This Privacy Policy was last modified on October 1, 2020.

WELCOME

SecureView Limited, Inc (“MySecureView“, “we“, “our“, or “us“) is committed to protecting and respecting your privacy.

SecureView operates a service that allows you to share your location with other users, family or friendship group (your “Family” or “Circle“), which we make available through our apps and our website https://www.mysecurevview.com (the “Service“). By sharing their locations, users are able to request assistance from their friends, families and service providers during emergencies.

This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many different countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

This Privacy Policy is therefore made up of two parts: Part 1 sets out information applicable to users outside the European Economic Area or Switzerland, and Part 2 sets out information applicable to users in the European Economic Area or Switzerland.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from users outside the European Economic Area or Switzerland, as well as your choices regarding the collection and use of information.

This Part 1 of the Privacy Policy was last modified on October 1, 2020.

1. PERSONAL INFORMATION COLLECTED

1.1 USER PROFILE

When You create a user profile in the Services, Secureview will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and phone number and email address. Additional information that may be provided include, but is not limited to, photo, gender. Secureview may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available.

1.2 INSTALLATION AND USE

When You install and use the Services, Secureview will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; applications installed on your device; operating system; web browser; IMSI; connection information; access to device address book.

Given below are how information collected from users is used:

• Personal contact (First name, last name, email address, phone number, photo): creation of user profile,
• Geo-location/ IP address: connecting user with service provider,
• Device information (ID, manufacturer, version, operating system): knowledge of user groups who use the service so as to improve service delivery,
• User address book: This allows users to share info about SecureView with their contacts as well as create user groups (family, friends, etc.) to have a better user experience.

Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.

1.3 THIRD PARTY SERVICES

You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information, content viewed by You, content liked by You and information about the advertisements You have been shown or may have clicked on) and You agree that we may collect, use and retain the information provided by these third party services in accordance with this Privacy Policy. You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.

1.4 CONTACT INFORMATION

Where the Mysecureview mobile applications (“Mysecureview Apps”) are obtained from other sources than Apple App Store or Google Play, You may share the names, numbers, Google ID’s and email addresses contained in Your address book (“Contact Information”) with Secureview. Where the Mysecureview Apps are obtained from Apple App Store or Google Play, we do not share any user Contact Information without your consent. In addition to Contact Information, if You choose to activate use of a third party service, such as social networks services, within the Services, Securevieww may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users.

Please note that no other contact information other than the phone numbers and thereto attached names, Google ID’s and email addresses will be collected and used from Your address book. Please also note that You can always choose not to share Contact Information with Secureview and if You have shared such information and changed Your mind, You can delist Your number or opt-out.

1.5 OTHER INFORMATION YOU MAY PROVIDE

You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number, that is not registered in the Secureview database or belongs to a User, with a business. Secureview may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in contests, surveys or other promotions. Secureview will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.

2. USE OF PERSONAL INFORMATION

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

We collect the following types of information about you:

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number and a photo, if you chose to have a photo associated with your account. If you want to add a family member’s name to your account, we collect the family member’s name, email address, and mobile phone number. We may also collect billing information when you sign up for Premium service.

Upload of your personal data: We upload your personal information that we collect from you to our web portal https://mysecureview.com for access to our website services and for storage purposes. The information that is collect is used to grant user access to the full functionality of Mysecureview app including being able to request the assistance of service providers and being notified of incidents around users.

Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite Places and to provide alerts when family members leave and arrive.

Geolocation. We collect your location information through your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. We collect and maintain location data to provide you the features and functionality of the Service. We may also share location information with our services providers as described in Section 2 “Sharing of Your Information,” below. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.

Messages and User Content. We collect information when you message other members of your Family through use of the service. We may also retain any messages you send to us.

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Family members, crime alerts in your neighborhood, etc.

Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Mysecureview’s website or Service.

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

• Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
• Information about how you use the Service, for example, the features you use, the links you click, and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.

We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

2.2 STATISTICAL DATA FROM THE SERVICES

We use aggregated or anonymized personal information for statistical and analytical purposes. We may come to share such data with third parties.

We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

2.3     SHARING OF YOUR INFORMATION

Personal Information:  We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

• We share your personal information, including name, email, location, with others within your Mysecureview Family and other safety circles.
• We may share your personal information, including your precise location data, unique identifiers or AD IDs and other data with our partners, such as mysecureview, for their marketing and business purposes, including without limitation, to inform and improve tailored advertising, attribution, analytics, research purposes. These partners may use this information according to their own privacy policies. Please see “Your Choices About Your Information” to learn how you may be able to limit some third-party data sharing.
• We share personal information with third-party partners that provide certain features and services you may use in connection with our Service. For example, depending on the features of the Service you have enabled, we provide your personal information and location data to service providers when you request for one or if we have reason to believe you have an emergency. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. The third parties that provide Premium service features may ask you for additional information in order to provide the full range of services to you. Any information provided to these third parties will be governed by that third party’s own privacy policy.
• Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app, or link your reviews to third party websites.

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

• We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services, and to other third-party partners or service providers who contractually agree to process personal information solely as necessary to provide services or features to our users.
• We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
• We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Secureview, our Users or others.

De-Identified Information:  We may also share your information with third parties in a form that does not reasonably identify you directly.  These third parties may use the de-identified information for any purpose.

THE PURPOSES OF PROCESSING YOUR DATA ON https://www.privacy-policy.mysecureview.com

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Device permissions for Personal Data access, Analytics, Registration and authentication, Access to third-party accounts, Registration and authentication provided directly by this Application and Advertising.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Why does Secureview need to collect and store personal data on https://www.mysecureview.com?

In order for us to provide you with a service, we need to collect some personal data. When you sign up for SecureView service or promotion that requires registration, we ask you for personal information (such as your name, phone number, email address), we also collect your device type and location details. For certain services, such as our payment services, we require your debit or credit card information. We typically do not store this information and when we do, we maintain the data in encrypted form on secure servers. We may combine the information you submit under your account with information from third parties in order to provide you with a better experience and to improve the quality of our services. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

What services do we process with your personal data on https://www.mysecureview.com

GPS enabled Help Alert Protocol: We collect your contact and location data to enable our system link you to a service provider that is close to your location for immediate response during emergencies.

Safety Circle Protocol: We share your personal information, including name, email, location and driving event data, with others within your Mysecureview Family and other safety circles. Depending on the features and functionality enabled, we may also share other information about your use of the Service with members of your Family Circle, such as whether you have logged in on a new or different device.

Secure Messaging: We collect information when you message other members of your Family through use of the service. We may also retain any messages you send to us.

Wallet: We collect your credit and debit card details when you subscribe to our plan. We also collect your credit card detail when you pay for services render by service providers and when you purchase coin from our platform.

Emergency Contacts Response Protocol: We collect your contact details when you add an emergency contact that should be notify during emergency situation.

GPS Enabled Location based security profiling: We collect your location information to enable us give you the security status of the location you are going into.

GPS Enabled Incident Notification: We use your location data to keep you updated with resent incident happening in your current location. We also collect your location data, photos, text, and video when your report incident from our app to mysecureview platform.

Subscription: SV has 2 subscription plans; Basic Free plan and Premium Paid plan. The Basic plan gives users access to all App features except making service request. The Premium plan provides the user with unlimited access to the App including issuing a service request. The premium plan is further subdivided into monthly, quarterly and annual plan. When you subscribe to our premium plan your credit card information will be collected and your payment is processed form paystack platform and you have the ability to cancel your subscription once you receive notification by email that your subscription will soon be due and will be renewed at a stated date.

Medical records on the go: Users are able to maintain records of their relevant medical records so that in an emergency, the SV medical partners can easily access the user’s medical records when needed

2.4 COMPLIANCE WITH LAWS AND PREVENTION OF FRAUDULENT OR ILLEGAL ACTIVITIES

We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of Secureview, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.

3.    HOW WE PROTECT YOUR INFORMATION

SecureView cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4.    YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case SecureView may not be able to provide its Services to you.

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at [email protected].

Close Your Account or Delete Personal Information: We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at [email protected]. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.

Emails and Notifications:  You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices).  You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests.

Third Party Tracking and Advertising: We may share, or we may permit third party ad networks, social media companies, and other third party services to collect, information about your use of our Services over time, including location information, so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third part ad partners may collect information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through cookies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. We and our advertising partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

To opt-out or control third-party tracking and advertising: 

• Interest-based advertising.To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
• Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferencesor by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Third Party Location Sharing: We collect location data to provide the Secureview Services, and may share your personal information, including location data, with other Secureview users in your Family Circle or other Safety Circle you belong to, and with third parties for advertising or other purposes.

• Limit location sharing with your Safety Circle.You may turn location sharing “OFF” for one or more of your Safety Circles through your App settings.  If you turn off location sharing in one or more of your circles, we will not share your location with such circles; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, to share your location with the other circles, or to provide location-based advertising). Note: if you press “Check In” in the App, your location will update in every Circle even if location sharing is turned off for one or more of your Safety Circles.
• Limit location collection and sharing. You can opt-out of future sharing of your precise location data with our third party partners by adjusting your settings on your mobile device to prohibit Secureview from collecting your location data. For example, depending on your mobile device, you may be able to “Turn location services ‘off.’ You can also adjust your device settings to withdraw permission for the MysecureView app to access location data. We and our third party partners may continue to approximate your location based on other data. Please note that your Mysecureview app may not be able to provide all of our Services to you if you disable access to location data through your device settings.

5.    LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

6.    CHANGES TO OUR PRIVACY POLICY

Secureview may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Secureview will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

7.    YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California. California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, address, phone number, email address, unique device identifiers or other similar identifiers;
• California customer records, such as birth date and payment information;
• Commercial information, such as records of services purchased, obtained or considered;
• Internet/Network information, such as device information, logs and analytics data;
• Geolocation data, such as precise location data from your mobile device (e.g., GPS coordinates) or generated based on your IP address;
• Inferences about your interests and preferences, generated from your use of our services; and
• Other personal information, such as driving event and movement data collected from your mobile device, or content or messages you send through the Service.

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (v) ad networks and advertising partners; (vi) analytics providers; and (vii) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California customer records, Commercial information, Internet/Network information, Geolocation data, Inferences, and Other personal information.

In the previous 12 months, we have sold the following categories of personal information to third party data partners and advertising partners for targeted marketing, attribution, analytics and research purposes (subject to your settings and opt-outs):  Identifiers, Internet/Network information, Geolocation, Inferences, and Other personal information, including driving event and movement data. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.

Your Rights and Choices.  As a California resident, you may be able to request to exercise the following rights:

• The Right to Knowany or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletionof personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Salesto third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

• To exercise your Right to Know or your Right to Request Deletion, please send an email to [email protected]and include your account name and mobile telephone number as well as the consumer right you would like to exercise.

Additionally, as is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses collect and disclose your personal information (including Internet / Network Information, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell that information to other businesses for advertising and other purposes.  By visiting here www.privacyrights.info or www.optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.   To learn more about how third parties collect information automatically on our Service and the choices you may have in relation to those activities, please see “Third-Party Tracking and Online Advertising section” of our Privacy Policy.

8.    YOUR NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at [email protected] or visit www.mysecureview.ng

9.    HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at [email protected]

+2347059988777

Part 2 – Privacy Policy for EEA and Swiss users

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) when you access our Service from the European Economic Area or Switzerland.

This Part 2 of the Privacy Policy was last modified on October 1, 2020

SecureView, Inc is the data controller of the personal information we hold about you.

1. PERSONAL INFORMATION COLLECTED

1.1 USER PROFILE

When You create a user profile in the Services, Secureview will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and phone number and email address. Additional information that may be provided include, but is not limited to, photo, gender. Secureview may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available.

1.2 INSTALLATION AND USE

When You install and use the Services, Secureview will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; applications installed on your device; operating system; web browser; IMSI; connection information; access to device address book.

Given below are how information collected from users is used:

• Personal contact (First name, last name, email address, phone number, photo): creation of user profile,
• Geo-location/ IP address: connecting user with service provider,
• Device information (ID, manufacturer, version, operating system): knowledge of user groups who use the service so as to improve service delivery,
• User address book: This allows users to share info about SecureView with their contacts as well as create user groups (family, friends, etc.) to have a better user experience.

Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.

1.3 THIRD PARTY SERVICES

You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information, content viewed by You, content liked by You and information about the advertisements You have been shown or may have clicked on) and You agree that we may collect, use and retain the information provided by these third party services in accordance with this Privacy Policy. You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.

1.4 CONTACT INFORMATION

Where the Mysecureview mobile applications (“Mysecureview Apps”) are obtained from other sources than Apple App Store or Google Play, You may share the names, numbers, Google ID’s and email addresses contained in Your address book (“Contact Information”) with Secureview. Where the Mysecureview Apps are obtained from Apple App Store or Google Play, we do not share any user Contact Information without your consent. In addition to Contact Information, if You choose to activate use of a third party service, such as social networks services, within the Services, Securevieww may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users.

Please note that no other contact information other than the phone numbers and thereto attached names, Google ID’s and email addresses will be collected and used from Your address book. Please also note that You can always choose not to share Contact Information with Secureview and if You have shared such information and changed Your mind, You can delist Your number or opt-out.

1.5 OTHER INFORMATION YOU MAY PROVIDE

You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number, that is not registered in the Secureview database or belongs to a User, with a business. Secureview may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in contests, surveys or other promotions. Secureview will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.

1.6     PERSONAL INFORMATION WE COLLECT ABOUT YOU

1.6.1    We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.

1.6.2    We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.6.3    We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.

1.6.4    We will store the personal information we collect about you for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

2.    RECIPIENTS OF PERSONAL INFORMATION

2.1    We may share your personal information with the following:

Others in your Safety Circle: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your preferences.

(b)    Third parties for their marketing and related purposes with your consent. Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, driving sensor data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and market research purposes.

(c)     Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services.

(d)     Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(e)     Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Secureview, its users or others.

2.2     Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.

3.    YOUR LOCATION

3.1    We collect information about your location in order to provide you certain functionalities of the Service.

3.2    We will collect your location where it is necessary for the purposes of providing you with the location-based services features of the app as well as for the legitimate interests of Secureview or our business partners, such as for data analytics into safe driving modelling. Where you have given us your consent to do so, we may also sell your location data to third parties for marketing and research purposes.

3.3    You can also stop sharing your location with us at any time by updating the settings on your mobile device to limit the app’s access to your location information. Please note, however, that we may not be able to provide all of the functionalities of our Services to you if you disable access to location data.

3.4    If you no longer want to continue using the Service, uninstalling the Secureview app or logging out from the Service will also stop us from collecting your location.

4.    MARKETING MESSAGES AND NOTIFICATIONS

4.1    From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

4.2    We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

4.3    You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

4.4    Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

5.    TARGETED ADVERTISING

5.1    We may share, or we may permit third party ad networks, social media companies, and other third party services to collect, information about your use of our Services over time, so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners may collect information such as click stream information, timestamp, hashed email address, device ID or AdID, and information about your use of third party applications. They may also collect and analyse information about your use of our Service in order to recognise you across various devices you use.

5.2    Where you have consented to us doing so, we may also share your precise geolocation data with advertising partners. We and our advertising partners use the information we collect about you to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

5.3    To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices.

5.4    You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile App Choices app.

5.5    Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out from receiving interest-based ads on that specific device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each device you use.

6.    STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

6.1    Security. We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

6.2    International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy.

6.3    Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield (“Privacy Shield“). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability (“Principles“) with respect to such data. If there is any conflict between the policies in this policy and the Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. For more information regarding our Privacy Shield certification, please see:  https://www.privacyshield.gov/list.

6.4    Onward Transfer. Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

6.5 Upload of your personal data: We upload your personal information that we collect from you to our web portal https://mysecureview.com for access to our website services and for storage purposes. The information that is collect is used to grant user access to the full functionality of Mysecureview app.

7.    USERS’ RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

7.1    In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a)   Right of access. You have the right to obtain:

(I)    confirmation of whether, and where, we are processing your personal information;

(ii)    information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii)    information about the categories of recipients with whom we may share your personal information; and

(iv)    a copy of the personal information we hold about you.

(b)    Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c)    Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d)    Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e)    Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f)    Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

7.2    If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

7.3    You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your driving event data and movement data, by updating your preferences at https://mysecureview.ng/policy. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data or driving event data.

7.4    You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8.    CONSENT

8.1    We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

8.2    We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

8.3    If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.

8.4    Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.

9.    COOKIES AND SIMILAR TECHNOLOGIES

9.1    Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.

9.2    Please see our Cookie Policy for more information about the cookies we use on our website, and how to manage cookies.

9.3    Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

10.    JURISDICTION AND ENFORCEMENT

10.1    As part of our participation in the Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

10.2    You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

11.    CONTACT SECUREVIEW AND RECOURSE

11.1    In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at [email protected].

11.2    In the event that you are concerned about how personal information you have provided to Secureview has been used, please address your inquiry or complaint first to us at the address listed above. Secureview takes all concerns about privacy and use of personal information very seriously, and shall endeavor to reply to you within 45 business days of receiving a complaint.

11.3    We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint. This service is provided free of charge to you.

11.4    If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.html for more information and to file a complaint.

12.    LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

13.    CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

14.    NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

15.    CONTACTING US

15.1    Please contact [email protected] if you have any questions, comments and requests regarding this Privacy Policy.