Privacy & X-Guard – GDPR/AVG

GDPR

X-Guard is committed to comply with the new law on the protection of personal data. The GDPR sets new requirements for how organizations are supposed to deal with your privacy.

On this page you will find our original privacy policy with additions concerning the GDPR. In connection with this, the following concrete questions were asked to ensure GDPR Compliance:

  1. Which suppliers/ third parties use X-Guard information?
  2. What data do we store?
    1. Why is this data stored?
    2. Is there a legal basis for storing this data?
    3. What is the origin of the data?
      Supplier/ third party, collected directly from the user or by X-Guard
    4. Which suppliers have access to this information?
    5. Does this data remain within the EEA?
    6. How long will this data be kept?
    7. Can the data be further anonymised (Privacy by Design)?
  3. Do we have processing agreements with all parties?
    1. Suppliers
    2. Jointly responsible parties
  4. Have all employees signed an NDA?
  5. Do we have a data breach protocol?
  6. How do we deal with data requests?
  7. Have our processes been set up correctly?
  8. Have we trained our staff sufficiently?

X-Guard works hard to ensure that all questions can be answered with clear and satisfactory answers. New processes are constantly being set up to ensure that the answer to these questions is satisfactory, also in the future.

Many of the above questions have been incorporated into our privacy policy below. In the unlikely event that you still feel insufficiently informed, you can contact us at any time.

General Privacy Policy

You can use our services in several ways: to search and share information, communicate with other people or create new content. When you share information with us, for example by creating an X-Guard account, we can make those services even better.

We want you to be able to clearly see how we use your information and how we can protect your privacy when using our services.

Our Privacy Policy explains:

  • What information we collect and why we collect it.
  • How we use that information.
  • The choices we provide, including how to access and update information.

Your privacy is important to X-Guard. Therefore, we ask you (whether you are a new or existing user of X-Guard) to take the time to read our privacy policy. If you have any questions, please feel free to contact us.

The information we collect

We collect information to provide better services to all our users in the following ways:

The information you provide to us. For example, many of our services require you to sign up for an X-Guard account. When you do this, we ask for personal data, such as your name, email address or telephone number.

The information we receive regarding use of our services. We collect information about the services you use and how you use them. This data includes:

  • Device information: We collect device-specific information, such as the hardware model, version of the operating system, unique device identifiers and mobile network information, including phone number. X-Guard can link your device IDs or phone number to your X-Guard account.
  • Log file information: When you use our services or view content provided by X-Guard, certain information is automatically collected and stored in server log files. This data includes:
    • Information about device events, such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request, and the referring URL.
    • Cookies that identify your browser or your X-Guard account.
  • Location information: When you use X-Guard services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS and other sensors that provide X-Guard with, for example, information about nearby devices, Wi-Fi access points and cell towers.
  • Unique application numbers: Certain services contain a unique application number. This number and information about your installation (e.g. operating system type and application version number) may be sent to X-Guard when you install or uninstall that service or when that service periodically contacts our servers, e.g. for automatic updates.
  • Local storage: We may collect and store data (including personal information) locally on your device using mechanisms such as application data caches.
  • Cookies and similar technologies: We and our partners use a variety of technologies to collect and store information when you visit an X-Guard service, which may include the use of cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you use services that we offer to our partners.

How do we use the information we collect

We use the information we collect from all of our services to provide, maintain, secure and improve the services, to develop new services, and to protect X-Guard and our users.

We can use the name you provide for your X-Guard profile in any of the services we offer that require an X-Guard account. In addition, we can replace names previously associated with your X-Guard account so that you appear the same across all our services. If other users already have your email address or other information that identifies you, we may display to those users your publicly visible X-Guard profile information, such as your name and photo.

When you contact X-Guard, we will record your messages to help resolve any issues you are experiencing. We may use your email address to notify you about our services, for example to notify you of upcoming changes or improvements.

We ask for your consent before using information for purposes other than those described in this Privacy Policy.

X-Guard processes personal data on our servers in many different countries around the world. We may process your personal data on a server located outside the country where you live.

A number of services and suppliers are used that have access to certain data from X-Guard. It has been carefully checked whether these companies have their privacy policy in order and are (also) preparing for GDPR Compliance.

The table below lists which suppliers process our data. Examples of data processed here have been added.

FreshDesk Helpdesk data: names, data that you email us
Slack Internal file sharing that may contain personal data or location data
Tawk.To Browser data, incoming chats on our website, length of your visit, number of (previous) website visits
Sentry Crash logs
HubSpot Customer data, contract data, outgoing and incoming emails related to our sales department, website visitors,

quotation requests

Tellu IoT AS Device data, contact information, location data, location history, usage statistics, alarm history
Google Website statistics, browser data, number of website visits, website events (e.g. forms that are completed),

all incoming and outgoing e-mail, personnel data, contact details, address books

Brunelco Demo account data, crash report data
Amazon (AWS) Logs, servers and databases (including all websites and systems that are internally managed with the

associated information: website visits, completed contact forms, website statistics)

Zube Anonymized crash logs

Transparency and options

People are concerned about their privacy in different ways. Our goal is to be transparent about the information we collect so that you can make informed decisions about how your information is used. For example, you can:

  1. Customize how the profile associated with your X-Guard account is displayed to others.
  2. Manage who you share information with through your X-Guard account.
  3. Transport data associated with your X-Guard account from many of our services.

You can also set your browser to block all cookies, including cookies associated with our services, or to indicate in which cases we may place a cookie. However, it is important to remember that many of our services may not function properly if the cookies are disabled. For example, we cannot remember your language preferences.

Information you share

Many of our services allow you to share information with others. Remember, when you share information publicly, it can be indexed by search engines, including Google. Our services provide you with various options for sharing and removing your content.

Access and update your personal data.

When you use our services, we try to give you access to your personal data. If that information is incorrect, we will try to provide you with ways to quickly update or delete it, unless we need to keep that information for legitimate business or legal purposes. When you update your personal data, we may ask you to verify your identity before we can process your request.

We may refuse requests that are unreasonably repeated, require disproportionate technical effort (such as developing a new system or making fundamental changes to an existing course of action), compromise the privacy of others, or would be highly impractical (such as requests regarding to data residing on backup systems).

Where we can provide you with options to access and correct data, we will do so for free, except where it would require a disproportionate effort. We strive to maintain our services in a way that protects data from accidental or malicious destruction. Therefore, after you delete data from our services, we may not immediately delete residual copies from our active servers or delete data from our backup systems.

Data we share

We do not share personal data with companies, organizations and individuals outside of X-Guard, except in one of the following circumstances:

  • With your consent: With your consent: We share personal data with companies, organizations or individuals outside of X-Guard when you have given us permission to do so. We require express consent to share sensitive personal data.
  • With domain administrators: If your X-Guard account is managed for you by a domain administrator (for example, for X-Guard Apps users), your domain administrator and resellers providing user support to your organization will have access to the data in your X-Guard account (including your email address and other details). Your domain administrator may be able to:
    • View statistics related to your account, such as statistics related to the applications you install.
    • Change your account password.
    • Suspend or terminate access to your account.
    • Access or save information stored as part of your account.
    • Receive your account information to comply with any applicable law, regulation, legal process, or governmental request.
    • Limit your ability to delete or edit information or adjust privacy settings.
  • For external processing: We provide personal data to our partners or other trusted companies or individuals so that they can process the information for us, based on our instructions and in accordance with our Privacy Policy and other appropriate confidentiality and security measures.
  • For legal reasons: We will share personal data with companies, organizations or individuals outside of X-Guard if we have a good faith belief that access, use, retention or disclosure of the information is reasonably necessary to:
    • Comply with applicable laws, regulations, legal process or requests from government agencies.
    • Enforce applicable Terms of Service, including investigating potential violations.
    • Detect, prevent or otherwise address fraud and technical or security issues.
    • Protect the rights, property, or safety of X-Guard, our users, or the public, as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners. For example, we may share data publicly to show trends related to the general use of our services.

If X-Guard is involved in a merger, an acquisition, or asset sale, we will continue to maintain the confidentiality of personal data and we will notify affected users before personal data is transferred or subject to any other privacy policy.

Data security

We work hard to protect X-Guard and our users from unauthorized access to or unauthorized modification, disclosure or destruction of information within our possession. In particular, the following applies

  • We encrypt many of our services with SSL.
  • We evaluate our data collection, storage and processing practices, including physical security measures, to protect against unauthorized access to systems.
  • We limit access to personal data to X-Guard employees, contractors and agents who need to know this data in order to process it for us. These individuals are subject to strict contractual confidentiality obligations and can be penalized or fired for failing to comply with these obligations.

Will the data remain within the EEA?

X-Guard only works with parties that process data within the European Economic Area (“EEA”). When using a hosting platform, an “availability zone” within the EEA will always be chosen. Concrete agreements have been made with all processing parties about the processing of data and where it may end up. There are no exceptions where data ends up is outside the EEA.

In what cases this Privacy Policy applies

Our Privacy Policy applies to all services offered by X-Guard B.V. and its partners, including services that X-Guard provides on Android, and iOS devices and services offered on other sites, but not on services that have separate privacy policies that do not include this Privacy Policy.

Our Privacy Policy does not apply to services provided by other companies or individuals, including products or sites that may be displayed to you in search results, sites containing X-Guard services, or other sites linked to our services. Our Privacy Policy does not cover the data policies of other companies and organizations that advertise on our services that may use cookies, pixel tags and other technologies to display and deliver relevant advertising.

Compliance and cooperation with supervisory authorities

We regularly check whether we comply with our Privacy Policy. We also adhere to multiple self-regulatory guidelines. When we receive formal written complaints, we will contact the person who made the complaint to discuss follow-up actions. We work with appropriate regulatory authorities, including local data protection authorities, to resolve complaints regarding the transfer of personal data that we cannot resolve directly with our users.

Amendments

Our Privacy Policy may be changed from time to time. We do not limit your rights under this Privacy Policy without your express consent. We will post any changes to the Privacy Policy on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notifications of Privacy Policy changes). We also keep previous versions of this Privacy Policy in an archive so you can always consult it.

Examples:

“Giving access to your personal data”

For example, the X-Guard Dashboard allows you to quickly and easily view some of the data associated with your X-Guard account.

“And other sensors”

Your device may have sensors that provide information to help understand your location. For example, an accelerometer can be used to determine things like speed and a gyroscope to detect how you are, such as unconsciousness detection.

“Device IDs”

With device IDs, X-Guard knows which unique device you are using to access our services. This information can be used to tailor our service to your device or analyse device issues related to our services.

“Your user experience”

For example, cookies allow us to analyse how users use our services.

“Legal process or requests from government agencies”

Like other technology and communications companies, X-Guard can receive requests from governments and courts around the world to hand over user data.

“Maintenance”

For example , we constantly monitor our systems to make sure they are working as intended and to detect and fix errors.

“Collect and process data about your actual location”

For example, X-Guard can centre the map view on your current location.

“Telephone number”

For example, if you add a phone number as a recovery option and you forget your password, X-Guard can send you a text message containing a code to reset your password.

“Security”

For example, one of the reasons we collect and analyse IP addresses and cookies is to protect our services from automated misuse.

“Delivering”

For example, the IP address assigned to your device is used to send the data you have requested to your device.

“Wi-Fi access points and cell towers”

For example, X-Guard can determine the approximate location of your device based on the known location of nearby mobile cell towers.

“Deleting your content”

For example, you can delete your history or your entire X-Guard account.

X-Guard uses cookies.

If you use our website, you agree that we will place cookies. More information can be found in our privacy statement.