Archtron Research & Development Sdn. Bhd.
PRIVACY POLICY
Last Updated: 10 Nov 2023
Archtron Research & Development Sdn. Bhd. and its affiliates (“ARCHTRON”, “we”, “our”, “us”) provide following services for use in conjunction with various ARCHTRON products (“Products”): (1) software applications that can be downloaded to a mobile device (“Mobile Apps”) including not limited to Ximple W2 Plus App; and (2) any services available on the Website, Web Apps and Mobile Apps (“Available Services”). The term “ARCHTRON Services” means the Website, Web Apps, Mobile Apps, and Available Services.
This Privacy Policy explains how ARCHTRON handles the collection, storage, and disclosure of information, including personal information, regarding ARCHTRON Services. It also applies to any information we collect from the operation and use of Products we sell while connected to ARCHTRON Services and any other ARCHTRON services that link to this Privacy Policy.
You will need to register an account via Website or Mobile Apps to access ARCHTRON Services. For the purposes of seeking to provide you with a better experience, to improve ARCHTRON Services or otherwise where you have consented, with such account without new registration, you may access to other services provided by ARCHTRON over Internet and/or mobile applications. You may also from time to time ask us to migrate or export your personal information contained in one service to another services, where such migration option is available. Any applicable privacy policy may apply to specific services provided by ARCHTRON, you are advised to read this Privacy Policy and any specific policy for your interest before using the services. We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.
We may modify this Privacy Policy at any time, provided certain provisions of this Privacy Policy prove to be incomplete or outdated and further provided that these changes are reasonable for you, taking into account your interests. If we make material changes to this Privacy Policy, we >will notify you by the email address specified in your account or by means of notice on the Website or apps of any such changes.
By using ARCHTRON Services and Products or other acting permitted by the applicable laws, you are deemed to have read, acknowledged and accepted all the provisions stated herein this Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e. g. General Data Protection Regulation in Europe Union), we will specifically seek prior express consent to the particular processing (e. g. providing marketing materials to you) of personal information. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.
You can determine when this Privacy Policy was last revised by referring to the date it was “Last Updated” above.
1. Definitions
2. The Type of Personal Information We Process and Why We Collect it
3. How We Use Your Personal Information
4. Cookies and Other Technologies
5. Personal Information Processed on Your Behalf as a Processor
6. How We Share Your Personal Information
7. Securing Your Personal Information
8. Your Rights and Retention of Your Personal Information
9. Social Community Features and Social Networks
10. Your Choices
11. Children’s Privacy
12. Global Operations and Data Transfers
13. Contact Us
14. Additional Terms
1. Definitions
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 physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, telephone number and Email address.
Personal information also includes information that alone cannot directly identify you, but with other information we have access to can identify you, such as product serial numbers, log data that automatically records information about your visit, such as your browser type, domains, page views, the URL of the page that referred you, the URL of the page you next visit, your IP address, and page navigation, unique device ID collected from Products and your mobile devices, the country and time zone of the connected Product, geo-location, mobile phone carrier identification, and device software platform and firmware information.
2. The Types of Personal Information We Process and Why We Collect It
In order to provide ARCHTRON Services to you, as a controller or processor, we collect and process your Personal Information. We will ask you to provide Personal Information that is necessary to provide those services to you, and we process the Personal Information which you voluntarily provide to us. If you do not provide your Personal Information, we may not be able to provide you with our Products or ARCHTRON Services. We may also collect Personal Information from publicly or non-publicly accessible sources, for example, Google, where you use your Google Account to register an ARCHTRON account.
Here are more details on the types of Personal Information we collect when you use ARCHTRON Services and Products:
§ When you create your account to use ARCHTRON Services (“Account”), we will collect information including email address.
§ When you add, install, activate and manage Products, we will collect certain basic information via ARCHTRON Services, such as your product name, the product’s serial number, and IP addresses which are unique to the Product connected to ARCHTRON Services and associated with your Account.
§ When you save and share content through ARCHTRON Services, like device, captions, and comments (“Your Content”), for other individuals to access, we will collect information to allow you to save and share Your Content, such as your email address and email address of the person you elect to share your content with.
§ Through ARCHTRON Services, you may be able to invite other people such as friends or family to use ARCHTRON Services and download our mobile app. We collect that person’s email address to automatically send an email invitation on your behalf. We collect this information to register your friend or family member, and to track the success of our invitation services. In order to refer a friend, you must first obtain the consent from the person being referred to provide information on their behalf and inform them that they will be receiving a communication from ARCHTRON.
§ When you respond to our e-mails, contact our customer service, or use other customer support tools, we collect your information to provide you with support, verify your identity with your Account profile information, and confirm your Product.
§ When you access ARCHTRON Services, we will collect information related to how you use ARCHTRON Products and Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities, to provide you with a more relevant experience, to improve ARCHTRON Products and Services, to prevent misuse, and to ensure that ARCHTRON Services are working properly. We may also record adjustments you make to our Products through ARCHTRON Services. We store this information along with data collected directly by your Product. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
§ We also collect information from and about the devices you use to access ARCHTRON Services. This includes information like the browser, device name, type of network, operator you use, device model, system version, language and time zone of your device.
§ When you use Third Party Services, in general, the corresponding third party service providers shall collect and process your Personal Information for providing services only after obtaining your authorization for permissions or offline consent, specifically, certain permission(s) managed through ARCHTRON Services, such as alarm push notification, may be reserved to such third party service providers by default to the extent that it is necessary under specific service situation. You, as the data subject, are suggested to learn about detailed influences of permissions authorization or reservation as listed in the Permission Statement, and shall agree with the third party service providers separately about related data protection obligation.
§ Other Personal Information you provide us with.
3. How We Use Your Personal Information
We process your Personal Information as a controller: (1) to provide ARCHTRON Services described in User Agreement; (2) in furtherance of our legitimate interests in operating ARCHTRON Services and business; and (3) with your consent. In some cases, we may process your information to comply with applicable law, legal process, or regulation, e.g. meeting a legal obligation, a court order, official request or other binding decision(s), such as sharing data with law enforcement or tax authorities.; protect any person from death or serious bodily injury; or to carry out a task in the public interest.
(1) Examples of ARCHTRON processing your personal information to provide you ARCHTRON Services include:
a. Providing, processing, maintaining, improving and developing the ARCHTRON Services and Products.
b. Personalizing your experience with ARCHTRON Services and Products.
c. Providing support and responding to your requests and enquiries.
d. Communicating with you about ARCHTRON Services, your Products, or addressing any general queries, such as updates, customer support.
f. Sending you reminders, technical notices, updates, alerts, support and administrative messages, service bulletins, and requested information.
(2) Examples of ARCHTRON processing your information in furtherance of our legitimate interests in operating ARCHTRON Services and business include:
a. For fraud prevention and detection.
b. Increasing the safety of ARCHTRON Services and Products – for example, for user authentication, security protection, fraud detection, filing, and backups.
c. Analyzing and developing statistical information about the use of ARCHTRON Services to better improve ARCHTRON Services.
d. Enhancing other information we have about you to help us better understand you and determine your interests.
e. Protecting our rights or property, enforcing our User Agreement and legal notices and for the establishment, exercise and defense of legal claims.
f. Managing our everyday business needs, such as auditing, administration of ARCHTRON Services, forum management, fulfilment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and User Agreement.
(3) Examples of ARCHTRON processing your Personal Information with your consent, include:
a. Contacting to tell you about our Available Services and Products as well as other promotions, which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us or unless you have not given us your consent in line with Applicable Data Protection laws.
b. Collecting feedback or answers to our questionnaires from you to improve our Services and Products, and develop new features.
5. Personal Information Processed on Your Behalf as a Processor
Where Personal Information of third party individuals (“Third Party Data”) are collected and processed via the Products purchased by you, ARCHTRON will process such Third-Party Data, as a processor, on your behalf.
6. How We Share Your Information
We do not sell any Personal information to third parties. ARCHTRON may share personal information with third parties on the basis of non-disclosure agreements. You hereby consent that we may disclose personal information to these third parties:
§ We share your personal information with ARCHTRON affiliates, who are required to use that information in accordance with the purposes described in this Privacy Policy.
§ We use service providers, vendors, technicians and other third-parties to help us process, store, and protect some of your data and otherwise help us administer our Products and ARCHTRON Services effectively, provide a better user experience and increase the quality of our Products and ARCHTRON Services. These third-parties are forbidden from using your personal information for non-ARCHTRON purposes and are required to protect your information in accordance with this Privacy Policy and applicable laws.
We may provide information to third-parties if we believe in good faith that we are required by mandatory law to do so. For example, to comply with legal orders and government requests; response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts; to protect the interests of our customers and users of ARCHTRON Service; to respond to claims that any content posted or displayed using ARCHTRON Service violates the rights of third parties; in an emergency protect the health and safety of users of ARCHTRON Service or the general public; or to enforce compliance with our User Agreement.
If ARCHTRON and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such circumstance, we will notify you by the email address specified in your account or by means of notice on website of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.
We share information to protect our own legitimate business interests when we believe in good faith that we are required or permitted by law to do so. For example, we may share your personal information as needed to support auditing, compliance, and corporate governance functions; to combat fraud or criminal activity; to protect our rights or those of our affiliates and users; or as part of legal proceedings affecting ARCHTRON.
We may also disclose non-personal information (for example, aggregated or anonymized data) publicly or with third-parties, provided those data have been rendered anonymous in such a way that the data subject is no longer identifiable. For example, we may share non-personal information:
· for the same reasons we might share Personal information;
· to better understand how our customers interact with ARCHTRON Services and Products, in order to optimize your experience, improve our products, or provide better services;
· for our own research and data analytics; or
· to our vendors for their own analysis and research.
7. Securing Your Personal Information
ARCHTRON has implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We also conduct periodic reviews and assessments of the effectiveness of our security controls.
Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, ARCHTRON cannot guarantee that your personal information is under absolute security with the existing security technology. However, we will handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.
If you have any questions about the security of ARCHTRON Services, you can contact use by email at technical@bluguard.com.my.
8. Your Rights and Retention of Your Personal Information
ARCHTRON generally stores your personal information on ARCHTRON’s servers which is established upon third-party servers, including Amazon Server, until you delete or edit it, or for as long as you remain a ARCHTRON user in order to provide you with the most relevant offers. Please contact us using the contact details below if you would like more information about our retention policies.
Keeping your personal information current helps ensure that we provide you with the most relevant offers. You can access, update or delete your personal information via your Account profile. We are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile and data.
9. Social Community Features and Social Networks
Social Community Features
ARCHTRON Services may allow you to publicly post or share information, communicate with others, or otherwise make information accessible to others. Prior to doing so, please read our User Agreement carefully. All the information you post, share, or communicate may be accessible to anyone with Internet access, and any personal information you include may be read, collected, and used by others.
Links to other websites
We may permit others to link to ARCHTRON Services or to post a link to their website. We do not endorse these websites and are not responsible for other websites or their privacy practices. Please read their privacy policies before submitting information.
10. Your Choices
We think that you benefit from a more personalized experience when we know more about you and your preferences. However, you can limit the information you provide to ARCHTRON as well as the communications you receive from ARCHTRON through your Account preferences.
Device Data
You may manage how your mobile device and mobile browser share certain device data with ARCHTRON by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
11. Children’s Privacy
ARCHTRON does not intend that any portion of its ARCHTRON Services will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction and such use is prohibited. ARCHTRON Services are designed and intended for adults. By using ARCHTRON Services, you represent that you are at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction in order to create an account and purchase the goods or services advertised through ARCHTRON Services. If we obtain actual knowledge that an account is associated with a registered user who is under the age of 18 years old, or equivalent minimum age in the relevant jurisdiction, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us please contact us by email at technical@bluguard.com.my. A parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof.
12. Global Operations and Data Transfers
We transfer and process your information globally both in our own facilities and with service providers, or partners, regardless of where you use our services. As ARCHTRON operates globally, we may transfer your personal information to our affiliates worldwide, when processing that information for the purposes described in this Privacy Policy, e.g. if you request for customer services from ARCHTRON, our colleagues in China may access certain of your information (wherever you are located) in order to provide the requested services to you. We shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You hereby agree to transfer the data and you have the right to be informed of the appropriate safeguards taken by ARCHTRON for this transfer of your Personal information.
Currently we have data centers in the U.S. and Ireland. The laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.
13. Contact Us
Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can always reach us by email at technical@bluguard.com.my. Please provide: (i) your name, Email address (to identify your account) and preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links.
14. Additional Terms
EU/UK addendum
If you are located in the European Economic Area (“EEA”) and the UK, please note:
i) For purposes of EU data protection legislation, Archtron Research & Development Sdn. Bhd. is the data controller responsible for the personal information processing covered by this Privacy Policy.
ii) You have a right to object to the processing of your Personal Information where the processing is carried out for our legitimate interests. Subject to limitations in applicable data protection laws, you have certain rights in respect to your Personal Information, such as a right of access, rectification, erasure, restriction, objection, portability and the right not to be subject to decisions based solely on automated processing, including profiling. In order to exercise your rights, please contact us. You also have the right to withdraw your consent at all times, free of charge. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal. However, your withdrawal may affect your continued use of ARCHTRON Services. If you have concerns about how we handle your Personal Information, you have the right to lodge a complaint with a data protection authority.
US addendum
If you reside in some states of the United States, you may have additional privacy rights pursuant to those state privacy laws.
The Additional State-Specific Privacy Notice (“Notice”) provides additional information to California residents and Virginia residents whose personal information is processed by Archtron Research & Development Sdn. Bhd. (collectively, “ARCHTRON”) pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”). Any terms defined in the CCPA and VCDPA have the same meaning when used in this Notice.
Categories of Personal Information Collected
ARCHTRON may collect the following categories of personal information:
Categories of Personal Information:
|
Business situation/Function |
Types of Data |
ARCHTRON’s role |
|
Account registration |
User’s nickname, country/region, phone number, e-mail address and password |
Controller |
|
Tracking |
Language setting, country |
Processor |
|
Product sharing |
The information of shared products and email address of the user receiving the shared products |
|
|
Product management |
Products information, e.g. the products names, serial numbers, IP address, etc. |
|
|
Personnel management |
account (e-mail), picture and authorities of the end user’s personnel |
|
|
Authority management |
Picture, nickname, of the end user’s personnel |
|
|
Alarm function |
Alerts information reported by the products, different products capture different data types, which may include timestamps, products serial numbers, event types |
Categories of Sensitive Personal Information as Defined in the CCPA:
-Email address
Please see the “Collection of Your Information” section of this Privacy Policy for more details about our information collection practices.
Categories of Sources from Which We Collect Your Personal Information
We may obtain and combine personal information from different sources:
Provided directly by you;
Collected from a device associated with you;
Collected from another company within our family of companies;
Collected from a third-party source that process your personal information on your behalf.
Purposes for Collecting Personal Information
We may use your personal information for the purposes described in the Use of Personal Information section of this Privacy Policy and as provided below:
(1) to provide ARCHTRON Services described in User Agreement; (2) in furtherance of our legitimate interests in operating ARCHTRON Services and business; and (3)in some cases, we may process your information to comply with applicable law, legal process, or regulation, e.g. meeting a legal obligation, a court order, official request or other binding decision(s), such as sharing data with law enforcement or tax authorities; protect any person from death or serious bodily injury; or to carry out a task in the public interest.
We only use and disclose sensitive personal information for the purposes permitted by the CCPA.
Sales of Personal Information
We do not and will not sell the personal information we collect for purposes of the CCPA. And during the 12-month period prior to the Last Updated date of this Notice, we have not sold any personal information.
Sharing of Personal Information
We do not share your personal information for cross-context behavioral advertising, as defined in the CCPA. And during the 12-month period prior to the Last Updated date of this Notice, we have not shared any personal information for cross-context behavioral advertising.
ARCHTRON does not knowingly share, for cross-context behavioral advertising, the personal information of consumers under 16 years of age.
Disclosure of Personal Information for Business Purpose
We may disclose your personal information to third parties (eg. service providers) for business purpose, as described in “6. How We Share Your Personal Information”. During the 12-month period prior to the Last Updated date of this Notice, we didn’t disclose any of your personal information.
CCPA Retention Disclosure
ARCHTRON stores your personal information for as long as necessary to provide the products or services, verify your identify, respond to your requests or questions, or fulfill the purposes stated in this Privacy Policy, unless otherwise requested by you or permitted by law.
VCDPA De-Identified Data Disclosure
We may use de-identified data in some instances. We either maintain such data without attempting to re-identify it or treat such data as personal data subject to applicable law.
Your Rights
You may have certain rights under the CCPA or VCDPA, including to:
· request information about ARCHTRON’s collection of your personal information and provide the specific pieces of personal information that ARCHTRON has collected in a portable way;
· access your personal information in a portable format;
· correct your inaccurate personal information;
· delete your personal information.
To exercise your rights, please submit your request by Email address: technical@bluguard.com.my
Depending on your data choice, some of the functionality and features available to you may change or no longer be available to you.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. For California residents, if you would like to use an authorized agent to exercise your rights, we may request evidence that the agent has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests in certain circumstances permitted by applicable laws, such as where we have a reasonable belief that the request is fraudulent. We will notify you with reasons for the denial. In the event that you desire to appeal a denial decision on your request, you may contact us with any Email address: technical@bluguard.com.my.
We will not discriminate against you for exercising your rights and choices under the CCPA.
If you have any questions about this Notice or need to access it in an alternative format due to having a disability, please contact technical@bluguard.com.my.
