(Arrayent is a wholly-owned subsidiary of Prodea Systems, Inc.)
This policy statement is effective as of 9/9/17
Arrayent and its subsidiary company Arrayent UK, LTD participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Arrayent is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, https://www.privacyshield.gov/list.
Arrayent is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Arrayent complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Arrayent is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Arrayent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Overview of our services
Arrayent is an Internet of Things (IoT) technology provider to manufacturers, resellers and retailers (Clients) of commercial and consumer products. Our technology and services are used by Clients to connect their products to the internet so that they and their customer users can monitor and control these products remotely, either directly through mobile or web based apps or in sync with other connected products from other connected product suppliers. We provide the communications technology that is embedded in each connected product and we also run the cloud based services that collect, hold and manage data from the connected product and the user and communicate between the connected product, the user and the Client.
The information we receive
In order to provide our services, we may receive data about users from different sources. From the user based app, we may receive registration data such as your name, email address, age, IP address and home address. Usage of the mobile app may provide data about your usage patterns regarding the connected product. Data from the connected product may include its service history, usage patterns and current state of operation, i.e. on or off, open or closed, full or empty, etc.
Arrayent collects this information under the direction of our Clients, and we have no direct relationship with the individuals whose personal data we process. If you are a customer of one of our Clients and would no longer like to be contacted by the Client that uses our service, please contact that Client directly.
From our website (arrayent.com), we may ask you to provide additional information that helps us enhance your site visit, assist you with technical support issues, or permit post-visit follow-up. For example, if you send us a support request e-mail, we receive your e-mail address, and any other information you provide, such as your name, telephone number, etc.
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you such as IP address. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include zip code or similar so that we can provide to our customers an indication of the geographical concentration of connected devices.
How the information is used
We use the information we receive through our services to provide connectivity, control and feedback to the connected product, the user and to the Client. For example, we may provide user registration data to help the Client keep track of its users and to understand better the demographics of its user population. We may also provide connected product use information to the Client such as usage history, features used, maintenance status and remaining useful life information that the Client could use to monitor the connected product and suggest maintenance, replacement or refill activities to the user. Finally, we may provide connected product state information to the user through their mobile or desktop app to allow them to control the connected product remotely. If the user, elects to connect to their connected product through a third party, we will also provide data to that third party.
We may disclose the information we receive, either through our services or submitted to us via email;
- In certain situations, Arrayent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements
- If we believe that we have a legal obligation to do so, such as to comply with a subpoena or similar legal process
- In situations where we believe it’s necessary to protect ourselves, our customers or users or to prevent or stop activity we may consider to be, or poses a risk of being illegal or legally actionable activity
- In connection with a corporate merger, acquisition, sale of assets, bankruptcy, or other change in corporate status. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to a third party with your prior consent.
What we don’t do with data
- We don’t attempt to determine any additional personal information not provided directly to us.
- We do not sell your personal information to third parties.
- We do not provide your personal data to third parties who might create ads or advertising segments related to sensitive interests, such as, medical conditions, certain financial situations, sexual preferences and products, and use of firearms, drugs or alcohol.
- We do not deliver ads.
- We do not intentionally collect data from children under 13 years of age. If we find that we have collected information from someone under 13 we will delete this information immediately.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We also collect information you submit to our dev kit on our web site. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
Arrayent and our partners, and analytics providers use technologies such as cookies, beacons, tags, scripts or similar technologies, to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Social Media Widgets
Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
Security of information
The security of information is important to us. Certain information provided to us (such as user’s password), is encrypted using generally accepted encryption methods.
We follow generally accepted standards to protect the information we receive. However, no method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
Sometimes we employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share your information with our Agents in order to make our services and site available to you. Unless we tell you differently, our Agents do not have any right to use your personally identifiable information or other information we share with them beyond what is necessary to assist us. Arrayent may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Opting out of the services on the website
If you’d like us to update, correct, delete, or deactivate any personally identifiable information that you have provided to us on our website, please send your request to us at email@example.com. Upon request we will provide you with information about whether we hold any of your personal information. We will respond to your request within a reasonable timeframe.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Updating your information with our Clients
Arrayent has no direct relationship with the end users whose personal data it processes on behalf of its Clients. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Arrayent Client (the data controller) directly. If requested to remove data by our Client, we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to them. Arrayent will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Links to Other Websites
Our website includes links to other sites whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
We encourage you to review this policy periodically to stay informed about how we collect, use, and disclose data.
Our Corporate Website; our Marketing Practices
Our corporate website at arrayent.com is designed for our customers and their users. We don’t collect personally identifiable information from users via our website unless users choose to provide it to us. Any information you submit to us will be used to send you the requested product or service information, or to respond to your questions or concerns. If you would like to discontinue receiving marketing emails, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at firstname.lastname@example.org.
California Residents: Your California Privacy Rights
Under California law, our customers that are California residents may request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. As detailed above, we do not share our customer’s personal information with unaffiliated third parties for direct marketing purposes without the customer’s approval.
If at any time you wish to opt-out of having your personal information shared with third parties and/or receiving information from Arrayent (via e-mail or postal mail) about new products, services, or promotions, you can do so. You may contact us at Arrayent 2317 Broadway Street #20, Redwood City CA 94063. You can also contact us by e-mailing us at email@example.com. Please indicate what publications or services you no longer wish to receive so that we may better address your needs.
Arrayent (a wholly-owned subsidiary of Prodea Systems, Inc.)
2317 Broadway Street #20
Redwood City, CA 94063