1. General
1.1
The protection of privacy and personal data is very important for Punfyre BV. This Privacy Statement has been prepared to inform data subjects about how Punfyre BV handles personal data in the context of Alarmira and how data subjects can exercise control over their personal data. It is recommended that data subjects read this Privacy Statement carefully before using Alarmira's website, products and/or services.
1.2
The controller of personal data processing is Punfyre BV, with registered office located at Vlamingstraat 4, 8560 Wevelgem (Belgium).
1.3
This Data Processing Privacy Statement has been prepared in implementation of the General Data Protection Regulation, other European regulations containing provisions relating to data protection and privacy, as well as applicable national data protection and privacy legislation and implementing decrees.
2. Definitions
"General Data Protection Regulation" or "AVG" is the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.
"Alarmira" is Punfyre BV's digital alarm button with accompanying application so that its users can quickly and accurately notify the right contacts to obtain assistance in an emergency situation.
"Data subject(s)" is/are the person(s) whose personal data are processed in the context of Alarmira's website, products and services.
"Personal data breach" is a security breach that results in the accidental or unlawful destruction, loss, alteration or unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
"Private users" are the customers of Punfyre BV who use Alarmira's digital alarm button and associated services.
"Personal data" is any information relating to an identified or identifiable person, being the data subject.
"Processing" means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
"Controller" is Punfyre BV which determines the purposes and means of processing personal data for Alarmira.
3. The personal data collected
3.1
The following personal data are collected by Punfyre BV - in connection with the website, Alarmira's products and services:
- Category 1: the ordinary personal data of data subjects:
- Category 1.1: the IP address, first and last name, address, billing address (optional), e-mail address, address and mobile phone number of visitors to Alarmira's website and/or customers or potential customers.
- Category 1.2: the first and last name, address, e-mail address, mobile phone number and location (GPS coordinates) of private users.
- Category 1.3: the first and last name, e-mail address, mobile phone number and capacity of private users' contacts.
- Category 2: the special identification data of data subjects:
- Category 2.1: the facial recognition, voice (optional) and medical data (optional) of private users.
3.2
The aforementioned personal data are collected for the following purposes:
- Category 1.1: (i) to ensure the proper functioning and optimisation of the Alarmira website visited by (potential) customers, (ii) to realise purchases of Alarmira's alarm button with associated subscription services via the website and (ii) to send out newsletters.
- Category 1.2 and 2.1: (i) to achieve registration of private users on Alarmira's services through the application and (ii) to ensure that private users can use Alarmira's services.
- Category 1.2, 1.3 and 2.1: (i) to have the alarm button activated and (ii) to ensure that private users can use Alarmira's alarm button and/or FollowMe.
3.3
For the processing of the special identification data of the data subjects (category 2.1) by Alarmira, the consent of the data subjects is requested. Moreover, the data subjects undertake to store the contact details of the contact persons (category 1.3) in Alarmira's application only if it has the consent of the contact person to do so. Under no circumstances can Punfyre BV be held liable for the unlawful use of a contact person's personal data by a data subject.
4. The purposes of processing
4.1 Delivery and operation of products and services of Alarmira
The processing of personal data is necessary for (i) the purchase of the alarm button with accompanying subscription services from Alarmira, (ii) the ability to contact the data subject as a customer in a simple manner, (iii) the delivery of the alarm button with accompanying subscription services to the customer, (iv) the preparation and sending of an invoice to the customer and (v) the proper functioning of the alarm button with accompanying subscription services from Alarmira.
4.2 Statistical reasons
The processing of ordinary personal data for statistical reasons takes place solely for the purpose of evaluating the operation of Alarmira's website and optimising its internal operation and Alarmira's products and services.
4.3 Transfer to third parties
Punfyre BV relies on third parties to perform and enable Alarmira's services, in particular for:
- realising emergency services;
- Providing web hosting services;
- helping to improve and optimise the operation of Alarmira's website;
- accomplishing the online purchase of a product and/or service from Alarmira through the webshop.
By subscribing to the "Plus" subscription, the data subject may choose to make use of the alarm follow-up by Securitas Alert Services NV. In that case, Securitas Alert Services NV will process the personal data of the person concerned and Securitas Alert Services NV's privacy policy shall apply. The person concerned acknowledges that he/she has had the opportunity to read the privacy policy of Securitas Alert Services NV.
4.4 Legal obligations
In the event of a court order or to comply with other mandatory laws or regulations, Punfyre BV may disclose personal data. Data subjects will be informed accordingly, unless subject to legal restrictions.
4.5
Punfyre BV does not sell, rent, distribute or make the collected personal data commercially available to third parties. Punfyre BV guarantees a similar level of protection by making contractual obligations opposable to appointees, which are similar to this privacy policy and guarantee the duty of discretion at all times.
5. Duration of processing
Punfyre BV retains and processes personal data for the period it is legally obliged to do so or for as long as it is essential for the purposes of the processing or for the contractual relationship with the data subjects.
6. Data subject's rights
6.1 Right of access and inspection
The data subject has the right to access his/her personal data and its use by Punfyre BV at any time.
6.2 Right of rectification, deletion and restriction
The data subject is free not to communicate certain Personal Data to Punfyre BV. The data subject always has the right to request Punfyre BV to amend his/her Personal Data. The data subject may also request that the processing of specific Personal Data be restricted, if the data subject believes that those data are inaccurate. In addition, the data subject has the right to request Punfyre BV to delete specified personal data. If the data subject refuses to disclose certain personal data or requests the deletion of specified personal data, Punfyre BV may no longer be able to (optimally) provide specified Alarmira products and/or services.
6.3 Right of opposition
The data subject has a right to object to the processing of their personal data if they have serious and legitimate reasons to do so.
6.4 Right of free data transfer
The data subject has, within certain limits, the right to obtain his/her personal data processed through Alarmira's website in structured, common and machine-readable form and/or to transfer it to other controllers.
6.5 Right to withdraw consent
Data subjects have the right to withdraw their prior consent to the processing of their personal data.
6.6 Rights regarding automated decisions and profiling
The data subject shall have the right to request Punfyre BV not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or significantly affecting the data subject.
6.7 Exercise of rights
The data subject may exercise his/her rights by contacting Punfyre BV and attaching a copy of his/her identity card to this request
- by e-mail to [email protected]
- by post to Punfyre BV, Vlamingstraat 4, 8560 Wevelgem (Belgium)
6.8 Right of complaint
The data subject has the right to lodge a complaint with the Belgian Data Protection Authority:
- Address: Data Protection Authority, Rue du Printing Press 35, 1000 Brussels,
- Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,
- Email: [email protected]
This is without prejudice to a remedy before a civil court. Should the data subject suffer damages as a result of the processing of their personal data, the data subject may bring a claim for compensation.
7. Security and confidentiality
7.1
Punfyre BV has developed security measures that are adapted on a technical, administrative and organisational level to avoid the destruction, loss, falsification, modification, unauthorised access or inadvertent disclosure to third parties of personal data as well as any unauthorised processing of these data. In the event that a aforementioned breach does occur and this would involve personal data, Punfyre BV will inform the data subject about the breach, including a description of the potential impact and a recommendation to limit the possible negative consequences of the breach.
7.2
Punfyre BV provides a secure, data subject-controlled environment for the use of Alarmira's website and application. Punfyre BV stores personal data securely on servers located within the European Economic Area.
7.3
Under no circumstances can Punfyre BV be held liable by a data subject for any direct or indirect damage resulting from an erroneous or unlawful use by a third party of the personal data.
7.4
The data subject bears responsibility for maintaining the privacy and security of Alarmira's application. For example: by not allowing a third party to use its personal login and by avoiding all unauthorised access to its account. The data subject alone is liable for the use of Alarmira's application on the devices/devices, IP address and identification data as well as its confidentiality.
7.5
The data subject must immediately inform Punfyre BV of any unauthorised use of their account by sending an email to [email protected].
8. Applicable law and competent courts
This Privacy Statement is exclusively governed by and to be interpreted in accordance with applicable Belgian law without regard to any conflict of laws or rules. The courts and tribunals of the judicial district of West Flanders, Kortrijk division shall have exclusive jurisdiction if a dispute arises regarding the interpretation or implementation of this Privacy Statement.