We ask that you read this document carefully because it contains important information about how we collect and use your Personal Data, in terms of both transparency and security.
iKydz Ltd (including its affiliates and subsidiaries) referred to in this document as iKydz is committed to maintaining your privacy in the course of all its activities. The purpose of this document is to explain the range of measures that we take to protect your privacy, and provides information about how we collect, use, share and store data including your Personal Data (see definition below) which is gathered as a result of the various services and activities that arise as a result of the relationship(s) we have entered into with you.
The purpose of collecting this Personal Data by iKydz is to comply with our obligations and responsibilities to you when you avail of our iKydz Services and the use of our website. When you buy or use our iKydz Products and Services and our website you are agreeing to our Terms and Conditions of Use. Please read carefully the iKydz Terms and Conditions of Use. These are the main legal basis on which iKydz rely to process your Personal Data. In certain limited circumstances iKydz will rely on your explicit and informed consent as the legal basis to process your Personal Data; this occurs for example when you explicitly have to opt in in order to receive certain marketing information at the point of purchase of the iKydz Services. You will be notified in advance of your right to opt out of receiving any future marketing information.
The iKydz Services that we provide to you include the use of the iKydz website, or applications designed to access the website, whether stand-alone applications for computers or mobile devices, or the software incorporated into a iKydz Unit or the Application Protocol Interface (shortened to API) which simply allows the software to communicate with iKydz servers (to allow information to flow from the iKydz Unit to users).
This policy should be read in conjunction with our revised and updated Privacy Statement and Cookies Policy which relates separately to how we use your Personal Data when you access our website www.ikydz.com, and our revised and updated iKydz Terms and Conditions of Use. These documents have also been updated in light of the new EU privacy legislation which came into force on the 25th of May 2018.
To start with it is important you understand what is the information we collect and process that is covered by this policy. For further information on your privacy rights within the EU please visit www.gdprandyou.ie.
A. What We Mean by “Personal Data”
“Personal Data” means any information (this would include information specific to the natural subject or other information when gathered together) relating to an identified or identifiable natural subject who is living; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a first and last name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, genetic, mental, economic, cultural or social identity of that natural person.
iKydz gather this information from various sources including: email address, a home, postal or other physical address, other contact information (including information discoverable via access to your mobile device’s operating system), and other information, including information that you submit to or save within the iKydz Services.
B. The Purpose for holding your Personal Data
iKydz confirm that they will only obtain, collect and process your Personal Data which is consistent with the stated purposes as set out below. Such Personal Data shall only be kept for as long as the stated purposes to which such data apply. Such Personal Data shall be kept in accordance with the company’s Data Retention Policy. However, in certain limited circumstances your Personal Data may be retained as required by statutory law.
When you use iKydz Services, the primary identifier that we work with is the ID Number of your iKydz Unit. This prevents unnecessary transfer of Personal Data whenever possible. iKydz does not need to know “who” is using the iKydz Services and in fact cannot identify who owns what devices that are connected to the iKydz Unit. Rather, we need to know “which” device is requesting, posting, or otherwise interacting with the API. The iKydz Unit Software carry preferences and filtering information independent of Personal Data.
We do log your IP address (the Internet address of your computer or network) to give us an idea of which parts of our website you visit and how long you spend there. This information is useful for us as regards how to improve our website design and layout and to provide improved services and products to you. It is also useful for us as regards understanding the geographical markets for our products and services. iKydz does not link your IP address to any Personal Data unless you have logged in to our website. Even then, the related Personal Data is encrypted while in transit and at rest.
Finally, during registration of your iKydz Unit or iKydz Mobile you are invited to submit information, including Personal Data, for the purposes of registering your iKydz Unit for warranty protection and creating your iKydz account. Once collected, this information is stored in a separate database, and is not readily accessible via the iKydz Services. The warranty period for the iKydz hardware is one year and so it will be necessary to hold such Personal Data for this purpose and for this duration.
In order to provide our services to you, we need to contact you, at times, using the contact details (email, phone number) that you have provided to us. You may at any time opt out of this by contacting us at firstname.lastname@example.org and informing us that you wish to opt-out of these communications, although this may limit the service that we can provide to you. To provide our service it will be necessary to hold certain Personal Data relating to you. At present we use MailChimp and Agile CRM, well known third party services, and our iKydz app to send this information to you. If you no longer want to receive such information you may also send a request to the company (see contact details at paragraph G below) and we will delete your Personal Data that we hold for that specified purpose.
You may also choose to receive information on our products and services and up to date news via our submission form by giving us your email. We may use one or more service providers to administer these messages. At present our third party service providers for this service are MailChimp and Agile CRM. You may at any time chose to opt out of receiving these email messages by unsubscribing using the unsubscribe instructions at the bottom of each email or by contacting us via our website.
While you are a user of the iKydz Services it will be necessary to hold your Personal Data for the limited purpose of providing functionality and features via these services. Once you cease to use the iKydz Services on a permanent basis we will no longer store your Personal Data. Only in limited circumstances we will continue to hold your Personal Data for a particular purpose such as complying with our warranty obligations. In simple terms a warranty is our promise to you the customer that we will repair or replace the product or services you purchased from us within a specific period of time. Any Personal Data held by us will be in accordance with the company’s Data Retention Policy.
When you use iKydz Services via a mobile application, you may be providing Personal Data as you establish your account credentials, utilise the features of the iKydz Services, transmit information to iKydz’s API, and otherwise engage with the iKydz Services. iKydz has access to Personal Data for the limited purpose of providing functionality and features via the iKydz Services. Except as necessary to provide the iKydz Services, Personal Data stored on the mobile application is not shared with iKydz, and iKydz does not archive such information on its servers. iKydz servers do not aggregate or retain this information beyond what is necessary for the iKydz app to function. Although the information stored in a mobile application is password-protected, you should not expect that the information is entirely secure. You are primarily responsible for the security of information stored in the mobile application, and the mobile device itself.
In summary, we collect and use Users personal information for the following purposes:
- To process transactions – we may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.
- To administer a content, promotion, survey or other website feature
- To send Users information and tips
- To send periodic emails – the email address Users provide for order processing, will only be used to send them information and updates pertaining to their order and the service to which they have subscribed or purchased unless the user consented to subscribe to our newsletter list during checkout or through another opt-in on our website. A user’s email and information such as their phone number may also be used to respond to their enquiries, and/or other requests or questions. If a User decides to opt-in to our newsletter list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our website. Our third parties that we use to send our email newsletters and messages to our users (MailChimp and AgileCRM) also include detailed unsubscribe instructions at the bottom of each email or the user can contact them directly
- Provide support services
- Send administrative information, such as changes to our terms, conditions, and policies
- Administer promotions or contests
- Survey our customers to get valuable feedback to provide a better customer and user experience
- Facilitate social sharing functionality
- Analyse and monitor Services usage and to make improvements
- Help secure the Services, prevent fraud and enforce our policies
- Help personalise our Services
- Communicate about other iKydz services
- Perform other activities with consent
C. Tracking Technology
D. Personal Information Sharing and Disclosure
Your Personal Data is never shared outside the iKydz Services without your permission, except under certain limited conditions explained below. Bear in mind that iKydz cannot be held responsible for your own disclosure of Personal Data, whether accidental or intentional.
iKydz may send your Personal Data to other companies or people under any of the following circumstances:
- As necessary to perform the Services and complete payment transactions
- When we have your explicit and informed consent to share your personal data. An example of this would be when you sign up to receive up to date information on our new products and services when you purchase iKydz Services; you may opt out of this at any time by contacting us. Another example of this would be if you invite another user to access the iKydz Services on your account as an additional authorised user
- With companies and vendors that help us to operate our business by providing services such as website hosting, fraud screening, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services
- With third parties that have contracted with iKydz to perform certain functions on our behalf
- With third parties sponsor of promotions or contests where consent has been given
- With our authorised third party email, phone call, text message marketing and Customer Relationship Management tools such as MailChimp and AgileCRM.
- Anonymous information with Facebook to provide a better shopping experience and display the product you like or have recently viewed.
- When we need to share your information to provide the product or service you have requested as part of our responsibilities and obligations under the contract we have with you. We rely for example on vendors, service providers and technicians who provide services as regards the processing and storage of Personal Data and with the monitoring of our servers for technical problems. In order to provide the iKydz Services it is necessary at times to provide your Personal Data for specific purposes to these third parties in order to ensure you receive satisfactory services as agreed between you and us when you purchased the iKydz Services. The access to and the use of your Personal Data is only for these purposes. Examples of third parties include Stripe or Paypal who process sales on our behalf and who will hold certain Personal Data necessary to validate and complete your purchase transaction. Another example would be our cloud provider who hold your Personal Data on our behalf for the purposes of providing our iKydz Services to you via our online CRM system, Agile CRM through whom we provide marketing services. As regards any transfer of Personal Data to our cloud provider this will only be on the basis of a data processing agreement. Another example would be where the iKydz Unit would have to be accessed remotely in order to troubleshoot, debug, and otherwise offer support and solutions to iKydz Unit users. iKydz does not access a given iKydz Unit unless a support request has been received from the user. Once the support request has been completed iKydz will discontinue access to the unit. By agreeing to the iKydz Terms and Conditions of Use you are permitting iKydz or its duly authorised support representatives to access your iKydz Unit as a result of your support request.
- When you have told us to send the information to other individuals on your behalf.
- If the company is sold: if a sale or transfer of the company occurs your Personal Data may be part of the assets sold or transferred.
- We will also disclose your Personal Data in good faith if required to do so for legal reasons. For example, we may disclose Personal Data in response to a legal process (for example where we have to enforce our Terms and Conditions of Use) or where we are requested to do so as a matter of law by public authorities for the purposes of law enforcement and national security.
Data associated with your direct iKydz Service is not transferred outside the EEA and Switzerland (European Economic Area which is all the EU Member States + Lichtenstein, Norway and Iceland).
MailChimp & AgileCRM Email marketing messages & subscription: Under GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations, will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with GDPR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences. You can also unsubscribe from our EMS lists by contacting us at email@example.com. Please note that we may not be able to provide you with your subscribed service should you choose to remove yourself from our list of customers.
Our EMS providers are MailChimp & AgileCRM and the following information is held about you within their EMS systems:
- Email address
- P address
- Subscription time & date
- Phone (if provided)
- Your Name (if provided)
- Product Category of past orders
Agile CRM Inc: (“Agile CRM” or “AgileCRM” or AgileCRM.com) is keen on data security as we are well aware that our users (you) care about how the personal information is used. Hosted on high performing Google & Amazon clouds, we assure you that all our customer information is held confidential. We never sell our customer list or our customer information. All the customer information collected such as name, email address, phone number, website, social media handles, mailing address, billing information or any other information related to third party integrations is collected for the sole purpose of providing best services to our customers and to update them of the improvements to our product and services.
We will send product updates, special offers or promotional notices via mail, email or voice broadcast, from time to time, to our customers and prospects who have expressed interest and requested such information. The customer/ prospect can always opt out from receiving such offers/ notifications by following the opt out link on the specific communication.
Google Analytics: We use Google Analytics, an analytics service, to help us analyse the traffic on our Site. For more information on Google Analytics’ processing of Personal Information, please see “How Google uses data when you use our partners’ sites or apps.”
Facebook: We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter of GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation:
Embedded content from other websites: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Media: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact form / Request an Appointment: Information submitted through the contact forms on our site are sent to our company email, hosted by Microsoft. Microsoft adheres to GDPR and the EU “Privacy Shield” policy and you can find more information about this here.
While we keep these submissions for customer service purposes they are never used for marketing purposes or shared with third parties, unless the user has explicitly consented to this.
If a lawful request is made to transfer Personal Data outside the EEA or Switzerland for the purposes of law enforcement and national security iKydz may be required by law to transfer such Personal Data; in this situation iKydz will carry out all reasonable technical endeavours to ensure your data is appropriately protected. If there are transfers of Personal Data to the US in response to a legal process and lawful request, iKydz will seek to comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework (currently in place).
The only situation where your Personal Data may form part of an asset is if iKdyz was sold or acquired. Under no other circumstances is your Personal Data sold or rented to a third party.
E. On Line Use by Children Under the Age of 13
F. Remote Access of Your iKydz Unit
The End User License Agreement for the iKydz Unit or iKydz Mobile services authorises iKydz or its duly authorised support representatives to access iKydz Devices and Accounts remotely. iKydz requires such access in order to troubleshoot, debug, and otherwise offer support and solutions to iKydz Unit and iKydz Mobile users. iKydz does not access a given iKydz Unit or Acount unless a support request has been received, and it becomes apparent to the support representative that there is a problem that can be solved via remote access. If you wish to limit the level of access iKydz or its duly authorised support representatives have to your iKydz Device or Account, you must state what limitations you wish to place on iKydz’s use of remote access at the time of your support request. iKydz or its duly authorised support representatives will only access your iKydz Unit or Account under the conditions that you set. Whether or not you set any limitations on remote access, iKydz will discontinue access upon resolution of the support request.
We at iKydz acknowledge the importance of ensuring your Personal Data is kept safe and secure while under our control. iKydz employ the most appropriate physical and technical measures in light of the state of technological development, including staff training and awareness in the area of data security. iKydz along with our technical support review on a regular basis these measures to ensure that your Personal Data is kept as safe and secure as reasonably possible.
H. Data Retention
We retain personal data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the website to you, your account with us remains open or any period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using the website for the purposes set out below.
After you have closed your account or ceased using the website for a period of at least 6 months, we usually delete personal data, however we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Terms and Conditions, or fulfil your request to “unsubscribe” from further messages from us.
We will retain de-personalised information after your account has been closed.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the website. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
I. Enforcing Your Data Protection Rights
Access to your Personal Data
If you wish to know what Personal Data we hold on you and for what purpose we hold such information or if you simply wish to amend, update or delete such information please contact us in writing at the address below. Please provide sufficient details which can help us locate and identify the Personal Data which you are requesting, e.g. previous addresses, customer account numbers etc. In most cases there is no charge made by us for providing this information. This is known as making a request for access to your Personal Data. We will endeavour to ensure that your personal details are up to date but your help would be appreciated to ensure that your information is accurate.
iKydz Limited, Unit 1A Hume Centre, Hume Avenue, Park West Industrial Estate, Dublin 12, D12 C8C7.
Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23
Tel: + 353 (0) 761 104800
Effective as of 25. May. 2018