TERMS OF SERVICES (PRIVACY POLICY)

EFFECTIVE DATE: OCTOBER 1, 2018
SeekitTM Mobile Application ("Licensed Application") is designed to tag, connect and find your valuables, thereby making it easy for you to keep your belongings closer to you. This Privacy Policy explains our policy regarding information collected by Panasonic India Private Limited (Company) from you and how we use this information to provide various services and features. This Privacy Policy is part and parcel of the Terms and Conditions of Use for SeekitTM services.

INFORMATION RECEIVED, COLLECTED AND STORED BY THE COMPANY

In this Privacy Policy, the term "Personal Information" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, or, in certain circumstances, location information, an IP address or the unique identifier allocated to each Seekit device. Specifically, we collect the following information from you, which may include Personal Information.

As we update, improve and expand the Services, this policy may change, so please refer back to it periodically. By accessing the Company website or this Application or otherwise using the Services, you consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.

We take your privacy as seriously as you do, and because of that we take great care to collect only the information necessary to provide you with the best possible experience.

EACH COUNRTY ANNEX FOR YOUR JURISDICTION SHALL ALSO BE APPLICABLE TO YOU.

INFORMATION RECEIVED, COLLECTED AND STORED BY THE COMPANY

In this Privacy Policy, the term "Personal Information" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, or, in certain circumstances, location information, an IP address or the unique identifier allocated to each SeekitTM device. Specifically, we collect the following information from you, which may include Personal Information.

A. INFORMATION SUPPLIED BY USERS

Registration data:

You’ll need to use a valid email address and create a password to create an account for Services on the SeekitTM app. You can choose whether or not you’d like to provide your first and last name. When you register using your other accounts like on Facebook, Gmail etc. we shall retrieve Information from such account to continue to interact with you and to continue providing the Services. We do not identify you personally to other users or make your account information available to any third parties in any way that could identify you without your prior consent.

Our Services are not directed to children and we do not knowingly collect Personal Information from children as per age defined by law. If we learn that we have collected Personal Information of a child, we will take steps to delete such information from our files as soon as possible.

Paid services or purchasing new device:

When you chose to buy a new SeekitTM device or services facilitated on SeekitTM Mobile application or website, our payment gateway provider (authorized partners) may collect your purchase, address or billing information, including your credit/debit card number and expiration date etc.

Internet charges:

By accessing the Services through Seekit device, you may be subject to charges by your Internet or mobile service provider and we recommend you to please check with them for the applicable charges. You shall be solely responsible for any such costs incurred.

Voluntary information:

We may collect additional information at other times, including but not limited to, when you provide feedback, change your content or email preferences, respond to a survey, or communicate with us.

B. INFORMATION COLLECTED FROM USE OF SERVICES

SeekitTM Device ID, Name and Photograph

As soon as you activate a SeekitTM using the SeekitTM app, it’s unique identifier or ID will be associated with your account. If you choose to give a name to your SeekitTM device or belonging to which it’s attached, or add a photo of it, this information will also be associated with your account.

Location Information

As part of SeekitTM services, the application can indicate where your belongings are. To make it possible it’s necessary to collect data about your location. We use the term “Location Information” to refer to the combined location data of your phone or device, and your SeekitTM devices.

As the SeekitTM app runs in background on your device, it periodically transmits your location information. This allows us to show you, on your map, the last place your SeekitTM app was seen by your device. We may also collect and update location information for your SeekitTM device anonymously from other SeekitTM app users who are running the app within Bluetooth range of your device. We do this to provide you with the most recent and accurate location of your SeekitTM devices, even if they are out of your devices’ Bluetooth range.

If you use a computer, phone, or other device to visit our website or help center, we use the IP address of that computer or device to determine an approximate location. We do this so that we can provide you with a better, more-personal customer service experience.

We use your Location Information to provide the Services and may use your Location Information to promote the Services or provide you with offers. However, your Location Information is never shared with other users unless you choose to share it through our Services.

Mobile Application Usage Information

We track how, and how often you use our Services. We also collect certain information that your mobile device sends when you use them for Services. This includes information such as your device’s model, operating system type and version, and the dates and times of your requests. We use this information to provide you with optimal services and support, and to collect anonymous statistics that help us understand our user base.

Cookies

To improve the responsiveness of the "Application" for our users, we may use "cookies", or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the user's individual interests using the identified computer. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer. The only personal information a cookie can contain is information you supply. A cookie cannot read data off your hard drive. We receive and store certain types of information whenever you interact with us via website, Application or Service though your computer/laptop/netbook or mobile/tablet/pad/handheld device etc.

Information Collected through Support Services

We provide support services via our website, email request submissions, recorded outbound telephone calls and direct email. We collect any Personal Information you may choose to provide to our customer care team and our Authorized Service partners in the process. This includes, but is not limited to: your name, email address, phone number, and mailing address. We may use and process your Personal Information, including location information, to handle your support request and provide you with the best support possible.

Clear GIFs

We may use "clear GIFs" (Web Beacons) to track the online usage patterns of our users in a anonymous manner, without personally identifying the user. We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. We use this information to inter-alia deliver our web pages to you upon request, to tailor our Site, Application or Service to the interests of our users, to measure traffic within our Application to improve the Application quality, functionality and interactivity.

THIRD PARTY SERVICES

The Application may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the application, you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from the application's homepage, you should contact the application owners directly for more information.

We do not provide any personally identifiable information to third party websites without your consent.

INFORMATION USE BY THE COMPANY

The Information as supplied by the users enables us to improve the Services and provide you the most user-friendly experience. All required information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the Services and for developing new services. Upon your consent, we may also use your email address or other personally identifiable information to send commercial or marketing messages in compliance with the local law in each jurisdiction. Upon your consent, we may use your email address for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, etc.).

In case you choose to decline to submit personally identifiable information on the Application, we may not be able to provide certain services on the Application to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

INFORMATION SHARING

The Company shares your information with any third party in the following limited circumstances:

  • When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.
  • The Company may share your information regarding your activities on websites or Applications with third party social websites to populate your social wall that is visible to other people however you will have an option to set your privacy settings, where you can decide what you would like to share or not to share with others.
  • The Company may also share your information with third parties if it is allowed to do so under the law of each jurisdiction.

ACCESSING AND UPDATING PERSONAL INFORMATION

You can access and modify your contact information, such as your name, email address or phone number, within the Services, or by contacting us at seekit.support@in.panasonic.com. We may ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.

DELETING YOUR ACCOUNT UPON YOUR REQUEST

If you want us to delete your Personal Information, Location Information and your Account, please contact us at seekit.support@in.panasonic.com. with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Please note, however, that if you delete your Personal Information, Location Information and Account, the location information associated with any active SeekitTM device, may still be collected anonymously from other users who are running the app within Bluetooth range (approximately 30-100 ft.) of your device. However, since your Personal Information will be deleted, any new location information that is collected will no longer be associated with your Personal Information. Please refer to details mentioned in Quick Start Guide to dispose-off your devices.

INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. And, of course, any information you include in a posting to the discussion areas or over Community forum on Application or website is available to anyone with Internet access.

© Panasonic India Private Limited, 2018
12th Floor, Ambience Tower, Ambience Island, NH-8, Gurgaon-122002, Haryana, India

COUNTRY ANNEX: JAPAN

For any inquires, complaints, assertion of rights under Japanese Personal Information Protection Act, please contact us at seekit.support@in.panasonic.com

COUNTRY ANNEX: KOREA

  • Notwithstanding any clause in this Privacy Policy, you will be entitled to give your consent to our processing of Personal Information, unless we are permitted to process your Personal Information without your consent under the applicable data protection regulation.
  • The following items shall be added to “Cookies” section: “You have the option to accept or refuse the installation of cookies. Therefore, you may adjust the options of your web browser to accept or refuse all cookies, or to receive notice each time cookies are installed. In the event you refuse to save cookies, you may experience difficulty in using certain services provided by us.
  • The following items shall be added to “Clear GIFs” section: “You have the option to accept or refuse the installation of clear GIFs. Therefore, you may adjust the options of your web browser to accept or refuse clear GIFs, or to receive notice each time clear GIFs are installed. In the event you refuse to save clear GIFs, you may experience difficulty in using certain services provided by us.
  • Despite the phrases in “Information use by the Company” Section, (a) we will only send commercial or marketing messages where we have obtained proper consent from you (provided that, we may send you commercial or marketing messages without such consent if it is permitted under the applicable data protection regulation), and (b) you will be notified of any disadvantages of not providing your Personal Information in cases where we obtain your prior opt-in consent.
  • Column b) of “Information Sharing” section will be deleted
  • The following items shall be added to this Privacy Policy:

“PERIOD OF PROCESSING AND RETENTION OF PERSONAL INFORMATION

We will process and retain your Personal Information pursuant to the period(s) set forth in the relevant laws and regulations, or period(s) to which you consented to at the time we collected the Information. The applicable periods for processing and retaining the Personal Information are as follows:

  • Online member registration and management thereof: until withdrawal from the membership. Provided, that in any of the following cases, we will be entitled to retain and process the necessary Personal Information until the relevant causes cease to exist, despite your withdrawal from the membership: (i) in case of an inspection or investigation by the authorities into us stemming from a breach of an applicable law or regulation, we will retain and process the Personal Information until completion of the relevant inspection and investigation; or (ii) in case there is an outstanding claim or debt stemming from your use of our online services, we will retain and process the Personal Information until the claim or debt is resolved.
  • Provision of products and services: until the products and services have been supplied and all related payment has been settled. Provided, that in any of the following cases, we will be entitled to retain and process the necessary Personal Information until the expiration of the relevant periods set forth below: Retention of communication records pursuant to Article 41 of the Protection of Communications Secrets Act: Date of telecommunications, start and end times of telecommunications, the subscription number of the other party(ies) involved in the telecommunication, frequency of use, GPS/location-tracking information of base stations - 1 year; Computer communications, internet log records, information on tracing the access location of a communication/access location-tracking information - 3 months.

DESTRUCTION AND SEPARATE STORAGE OF PERSONAL INFORMATION

If Personal Information is no longer needed due to its retention period having expired or its processing purpose having been achieved, we will destroy the Personal Information without delay. If we need to continue storage of the Personal Information pursuant to an applicable law or regulation even though the retention period of the Personal Information to which you consented to has expired or the purpose of processing the Personal Information has been achieved, we will store the Personal Information after transferring it to a separate data base or different storage location.

We will select the relevant Personal Information to be destroyed and destroy it with the approval of our privacy officer. We will destroy Personal Information recorded and stored in the form of electronic files by using a technical method ensuring that the records cannot be reproduced, while Personal Information recorded and stored in the form of paper documents shall be shredded using a paper shredder or incinerated.

OUTSOURCING OF THE PROCESSING OF PERSONAL INFORMATION

We will outsource the processing of Personal Information as follows to facilitate our processing of personal information:

Outsourced Service Provider Outsourced tasks
Service Lee Technologies Private Limited Customer Inquiry

INQUIRIES REGARDING OUR PROCESSING OF YOUR PERSONAL INFORMATION

You may contact the department specified below for any inquiries you might have regarding our processing of your Personal Information. We will make every effort to promptly respond to such requests.

▶ Departments in charge of handling requests for access to Personal Information

Department: Mobility department, Panasonic India Pvt. Ltd.

Contact: seekit.support@in.panasonic.com

COUNTRY ANNEX: Hong Kong

A. Introduction

  • We are committed to protecting the privacy, confidentiality and security of the Personal Information we hold by complying with the requirements of the Personal Data (Privacy) Ordinance (Cap.486) (“PDPO”) in Hong Kong with respect to the management of personal information, which according to section 2 of the PDPO means any data— (a) relating directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. We are equally committed to ensuring that all our employees and agents uphold these obligations.
  • This Annexure is included to comply with the additional requirements relating to data privacy in Hong Kong, and shall be read together with the Terms and Conditions of using the SeekitTM Services (the “End User License Agreement”), and the Terms of Services (Privacy Policy) (the “Privacy Policy”) of the SeekitTM Services. Should there be any discrepancy or inconsistency between the Privacy Policy and this Annexure, this Annexure shall prevail to the extent applicable under the laws of Hong Kong.
  • Unless the context requires otherwise, terms defined in the End User License Agreement and the Privacy Policy shall have the same meaning when used in this Annexure.

B. Purposes for the collection of information

  • In general, the information collected from you will be used for the purpose of rendering our Services to you, to maintain, protect and improve our Services, to develop new services and/or all other matters incidental to the provision of the Services to you.
  • Please refer to the Privacy Policy for the purpose(s) for the collection of each specific type of information
  • Please note that paragraph (b) of “Information Sharing” under the Privacy Policy is not applicable to customers in Hong Kong.

C. Obligation to provide information

The Privacy Policy sets out the types of information the Company will collect from you which may include Personal Information. Please note that it is mandatory for you to provide the following types of information:

  • Registration data for the creation of your account on the SeekitTM Application: email address
  • SeekitTM Device ID and the name you have given to your SeekitTM Device (if any)
  • Location Information
  • Mobile Application Usage Information

In the event that you do not provide the information listed above, we may not be able to render our Services to you.

  • You do not have to provide any information not covered in paragraph 7 above, but it will enable us to improve our Services and provide you with the most user-friendly experience if you do so.

D. Cookies, Clear GIFs, etc.

  • As specified in the Privacy Policy, we may use cookies, clear GIFs (Web Beacons) or other similar information collecting tools in our Site, Application or Service.
  • Cookies is used for the purpose of improving the responsiveness of the Site and Application. Cookies will assign to each user a unique, random number as a User ID to understand each user’s individual interests using the identified computer/mobile device. Unless you supply information voluntarily (e.g. through registration), cookies will not collect any information from your computer that identifies you personally. You may choose not to accept cookies by changing the settings, but if you do so, you need to fill in the format again.
  • Clear GIFs (Web Beacons) is used for the purpose of tailoring our Site, Application or Service to the interests of each individual users, to measure traffic within our Application, to improve the quality, functionality and interactivity of the Application. Clear GIFs will track the online usage patterns of our users anonymously, without personally identifying the users. We may disclose the information collected through clear GIFs to advertisers for them to know the geographic locations of the users. You may choose not to accept clear GIFs by changing the settings.

E. Retention of Personal Information

  • In general, your Personal Information will be retained by the Company for 1 (one) year after you have ceased to use the Services, provided that you have not made any deletion request.
  • Where 1 (one) year has passed after we collect your Personal Information or you have requested us to delete your Personal Information,
  • Upon your written request to remove your Personal Information in our system (unless otherwise required by any applicable law), we will provide you with the details in relation as to how to permanently remove your personal data from our system. However, in the event that any information listed in paragraph 7 above is removed, we may not be able to render our Services to you.

F. Access of Personal Information

G. Transfer of Personal Information collected to our server outside Hong Kong

  • For the purposes of providing our Service to you, we will transfer your name, email address, mobile phone number, home/office address, identification information of your mobile device and identification information of your SeekitTM Device outside Hong Kong to our server situated in [India], where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as the PDPO in Hong Kong. That means your personal data may not be protected to the same or similar level in Hong Kong.

H. Enquiries

COUNTRY ANNEX: CHINA

If your country of residence is the People’s Republic of China (the “PRC”, for the purpose of this Privacy Policy, excluding Hong Kong, Macau and Taiwan), in addition to the TERMS OF SERVICES (PRIVACY POLICY), please also refer to the SUPPLEMENTAL PRIVACY POLICY below. Any matters not mentioned in this SUPPLEMENTAL PRIVACY POLICY shall apply the TERMS OF SERVICES (PRIVACY POLICY). If there is any discrepancy between this SUPPLEMENTAL PRIVACY POLICY and the TERMS OF SERVICES (PRIVACY POLICY), this SUPPLEMENTAL PRIVACY POLICY shall prevail.

SUPPLEMENTAL PRIVACY POLICY

EFFECTIVE DATE: 19th April 2019

INFORMATION CONTROLLER

The information controller is Panasonic India Pvt. Ltd.. Contact information:

Address: 12th Floor, Ambience Tower, Ambience Island,NH-8, Gurgaon, Haryana-122002, India

Email: seekit.support@in.panasonic.com

REGISTRATION DATA:

You will need to provide your valid mobile phone number for us to certify your identification before creating an account for Services on the SeekitTM app.

OPERATING GLOBALLY AND INTERNATIONAL TRANSMISSION

We store your Personal Information in servers located within the PRC. However, in order to facilitate the Services and our global operations, we may give direct access to your Personal Information and/or transmit your Personal Information to our affiliate companies outside the PRC, provided that the transmission is made in compliance with laws and regulations of the PRC and other jurisdictions where your Personal Information is transmitted to. Where we transmit, store and process your Personal Information outside the PRC, we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING

You may withdraw your consent to our processing your Personal Information at any time by sending a message to us specifying which consent you wants to withdraw. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities conducted by us based on such consent before its withdrawal. In case you choose to withdraw consent to our processing your Personal Information, we may not be able to provide certain services on the Application to you. We will make reasonable efforts to notify you of the same when we receive your request of withdrawal. In any case, we will not be liable and or responsible for the denial of certain services to you for your withdrawal of consent.

AMENDMENT OF THE TERMS OF SERVICES (PRIVACY POLICY) AND THIS SUPPLEMENTAL PRIVACY POLICY

If we make any amendment to the Terms of Services (Privacy Policy) and this Supplemental Privacy Policy, we will provide notice through this Application and the Company website, or contact you via your contact information, for example by email or some other equivalent method to provide you the opportunity to review the amendment before they become effective.

COUNTRY ANNEX: SINGAPORE

If you use the Services in Singapore, the following additional terms shall apply:

Data Protection Officer:If you have any queries or comments on this Policy or the use of your Personal Information, please contact the Company’s data protection officer at:

Email address: seekit.support@in.panasonic.com

Address: 12th Floor, Ambience Tower, Ambience Island, NH-8, Gurgaon, Haryana-122002, India

WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING

You may withdraw your consent to our processing your Personal Information at any time by sending a message to us specifying which consent you wants to withdraw. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities conducted by us based on such consent before its withdrawal. In case you choose to withdraw consent to our processing your Personal Information, we may not be able to provide certain services on the Application to you. We will make reasonable efforts to notify you of the same when we receive your request of withdrawal. In any case, we will not be liable and or responsible for the denial of certain services to you for your withdrawal of consent.

AMENDMENT OF THE TERMS OF SERVICES (PRIVACY POLICY) AND THIS SUPPLEMENTAL PRIVACY POLICY

If we make any amendment to the Terms of Services (Privacy Policy) and this Supplemental Privacy Policy, we will provide notice through this Application and the Company website, or contact you via your contact information, for example by email or some other equivalent method to provide you the opportunity to review the amendment before they become effective.

COUNTRY ANNEX: TAIWAN

If you use the Services in Taiwan, the following additional terms shall apply:

PURPOSES FOR THE COLLECTION OF INFORMATION

In general, the information collected from you will be used in Taiwan and India (except where any of the information used in the area other than Taiwan and India pursuant to the provision of INFORMATION SHARING below) for the purpose of rendering relevant services of SeekitTM Mobile Application to you, to maintain, protect and improve such services, to develop new services and/or all other matters incidental to the provision of such services to you during the period of 1 (one) year after you quit our service.

The section titled “ACCESSING AND UPDATING PERSONAL INFORMATION” shall be deleted and replaced with the following:

"ACCESSING, DUPLICATING AND UPDATING PERSONAL INFORMATION

You can access, duplicate and modify your contact information, such as your name, email address or phone number, within the Services, or by contacting us at seekit.support@in.panasonic.com We may ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.”

inquiry and request for a review of the personal information; The section titled “DELETING YOUR ACCOUNT UPON YOUR REQUEST” shall be deleted and replaced with the following:

If you want us to stop collecting, processing or using your Personal Information and to delete your Personal Information, Location Information and your Account, and inquiry or request for a review of the personal information, please contact us at seekit.support@in.panasonic.com with your request. We’ll take steps to discontinue the collection, processing or use of your information and delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Please note, however, that if you delete your Personal Information, Location Information and Account, the location information associated with any active SeekitTM device, may still be collected anonymously from other users who are running the app within Bluetooth range (approximately 30-100 ft.) of your device. However, since your Personal Information will be deleted, any new location information that is collected will no longer be associated with your Personal Information. Please refer to details mentioned in Quick Start Guide to dispose-off your devices.”