this policy.

What this policy covers

This Policy informs you of our policies regarding:

1. Ownership of Data and Consent
2. What data we collect
3. How and why we collect Personal (and other types of) Data
4. How we use Personal Data
5. Transfer of Data
6. Circumstances under which we would share Personal Data / Third Parties with access to Personal Data
7. How we secure your Personal Data
8. Children’s Privacy
9. What are your responsibilities and What are your choice
10. The use of Cookies and Other Tracking Technologies

Ownership of Data and Consent

You are the owner of your data. By confirming your consent in the course of creating an account, downloading and/or accessing and/or using any part of the App you agree to be bound by the Terms of use and you further grant to MEGAMAN^® a non-exclusive right to handle your data, including Personal Data, according to the terms set out in this Policy.

You are entitled and may request a copy of all Personal Data that we hold about you or, if you have any questions relating to your Personal Data, please contact us.

What Data we collect

We collect personal data you provided to us, and also usage data, cookies data and non-personally identifiable data that we collect automatically.

How and why we collect Personal (and other types of) Data

The App obtains the personal data you provide when you download and register the App. Registration is mandatory in order to be able to use the features of the App and its related services.

Personal Data: When you create an account to use the App you will be required to provide us with personally identifiable information (‘Personal Data’) that can be used to contact you and/or identify you and/or provide you with a tailored service based on your subscription to the App. Personal Data may include, but not be limited to:

• First and Last name
• Email address
• Contact numbers
• Address
• Transaction-related information
• Cookies and Usage Data

We do not sell or rent any Personal Data supplied by our customers and we only share information in accordance with the terms of this policy.

If you submit personally identifiable information in response to anything contained in the App, this may require us collecting Personal Data. This Personal Data will only be used for the purpose for which it was intended but will, at all times, be done in accordance with our Terms of Use and this Privacy Policy.

Any further e-mail addresses, phone numbers and other contact information submitted to MEGAMAN^® voluntarily in the course of inquiries and comments are used only for purposes of taking action in relation to the nature of the inquiry or comment.

Usage Data: We may collect information that your mobile device sends whenever you access the App (‘Usage Data’). This Usage Data may include, but not be limited to:

• Type of mobile device
• Your mobile device unique ID
• The IP address of your mobile device
• Your mobile operating system and version
• The type of mobile internet browser you use
• Unique device identifiers
• Time logs
• Diagnostic data
• Real-time location information
• Information about the way you use the App

Cookies Data: Cookies are small files that are stored on your device for record-keeping purposes. We use cookies and similar tracking technologies (like beacons, tags and scripts) to collect and track information and your use of the App to enable us to analyse and improve the App and our service to you.

Non-personally Identifiable Data: This information is collected through the cookies and is used to periodically analyse the App logs to assess aggregate usage trends in order to better serve the needs of our customers. This information may also be used for purposes of systems administration, server troubleshooting and security purposes.

How we use Personal Data

The data that is collected is being used for different purposes, including:

• To provide a service and to maintain the App
• To notify you of any changes to the App
• To enable you to participate in the interactive features of the App if and when you choose to do so
• To provide customer care and support
• To provide analysis of the information to that we can improve our service and our App
• To monitor the usage of the App
• To detect, prevent and address any technical issues
• To comply with legal obligations
• Marketing promotions

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – servers that are located outside of your country where the data protection laws may differ from those in your country of residence.

If you are located in the European Economic Area (EEA) and United Kingdom (UK) and choose to provide information to us, please note that we process data, including personal data in a cloud-based server in the EEA. Technical support for such data processing may be located outside of the EEA.

Your consent to this Privacy Policy followed by your submission of such data through the App represents your agreement to such transfer of your data.

MEGAMAN^® will take all reasonable and required steps to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Data will take place to an organisation or country unless there are adequate controls in place, including the security of your data.

Circumstances under which we would share Personal Data / Third Parties with access to Personal Data

MEGAMAN^® may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of MEGAMAN^® from legal claims
• Prevent or investigate possible wrongdoing in connection with the App
• Protect the personal safety of users of the App
• Perform service-related services
• Protect against legal liability

We may employ third-party companies and/or individuals to perform service-related services in relation to the App or to assist us in analysing how the App is being used. These third parties will only have access to such Personal Data as is required to enable them to fulfil their legitimate tasks and are obligated not to disclose or use it for any other purpose.

How we secure your Personal Data

The security of your data is very important to us. Although no data can be guaranteed to be 100% secure when transmitted over the internet or electronically stored, we do take precautionary measures by striving to use commercially acceptable means, such as secure servers, to protect the security of the transmitted and stored data. And to prevent the risks such as the unauthorized access, destruction or loss of your Personal Data.

Children’s Privacy

Our Terms set out that you are required to represent that you are of sufficient legal age to register your details. The App is not intended for anyone under the age of 16 (‘Children’). We will not, therefore, knowingly collect Personal Data from Children. If you are a parent/guardian and you are aware that your Children have provided us with Personal Data, please contact us.

If we become aware that we have collected the Personal Data of Children, we will take steps to remove such information from our servers.

What are your Responsibilities and what are your Choices

Your Responsibilities. It is your responsibility to ensure that the data you provide us are accurate, complete and up-to-date.

Managing Your Information. We will retain your data for as long as you use the App and for a reasonable time thereafter to fulfil our legal responsibilities. If you would like us to delete data that has been provided by you via the App, please contact us. Some or all of the user provided data is required for the App to function properly. Should you wish us to delete this data the App may not work anymore.

Opt-out. You can stop all collection of data by the App by uninstalling it and unplug all the system devices connected to the Internet. You can use the standard uninstall processes that are available as part of your mobile device or via the applicable mobile application marketplace or network to delete the App from your mobile devices. You can also opt-out and erase your registered accounts by contacting us.

Data-Portability. We can only provide you with a copy of the personal data we hold about you, you have the right to provide such information to other organizations. We will require your request regarding personal data to be accompanied by proof of identity to ensure that we are providing data to the right person.

The use of Cookies and Other Tracking Technologies

Cookies. Most browsers are set to accept cookies, but should you not wish to receive cookies we recommend that you set your browser to refuse these. Disabling cookies from this App may affect your ability to use all or parts of the App.

Google Analytics. We use Google Analytics to enable us to develop and improve our services and the App. Google Analytics makes use of cookies to see how you use the App. If you don’t want data to be reported by Google Analytics, you can opt-out by installing the Google Analytics Opt-Out Browser Add-On.

Changes of Privacy Policy

We reserve the right to make changes to this Policy from time to time. We will notify you either clearly on the home page of the App or by email that changes will be made to this Policy, that the amendments may be viewed and then they become effective.

Updated: May 2018