1. Who we are
Smart Network Technology Co. Limited., (“we”) respects your privacy and values the trust you place in us when you share your personal data with us. This policy sets out how we, as data controller, collect and use your personal data, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal data. This policy covers our use of your personal data arising from use of AirSendit, AirSendit application (“APP”) and our official website (“Website”) (www.360totalsecurity.com/airsendit). If you have any questions or need any further clarity, please get in touch. Contact details are set out below.
2. Your information
We will collect and use your personal information to allow access to AirSendit and Website and for other purposes set out in more detail in this section.
| ||What we collect ||How we use it |
|1. || |
Information automatically collected through your use of AirSendit Website and APP, including:
- IP address;
- Unique 360 serial number which created during your use of certain services;
- Wi-Fi network information (including Wi-Fi account name, no password);
- Device information, such as your operating system version, system language;
We use this information, including to:
- Offer features such as device connection and files transfer
- Identify issues with AirSendit and your experience of it
- Manage your mobile through PC or Web pages such as check device, clipboard, web, app, and etc.
|2. || |
Information we collect when you participate in User Experience Improvement Program of AirSendit:
- Features you use in AirSendit;
- The pages of AirSendit you requested and viewed;
- Error log and DUMP files such as crash report.
- The sizes of files which you have transferred
You can turn off User Experience Improvement Program through Settings-General-User Experience Improvement Program
We use this information, including to:
- Identify issues with AirSendit and user's experience of it;
- Improve our service;
|3. || |
Information when you communicate with us whether in person, through our website，email or feedback feature of AirSendit, through social media or via any other medium, including:
- Your email address;
- The details of your communications with us;
- The details of our messages to you.
We use this information, including to:
- Answer your questions;
- Monitor customer communications for service improvement and training purposes;
- Improve our services;
Why we collect and how long we keep your information
We collect and use your information for a variety of reasons. We need your information to enter into and perform our contract and realize the functions of AirSendit.
Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our users’ identities.
Other information we collect because we have legitimate business interests, for example, in:
- Understanding how our users use AirSendit and website;
- Delivering our services and communications to you as well as our other users and partners
- Understanding and responding to customer feedback;
- Researching and analyzing the services our users want;
- Developing new services and improving our services;
- Understanding the type of products and services our users buy or use and how they use them;
- Providing security over our business and who we trade with.
How long we keep your information
We will keep your information for as long as it is reasonably necessary (except cloud video recording as stated above). It will depend on factors such as whether you have an account with us or have interacted with us. We will also routinely refresh our information to ensure we keep it up-to-date.
Uses for compliance with legal requirements
Your personal data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
Information we share
We do not sell, lease, rent or give away your personal data. There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.
- We may also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use database service providers, advertising agencies, third party analytic service providers (e.g. Google’s Firebase), or customer relation management service providers.
Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide to them, including your information, will only be provided in connection with the performance of their function.
Your personal data may be transferred to other third party organizations in certain scenarios:
- If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
- If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;
- If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
- If we are defending a legal claim your information may be transferred as required in connection with defending such claim;
- If we have obtained your explicit consent in advance.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
4. Where your information will be stored
The information when you use Software through your PC, Mobile and Website will be stored in the EU and accessed from China by us and our external IT services providers. We will ensure an adequate data protection level by agreements with our data base provider and other arrangements. Please feel free to contact us for further details.
5. Your rights
You may have certain rights in relation to your information including a right to access or to correct the information we hold on you. We’ve listed the rights you have over your information and how you can use them below. These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we are required by law to keep the information or if the information is relevant to a legal dispute.
- You can ask us to confirm if we are processing your information through the feedback channel in 360 Total Security or sending email to our Data Protection Department.
- You can disable User Experience Improvement Program by turning off User Experience Improvement Program through Settings-General-User Experience Improvement Program.
- You can ask us to restrict how we use your personal data.
- You can ask us to stop using your personal data, but only in certain cases.
- You have the right to complain to the relevant supervisory authority.
We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.
- We transfer and store personal data using encryption to ensure the privacy of such data. AirSendit uses HTTPs between our APP and server with 2-way authentication interaction to protect your data. All the video stream uses private encryption protocol for anti-hacking and anti-peeping to ensure the security of data transmission.
- If you have a 360 account, we may analyse the login time, IP address, login times and other relevant information for our risk control and management. If our application adopts WebView technology, we conduct URL verification on all file agreements used in the WebView and restrict the access to the personal data and SD Card data to avoid the malicious misuse of any private documents and sensitive data of our products without special permission.
- We implement access control mechanism in our service end. We require our employees who may have access to your personal data to obey the principle of data minimization and examine the access list and access records on a regular basis.
- Our server systems used to store your personal data are equipped with strengthened safeguards. We conduct account audit and monitoring on the operation of our servers. Where any security problem of the server systems is reported, we will immediately complete security upgrades for the server systems to ensure the security of our server systems and applications.
- We conduct regular training on the relevant laws and regulations related to personal data protection to strengthen our employees’ awareness of privacy protection.
- If any destruction of our physical, technical or management safeguard measures occurs, we will launch our emergency plan in a timely manner to prevent the spreading effect of the security incident and will report the same to the competent authority in accordance with the relevant laws and regulations. We will also notify you, in a timely manner, of the security incident, potential impacts and the measures we have taken or will take to deal with the incident, in a reasonable and effective way such as pushing notifications and publishing announcements.
8. Changes to the policy
This policy will be changed from time to time.
If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change.
You can email the Data Protection Department for previous versions, you can get in touch at the following email address: email@example.com.
9. How to contact us
If you have any questions about this policy please contact our Data Protection Department: firstname.lastname@example.org or through “Settings<-Feedback” of AirSendit.