PRIVACY NOTICE FOR MOBILE ACCESS
BACKGROUND
1.1 This Privacy notice forms a part of the Mobile Access License and User Agreement and is part of the agreement between You and Walmek Security Innovations for the Licensed Materials and Services (both as defined in the Mobile Access License and User Agreement) (the “Agreement”). Capitalized terms in this Privacy notice have the meaning given to them in the Agreement.
We respect Your right to privacy and are committed to following applicable data protection rules to safeguard Your rights. We want to make sure that You understand the type of information We collect about You, how it is used and how We protect it.
We need to collect some information about You so that We can provide You with the Licensed Materials and Services. This Privacy notice describes the information We collect about You (“Data”) and how that Data is treated and for what purposes We may share the Data and how You can contact Us about Your Data.
WHAT THIS PRIVACY POLICY COVERS
1.2 We use Data for purposes which are not directly connected to providing You with the Licensed Material and Services (such as development of new products), We are responsible for the use of Your Data in accordance with applicable law. This privacy notice describes how We use Your Data.
THE DATA WE MAY COLLECT
1.3 We may collect the following Data:
Your name, phone number, email address, ID and password, and other data which Walmek Security Innovations uses to identify You when making it possible for You to use the Service.
1.4 We may collect the following Data:
Technical data and related information about the Device being used for the Services, including unique push ID, operating system, application software and peripherals;
Information related to the use and performance of the Licensed Materials and Services; and
Information about Your use of Our customer services and support.
If We need to collect additional information or access certain parts of Your Device, we will first inform You and/or ask for Your consent (as applicable) and the Data will only be used in accordance with this Privacy notice.
WHY WE COLLECT THE DATA AND BASIS FOR THE COLLECTION
1.5 We collect Your Data to:
license the Licensed Materials or Services to You and to enable Us to provide You with the Licensed Materials and Services and any associated products or services;
provide You with software updates and support, improve and develop new products and services, and maintain and manage Our websites and other related services;
communicate with You about the Services;
fulfil Our legal and administrative obligations (such as making tax returns/payments);
enforce this Privacy notice and the Mobile Access License and User Agreement;
protect the rights, property or safety of Us, Our customers or others.
We do not sell or trade the Data or collect or use it for direct marketing purposes.
We base Our right to collect Your Data on the need of Your Data in order to provide You with the Licensed Material and Services, as stated above. To the extent that Your Data is used to improve and develop new products and services or to maintain and manage Our websites and other related services, We base Our use of Your Data on Our legitimate interest to perform such actions.
WHO MAY WE DISCLOSE DATA TO?
1.6 If applicable, Data may also be transferred to:
local or foreign regulators, governments and law enforcement authorities, including tax collection agencies and stock or other exchanges;
local and foreign courts, tribunals, arbitrators or other judicial committees;
persons to whom We may assign or transfer Our rights or duties under this agreement or under any other agreement We may have with or concerning You;
persons in connection with any sale, merger, acquisition, disposal, reorganization or similar change of Our business (including any potential or actual purchaser of that business and that purchaser’s advisors); and
third parties, if so required to comply with mandatory law or requirements or to address fraud or technical issues.
PERIOD OF RETENTION AND USE
1.7 We will retain the Data for as long as is necessary for the relevant activity or services described above or for as long as We are lawfully required to do so.
The Data will be deleted or anonymised if:
the purpose of collection and use of Data has been achieved (as described above);
the business for the Licensed Materials or Services concerned is discontinued (if earlier than achievement of the purpose as stated above); or
in relation to Data used only for purposes not directly related to providing the Licensed Material or Services to You (as further described under Section 1.4 above), if You request that Your Data is deleted by contacting Us (for contact information please see Section 1.13 below).
Anonymous information used purely for statistical purposes may be stored for a longer period than set out above.
TRANSFER
1.8 We may share Your information with other companies in Our group or with Our trusted subcontractors for research and development, problem solving and in order to provide the Services and for the purposes set out in this Privacy notice. Processing of Data may therefore take place in countries other than Your home country. Data collected in the European Union (the “EU”) and European Economic Area (the “EEA”), may be stored, processed or transferred outside of the EEA, as described in this Privacy notice. The destination country may not offer the same level of protection of the Data as the country where You are located and may only provide You with fewer legal rights in relation to the Data. When transferring Data to countries outside the EU/EEA, We use EU model clauses approved by the European Commission, in order to ensure an adequate level of data protection. You find the EU model clauses here.
PRECAUTIONS
1.9 We protect Your Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, You are responsible for protecting the Device against unauthorized access and use, and any transmission of Data will be at Your own risk.
CHILDREN
1.10 The Licensed Materials or Services are not directed to children under the age of 18, and We do not knowingly collect Data from children under 18.
CHANGES
1.11 We may amend this Privacy notice from time to time. We will notify You before such change, through the Service.
INFORMATION AND ACCESS RIGHTS
1.12 You may at any time request the rectification or erasure of your personal data. Please note however that deletion could mean that Walmek Security Innovations cannot process requests or orders, or that your account expires. You have the right to request a copy of your personal data from our record. You have the right to request a limitation of the use of your personal data (for example if you deem the data to be incorrect) or the termination of use of your personal data (for example as regards the use of the data to improve Walmek Security Innovation’s website). You are entitled to request the personal data used to process an order, to administrate your account or our client relationship in a machine-readable format which you are entitled to transfer to another data controller.
1.13 Walmek Security Innovations is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to privacy@walmek.ie.
1.14 If you have a complaint regarding the processing of your personal data by Walmek Security Innovations you are entitled to report such dissatisfaction to the Irish data protection agency, DPC (Data Protection Commission), the supervisory authority for the personal data processing of Walmek Security Innovations.
Version 1.0 Jan 20th, 2021