Last Update: October, 2019
1. What Information We Collect
In order to provide ZEMGO SMART Services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.
“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, email address, physical address, and payment information.
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, data from cookies, pixel tags, and web beacons, the country and time zone of the connected Product, geo-location, mobile phone carrier identification, and device software platform and firmware information.
2. How We Collect and Use Your Information
Here are some examples of the personal information we may collect and how we may use it:
- When you create your account to use ZEMGO SMART Services (“Account”), we will collect information including your name, phone number and email address. In addition, when you install and activate Products, we will collect certain basic information via ZEMGO SMART Services, such as your product name, the product’s verification code, and serial number, which are unique to the Product connected to ZEMGO SMART Services and associated with your Account.
- When you subscribe to online data storage services, we will collect your payment information, such as a credit card number, account security code, and any other information necessary to complete the transaction and further facilitate and fulfill your subscription of storage services. Your personal information will be saved as your user profile in your Account, including payment information for recurring charges.
- When you save and share content through ZEMGO SMART Services, like video clips, live video streams, images, 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 ZEMGO SMART Services, you may be able to invite other people such as friends or family to use ZEMGO SMART 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 send this email, to register your friend or family member if your invitation is accepted, 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 ZEMGO SMART.
- When you connect or link to ZEMGO SMART Services via social networking sites, including by sharing Your Content with friends via your social networking account, such as Facebook, we collect your profile information from your social networking account. For information on what information is shared with us, please review the privacy settings in your social media account or the permission screen presented at the time of connection.
- 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 ZEMGO SMART Services, we will collect information to provide you with a more relevant experience, to prevent misuse, and to ensure that ZEMGO SMART Services are working properly. We may also record adjustments you make to our Products through ZEMGO SMART 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.
- When you save and share Your Content through ZEMGO SMART Services for other individuals to access, we will collect information to allow you to save and share Your Content.
- ZEMGO SMART Services may also contain links to other websites operated by third parties and may include social media features such as Facebook and Twitter buttons (such as “Like,” “Tweet” or “Pin”). We record your interaction with these links.
- When you use the Product’s recording or streaming features, we may record and process video and/or audio content from the Product. This may include capturing and emailing to you portions of this data as part of a notification or analyzing the data to identify motion or other events. We may process information from your Product so that we can send you alerts when something happens. In addition, if you have the recording features enabled, we will capture, process and retain video and audio data recordings from your device for the duration of your recording subscription period.
We may also use the information we collect for the following purpose:
- send you reminders, technical notices, updates, alerts, support and administrative messages, service bulletins, and requested information; and
- pursuant to our legitimate business interests:
- operate, maintain, improve, and develop ZEMGO SMART Services and Products;
- personalize your experience with ZEMGO SMART Services and Products;
- increase the safety of ZEMGO SMART Services and Products – for example, for user authentication, security protection, fraud detection, filing, and backups;
- perform analytics and conduct customer research;
- communicate and provide to existing customers additional information that may be of interest to you about our products and services;
- manage our everyday business needs, such as auditing, administration of ZEMGO SMART Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service;
- enhance other information we have about you to help us better understand you and determine your interests; and
- in the context of a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger) and to protect our rights or property, to enforce our Terms of Service and legal notices and for the establishment, exercise and defense of legal claims;
- with your express consent to
- send you electronic communications in order to inform you about new products and services, unless you choose to unsubscribe;
- use certain non-essential cookies to better understand user behavior, in order to optimize user experience, perfect function design and offers for products and services from us or to provide better services;
- meet a legal obligation, a court order or other binding decision(s); and
3. Cookies and Other Technologies
We may also engage one or more third party service providers to serve online advertisements on our behalf via ZEMGO SMART Services. They may use a pixel tag or other similar technology to collect information about your visits to sites, and they may use that information to target advertisements for our Products and ZEMGO SMART Services. For more information regarding this practice and to opt-out of such collection and use of this information by our third party service providers, please see www.networkadvertising.org.
4. How We Share Your Information
ZEMGO SMART may disclose personal information to cloud service provider, network service provider and other service providers on the basis of non-disclosure agreements.
The following are the limited situations where we may share personal information:
- 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 ZEMGO SMART Service; to respond to claims that any content posted or displayed using ZEMGO SMART Service violates the rights of third parties; in an emergency protect the health and safety of users of ZEMGO SMART Service or the general public; or to enforce compliance with our Terms of Service.
- If ZEMGO SMART 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 ZEMGO SMART.
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 ZEMGO SMART 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.
5. Securing Your Personal Information
ZEMGO SMART 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, ZEMGO SMART cannot guarantee that your personal information is under absolute security with the existing security technology. If you have any questions about the security of ZEMGO SMART Services, you can contact us by phone at 1-888-504-3318 or email at email@example.com.
6. Accessing, Correcting and Retention Your Personal Information
ZEMGO SMART generally stores your personal information on ZEMGO SMART’s servers which is established upon Amazon Servers until you delete or edit it, or for as long as you remain a ZEMGO SMART customer in order to provide you with the most relevant offers.
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. Your personal information might not be immediately deleted, as we are required to retain records relating to previous purchases through ZEMGO SMART Services for financial reporting and compliance reasons pursuant to applicable laws. In addition, because of the way we maintain certain services, after you delete certain information, we may temporarily retain backup copies of such information before it is permanently deleted.
7. Social Community Features and Social Networks
Social Community Features
ZEMGO SMART 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 Terms of Service 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 ZEMGO SMART 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.
8. 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 ZEMGO SMART as well as the communications you receive from ZEMGO SMART through your Account preferences.
You will only receive commercial e-mails from us if you have granted prior express consent or if sending those e-mails is otherwise permitted, in accordance with applicable laws.
You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send or by logging into your Account and adjusting your e-mail preferences. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your Account and your transactions on ZEMGO SMART Services.
You may manage how your mobile device and mobile browser share certain device data with ZEMGO SMART 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.
9. Children’s Privacy
ZEMGO SMART does not intend that any portion of its ZEMGO SMART 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. ZEMGO SMART Services are designed and intended for adults. By using ZEMGO SMART 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 ZEMGO SMART 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 phone at 1-888-504-3318 or email at firstname.lastname@example.org. 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.
10. Global Operations
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. 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. In the European Union (EU), we will store and keep Your Content inside the EU in encrypted form including when we utilize a third party for storage. In exceptional circumstances ZEMGO SMART in the US and China may have access to this content in order to provide product support services. Your registration data will be collected and used or stored by ZEMGO SMART, currently in the U.S., Singapore, Brazil and Ireland. ZEMGO SMART put in place contractual protections, approved by the European Commission, to secure your information. A copy of those contracts can be obtained by contacting us at the address below.
11. Contact Us
The data controller is FPC Security registered at 10025 NW 116 Way, Suite# 12, Medley, Fl 33178, United States.
For the purpose of the Law on Data Protection of the United States (the “Law”), the data controller is FPC Security registered at 10025 NW 116 Way, Suite# 12, Medley, Fl 33178, United States.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
* Information you give us. You may give us information about you by registering to use openseewebapp.zemgosmart.com or our app or entering into any contract for chargeable services.
* Information we collect about you. When you use your app or openseewebapp.zemgosmart.com we may automatically collect the following information:
* Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, device type and version, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
* Information about your use of the app, including any interactions with a security system.
* eMail – Your eMail is sent to us when you use Google sign-in function. eMail is required to register an account as it is used as a username.
* Name – Your name is sent to use when you use Google sign-in function. Name is an optional field filled during a regular registration. We use your name received from Google to auto fill the field so you don’t have.
* Camera data – Your devices’s camera is only used to scaning QR code during the system setup process.
* Device ID – Unique ID of your device is used to distinguish between different devices you have. This is so you could log-in simultaneously from multiple devices.
* Push token – Google FCM token assigned to your device is used for sending you push notifications.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
* Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
* Where you register with us for services we will use your personal information to provide those services to you including, for chargeable services, for billing purposes.
* Where you use the app to interact with a security system we will maintain a record of those interactions. This record will be visible to the system administrator (which may be a third party including the property owner, the tenant, a managing agent or an alarm installer). Where a third party system administrator has access to the personal data they are responsible for telling you how they will use it.
* to provide you with information about other goods and services we offer that are similar to those that you have already purchased.
* to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
* to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
* to allow you to participate in interactive features of our service, when you choose to do so;
* as part of our efforts to keep our site safe and secure;
DISCLOSURE OF YOUR INFORMATION
We may share your information with selected third parties including
* System administrators where your system is managed by a third party (i.e. not by you or us). Where a third party system administrator has access to the personal data they are responsible for telling you how they will use it.
We may disclose your personal information to third parties
* In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
* If FPC Security or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on secure servers provided by a third party. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We do not store credit card details nor do we share customer details with any 3rd parties.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise the right at any time by contacting us at email@example.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The Law gives you the right to access information held about you. Your right of access can be exercised in accordance with the Law. Any access request may be subject to a fee of 10 EUR to meet our costs in providing you with details of the information we hold about you.