Last updated: 23.01.2017
1.1. Law means The Processing of Personal Data Law (Protection of Individuals) Law of 2001 (Law. 138 (I)/2001);
1.2. PaS means Prevention at Sea Ltd, a private company registered and existing under the laws of the Republic of Cyprus (Reg. No. HE214304) and having its registered office at 8, Athinon Avenue, Office 1002, PC 6023, Larnaca, Cyprus;
1.3. PaS Group means PaS and any affiliated entities thereto; and
1.4. Website means www.preventionatsea.com and all the PaS
2. GENERAL INFORMATION
2.1. Respecting your privacy is important for PaS and the PaS Group. For this reason we apply this Policy which governs the method of collection, usage, disclosing, transferring and storing of your data.
2.2. PaS is committed in respecting the laws and regulations of the Republic of Cyprus as well as the applicable European Union legislation in relation to privacy and individual liberties. To this end, where necessary, PaS has given, or will give in the future, relevant notifications to the competent authorities.
2.3. This Policy describes how PaS, both for itself and on behalf of PaS Group, collects, uses and processes personal data which is collected from you as a user of websites, devices, applications of PaS or of PaS Group.
2.4. PaS strives to comply with all laws applicable for the managing of information collected in relation to you. At the same time, it undertakes to process the data collected fairly and with transparency.
2.5. The Policy applies to your access and use of our Website. It also applies regardless of whether such access or use is effected through personal computer, mobile phone, tablet, TV or other device. It is important to read carefully the Policy because every time you use our Website, we consider that you accept the practices described in the Policy. If you do not agree with the practices described in the Policy, you should not use our Website. Please read this Policy carefully. In case you have any question or doubt about anything, do not hesitate to contact us. In case you do not contact us, we shall assume that you have read and understood this Policy.
2.6. This Policy is reviewed regularly and any amendment or possible future addition will be incorporated in this Policy and will be available on the Website. In any case, PaS reserves the right to change its Policy and, in general, modify its data protection conditions in accordance with the applicable legal framework. As this Policy may change, please check periodically the Website so that you are aware of any changes prior to use of the Website.
2.8. The use of the Website constitutes an automatic acceptance of this Policy with respect to privacy issues. Continuous use of the Website confirms the acceptance of this Policy with all amendments thereto.
3. PROVIDERS OF TELECOMMUNICATIONS DATA AND OTHER PROVIDERS
3.1. The administrator of the wireless network, the provider of the operating system of your mobile device, tablet, PC and/or applications, toolbars, services, uploads, social networking platforms and third party websites may also collect, use and share information about you, your device and your usage of our Website. This Policy does not cover any third parties, products, actions or their services. PaS cannot control the way in which third parties collect, use or protect your data. For more information about the privacy practices of third parties, refer to their own privacy policies. In any case, you are recommended to download applications, connect and communicate only with credible third parties.
4. INFORMATION YOU PROVIDE TO US
4.1. Use of this Website may entail or require that you provide information directly to us. For example, this may be the case when:
4.1.1 you contact PaS or PaS Group;
4.1.2. you visit the Website;
4.1.3. you purchase a PaS product online or subscribe to a PaS service;
4.1.4. you order a product or service;
4.1.5. you submit any warranty request granted through our Website or otherwise;
4.1.6. you contact PaS by telephone or by e-mail in relation to our services;
4.1.7 you request an offer or documents or information in relation to a service or any matter referred to the Website.
4.2. The administrator of the website collects personal information from users only when they themselvesvoluntarily provide them. The registration process on the Website and the usage of services requires the provision of a minimum personal data. Personal data is data or information that identifies an individual, such as name, e-mail address or other data which can be reasonably linked to a person’s identity. Any personal data provided by the user anywhere on the Website is strictly limited to ensure the operation of the service and may not be used by any third party, without complying with the provisions of the Law, as currently in force on the protection and processing of personal data, as applicable each time.
4.3. The Website may give its users the opportunity to browse via special connections (links, hyperlinks, banners) to websites of third parties, the content of which is the entire responsibility of these parties. PaS does not guarantee their availability and does not endorse nor is responsible for the content, accuracy, legality, completeness, timeliness and accuracy of the information nor for the quality and properties of products or services, which are available from these persons through the above websites. PaS is not responsible for errors or malfunctioning of the webpages of third parties, and for any loss of users from access and use of services provided by such information, services and products.
4.4. Internet is not always a safe environment. While PaS and PaS Group uses anti-virus software in computers and general protection, it does not guarantee that the functions of the website will be uninterrupted or free of any errors and viruses and is not responsible for any data loss or other damage to the user or to third parties, whether due to usage, copy, uploading, downloading or for infection by viruses or other unauthorized third party interventions to files and information available through the website. The user is solely responsible for protecting the system against viruses.
5. INFORMATION THAT WE REQUEST FROM YOU
5.1. We collect both personal and anonymous information. Through statistical processing, this anonymous data allows us to improve our products and services.
5.2. We collect information you give us during your registration process to PaS services on the Website or to PaS Group websites concerning the user’s name and any other information about his identity required for the management of the user’s account. We inform you that your personal data and information collected and processed when managing your account on the Website or to PaS Group websites is appropriate for the occasion and is required to process your requests and use of the remote management of alarm service via internet.
5.3. Data collected (indicatively and without limitation) comprise the e-mail address, Login information, password, IP address, Network Type, Host name, port, PIN device code, product name and version, date and time of access to the Website, general information on the duration and type of use of the device, data stored in the central management device such as date and system boot time, date, time and duration of operation associated to the household appliance system, items related to taking pictures, energy consumption data of appliances, types and versions of operating systems of devices, data and information related to the way our services are used during the submission of your requests, name, date of birth, language preference, country, address (street, postal code, city, municipality), citizenship, nationality, company name (in case of a legal person), mobile phone number, profession, fax number, housing data (property type, surface size, property description, address type), device installation location, confirmation devices use (number and type), history alerts and updates (notifications).
5.4. Some of our services may make use of GPS and thus for more information about the privacy practices of any third party, refer to their own privacy policies.
5.5. You may be given the opportunity to enable or activate location services with your consent. The necessary equipment for the provision of such services usually consists of, firstly, a location-based device, which includes a SIM card to connect to a cellular network or possibility of connecting to the Internet via Wi-Fi, GPS (Global Stigmatothetisis System) and on the other hand in a system-software application (app), which is installed to the device of the user device and records the geographical location of the carrier of the device in real time.
5.6. PaS does not manage, collect or process the location data, collected and processed exclusively by the companies that offer the operating system of the device you use (in the case of manual operating ios -Apple Inc while in case of using android – Google Inc operating system). PaS has no access to the refresh rate of the GPS position.
5.7. We also collect some useful information such as the date of sale of the product, information about a technical problem or a request for assistance, account history of use, date of entry in the account, source user (manual, trigger or scenario), the starting point via the device (web, iPhone, android), technical data and settings on your connected home automation. It is also noted that if you purchase any additional product/accessory, such as camera motion detector, the data of the photos which will be taken will be collected (photos, date and name).
5.8. When we collect data, we will inform you, whether disclosing it to us, is mandatory or optional. Any refusal to give information required as mandatory will result in you being unable to submit your request.
6. USE OF YOUR PERSONAL DATA
6.1. Generally, we will use data related to you for the purpose of supplying, maintaining and improving our products and our service we provide to you. If there is a need to collect personal data in order to be used in a manner which is not covered by this Policy or by Law or is not related to the use concluded with their provision, we will ask for your consent.
6.2. We may use all or part of the data we collect, for:
6.2.1. the proper operation and continuous improvement of the Website and PaS Group websites and our products and services;
6.2.2. the creation of statistics to improve the function of the Website and PaS Group websites and our products and services;
6.2.3. the creation of membership programs and user communities;
6.2.4. to improve the quality of services we provide to users;
6.2.5. to provide maintenance services to your device;
6.2.6. to evaluate the customer market, our products and services by using statistical data and information on the services and;
6.2.7. to be used for marketing research purposes, sending advertisements and other offers (subject to your prior agreement and upon your explicit consent); and
6.2.8. more generally, to create and maintain a business relationship with our clients.
6.3. We may share all or part of the data we collect, for:
6.3.1. sharing the information within PaS Group;
6.3.2. sharing this information with our affiliates for direct commercial purposes, subject to your prior agreement and upon your explicit consent;
6.3.3. observing the law and the requests of the relevant legal or governmental authorities;
6.3.4. taking legal action or exercising our right to defend ourselves; and
6.3.5. preventing fraud or any other illegal activity.
6.4. We may provide you with various options about how we use your information and in particular to be able to choose whether to receive promotional communications from us. When you provide us with your personal information, you will be able to inform us that you do not wish to use, either by ourselves or any third party, such information for the purposes of direct marketing. We will use this information for the purpose of direct marketing only according to your own preferences or where the legislation allows us.
6.5. With your preferences, you specify whether you consent or not and if we may, contact you accordingly as part of direct marketing.
6.6. PaS and PaS Group transports, processes and stores information for our users to servers located in Cyprus. Consequently, PaS may disclose your information to other companies within the PaS Group, to carry out the activities set forth in the present Policy. This information is accessible to companies belonging to PaS Group and natural or legal persons working in PaS Group and are responsible to process data on our behalf in order to provide the Services to you.
6.7. Subject to the provisions of the Law, PaS can also subcontract the processing or disclosing of your information to third parties located in countries which are Member States of the EU, States parties to the EEA and to third countries.
6.8. Technical data in relation to your equipment and in relation to the usage and configuration of your installation is stored and held in our technical servers for the entire duration of our services and products use. This technical data and data on usage may also be used by PaS or any of its partners with your consent in order to offer you services, in particular maintenance and support
6.9. As part of your visits to the website or the purchase of products or services from us, it is possible to visit sites which are presented in social media, such as facebook, twitter, google + or Pinterest. All information that you share on these platforms and which are accessible by the general public, can be reached by us and their concession constitutes consent to be used by us. However, PaS does not create and does not use any standalone database in relation to such data which can be found in social networking bases. If you don’t want PaS to have access to such data, you should use the means available to each social networking platform in order to restrict access to your personal data.
7. RESPECTING YOUR PREFERENCES
7.1. In accordance with the Law, you have the right to be informed, i.e. the right to know if personal data relating to you is or has been processed.
7.2. In accordance with the Law, you have a right to access your personal data in order to add to, correct, or delete said data, i.e. the right to request and receive a copy of any information held in relation to you by submitting a written request for this. You may also ask us to let you know about the information we maintain in relation to you. If it has come to your knowledge that the information held in relation to you is false or inaccurate, you have the right to rectify it.
7.3. In accordance with the Law, you have also the right to object. More specifically to express your objections for the processing of data which concern you explicitly, including the possibility of a request to delete your personal data.
7.4. If you wish to exercise your rights, please contact us at firstname.lastname@example.org.
7.5. In the event that you afford us with a copy of your personal ID in order to give proof of your identity, we will keep it for one (1) year, unless you afford us with it, in order to have an objection right. In this case, we will keep it for three (3) years.
7.6. You can agree to receive commercial offers and information from PaS or PaS Group by ticking the relevant box to PaS Website or to PaS Group Website. This allows you to control and restrict the scope of our contact with you.
7.7. You can agree to receive commercial offers and information from companies affiliated to PaS or PaS Group, by selecting the appropriate box on the website or to PaS Group website.
8. GENERAL RULES GOVERNING PERSONAL DATA
8.1. Duration of storing of personal data
8.1.1. We do not want your personal data for longer than what we need, therefore we keep it only for the time needed to accomplish the purpose for which we collected it. Once the account cancellation abide by PaS, the data collected for the purpose of execution of marketing actions, may be maintained up to three (3) years from the account cancellation or termination of cooperation and be used for the promotion of PaS Group products.
8.1.2. The personal data used for direct marketing purposes is kept only for three years from the end of the business relationship or the date of the consent to use that data for these purposes.
8.1.3. Bank details (where applicable) are handled by our service provider and are only held for as long as is necessary for the relationship or transaction.
8.2. Security of personal data collected
8.2.1. The security of your personal information is of the utmost importance to us.We have put in place the technical resources needed to prevent the accidental or abusive destruction, loss, deterioration, unauthorised disclosure, or modification of, or access to, your personal data.
8.2.2. Employees with access to your personal data undertake to respect its confidentiality.
8.3. Links to other websites
8.3.1. The fact that we enable you to access other websites by means of hypertext links shall not render us liable for any practices relating to personal data on these sites.
9. MINORS PERSONAL DATA
9.1. PaS services are not intended for children under 13 years of age.
9.2. PaS does not knowingly collect personal information from children under age 13 or below the current age.
9.3. If a user is under the age limit, he must not use any Service or provide any information to us.
9.4. If you are a parent and believe that your child who is less than 13 years old, has provided us with his personal data, please contact us to remove your child’s information.
9.5. If we find that we have collected personal data of a child under 13, or equivalent minimum age depending on the jurisdiction, without obtaining parental consent with the possibility of verifying, we will proceed to remove that information as soon as possible.
10. AUTOMATED DATA COLLECTION USING COOKIES.
10.1 What is a cookie?
10.1.1. Cookies are small text files stored on users’ computers during their visits to various websites on the World Wide Web), in order to give to the website the opportunity to identify the user on subsequent visits to the same site. In particular, they provide personalized services such as, for example, users can choose the language in which they prefer to see a web page and this preference is stored so you do not have to choose again the language during the next visit to the same web page. Also they are used in the famous «shopping cart» where the user can store various products that he intends to buy and come back at a later time to buy. Apart from the above uses, cookies can be used to monitor the movements of users on the web to form the profile of their preferences in order to present them with advertisements they would likely find attractive.
10.1.3. Different kinds of cookies are used on our websites and serve different purposes. Some are required in order to use our websites. These are cookies that are necessary for the Site to operate and to allow you to use the basic functions. Without them, you cannot normally use the Website or PaS Group website. These cookies are registered by PaS and they related with the operation of the website or PaS Group websites only. Other cookies provide information regarding the use and performance of the Site and help us to improve their operation (for example the most visited pages, etc.). Most of them are cookies of PaS or PaS Group.
10.1.4. Furthermore, cookies may be used for any technical storage or access for the sole purpose of which is to carry out the transmission of a communication over an electronic communications network, or as strictly necessary in order for the information society service provider which has explicitly requested the subscriber or the user to provide that service.
10.1.5. Your web browser handles cookies. You can set your web browser at any time to delete cookies from your hard disk, to prevent the storage of new ones, or receive a warning before storing them in order to proceed with their blocking. In this way, you can automatically block cookies by adjusting your web browser. Most web browsers allow you to manage preferred cookies. You can set your web browser to block or delete certain cookies. Generally, you can also manage similar technologies in the same way, using your favorite web browser. You should check which version of each web browser you use, so you can refer to the corresponding instructions that are provided for the management of Cookies, indicatively you will find below some links depending on the web browser.
10.1.6. Please remember that the rules can lead to changes in the conditions of access of Services and the website or PaS Group websites which require their use. If your web browser is configured to block all cookies, you will not have the optimum access to our Services or may be unable to access.
10.1.7. By using the Website, you give your consent to install cookies for the purposes stated in this Policy.
11.1. The person responsible for data collection of PaS is the Administration Officer.