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Privacy Statement

Introduction

Doctor A Security holds itself to high standards in handling and processing personal information. The statement outlined below establishes the boundaries of what Doctor A Security processes and what you, as our customer and the data subject ("users"), are entitled to. This Privacy Statement applies when you use our features and services ("Services"). Additionally, we have a Cookie Policy for use of our website. Doctor A Security operates around the world and has adopted English as the controlling language of this Privacy Statement.


Your Personal Data

Personal data refers to identifying information that relates to an individual. Identification can be by the data alone or in conjunction with any other data in the data controller's possession or likely to come into such possession. Doctor A Security collects information only to provide you with the Services that you opted into. In order to provide you with our products or Services, including responding to your inquiries, we may ask for your personal information. If you choose not to provide the requested information, we may be unable to deliver the desired Services. Most of Doctor A Security's Services are provided under a Doctor A Security Account, and if you no longer require the Service or wish to have your data removed, you may delete your Doctor A Security Account.


In general, Doctor A Security collects personal data from you via mail, email, telephone, or via our cookies for the purpose of delivering our Services to you, details of which are further set forth in the "Services" section of this policy, to operate our websites to provide you access to and use of our websites and Services, to administer your use of our Services, to communicate with you and respond to your requests, to manage your account, to customize your Service experience with us, to improve our Services and products, to provide you with our online or offline marketing measures and activities, including but not limited to newsletters, online and live event registrations, and other promotional information and materials, to share your contact details with our subsidiaries, affiliates, authorized repair and support centers, authorized logistics companies, communications infrastructure, and other entities deemed necessary to carry out providing these Services to you, to share your contact details with our affiliate offices around the world within our group of companies for the purposes of internal administration and back-office support, to ensure our network security, and to prevent fraud, to enforce or defend our policies or contract with you, and to maintain the integrity and safety of our data technology systems that store and process your personal data.


Examples of data we collect and store include:


• Your e-mail address, which is used as identification for our services and as the primary communication method.


• Your name, address, phone number, and additional contact information are used to provide registration, device shipping, and billing verification services.


• Your payment method and financial data (credit card, bank account number, etc.), which is used for payment transactions for a service or product, logistics and billing data (such as customs ID and tracking number).


• Your account login, account name, account number, password, account activity, files accessed or used by you, transaction data and any information you provide during a transaction, or other transaction-based content that you generate or connected to your account as a result of your transaction.


• Your chat and service history with us, and any other information you may provide us when you interact with us.


Other information that you provide to us through digital or physical means may be stored on a case-by-case basis depending on the reason it was provided.



Non-Personal Data

Doctor A Security may collect additional information that, by itself, cannot be used to identify any specific individual. This information is used to help facilitate our business operations. For example:


• Device analytics are opt-in and used to understand how our users interact with our products and services. Information collected cannot be used to identify our users nor the data that they store on their devices. Refer to the Services section for more information.


• We collect single-session information from our users when they browse our website, including help articles, to understand which topics are more important and if the content is relevant to our users or potential customers. Read our Cookie Policy.



Lawful Bases and Other Usage

The lawful bases for Doctor A Security to process your personal data for the various types of processing performed on your personal data are, as applicable, processing based on your consent, as necessary for us to enter into and to perform our contract with you, or in certain circumstances, as necessary for Doctor A Security to pursue our "legitimate interests", where our interests are not outweighed by your rights and freedoms.


"Legitimate interest" situations necessitating such actions may include the following: to protect you, us, or others from security threats, to comply with laws we are subjected to, to implement information sharing within Doctor A Security's group affiliates, to prevent fraud, misuse of company IT systems, to operate a whistleblowing scheme, for purposes of mergers and acquisitions, and to perform internal investigations and auditing.


Doctor A Security will collect, process, and use the personal data supplied by you only for the purposes communicated to you and will not disclose your data to third parties except under the lawful bases set forth above. Doctor A Security does not share your personal information with third parties for the purpose of direct marketing.


You are not under any obligation to provide us any of your personal data. However, please note that without certain data from you, we may not able to undertake some or all of our obligations to you under our contract with you, or adequately provide you with our full range of services. If you would like to obtain more detail about this, please contact us following the instructions in the "Contact Information" section below.



Period of Storage

Doctor A Security keeps your personal data for no longer than reasonably necessary for the given purpose for which your data is processed. If you will provide us, or have provided us, consent for us to process your data, we will process your data for no longer than your consent is effective. Notwithstanding the above, we may retain your personal data as required by applicable laws and regulations, as necessary to assist with any government and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal, or administrative proceedings. If none of the above grounds for us to keep your data apply, we will delete and dispose of your data in a secure manner.


Data Controllers, Contracting Parties, Transfer of Data

We use the term "Designated Countries" to refer to countries that are in the European Union (EU), European Economic Area (EEA), and Switzerland. If you reside in Designated Countries, Doctor A Security Systems (HK) Limited will be the controller of your personal data. Doctor A Security would be responsible for collecting, and processing data per our services, which will be covered by the Terms of Service of the relevant service.


For users residing outside of Designated Countries, Doctor A Security Systems (HK) Limited, ("Doctor A Security") will be the controller of your personal data. Your usage of services provided by Doctor A Security will be bound by the Terms of Service of the relevant service.


Doctor A Security's Services include providing technical support, device replacement, payment services, event registration, as well as the transfer of data based on users' decisions, around the world. The nature of these Services requires us to be able to transfer data into and out of the European Union (EU) to Doctor A Security subsidiaries, affiliates, authorized repair and support centers, authorized logistics companies, communications infrastructure, and other entities deemed necessary to carry out providing these Services. We may also transfer your data to third-party service providers whom we subcontract to work on our behalf or for us and therefore may have access to the data only for purposes of performing these tasks on our behalf and under obligations similar to those described in this Privacy Statement, who perform functions such as data processing, auditing, order fulfillment, managing and enhancing customer data, providing customer service, conducting customer research or satisfaction surveys, marketing support, payment processing and invoice collection support, informational systems technical support, to help us provide, analyze, and improve our Services and to assist us in detecting and dealing with data breaches, illegal activities, and fraud. We may also share your personal data with governments and/or government-affiliated institutions, courts, or law enforcement agencies, to comply with our obligations under relevant laws and regulations, enforce or defend our policies or contract with you, respond to claims, or in response to a verified request relating to a government or criminal investigation; provided that, if any law enforcement agency requests your data, we will attempt to redirect the law enforcement agency to request that data directly from you, and in such event, we may provide your basic contact information to the law enforcement agency. We may also provide your data to third parties involved in a legal proceeding, if they provide us with a court order or substantially similar legal procedure requiring us to do so. The above parties are the recipients of your personal data. Doctor A Security safeguards EU personal data when transferred out by adopting European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers to locations the European Commission have not deemed to have an adequate level of data protection.



Your Rights to your Personal Data

Doctor A Security's services are generally provided on an opt-in basis, with required and collected information differing on a per service basis. Unless subject to an exemption, you will have the following rights with respect to your personal data:


• The right to delete data: You can ask us to delete data for which we no longer need in order to provide service to you.


• The right to correct or change data: You can modify your contact information through your Doctor A Security Account. You can also ask us to change, update, or fix data that are incorrectly presented and unable to be changed by yourself.


• The right to object: You can object to the usage of some or all of your personal data which is based on legitimate interests pursued by Doctor A Security.


• The right to delete data: You can ask us to delete data for which we no longer need in order to provide service to you.


• The right to restrict use of data: You can ask us to stop or limit the usage of some or all of your personal data that we no longer need, in order to provide service to you, or have legal rights to retain.


• The right of access: You may request a copy of your personal data that we have at the time.


• The right of portability: You may request us to transmit your personal data directly to another data controller, where the processing is based on your consent or is necessary for the performance of a contract with you, and in either case, we process the data by automated means.


You may make these requests by submitting a request through your Doctor A Security Account or through our website. Upon receipt, we will evaluate your request and inform you how we intend to proceed. Under certain circumstances, and according to applicable European Union or European Union state laws and regulations, we may withhold access to your data, or decline to modify, erase, port, or restrict the processing of your data. Doctor A Security will respond to your request within thirty days after receiving it. Please be advised that if you exercise the rights to erase data, restrict, or object to our processing, or to withdraw your consent, we may not be able to continue our Services to you if the necessary data is missing for processing.


If you are a resident of one of the Designated Countries, you have the right to file a complaint with the competent authority where you reside or in which your data is processed. In case of disagreements relating to Doctor A Security’s processing of your personal data, you can submit a request for administrative action to the data protection supervisory authority with the competent authority where you reside or in which your data is processed. Please click here for a list of local data protection authorities in EEA countries: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.



Services

This Privacy Statement applies to Doctor A Security-provided services offered on drasecurity.com, Doctor A Security branded applications, services provided from physical Doctor A Security products ("Doctor A Security Devices"), and digital or physical services directly offered by Doctor A Security unless stated otherwise. A list below details the characteristics of Services provided.


Services - This Privacy Statement applies to Doctor A Security-provided services offered on drasecurity.com, Doctor A Security branded applications, services provided from physical Doctor A Security products ("Doctor A Security Devices"), and digital or physical services directly offered by Doctor A Security unless stated otherwise. A list below details the characteristics of Services provided.



Doctor A Security Account By creating an account, you can gain access to multiple Doctor A Security services, such as Technical Support, and Package Activation. We collect basic information from you to help facilitate communications and provide services to you. Doctor A Security does not use this information for any other purpose. Doctor A Security does not share this information unless otherwise specified for the particular service.Information about specific functionalities is listed below. You may delete your Doctor A Security Account at any time. However, we may be unable to provide you certain services afterwards. Account deletions, including all the associated data with the specified account, are irreversible. Doctor A Security may retain certain data in order to fulfil our legal obligations, which differ on a per service basis. Doctor A Security collects package download information from your Doctor A Security device in order to help us understand how we can better improve our devices and software. The data we collect does not contain information that can identify you, the user. When a Doctor A Security device issues a download request to Download Center, Doctor A Security's database will record the action with a unique ID. This ID is used only to identify download activity in Download Center. None of this information contains any of your personal information or metadata pertaining to your files. Download Center does not track or record your device's serial number, MAC address, or IP addresses for uses that do not require additional licenses



Licensing

Purchasing package licenses, whether a single purchase, subscription-based, or in-app purchase, requires a Doctor A Security Account*. We will collect certain information from your Doctor A Security device for licensing purposes, including product serial number, IP address, MAC address, and registered Doctor A Security Account. We store this information to verify your license when it is applied to a Doctor A Security device. Activating and updating packages will usually require an Internet connection to our servers. We identify your Doctor A Security device with a unique device ID. For record keeping and future troubleshooting, we may keep track of information such as whether the update was successful or not. We may use the information collected through activation or updates to validate your license status. Doctor A Security only shares aggregated statistics that does not contain personal information to our partners, licensors, and licensees.


Services - This Privacy Statement applies to Doctor A Security-provided services offered on drasecurity.com, Doctor A Security branded applications, services provided from physical Doctor A Security products ("Doctor A Security Devices"), and digital or physical services directly offered by Doctor A Security unless stated otherwise. A list below details the characteristics of Services provided.


Doctor A Security Account By creating an account, you can gain access to multiple Doctor A Security services, such as Technical Support, and Package Activation. We collect basic information from you to help facilitate communications and provide services to you. Doctor A Security does not use this information for any other purpose. Doctor A Security does not share this information unless otherwise specified for the particular service.Information about specific functionalities is listed below. You may delete your Doctor A Security Account at any time. However, we may be unable to provide you certain services afterwards. Account deletions, including all the associated data with the specified account, are irreversible. Doctor A Security may retain certain data in order to fulfil our legal obligations, which differ on a per service basis. Doctor A Security collects package download information from your Doctor A Security device in order to help us understand how we can better improve our devices and software. The data we collect does not contain information that can identify you, the user. When a Doctor A Security device issues a download request to Download Center, Doctor A Security's database will record the action with a unique ID. This ID is used only to identify download activity in Download Center. None of this information contains any of your personal information or metadata pertaining to your files. Download Center does not track or record your device's serial number, MAC address, or IP addresses for uses that do not require additional licenses


Package Activation

Data we collect - To activate certain Doctor A Security-published packages, your Doctor A Security Account is required to complete the activation. Doctor A Security collects device-specific information and information from your Doctor A Security Account such as hardware model name, user's type (business or home), data storage location, and company name.


How we use your data - Doctor A Security encrypts the raw data received and then analyzes it to produce human-readable results, to help us provide better service/software for you in the future. The raw data is never shared with any third parties. Package activation does not track your device's serial number, MAC, or IP addresses.


Data we collect - To activate certain Doctor A Security-published packages, your Doctor A Security Account is required to complete the activation. Doctor A Security collects device-specific information and information from your Doctor A Security Account such as hardware model name, user's type (business or home), data storage location, and company name.


How we use your data - Doctor A Security encrypts the raw data received and then analyzes it to produce human-readable results, to help us provide better service/software for you in the future. The raw data is never shared with any third parties. Package activation does not track your device's serial number, MAC, or IP addresses.



Payment

How we store your data - Doctor A Security employs industry-standard encryption practices to safely protect your raw data. Even in the event of a breach, the data collected cannot be used to identify you. Doctor A Security restricts access to both the raw and aggregated data by specific employee roles. Data collected is deleted when the relevant Doctor A Security Account is deleted.


How we use your data - Doctor A Security uses third party processors to securely handle your payment method and to calculate and report taxes. Doctor A Security only uses information we collect from the payment process to complete transactions, generate receipts, report taxes, and for financial and legal auditing purposes. We do not share or use this information for any other purpose.


How we store your data - DYour purchase history, even if refunded or canceled, will be stored for a minimum of four years per legal requirements imposed on Doctor A Security and its subsidiaries. Doctor A Security will retain this history, including your billing information, for an indefinite period in the following situations; If the order contains a perpetual license, a license renewal, a physical item, extended support, or is needed for financial or legal purposes. Our payment processors and tax reporting providers may additionally be subjected to other legal obligations. Doctor A Security generates a receipt that is made available on your Doctor A Security Account for each transaction. By deleting your Doctor A Security Account, you will be forfeiting all purchased licenses. Doctor A Security will remove your transaction history after the minimum storage period based on our legal obligations.



Security

Doctor A Security employs multiple methods of data protection in order to minimize the risk of misuse, unauthorized access and disclosure, and loss of access. Some of these safeguards include the use of data encryption, data hashing, and other technologies and permission control methods. When our employees directly handle, or access your personal information, we do so on secured networks and through fine-grained permission control to limit who can access your information. Data you provide to us is encrypted and stored on both third-party storage and on Doctor A Security-managed devices, depending on the service. Doctor A Security logs and stores IP addresses of both users to our web services solely for security purposes. This log is archived and then removed at irregular intervals depending on ongoing or existing security threats or investigations. If Doctor A Security has overwhelming evidence that certain IP addresses, users, or devices may be purposely damaging or hindering our operations or service quality, we may deny further services and/or report such behaviour to relevant authorities. Doctor A Security removes data that is no longer required to provide services based on each service.



Changes to Statement

Doctor A Security may make amendments to this document when needed to reflect statement updates, customer feedback, as well as new products or services. We will provide a brief overview of the changes, and if the terms modify the way we process or handle your data or affect your rights, we will notify you through direct message or by posting notices if we are unable to directly reach you. We encourage that you regularly review this Privacy Statement to understand how your data is handled.



Data from Children

Doctor A Security's products and services are targeted at professionals and are not designed nor intended to be used by children under 16 years of age. Doctor A Security does not typically collect date of birth information as it is not used by Doctor A Security. If children under the minimum age of the relevant jurisdiction must use Doctor A Security's products and services, explicit parental consent must be provided and verified. If Doctor A Security is notified or discovers that data collected is from a child under the minimum age, we will take procedures to delete the information as soon as possible.



Do Not Track

Doctor A Security does not track users to provide targeted advertising and therefore will not respond to Do Not Track (DNT) signals.



Notice to End Users

Certain Doctor A Security products or services may be managed or administered to you by organizations or other users. Your use of these managed Doctor A Security products or services will be affected by the terms or policies that are provided and dictated by the organization or service provider. Please direct inquiries in these instances to the administrator of the device or service. Doctor A Security will not be responsible for the privacy or security practices, including the lawfulness of practices for our customers as they may manage or implement our products and services in a manner that is no longer determined by Doctor A Security's policies or agreements.



Contact Information

You can directly contact us through your Doctor A Security Account, or by submitting a form on our website for privacy related questions or concerns. If you are unable to resolve the issue, you have options to exercise your rights as detailed in the previous Your Rights to your Personal Data section. Doctor A Security will respond to your requests within thirty days after receiving it. You may also contact Doctor A Security through the following addresses. For users residing in "Designated Countries" & for users residing in all other regions: Doctor A Security Systems (HK) Limited. Attn: Data Protection, Unit 601, 6/F Megacube, 8 Wang Kwong Road, Kowloon Bay, Kowloon, HONG KONG. Tel: +852 23424330



Last Updated: July 2019