Avanquest S.A.
89/91 Boulevard National – Immeuble Vision Défense
92250 LA GARENNE COLOMBES
France

Privacy Policy

Last Update: August 1st, 2016

1. Introduction

Avanquest SA, having its registered office at 89/91 Boulevard National – Immeuble Vision Défense 92250 LA GARENNE COLOMBES, France ("we", "us", or "our") as data controller of your Personal Data, is concerned about your privacy and values the relationship we have with you. This Privacy Policy covers the collection and processing of personally identifiable information relating to you ("you" or "yours") as an individual ("Personal Data") that you provide us with or that we gather when you access or use our Websites or our services.

This Privacy Policy describes the types of Personal Data we collect about you, for which purposes we use such Personal Data, with whom we may share it, and the choices available to you regarding our use of your Personal Data. This Privacy Policy also describes the measures we take to protect the security and confidentiality of your Personal Data and how you can contact us about our privacy practices.

By visiting or using our websites ("Websites"), ordering and using our IP camera products ("Equipment") and our services (collectively, the "Services"), you acknowledge that you consent to the collection and processing of your Personal Data as detailed in this Privacy Policy, and you hereby consent that we will collect, use, and share your Personal Data as described below. You also undertake and agree that, with respect to Personal Data you control and store in our systems as part of our Services and that we process on your behalf, you are the data controller and that, in such capacity you shall comply with all applicable legal requirements in respect of such data.

This Privacy Policy is an integral part of our General Conditions available here ( https://www.ioteo.com/gb/terms-and-conditions ). By accepting our General Conditions, you also consent to this Privacy Policy.

2. Types of Personal Data

We may obtain and process Personal Data about you from various sources.

Firstly, as part of the ‘Video as a Service’ ("VaaS") that we provide to you, we shall process certain information, including Personal Data, on your behalf and on your instructions, as described in Section 2.1 below.

Secondly, we may collect Personal Data that you provide to us when purchasing our Equipment, ordering our Services, when registering on our Websites, when configuring and using your account or when communicating with us in any way, as described in Section 2.2 below.

Thirdly, we may collect and process Personal Data by automated means regarding the operation of your IP cameras or sensors, including metadata, as well as the occurrence of certain events detected by your IP cameras or sensors (such as intrusions, etc.). We may also collect certain information by automated means, using technologies such as cookies, web server logs, web beacons, and similar technologies, when you visit our Website or use our Services, as further described in Section 2.3, with your prior consent where required by applicable law.

2.1. Information you provide to us and that we process on your behalf

Our Services consist in a ‘Video as a Service’ ("VaaS") including the recording, encryption, transmission and storage of images and sound recorded by your Equipment in an encrypted manner (the "Content") on remote servers in a cloud computing environment, which you can then access remotely from anywhere via an internet connection. By registering and using our Services, your acknowledge and accept that we have no control over the Content and that you alone decide on the purposes and essential means of processing such Content and that you are the data controller of any Personal Data included or related to such Content.

As provider of the VaaS, we only process and store such Content on your behalf and further to your instructions, as data processor. In this respect, we undertake to – and shall ensure that any person acting under our authority and having access to our systems – act only on your behalf and on your instructions with respect to your Content, unless otherwise required by law. We shall implement appropriate technical and organisational security measures to protect the security and confidentiality of your Content as described under Section 5 below.

Except for our undertaking to implement appropriate security measures and to act under your instructions, we do not assume any responsibility or liability with respect to the Content, and, as data controller, you are solely responsible for compliance with applicable data protection and privacy laws or any other applicable laws, as further described in our Terms and Conditions.

You are responsible, in particular, for compliance with all local requirements and obligations applicable to the recording, processing and storing of Content (in particular audio and/or video records), including any local legal requirement applying to camera-surveillance systems. These legal requirements and obligations may vary depending on the jurisdiction where you are established, the place where the Equipment is installed and the purposes for which you use such Equipment and our Services (e.g., for exclusively domestic purposes or for other purposes). For an overview of the main obligations under applicable legislation relating to surveillance cameras and the protection of personal data in your country of residence, please refer to your national data protection agency.

You also understand and acknowledge that we cannot control what other users do with any Content that you voluntarily disclose for such users to view on the Services or otherwise. For example, we may share your video Content with other users as directed by you via the functionality of the Services. We cannot control if other users you have allowed to access to your Content make such Content publicly available to be collected and used by others, or to be redistributed through the internet and other media channels.

You agree and undertake to hold harmless, defend and indemnify Avanquest and its directors, officers, employees, contractors, and agents from and against all claims, proceedings, damages, expenses, costs and losses (whether direct, indirect, economic or consequential, and including without limitation loss of profit, loss of opportunity, loss of business, loss of data and loss of goodwill, as well as third parties' claims) (collectively “Claims”) arising out of, in connection with or otherwise in relation to your use of the Equipment, Services and/or Content, or any use thereof by any third party, including but not limited to any recipient of such Content, as well as for any other violation of our General Conditions.

You also agree that we may delete your Content, your personal account, as well as any other Personal Data we hold about you or on your behalf after a reasonable period of time following :

  • inactivity of your personal account;
  • loss of your password rendering the Content inaccessible;
  • termination or suspension of our Contract for whatever cause.

To the fullest extent possible and in accordance with applicable law, we shall use commercially reasonable efforts to notify you before deleting your Content, by sending an email to the email address you provided when registering.

2.2. Personal Data you provide to us and that we process for purposes that we define

You provide your Personal Data to us when you order and purchase Equipment and Services from us, when you register for our Services, when you register, configure or use your account, when you contact us or when you provide us with your details so we can contact you, including for direct marketing purposes. This Personal Data includes:

  • your contact details (such as your name, address, email address, and mobile or other telephone number);
  • your username and password; please note that, If you lose your password, the associated encryption key will also be lost. To once more be able to access your Content stored on Avanquest's IT systems, you will be able to generate a new password if you so request;
  • payment information (such as your payment card number, expiry date, delivery address, and billing address);
  • details of other persons you authorise to access to your account;
  • information regarding the content (including video and audio content, the "Content") you provide and store on your account (it being noted that Content is encrypted both during transfer and storage and that we therefore cannot view the Content itself); and
  • information collected when you visit our Websites or when you connect to your account, including your IP address.

We may use your Personal Data for our own purposes, to:

  • manage your orders;
  • ship our product to you;
  • provide our Services to you;
  • provide support related to our Services;
  • process payment transactions;
  • create and manage your online account and profile;
  • respond to your inquiries and complaints;
  • communicate with you about our products and services, including new products and services, as well as, subject to your prior consent where required by law, for the purpose of sending you promotional material by email, SMS, MMS or any other means of communication;
  • operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analysing our products; performing data analytics);
  • comply with applicable legal requirements, relevant industry standards and our internal policies.

2.3. Information we collect by automated means for purposes that we define

We may collect and process Personal Data regarding the working of your IP cameras or sensors, including metadata, as well as the occurrence of certain events detected by your IP cameras or sensors (such as intrusions, etc.).

When you visit our Websites or when you use our Services, we may also use a variety of technologies that automatically or passively collect certain information by automated means about how our Website and Services are accessed and used (“Usage Information”). We may notably collect Usage Information regarding our Services in general (such as the number and frequency of visitors to our Websites), as well as information that resides on your computer or mobile device and that is generated by your use of the Services, including, without limitation, statistics on the frequency at which data is captured, transferred, stored, copied, manipulated, or downloaded, performance indicators relating to the Services, and configuration settings. Usage Information may consist of your browser type, operating system, the page(s) viewed, the time, and the previously viewed pages. Usage Information is generally non identifying, but if we associate it with other information so that you can be identified, we treat it as Personal Data.

We may also automatically collect your IP address or other unique identifier for the computer, mobile device, technology or other device you use to access our Websites or Services. A unique identifier is a number that is automatically assigned to your device when you access a website or its servers, and our Computer Systems identify your device by this number (“Device Identifier”). These Device Identifiers can track and store your user preferences while you are visiting and/or using our Websites and/or our services, as well as technical information about your use of the Website and/or Services.

We may use the above information for a number of purposes, including to:

  • provide general internal and customer analytics;
  • study traffic patterns in order to improve our Websites' performance and our Services, to customize the user experience;
  • keep track of preferences you specify while you are using our Services;
  • authenticate your account login and verify the Content you are permitted to access;
  • provide security measures, such as requiring re-login into our Services after a certain amount of time has elapsed;
  • save your username so that we can process the saved login information and quickly log you into our Websites and Services;
  • provide additional services that may be of interest to you;
  • assist in identifying possible fraudulent activities.

What are cookies?

Cookies are small files or pieces of information that may be stored on your computer device.

Avanquest may use two types of cookies, "session cookies" and "persistent cookies". Session cookies are automatically deleted at the end of your browsing session. Persistent cookies remain longer on your device, for a duration specific to each cookie, and will be automatically deleted at the end of their "life".

For what purposes does Avanquest use cookies?

Are third-party cookies used?

Avanquest uses a number of suppliers that may also place cookies on your computer device on our behalf to allow them to deliver the Services they provide. If you would like to learn more about these cookies, as well as information on how to reject such cookies, please refer to their privacy policies.

Google Analytics

Google Analytics is a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to compile anonymous, aggregated statistics. Google will use the information generated by the cookie to assess your use of the Website, compiling website activity reports for website operators and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google.

Further information and how to reject this cookie:

https://support.google.com/analytics/answer/6004245


How can you control, delete or withdraw your consent to the use of cookies?

If you wish to withdraw your consent, to the extent it is required, to our use of cookies, or if you wish to delete or control the placing of cookies on your computer, you can change your browser settings to block or delete cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings at:



If you disable some of the cookies used by the Websites or our Services, this can affect your experience when using the Websites and parts of them may not work correctly.

3. How we share your Personal Data:

We do not sell or disclose the Personal Data we collect in any way, except to the extent described below or with your prior consent.We may share your Personal Data with:

  • our affiliates, for the purposes described in this Privacy Policy;
  • third-party service providers that we hire to perform services and data processing tasks on our behalf and on our instructions; these third-party service providers may include entities that provide data hosting services and cloud computing services for the storage of your Content as part of our Services; entities that process and authorise online payments, or entities that provide other IT and maintenance services.

We use the SSL128 bits (Secure Socket Layer) encryption standard, currently the most widely used and reliable standard on the Internet. Your credit card number is encrypted. We do not sell your banking information; it is deleted once your order is complete.

In addition, we may disclose information about you (i) if we are required to do so by law, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate for our legitimate interests (or those of the third party to whom we disclose your data), provided that they do not prevail over the interests or fundamental rights and liberties of the person concerned.

We also reserve the right to transfer Personal Data we have about you to a (prospective) buyer in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Data you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of this information.

4. How we may transfer your Personal Data

We may transfer the Personal Data we collect about you, including your Content, to countries other than the country in which it was originally collected, it being noted that your Content will however remain within the European Economic Area ("EEA") or other countries recognized by the EU Commission as offering an adequate level of protection of Personal Data, such as Switzerland. We may, however, transfer your Personal Data (such as your name, email address, personal account information, excluding Content) inside and outside of the EEA, including in countries which may not offer the same level of data protection as in the EEA, in particular to third party service providers providing services to us for the management of our contractual relationship, as well as for marketing purposes. When we transfer your Personal Data or Content to other countries, we will protect this information as described in this Privacy Policy and our Terms and Conditions for Services.

If you are located in the EEA or Switzerland and your Personal Data or Content is initially obtained or recorded therein, we shall comply with applicable legal requirements providing adequate protection for the transfer of Personal Data to countries outside of the EEA or Switzerland, such as for example by entering into appropriate data transfer agreements conforming to the EU Commission's standard contractual clauses and/or obtaining your unambiguous consent to such transfers.

5. How we protect your Personal Data

As data processor of the Content that we process on your behalf, we shall implement appropriate technical and organisational security measures to protect its security and confidentiality, in particular by encryption methods both during the transfer of Content from your camera(s) to our Servers (SSL encryption), as well as when stored on our Servers (AES encryption).

In addition, your account is protected by a password for your privacy and security. You must prevent unauthorised access to your account, Content, and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account. If you lose your password, the associated encryption key will also be lost; to once more be able to access your Content stored on Avanquest's IT systems, you will be able to generate a new password if you so request.

As data controller of your Personal Data, we also maintain appropriate administrative, technical and physical safeguards designed to protect Personal Data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

While we endeavour to protect the privacy and confidentiality of your account, Content and Personal Data as mentioned above, we cannot guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

6. Personal Data about related persons

If you provide us with Personal Data about dependents, family members and/or any other persons, it is your responsibility to inform such individuals about the processing of their Personal Data by us for the purposes and in the way described in this Privacy Policy, about their rights of access, rectification, deletion and objection in accordance with applicable law, as well as to obtain their consent, where necessary, to the processing and transfer of their Personal Data as set out in this Privacy Policy.

7. Minors

We do not knowingly collect Personal Data from anyone under the age of 18 or knowingly allow such persons to register. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Data from a child under the age of 18, we will delete that information as quickly as possible.

8. Links to other websites

Our Websites or Services may provide links to other websites for your convenience and information. These websites operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you read if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the content, use or privacy practices of these websites.

9. How we may update this Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in our data processing practices. We will notify you of any significant change by posting a prominent announcement on our Services or by sending you an email and shall indicate at the top of the Privacy Policy the date when it was most recently updated. You will be bound by these changes to the Privacy Policy when you use the Services after such changes have been notified to you as described herein.

10. What are your rights

Subject to applicable laws, you have the right to request access to and receive details on your Personal Data we hold as data controller, to request the update and rectification of inaccuracies in your Personal Data, and to have the information blocked or deleted, as appropriate. You also have the right to object, at any time and free of charge, to the processing of your Personal Data for direct marketing purposes. The right to access Personal Data may be limited in some circumstances by local law requirements. If you wish to wish to exercise your rights, please refer to the procedures described in Sections 11 and 12 below.

11. How to opt-out of email, SMS, MMS or other electronic communications

You may opt-out of receiving promotional material from us by email, SMS, MMS or any other means of communication by following the instructions provided to you in these communications or by contacting us as described in Section 12 below.

12. Contact us

If you have any questions or concerns about this Privacy Policy, or if you would like to exercise your rights of access, rectification or deletion, or to object to the processing of your Personal Data for direct marketing purposes, please contact us by email at support@ioteo.com or write to us at:

Avanquest S.A.
89/91 Boulevard National – Immeuble Vision Défense
92250 LA GARENNE COLOMBES
France