What does Akuvox do?

Akuvox (Xiamen) Networks Co., Ltd. ("Akuvox", "we", "us" and "ours") is a smart intercom products provider, based in China, with group companies in Singapore. It provides cloud-based services in connection with Akuvox smart intercom and access control products, regional sales, and support to customers in the EEA and the UK ("Services"). Akuvox primarily processes personal data as a processor on behalf of its customers, and in accordance with their instructions.

This privacy notice describes the limited circumstances in which Akuvox acts as a controller of your personal data and determines the purposes and means of its processing. This includes EU/UK personal data processed through our website at www.akuvoxsmartplus.com ("Website"), and personal data of our business contacts.

This Privacy Notice explains how Akuvox collects, shares and uses your personal data and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal data, please contact us using the contact details under the How to contact us heading below.

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Personal data we collect and process

a) We collect personal data about you from the following sources:

Information that you provide directly

We collect personal data directly from you when you choose to provide us with this information on our Website and through your other interactions with us (such as, for example, data collected via customer service communications). A contact form on our Website asks you to provide your business contact details when you enquire about our Services.

Information that we collect indirectly

We collect your personal data indirectly, including through automated means from your device when you visit our Website. The information we collect indirectly is captured using cookies, as explained further in the Cookies and similar tracking technology section below.

b) The table below describes the categories of your personal data that we process as a controller:

We do not collect any sensitive personal data about you, such as health-related information or information about your race or ethnicity, or sexual orientation.

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How we use your personal data (our purposes) and our legal basis for processing it

We use the personal data that we collect from you only for the purposes described in this Privacy Notice. Depending on our purpose for collecting your information, we rely on one of the following legal bases:

• Consent - where legally required, we ask for your consent before we collect your personal data through cookies, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;
• Legitimate interests - we will use or disclose your personal data for the legitimate interests of Akuvox or a third party, but only when we are confident that your privacy rights will remain appropriately protected. These interests are to: operate, provide and improve our Website and Services; communicate with you and respond to your questions; use the insights to improve or develop marketing activities and promote our products and Services; detect or prevent illegal activities (for example, fraud); and/or manage the security of our IT infrastructure. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business and which does not materially affect your rights and freedoms.

The following table provides more details on our purposes for processing your personal data and the related legal bases.

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Who we share your personal data with

We share your personal data with the following categories of recipients:

• our group companies, including Akuvox (Xiamen) Networks Co., Ltd. and potentially other Akuvox group companies, who we engage to provide data processing services necessary to deliver our Services (such as hosting the data and providing essential technical support, software maintenance, and cloud server operation services). Akuvox (Xiamen) Networks Co., Ltd. and our other group companies to which we may transfer your personal data are based in China;
• third party service providers who provide data processing services to us as necessary to support the delivery of our Services and Website, such as website analytics services or cookie consent management;
• any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or so a third party can defend theirs;
• a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice; or
• any other person with your consent to the disclosure.

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Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, "Cookies") to collect and use Website Data. For further information about the types of Cookies we use, why, and how you can control them, please see our Cookie Notice.

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How we keep your personal data secure

We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include encrypting your personal data in transit and at rest; using an industry standard framework as part of any Information Security programme; employing advanced malware protections; implementation of other reasonable security defences (including vulnerability management, access management and recovery/resilience measures).

Where you have created an account with us that uses a unique password to enable you to access our Website, it is your responsibility to keep this password secure and confidential.

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International data transfers

Where your personal data is transferred to another Akuvox company or, in some cases, third parties, it is processed in countries other than the country in which you are resident (outside the EU/UK). These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.

Specifically, our Website servers are located in Germany, and our group companies are in China. Our third party service providers and partners operate around the UK and the EEA. This means that we will process your personal data in any of these countries.

Where we transfer your personal data (Business Contacts Data, Communications Data and Website Data) to countries outside of the EEA and the UK, which have been formally recognised as providing an adequate level of protection for personal data, we rely on the relevant "adequacy decisions" from the European Commission and "adequacy regulations" from the Secretary of State in the UK. For other transfers, not subject to an adequacy decision or regulations, we have taken appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Notice and applicable laws. The safeguards we use to transfer personal data are the European Commission's Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2) using module for controller to processor transfers, and the UK Addendum to the European Commission's Standard Contractual Clauses for the transfer of UK data.

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Data retention

We retain the personal data we collect from you where we have an ongoing legitimate need to do so (for example, to provide you with information about our Service, to operate our Website, or to comply with applicable legal requirements). In certain circumstances, we will need to keep your information for legal reasons. The specific retention periods depend on the nature of the information and why it is collected and processed and, where relevant, the nature of the legal requirement. For example, we would retain your data for longer than the usual retention period when there is an ongoing complaint, litigation or regulatory matter.

When we have no ongoing legitimate need or legal reason to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

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Your data protection rights

Individuals located in the UK and EEA have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under the How to contact us heading below.

• You may access, correct, update or request deletion of your personal data.
• You can object to processing of your personal data, or ask us to restrict processing of your personal data.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you or contacting us directly. If you choose to opt out of marketing communications, we will still send you non-promotional emails, such as emails concerning the relevant ongoing business relations.
• If we have collected and processed your personal data with your consent (Website Data), then you can withdraw your consent at any time by following directions in our Cookie Notice. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to us as a controller, and to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Contact details for supervisory authorities in Europe are available here and for the UK here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

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Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.

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How to contact us

If you have any questions or concerns about our use of your personal data, please contact us or our data protection officer using the following details:

Data Protection Officer (DPO)
Tyler Zeng
dpo@akuvox.com
+86-592-2133061 ext. 7679

You may also contact our representatives in the EEA and the UK.

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