Personal information means all information used to directly or indirectly identify an individual (“Personal Information”).
We collect Personal Information only in the course of our activities and in order to respond to your requests, in compliance with applicable laws and, in particular, the General Data Protection Regulation (the “GDPR”).
You will never be asked to share “sensitive” Personal Information such as your racial or ethnic origin, or your political, philosophical or religious opinions.
When you access the www.alarmtilt.com website (the “Site”) or when you enter into a relationship with M-PLIFY or its subsidiaries (the “M-PLIFY Group”), such as when contacting customer service, you acknowledge having read and understood the terms of Personal Information collection and use, as set out in this Policy.
What is in this Policy? What happens to my Personal Information if I interact with this Site or with the M-PLIFY Group in general?
This Policy applies to Personal Information that is collected and/or used when:
1. You interact with the www.alarmtilt.com website, which is operated by M-PLIFY S.A., established and headquartered at 68 avenue de la Liberté, L-1930 Luxembourg.
2. You solicit services from M-PLIFY or one of its subsidiaries either online on the site, or offline, including when you contact customer service to ask questions or make specific requests or as part of the performance of a contract.
3. M-PLIFY shares with you as part of its marketing activities.
For specific uses, we may require your consent to use your Personal Information. In this case, before you share your personal information, M-PLIFY will ask you to electronically confirm your consent to the activity in question, by checking the box(es) provided for this purpose.
Voluntarily checking the corresponding box and using the Site means that you agree to the activity in question.
The documents attesting your acceptance of this Policy, with the date affixed, and any subsequent modifications to this Policy will be considered to be conclusive written proof of your consent.
Who Controls the Handling of My Personal Information? Who Can I Contact If I Have a Question or Complaint?
The entity responsible for using your Personal Information is:
M-PLIFY S.A., established and headquartered at 68 avenue de la Liberté, L-1930 Luxembourg, registered in the registre de commerce et des sociétés de Luxembourg (Luxembourg Trade and Companies Registry) under number B 80.206.
When you enter into a relationship with a subsidiary of M-PLIFY, this subsidiary is also responsible for using Personal Information that you have shared with it.
You may contact the M-PLIFY Group’s Data Protection Officer through any of the following methods:
Phone: +352 261 846
mail: 68, avenue de la Liberté, L-1930 Luxembourg
What Personal Information is Used?
Personal Information Collected Automatically On This Website
The use of your Personal Information when you are only visiting the Site is limited to your connection and browsing data, namely the information whose transmission to the Site helps operate the systems responsible for managing the Site and the internet-specific communication protocols.
This information includes your IP address, your internet services provider, information about your browser, your location information, the date and time of the connection, the number of visits, your browsing pattern on the Site or even how long you viewed the page(s).
If you disable the cookies used by M-PLIFY, it may impact Site navigation.
Personal Information That You Provide Voluntarily
M-PLIFY collects and uses:
1. Personal Information you share when you use the Site’s functionalities, such as when you download content available on the Site.
2. The Personal Information you share when you sign up for, or participate in, M-PLIFY’s marketing activities (either through the Site or offline), for example when you subscribe to our newsletter or participate in events or initiatives organised by M-PLIFY.
3. The Personal Information you share when you exchange with M-PLIFY’s customer service. For example, when you contact it through the contact form or by email, when you share feedback, or when you contact M-PLIFY’s customer service to obtain a demo or a specific service.
4. The Personal Information you share when you solicit a service offer as part of the conclusion and execution of a contract with M-PLIFY or its subsidiaries.
This data includes:
- Your identification and contact information, including your first and last name, mailing address, email address, phone number, company, function).
- Your authentication information (your user name and your password if you create an account on the Site).
- Information about why you contacted customer service.
- The content of your communication with customer service.
- Your habits and preferences (information collected from your interactions with our customer service department, our Site, from the social media, and from emails).
- Your request(s) history.
When you provide another person’s personal information (for example, when using the “Recommend this page” function), you hereby confirm, insofar as applicable laws permit, that you are entitled to share this personal information with M-PLIFY and that you have informed the other person about how their personal information will be used under this Policy, and, if applicable, that you have obtained their consent.
Personal Information Collected From Third Parties
M-PLIFY collects Personal Information about you from third parties, in order to verify or enrich its database, through the following means:
- Publications and databases provided by the official authorities.
- Websites/social network pages containing information that you have made public.
How Is My Personal Information Used?
M-PLIFY collects and uses your Personal Information for the following purposes:
1. To operate and manage the Site, and in particular:
- To provide you with the services and functionalities that you request on the Site
- To manage your subscription to M-PLIFY services
- To improve your browsing experience and to improve the Site.
2. To conduct marketing activities for the M-PLIFY Group, and in particular:
- For prospecting purposes, including:
- To manage your subscription to M-PLIFY’s newsletter and its mailing lists.
- To enable you to participate M-PLIFY initiatives and promotional events.
- To send you, with your consent, by email or other electronic media, information and promotional material about M-PLIFY services, special pricing and promotion initiatives, events, exhibitions and fairs organised by M-PLIFY, or to which M-PLIFY takes part.
- For investigation purposes.
- For profiling purposes:
- In order to evaluate your expectations and to provide you with services that meet your situation and your profile as defined by M-PLIFY.
- In order to evaluate the effectiveness of advertising messages and to adapt them.
- To improve the Site and M-PLIFY’s services
3. To provide you with customer service, and in particular:
- To reply to your requests for information, questions, emails or feedback about your experience
- For internal training purposes and to improve M-PLIFY’s customer service
4. To enter into a contract with you and to execute it:
- To provide you with information about the M-PLIFY Group’s services
- To manage customer relationships
- To provide the services of customer companies’ with which you are an agent or employee.
5. For other purposes:
- For the purposes of preventing fraud and abuse
- In order to comply with its obligations under applicable law as well as to establish and defend its rights in court
What Are the Legal Foundations for Using My Personal Information?
M-PLIFY collects and uses your Personal Information based on the following legal foundations:
- Using your Personal Information is required to perform a contract to which you are a part or to perform pre-contractual measures made upon your request.
- The use is required for M-PLIFY’s legitimate interests or the legitimate interests of its subsidiaries, unless your interests or freedoms prevail; M-PLIFY’s legitimate interests include, among other things, managing and maintaining its contractual relationship with its customers, responding to specific requests, requesting your feedback in order to improve the Site and the services provided, or to engage in marketing and profiling activities.
- When using your Personal Information requires obtaining your consent under the terms of this Policy, your Personal Information will be used based on this consent
For How Long is My Personal Information Kept?
Your Personal Information is kept only for the time required to accomplish specific tasks related to their use, unless applicable law prescribes shorter or longer retention periods.
Customers’ Personal Information is kept for the duration of the contractual relationship and Personal Information relating to the contract or M-PLIFY’s rights is kept for 10 years after the end of this relationship.
Leads’ Personal Information is kept for three years after their last contact with the M-PLIFY Group.
Information collected through cookies and other tracking technologies is kept for a period of one year after its collection.
Is My Personal Information Secure?
M-PLIFY strives to protect the security and confidentiality of your Personal Information. M-PLIFY takes – and requires all service providers and/or subcontractors using your Personal Information on its behalf and according to its instructions to take – appropriate organisational and security measures in order to prevent loss and destruction of information, including accidental, unauthorised access to information, or illegal or unfair use of it.
For example, the Personal Information that you provide is kept on secure servers located in controlled locations.
However, no stored information or electronic communication can be 100% secure.
If your Personal Information is password protected, you are responsible to keep it confidential and not to share this information with anyone.
The Site may contain links to other third-party websites, including to social networks. If you click on a link to a third-party site, you understand and agree that you are leaving the Site governed by this Policy and that M-PLIFY does not control these third-party websites.
Who Receives Your Personal Information? Where is Your Personal Information Sent and For What Purpose(s)?
Personal Information collected by the M-PLIFY Group through the Site or offline is kept on the servers provided to the M-PLIFY Group and managed by storage and hosting providers located in the following places:
- Planet Hoster : Paris, France,
- Amazon Web Service : Europe.
Some Personal Information may also be kept at M-PLIFY’s head office. M-PLIFY shares your Personal Information with the recipients listed below:
- Within the M-PLIFY Group your Personal Information will be available to internal and external personnel who need to access for the handling purposes specified in the Policy. M-PLIFY ensures that these people are subject to appropriate obligations with regards to security and confidentiality. A list of M-PLIFY companies is available upon request.
- Your Personal Information may also be accessible to third-party service providers appointed by M-PLIFY to use Personal Information on its behalf and according to its instructions as subcontractors. These third-party service providers work in particular to provide technical and organisational services related to managing the Site and any related activities. These subcontractors are bound by appropriate contractual obligations that required them to implement adequate organisational and security measures intended to protect Personal Information security and confidentiality.
- Your Personal Information may be communicated to third parties, provided that applicable law allows, as part of legal proceedings, requests from the competent authorities or courts, or on the basis of any other legal obligation to protect and defend M-PLIFY’s rights, as well as those of the Site.
- M-PLIFY may be required to share your Personal Information to third parties in case of mergers, acquisitions or transfer of assets.
Apart from the above, your Personal Information will not be shared with third parties, whether they are natural or legal persons, who have no relationship with the M-PLIFY Group and who do not perform commercial or technical work for M-PLIFY.
Your Personal Information will not be shared with third parties for their own prospecting purposes.
These transfers occur according to the basis of use identified herein.
The aforementioned recipients may be located in countries other than the one in which your Personal Information was initially collected. However in principle, your Personal Information will not be transferred outside of the European Economic Area (EEA) or other countries recognised by the European Commission as providing an adequate level of protection of personal information.
In the event the above recipient is established in a country outside the EEA which is not the subject of the European Commission’s adequacy decision, M-PLIFY implements appropriate guarantees, including, but not limited to, relevant data transfer agreements based on the standard contractual clauses adopted by the European Commission for transferring data to outside countries or binding corporate rules. A copy of these guarantees can be obtained from M-PLIFY.
Am I Required to Provide My Personal Information?
Other than browsing information, sharing your Personal Information may be required to conclude or execute a contract, or to access/use certain services provided by the Site, such as downloading content (like a white book, for example); subscribing to our newsletter, signing up for a demo, managing participation in initiatives communicated through the Site, responding to information requests, questions, communication or feedback and their handling.
In the aforementioned cases, refusal to share your Personal Information will prevent performance of the contract or access to the requested services or information.
Sharing your Personal Information for investigation purposes, for business development and profiling is optional. In this case, your opposition to the collection of your Personal Information will not affect the conclusion and performance of the contract.
Does the Site have any elements controlled by third parties?
The Site may contain links to other sites as well as objects or elements controlled by third parties.
These include plug-ins that may connect M-PLIFY’s website to social networks such as Facebook, Google+, Twitter or LinkedIn (“social plug-in”), which are usually identified by the logo of the corresponding social network. If you use a social plug-in on the Site, your browser may send Personal Information about you to the social network in question (information on the Site, for example). This information may be held and used by the social network(s), in accordance with their privacy policies.
M-PLIFY has no access or control over tracking elements or technologies owned and operated by third parties that are found on the Site or on corresponding third party websites, nor on the ways your Personal Information is used by third parties through these elements or websites.
What Are My Rights Regarding the Use of My Personal Information and how can I exercise them?
You can exercise your rights at any time within the framework of the laws on the protection of Personal Information, including but not limited to, the right to access, correct, and to delete your Personal Information, the right to portability, the right of opposition (in particular by refusing the use of your Personal Information for direct marketing purposes at any time and without cost), the right to limit as well as the right to withdraw your consent.
You are also entitled to file a complaint with a competent supervisory authority.
Annex 1 herein specifies the content of these rights.
You can exercise your right(s) at any time and at no cost by addressing your request to the M-PLIFY Group’s Data Protection Officer by email (email@example.com) or by mail (68 avenue de la Liberté, L-1930 Luxembourg), and by attaching a copy of you identification. This requirement enables us to verify that you are indeed the originator of the request.
M-PLIFY undertakes to reply to your request to exercise your rights or any other additional request for information within a reasonable time, which cannot exceed one month from receipt of your request.
Can This Policy Be Modified?
M-PLIFY reserves the right to update and modify all or a part of this Policy at any time, insofar as applicable law allows.
The version published on the Site is the current version.
If M-PLIFY modifies the Policy, you will be informed on the Site’s Home page, through a link to the revised Policy and/or other means.
Your rights change with the GDPR, so we have chosen to list the principle rights concerning your personal information. If you have 5 minutes, it would be a good time to read this now.
ANNEX 1 – RIGHTS OF THE PERSON CONCERNED
1. Right to Access, And Communication of Your Information
You have the right:
- To obtain confirmation from M-PLIFY that your Personal Information is used or not.
- To access your Personal Information and to receive a copy of it.
To be informed of the conditions of use of your Personal Information, and in particular the categories of Personal Information concerned, the reasons for its use, and its recipients. This right is not absolute as M-PLIFY must take into account the rights and freedoms of others.
M-PLIFY is entitled to object to manifestly abusive requests due to their number or repetitive nature.
2. Right to Rectification
You have the right to request that inaccurate, incomplete or obsolete Personal Information be corrected, updated, locked up or deleted.
3. Right to Erasure (Right to be Forgotten)
You have the right to request deletion of your Personal Information in a number of cases referred to in Article 17 of the GDPR.
If your request falls into one of these cases, M-PLIFY will delete your Personal Information as soon as possible.
4. Right to Data Portability
You are entitled to receive the Personal Information you have shared with us, in a commonly-used, structured and machine-readable format, and you have the right to share this information with another entity responsible for handling or requiring that M-PLIFY share this information directly with another handling entity, provided that:
- The use of this Personal Information is based on your consent or the execution of a contract
- It is handled through automated processes.
This right is not absolute insofar as M-PLIFY must take into account the rights and freedoms of others.
5. Right to Object to Processing
For reasons related to your individual situation, you have the right to oppose, at any time, that M-PLIFY use your Personal Information for the purposes of its legitimate interests or for statistical purposes.
M-PLIFY will be required to stop using your Personal Information, except if it can demonstrate that there are legitimate and compelling reasons for its use that prevail over your rights and freedoms or to recognise, exercise or defend its rights in court.
6. Right to Object to Direct Marketing
You have the right to object to the use of your Personal Information at any time for direct marketing purposes (including profiling to the extent that it is related to such marketing).
M-PLIFY will immediately cease this kind of use upon receipt of your request.
7. Rights Related to Automated Decision-Making, Including Profiling
You have the right not to be subject to a decision made exclusively by automated processing, including profiling, as soon as this decision significantly affects you, except if:
- This decision is required to conclude or execute a contract between M-PLIFY and yourself.
- M-PLIFY’s rights authorise making this decision.
- You have given your explicit consent prior to this decision being made.
8. Right to Restriction of Processing
You have the right to obtain a restriction on the use of your Personal Information in the following cases:
- If you dispute the accuracy of your Personal Information during the period within which M-PLIFY can verify its accuracy.
- In case your Personal Information is unlawfully used and you prefer that its use be restricted rather than erased.
- M-PLIFY no longer needs to use your Personal Information but it is still required to recognise, exercise or defend rights in court.
- If you have objected to your Personal Information being used for M-PLIFY’s legitimate interests during the verification period used to determine if the legitimate reason pursued by M-PLIFY prevails over your legitimate interests.
In this case, your Personal Information cannot be used without your consent, except for its retention or for the establishment, exercise or defense of rights in court, or for the protection of the rights of another natural or legal person, or for important reasons of public order.
9. Right to Withdraw Consent
If you have consented to the use of your Personal Information, you may withdraw this consent for the future at any time.
Withdrawing consent does not affect the use of your Personal Information prior to this withdrawal.
10. Right to Lodge a Complaint
If you believe that M-PLIFY is not meeting its obligations concerning your Personal Information, you can lodge a complaint or make a request to a supervisory authority, including in the State of your usual residence, your place of work or the location where the violation occurred.
In the Grand Duchy of Luxembourg, the competent authority is the Commission Nationale pour la Protection des Données (CNPD) (Complaints Service, 1 avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette).