SGA Home Security

PRIVACY POLICY

Last Updated: 28 July 2023

This Privacy Policy explains how SGA Kenya Limited handles the collection, storage, and disclosure of information, including personal information, regarding SGA Home Security App. It also applies to any information we collect from the operation and use of the devices we provide while connected to SGA Home Security App and any other SGA Kenya Limited Services that link to this Privacy Policy.

You will need to register an account via the SGA Home Security App, for the purposes of seeking to provide you with a better experience, to improve SGA Home Security App or otherwise where you have consented, with such account without new registration, you may access to other services provided by SGA Kenya Limited 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 service, where such migration option is available. Any applicable privacy policy may apply to specific services provided by SGA Kenya Limited, 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modify this Privacy Policy at any time, provided certain provisions of this Privacy Policy prove to be incomplete or outdated and further provided that these changes are reasonable for you, taking into account your interests.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 on app of any such changes.

By using SGA Home Security App 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

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, 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.

Administrator means anyone who creates and establishes organizational structure for your Home/Organization/Team and manage the use of Solution with administrative privileges on behalf of the Home/Organization/Team.

Individual User means any data subject, who is the user of SGA Home Security App, including but not limited to a member of your Home/Enterprise/Team.

Alarm Services means services provided by Alarm Receiving Center to Individual Users, of which, you can, with the permission of Individual Users, provide remote monitoring services by Alarm Monitoring Software, including ) alarming abnormal events of the receiving equipment; ii) obtaining device parameter information and arming and disarming the device; iii) video preview, video playback, picture capture, PTZ operation, video download within specific timing, etc.

Alarm Receiving Center means the operation center to provide Alarm Services.

2. The Types of Personal Information We Process and Why We Collect It

In order to provide SGA Home Security services to you, as a controller, 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 SGA Home Security Service. 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 account.

Here are more details on the types of Personal Information we collect when you use SGA Home Security App and Products:

3. How We Use Your Personal Information

We process your Personal Information as a controller: (1) to provide SGA Home Security App described in Terms of Services; (2) in furtherance of our legitimate interests in operating SGA Home Security App 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 SGA Kenya Limited processing your personal information to provide you SGA Home Security Services include:

  1. Providing, processing, maintaining, improving and developing the SGA Home Security App and Products.
  2. Personalizing your experience with SGA Home Security App and Products.
  3. Providing support and responding to your requests and enquiries.
  4. Communicating with you about SGA Home Security App, your Products, or addressing any general queries, such as updates, customer support.
  5. Sending you reminders, technical notices, updates, alerts, support and administrative messages, service bulletins, and requested information.

(2) Examples of SGA processing your information in furtherance of our legitimate interests in operating SGA Home Security App and business include:

  1. For fraud prevention and detection.
  2. Increasing the safety of SGA Home Security App and Products – for example, for user authentication, security protection, fraud detection, filing, and backups.
  3. Analyzing and developing statistical information about the use of SGA Home Security App to better improve SGA Home Security App.
  4. Enhancing other information we have about you to help us better understand you and determine your interests.
  5. Protecting our rights or property, enforcing our Terms of Service and legal notices and for the establishment, exercise and defense of legal claims.
  6. Managing our everyday business needs, such as auditing, administration of SGA Home Security App, forum management, fulfilment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service.

(3) Examples of SGA Kenya Limited processing your Personal Information with your consent, include:

  1. 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.
  2. Collecting feedback or answers to our questionnaires from you to improve our Services and Products and develop new features.

4. Cookies and Other Technologies

We also use cookies, web beacons, and other technologies to keep records, store your preferences, improve our advertising, and collect information such as log data and device data. This allows us to better understand how you use SGA Home Security Apps and Products, diagnose, and troubleshoot any problems you’re having, and otherwise administer and improve SGA Home Security Apps and Products. For more information about cookies, please refer to our privacy policy https://www.sgasecurity.com/privacy-policy

We may also engage one or more third-party service providers to serve online advertisements on our behalf via SGA Kenya Limited. 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 SGA Home Security Apps.

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, SGA Kenya Limited will process such Third-Party Data, as a processor, on your behalf.

In particular, when you use the Product’s recording or streaming features, we record and process video and/or audio content from the Product which will include Third Party Data. This includes capturing and sending in app notifications to you in portions of the Third-Party Data as part of a notification or analysing the Third-Party Data to identify motion or other events. We process Third Party Data 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 recordings from your Product for the duration of seven days.

6. How We Share Your Information

We do not sell any Personal information to third parties.SGA Kenya Limited 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 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 SGA Home Security App; to respond to claims that any content posted or displayed using SGA Home Security App violates the rights of third parties; in an emergency protect the health and safety of users of SGA Home Security App or the general public; or to enforce compliance with our Terms of Service.

If SGA Kenya Limited 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 SGA Kenya Limited.

We may also disclose non-personal information (for example, aggregated or anonymized data) publicly or with third parties, provided that 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:

7. Securing Your Personal Information

SGA Kenya Limited 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, SGA Kenya Limited 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 the SGA Home Security App, you can contact us by phone at +254 (0) 111 024000 or email at dss@ke.sgasecurity.com.

8. Your Rights and Retention of Your Personal Information

SGA Kenya Limited generally stores your personal information on servers which are established upon third-party servers, including Amazon Server, until you delete or edit it, or for as long as you remain a SGA Home Security App 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 by selecting “Person” button. 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 SGA Home Security App 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.

We will retain your personal information for the period necessary to fulfill the purpose outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law.

9. Social Community Features and Social Networks

Social Community Features

SGA Home Security App 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 SGA Home Security App 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 SGA as well as the communications you receive from SGA Kenya Limited through your Account preferences.

Commercial E-mails

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 SGA Home Security Apps.

Device Data

You may manage how your mobile device and mobile browser share certain device data with SGA Kenya Limited 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

SGA Kenya Limited does not intend that any portion of its SGA Home Security App 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. SGA Home Security App is designed and intended for adults. By using SGA Home Security App, 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 SGA Home Security Apps. 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 +254 (0) 111 024000 or email at dss@ke.sgasecurity.com. 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 SGA Kenya Limited operates with other global affiliates, we may transfer your personal information to our affiliates worldwide, when processing that information for the purposes described in this Privacy Policy. 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 SGA Kenya Limited for this transfer of your Personal information.

Currently our affiliate company has data centers in the U.S., Singapore, Brazil 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 phone at +254 (0)111024000 or email at dss@ke.sgasecurity.com. Please provide: (i) your name (or account username) and preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links.