Privacy Policy (GDPR / AVG)

X-Guard BV (hereinafter: X-Guard) is committed to complying with the new personal data protection law. The AVG or GDPR sets new requirements for how organizations must deal with your privacy.

On this page you will find our original privacy policy with additions for the GDPR. The following specific questions have been asked to ensure GDPR Compliance:

  1. Who does it use X-Guard information?
  2. Which data is collected by X-Guard?
  3. For what Is this data stored by X-Guard?
  4. How long is this data kept?
  5. What if you want to view, delete or change your data?

We have asked the following additional questions for the above questions:

  1. Is there a legal basis for storing the data?
  2. What is the origin of the data?
  3. Which suppliers have access to this information?
  4. Does this data remain within the EEA?
  5. Can the data be further anonymized (Privacy by Design)?
  6. Do we have processing agreements with all parties?
  7. Have all employees signed an NDA?
  8. Do we have a protocol for data breaches?
  9. How do we handle data requests?
  10. Are our processes set up correctly?
  11. Have we adequately trained our staff?

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

Many of the above questions are incorporated into our privacy policy below. If you still feel insufficiently informed, you can contact us at any time.

General

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

When you use our services, we want you to be able to clearly see how we use your data and the ways we can protect your privacy.

Our Privacy Policy explains:

  • What data we collect and why we collect it.
  • How we use that data.
  • The choices we offer, including how you can access and update information.

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

Our Privacy Policy applies to all services offered by X-Guard BV and its partners, including services provided by X-Guard on Android, and iOS devices and services offered on other sites, but not to services provided separately have 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 that contain X-Guard services, or other sites linked to our services. Our Privacy Policy does not cover the data practices of other companies and organizations that advertise on our services and may use cookies, pixel tags and other technologies to display and deliver relevant advertisements.

1. Who uses X-Guard information?

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

FreshDeskHelpdesk data: names, data that you email us for questions to our helpdesk employees
SlackFor mutual communication with X-Guard personnel
SentryCrash logs
HubSpotCustomer data, contract data, outgoing and incoming emails relating to our sales department, website visitors, quote requests
Google SuiteEmail traffic, agenda, forms, docs.
Google Cloud EMEA Limited (Ireland)Device information, contact information, contact lists, photos and images, location data, location history, usage statistics, alarm history, logs, servers and databases.
Google AnalyticsWebsite statistics, browser data, number of website visits, website events (e.g. forms being completed), all incoming and outgoing e-mail, personnel data, completed contact forms.
twillioA conference call is set up between the app users or the emergency center via Voice over IP
TeethAnonymized crash logs

 2. What data do we collect?

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

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 you for personal information, such as your name, email address or telephone number.

Information we receive based on your 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 hardware model, operating system version, unique device identifiers, and mobile network information, including phone number. X-Guard may associate your device IDs or phone number with your X-Guard account.
  • Log file data: When you use our services or view content provided by X-Guard, certain data is automatically collected and stored in server log files. This data includes:
    • Device event data, such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request, and the referring URL.
    • Cookies that allow your browser or your X-Guard account to be identified.
  • Location details: 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, for example, provide X-Guard with 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 (for example, the operating system type and the application version number) may be sent to X-Guard when you install or uninstall that service or when that service periodically contacts our servers, for example for automatic updates.
  • Local storage: We may collect and store data (including Personal Data) locally on your device using mechanisms such as application data caches.
  • Cookies and similar technologies: We and our partners use various technologies to collect and store information when you visit an X-Guard Service, which may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you use services we offer to our partners.
  • Contacts / Contact Lists: The app can query your contacts to determine whether you have saved important phone numbers such as the X-Guard Emergency Center phone number. We do not store this information or use this functionality for anything else. This feature is solely to ensure that you have saved the important phone numbers as provided by the app. Your contacts never leave your phone through our app.
  • Pictures: When you upload an image or photo to the app, this photo will be stored on our servers and may be displayed to Emergency Center staff or other users during an alarm situation.

3. What do we use data we collect for?

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

We may use the name you provide for your X-Guard profile in all 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 identifying information, we may display to these users your publicly visible X-Guard profile information, such as your name and photo.

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

We will ask your permission before we use data 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 in which you reside.

A number of services and suppliers are used that have access to certain data from X-Guard. Careful checks have been made to determine whether these companies have their privacy policies in order and (also) prepare for GDPR Compliance.

4. How long is data kept?

X-Guard retains this data for as long as this is necessary for the performance of services with you as a customer, or for as long as this is legally required. When requesting a service, you only give permission to use this data to perform this task. Fixed values ​​have been set for the following data. Dynamic data up to three months, alarm logging up to one year. If you wish to deviate from this, this can be included in the contract.

5. What if you want to view, change or delete your data?

People are concerned about their privacy in different ways. Our goal is to be clear about the data we collect so that you can make informed decisions about how your data is used. You naturally have the right to inspect, change or delete your personal data that X-Guard has collected about you. 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. Bring data associated with your X-Guard account from many of our services.
  4. Deleted given app users.

You can also set your browser to block all cookies, including cookies associated with our services, or to indicate when we place a cookie. However, it is important to remember that many of our services may not function properly if your 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 that when you share data publicly, it may be indexed by search engines, including Google. Our services give you different options for sharing and removing your content.

Access and update your personal information.

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

We may deny requests that are unreasonably repetitive, require disproportionate technical effort (such as developing a new system or making fundamental changes to an existing practice), jeopardize the privacy of others, or would be grossly impractical (such as requests regarding to data residing on backup systems).

Where we can provide you with opportunities to access and correct data, we will do so free of charge, except where this would require a disproportionate effort. We strive to maintain our services in a manner 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.

Information we share

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

  • With your permission: we share personal information with companies, organizations or individuals outside of X-Guard when you have given us permission to do so. We require explicit consent before sharing sensitive personal data.
  • With domain administrators: If your X-Guard account is managed for you by a domain administrator (for example, for your email address and other information). Your domain administrator may be able to do the following:
    • 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 data stored as part of your account.
    • Receive your account information to comply with applicable laws, regulations, legal process, or requests from government authorities.
    • Limit your ability to delete or edit data 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 data on our behalf, based on our instructions and in accordance with our Privacy Policy and other appropriate confidentiality and security measures.
  • For legal reasons: We share personal information with companies, organizations or individuals outside of X-Guard when we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
    • Comply with applicable laws, regulations, legal processes or requests from government authorities.
    • Enforce applicable Terms of Service, including investigating possible violations.
    • Detect, prevent or otherwise address fraud and technical or security problems.
    • 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 regarding the general use of our services.

If X-Guard is involved in a merger, acquisition, or asset sale, we will continue to maintain the confidentiality of personal information and will notify affected users before personal information is transferred or becomes subject to a different 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 data in our possession. In particular, the following applies:

  • We encrypt all our services with SSL/TLS.
  • 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 information to X-Guard employees, contractors and agents who need to know that information in order to process it for us. These individuals are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to comply with these obligations.

Does the data remain within the EEA?

X-Guard only works with parties that process data within the European Economic Area ('EEA'). When a hosting platform is used, 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 comes outside the EEA.

Compliance and cooperation with supervisory authorities

We regularly check whether we comply with our Privacy Policy. We also adhere to several self-regulatory guidelines. When we receive formal written complaints, we will contact the person who filed the complaint to discuss follow-up actions. We work with appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we are unable to resolve directly with our users.

modifications

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 indicate 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 notices of the Privacy Policy changes). We also maintain prior versions of this Privacy Policy in an archive for you to consult.

Version date: February 20, 2024