PRIVACY POLICY
1 OUR PRIVACY PLEDGE
1.1 We respect your right to privacy. This is our guiding principle for everything we do.
1.2 Lytehouse provides a physical security monitoring platform as a service, which includes threat detection and video analytics software. This is a core part of our service. We may also store data on our customers behalf, if so required.
1.3 We will not share your data unless we have your consent, we are contractually permitted to or are legally required to do so.
1.4 We will use standard data security tools to keep your data safe and protect our products and services from hackers.
2 Lytehouse Pte Ltd and its subsidiaries and affiliates (collectively referred to herein as “Lytehouse”, “we,” “us,” or “our,”), respects your privacy and the importance of the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you use the Lytehouse website (“Website”) or any of our Services, how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the Website or Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Website or Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. Any capitalised terms not defined herein shall have the meaning as set forth in the applicable customer, partner or distributor agreement, as the case may be.
3 In this Policy, the term Services includes the Lytehouse platform and all related Lytehouse products, software, and services. This policy applies in circumstances where we are acting as a data controller / responsible party with respect to the Personal Information (as defined herein) of all visitors, users, customers and others who access or use the Website and/or Service (“Users”); in other words, where we determine the purpose and means of the processing of that Personal Information.
4 Please note that this Policy does not apply to information we collect or process on behalf of our customers. If you have a query regarding how our customers use your information, please contact them directly. In addition, this Policy does not apply to your use of third-party sites, services, or applications you may access. This includes whether such third-party sites, services, or applications are accessed through or in connection with our Website or Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
5 INFORMATION WE MAY COLLECT
5.1 Information you provide to us
5.1.1 In order to provide the Services to you, we may collect and process data provided by you which includes, amongst other things, closed circuit television (“CCTV”) footage from sites which may belong to you, or are being monitored by you and information relating to those sites. This data may contain certain information that can identify you (“Personal Information”). For the purpose of this Privacy Policy, Personal Information may include the Personal Information of other individuals that you may provide to us in accordance with your access to the Website or use of our Services. By providing such information you warrant that you have all the necessary permissions or consents to disclose such Personal Information. Personal Information also includes, for purposes of this Policy, the definition of personal data as such term is defined in the Personal Data Protection Act of Singapore (“PDPA”) and other applicable data protection and privacy laws, such as Chapter 1 of the Protection of Personal Information Act No 4 of 2013 (“POPIA”). We will never sell, rent, trade or use your Personal Information other than as specifically needed to provide the Services specifically requested by you. Lytehouse discloses Personal Information only to those of its employees, contractors, affiliated organisations and subcontractors that (i) need to know the information in order to process it on yours and our behalf, and (ii) that have agreed in writing to non-disclosure restrictions at least as strong as those herein.
If you do not want to provide us with Personal Information you don’t have to, but it may mean we are unable to provide you with access to parts of the Website or our Services.
5.2 Information we collect automatically when you access or use the Website or Services
5.2.1 When you access or use the Website or Services, we automatically collect information about you, including some or all of the following
5.2.2. Log information
We log information about your use of the Website or Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Website or Services.
5.2.3 Device Information
We collect information about the computer or mobile device you use to access the Website or Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information. Also, we collect video and audio signals and data as well as environmental data and technical information from cameras, sensors and other devices.
5.2.4 Information Collected by Cookies and Other Tracking Technologies
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored in device memory that help us to improve the Website and your experience, see which areas and features of the Website are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Website or emails and help deliver cookies, count visits, understand usage and determine whether an email has been opened and acted upon.
5.3 We also may collect other types of information in the following ways when you visit or use the Website or Services
5.3.1 Details of how you used and interacted with the Website or Services, such as your search queries and how you responded to certain questions.
5.3.2 Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
5.3.3 Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track your movements around the Website or Services and understand trends.
5.4 Information We Collect From Other Sources
We may also obtain information from other sources and combine that with information we collect through the Services. For example, we may collect information about you from third parties who provide services on our behalf, such as maintaining and monitoring usage of the Website and Services and processing payment transactions.
5.5 Should you share Personal Information of your customers with us, you shall comply with your obligations under the applicable data protection and privacy laws and specifically ensure that you have a lawful basis for sharing the Personal Information with us and for us to process the Personal Information of your customer.
6 USE OF INFORMATION
6.1 We may use information about you for various purposes, including the following
6.1.1 Provide, maintain, deliver and improve the Website and Services, and send you information in relation to this;
6.1.2 Verify your identity and, if applicable, authorisation for you to use the Website and Services;
6.1.3 Process payments for Services;
6.1.4 To prevent or address service, security, technical issues or at your request in connection with customer support matters;
6.1.5 Respond to your comments, questions, and requests;
6.1.6 Send you technical notices and other administrative messages;
6.1.7 Communicate with you about products and services, offered by us or others, and provide news and information we think will be of interest to you;
6.1.8 Monitor and analyse trends, usage, and activities in connection with the Website and Services;
6.1.9 Conduct research, analysis, and surveys;
6.1.10 Personalise and provide content or features that match user profiles or interests;
6.1.11 Enforce our Terms of Use and/or applicable customer, partner or distributor Agreement;
6.1.12 Link or combine with information we get from others in connection with the Services; and
6.1.13 Carry out any other purpose for which the information was collected.
6.2 This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable User of the Website or Services.
7 SHARING OF INFORMATION
7.1 We may share or transfer information about you as follows or as otherwise described in this Privacy Policy
7.1.1 With vendors, consultants, subcontractors and other service providers who need access to such information to carry out work on our behalf. Any such parties only have access to such information as necessary to perform their functions and may not use it for any purpose other than to provide services to us;
7.1.2 Any vendor, consultant, subcontractor or other service provider will act on our instructions and be contractually bound to take all reasonable steps to secure your personal information and treat your Personal Information as confidential;
7.1.3 In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation; and
7.1.4 In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company (we will request a purchaser to treat our data under the privacy policy in place at the time of its collection).
8 ANALYTICS SERVICES
8.1 We may allow others to provide analytics services in connection with the Services. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Website and Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyse and track data, determine the popularity of certain content, personalise the user experience, and better understand your activity.
9 DATA RETENTION
9.1 We will retain your Personal Information for the period of time that is necessary to fulfil the original purposes for which it has been collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. Please keep in mind that, in certain cases, a longer retention period may be required or permitted by law or to allow us to pursue our business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute. We may also retain cached or archived copies of information about you for a certain period.
9.2 The criteria used to determine our retention periods include
9.2.1 Time needed to provide you with our Services or to operate our business.
9.2.2 Whether you are an active Customer of Lytehouse.
9.2.3 Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract, audit or litigation.
9.3 Please note that we are not responsible for storing any information that you provide to us with the exception of when we provide data storage which may include Personal Information as part of our Services, or for any content or information that we provide to you.
9.4 Lytehouse has specific data retention policies for the following types of data
9.4.1 CCTV Video Footage Data on the Platform
Videos will be stored as part of the delivery of our Services. The Lytehouse platform will intelligently select how long videos will be retained based on the importance of a video, or the need to retain, in accordance with the Services provided to you. As a User of the Platform, you may also cause video data to be retained by the Platform should they require further investigation. Lytehouse will also retain video data to improve the Services. If you wish to have specific videos removed from this latter use, please contact us on privacy@lytehouse.io
9.4.2 Personal Data on Lytehouse Servers
Lytehouse generally stores your personal information on Lytehouse’s servers for as long as you remain a Lytehouse customer in order to provide you with Lytehouse Services. You have the right to access, amend or delete your Personal Information. Because of the way we maintain certain Services, after your information is deleted, backup copies may linger for some time before they are deleted, and we may retain certain data for a longer period of time if we are required to do so.
10 SECURITY
10.1 Security is a priority for us when protecting your data. We work hard to protect your information and take appropriate commercially reasonable physical, electronic, and other security measures to help safeguard information and data from loss, unauthorised access, alteration, misuse or disclosure. For further details on our security practices that are in place, please contact privacy@lytehouse.io
10.2 No method of transmission over the Internet or method of electronic storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.
10.3 Lytehouse does not seek to collect sensitive Personal Information. If we do so we will always collect the data in accordance with applicable data privacy requirements. If you choose to provide us with unsolicited sensitive Personal Information, we will treat the information in accordance with this Privacy Policy.
11 OTHER WEBSITES AND OTHER PRODUCTS
11.1 This Privacy Policy applies only to information we collect through our Website or Services. The Website and Services may contain links to or embedded content from third party websites. A link to or embedded content from a third party website does not mean that we endorse that third party website, the quality or accuracy of information presented on the third party website or the persons or entities associated with the third party website. If you decide to visit a third party website, you are subject to the privacy policy of the third party website as applicable and we are not responsible for the policies and practices of the third party website. We encourage you to ask questions before you disclose your information to others.
11.2 Any data that Lytehouse receives from third-parties will be processed and stored by Lytehouse and will be treated in accordance with this Privacy Policy. This information may be processed in the same ways as if it were any other User data that is collected and processed in accordance with this Privacy Policy. This will include instructions we receive from you relating to your customers.
12 CHILDREN UNDER THE AGE OF 18
The Website and Services are intended for users who are eighteen (18) years of age and older. If you are under the age of eighteen (18), you are not permitted to submit any Personal Information to us.
13 TRANSFER OF PERSONAL INFORMATION & INTERNATIONAL VISITORS
13.1 You are solely responsible for ensuring compliance with the laws of your specific jurisdiction, including the specific laws of your jurisdiction regarding the import, export, or re-export of the Services. By providing your Personal Information, you are: (a) permitting the transfer of your Personal Information to our secure cloud-hosted servers outside of your specific country of residence; and (b) are permitting the use of your Personal Information in accordance with this Privacy Policy.
13.2 Protecting your data outside of your country of residence
13.2.1 We serve customers globally. We may transfer, store and process Personal Information that we collect from you to third-party data processors in countries that are outside of your country of residence and Singapore, specifically to the United States.
13.2.2 If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside Singapore. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these standards please contact privacy@lytehouse.io. Any transfer of your Personal Information will be treated under the guiding principles of this Privacy Policy.
13.3 For all customers
13.3.1 By using our services or providing your Personal Information to us, you expressly consent to the processing of your Personal Information by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes but we may not be able to provide Services to you in some circumstances.
13.3.2 Sometimes we’ll need to transfer your Personal Information between countries to enable us to supply the Services you’ve requested. In the ordinary course of business, we may transfer your Personal Information from your country of residence to ourselves and to third parties.
13.3.3 By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your Personal Information outside of your country of residence for our ordinary business purposes. If you are using Lytehouse Services in the European Union or other regions with laws governing data collection and use that may differ from Singapore law, you consent to the transfer of your personal data to Singapore and other countries where Lytehouse operates for the purposes of providing those Services, for providing technical support of the Services and for data hosting and backup.
13.3.4 This may occur because our cloud hosted data storage facilities and servers are located outside your country of residence, and could include storage of your Personal Information on servers in Singapore, South Africa and the United States.
13.3.5 We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your Personal Information in any way that’s not set out in this Privacy Policy. We’ll also make sure we adequately protect the confidentiality and privacy of your Personal Information.
14 YOUR RIGHTS / OPTIONS
14.1 Access and Control of Your Personal Information
14.1.1 You may request updates, corrections or deletions of Personal Information at any time by contacting us at privacy@lytehouse.io. Whenever you have given us your consent to use your Personal Information, you have the right to change your mind at any time and withdraw that consent.
14.1.2 Access to Personal Information
You have the right to request what Personal Information we hold about you subject to our right to identity verification. If you request a copy of your data, we may charge you a fee, except where this is not permissible under applicable law.
14.1.3 Correction and Deletion
In some jurisdictions, including the EU (according to data protection laws for data subjects in the EU), you have the right to correct or amend your Personal Information if it is inaccurate or needs to be updated. You may also have the right to request the deletion of your Personal Information, however this may not be always possible due to legal requirements and other obligations to keep such data. If we are asked to delete your data, we may keep some minimal information about you to be able to demonstrate that we have fulfilled our obligations.
14.1.4 Filing a Complaint
In some jurisdictions, including according to data protection laws in the EU for complaints issued from subjects in the EU, you have the right to lodge a formal complaint with a data protection authority.
14.1.5 Marketing Preferences
We may send you marketing communications about our services, via different channels such as email, phone, SMS and third-party social networks, in accordance with relevant marketing laws. When required by applicable law, we will obtain your consent before starting these activities.
14.2 Third Party Marketing Communications
Under no circumstance do we share Personal Information for any commercial or marketing purpose unrelated to the activation and delivery of the Services. If this changes at any point in the future, we will be required to ask you first.
14.3 Marketing Communications Opt Out
You may opt out of receiving marketing communications from us by following the instructions in those communications or by emailing us at privacy@lytehouse.io. In such cases, we will retain minimum Personal Information to note that you opted out in order to avoid contacting you again. Please note that even if you opt out from receiving marketing communications, we may still send you administrative communications, such as technical updates for our Services, information relating specifically to the Services we provide to you, and other important notices.
15 PRIVACY POLICY CHANGES
Lytehouse reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise.
16 LAST MODIFIED
Last modified in May 2021