This Privacy Policy for TORLIN Products and services (“Privacy Policy”) describes information that Headsoft s.r.o. collect, use, share, or store, including personal information (i.e., information that directly or indirectly personally identifies you) or a combination of data that can be reasonably used to infer information about you (such as your email address or mobile phone IMEI).

This document focuses on information related to the operation of the following Headsoft products and services: TORLIN Alarm, TORLIN App. In this Privacy Policy, the expression “TORLIN Products” also includes our Mobile App, PC App, and Headsoft Cloud.

If you do not agree with this Privacy Policy, you must not submit information to us through or in connection with the website or use Headsoft Products.

How We Collect Data

We will collect and store your personal data when you interact with our website, when you contact us, request TORLIN Products and services or when you use TORLIN Products, as further detailed below. We collect personal information in writing, by telephone and by email.

International Transfers of Personal Data

Depending on your geographic location, your personal information may be collected, processed and stored by Headsoft or its service providers. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country.

What information does Headsoft generally collect?

Identity data – includes first name, last name, title, date of birth and gender.

Contact data – includes address, email address and telephone numbers.

Technical data – includes information about your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

If you are a customer of Headsoft, personal data that we hold about you may include the same information listed in above, along with:

- Business data – your function/job title within the company and your work email address, company’s name, postal address, VAT and/or company number.

- Financial and transaction data – including bank account and payment card details as well as details about payments to and from you and other details of services you have purchased from us.

- Marketing and communications data – where you have opted-in via your user preferences in your account settings, we hold details about your preferences for receiving marketing from Headsoft and our third parties, your communication preference, your language and your social network accounts.

Specific TORLIN Products collect specific additional data as further detailed below.

What information does the TORLIN Products collect?

TORLIN products collect:

• Setup information you provide

• Video signals and data (sequences and images)

• Technical information from the device

Data protection and privacy laws in your locality may impose certain responsibilities on you and your use of TORLIN Products. You (not Headsoft) are responsible for ensuring that you comply with any applicable laws when you use Headsoft Products. Note that recording and sharing clips that involve other people may affect their privacy and data protection rights.

How does my TORLIN Product or account interact with third parties?

Any Headsoft data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession.

Any data that Headsoft receives from third-parties (for example, information received from Facebook after you login to your Facebook account to share content) will be processed and stored by Headsoft and will be treated in accordance with this Privacy Policy. This information may be processed in the same manner as any other data that is a part of your Headsoft account or the Headsoft logs.

What additional information does Headsoft collect and store when a user connects a TORLIN Product to the Internet or creates an account?

Email Addresses: When you create a TORLIN account, we collect and store your email address. From that point forward, your email address is used for communications from Headsoft. In addition, Headsoft may provide you with the ability to login with alternative credentials, such as a Facebook account.

Basic Profile Information: Your account allows you to provide certain basic profile information like a username of your choice and profile photo. Usernames and profile photos may be shown to others in connection with Headsoft services. We routinely record log entries and technical information when your mobile device, tablet, PC, or TORLIN Product contacts our systems.

How does Headsoft use the information it collects?

We use this information to provide, develop and improve TORLIN Products and services, including making assessments and recommendations about products or safety. We may use your contact details to send you this information, to ask you to participate in surveys about your TORLIN use, and to send you other communications from Headsoft.

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated, non-identified information about the number of times users in a particular region use a particular function to help us determine if the function is desired by customers. We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

If you have agreed that we may do so, we may use your information to send you marketing via the communications methods you have selected via your user preferences in your account settings. Not all TORLIN Products conduct direct marketing. Where this functionality is available, you can change your preferences at any time and switch this option on/off. We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our systems.

Depending on your location and type of data, Headsoft may process your personal information on servers that are not in your home country. If you are in the Czech Republic, Headsoft processes your personal information only in the Czech Republic. If you are outside of the Czech Republic, Headsoft processes your personal information in Czech Republic or Slovak Republic.

Our legal bases for processing information

In order to store, hold and process your data lawfully where EU Data Protection Law (including the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016), read in conjunction with and subject to any consequential national data protection legislation) applies, we rely on one or more of the following legal grounds:

Where it is necessary for the performance of a contract - we process your data to provide and support a product or service you have asked for under a contract.
When we are pursuing legitimate interests. We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:
- offering and improving TORLIN Products and services
- developing new products and features
- understanding how people use our products and services
- performing research that improves our services for our users and benefits the public
- protecting against harm to the rights, property, and safety of Headsoft, our users, and the public
- detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
- maintaining and improving the integrity of our computing systems, and protecting our users’ data security
- enforcing legal claims, including investigation of potential violations of law

When we are complying with legal obligations. We process your data when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable governmental request.

With your consent. Where necessary, we ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at any time.

Individual Rights in the European Economic Area

If you are located in the EEA, you may seek confirmation regarding whether Headsoft is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to Headsoft’s processing of your personal information at any time. However doing so may impact your use of the TORLIN Products and services.

If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by Headsoft, you may do so, as applicable, through controls in the TORLIN app or by contacting Headsoft at support@headsoft.cz.

Further information on your rights in the EEA is set out below:

• Right to obtain a copy of your personal data – you have the right to obtain a copy of the personal information we hold about you. If you would like to make a SAR, i.e. a request for copies of the personal data we hold about you, you may do so by contacting us at the contact details above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.
• Right to rectification – you may request that we rectify any inaccurate and/or complete any incomplete personal data.
• Right to withdraw consent – you may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.
• Right to object to processing – including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your personal data. In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention.
• Right to erasure – you may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
• Right to data portability – in certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services.
• Your right to lodge a complaint with the supervisory authority – please contact us first about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant EEA supervisory authority directly.

In what circumstances does Headsoft share my information?

We do not share personal information for any commercial or marketing purpose unrelated to the activation and delivery of TORLIN Products and services without asking you first.

The following are the limited situations where we may share personal information:

• For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers and systems for technical problems. These technicians (as well as Headsoft employees) can access certain information about you or your account relating to this work, but these technicians are not allowed to use this data for non-Headsoft purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video recordings that you have not shared.
• As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request that a purchaser treat our data under the Privacy Policy.
• For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, we may disclose information in response to legal process and we may disclose information in response to lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.

If you select an outside party for the purchase, installation, or service of your Headsoft device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a TORLIN Product from a retailer, the retailer may collect personal information as part of the transaction.

What choices do I have and how can I delete my personal information?

Headsoft generally stores your personal information on Headsoft’s systems until you delete or edit it, or for as long as you remain a Headsoft customer, in order to provide you with TORLIN Products, but your photo, and video files are stored for a limited time (e.g., 7, 15, or 30 days). Your Headsoft account allows you to delete audio, photo, and video files that you choose before the limited storage time has elapsed. In addition, should you wish to delete your entire account, including all recordings associated with it, contact support@torlin.cz.

As described above, some information is processed and stored directly on the TORLIN device. All personal information is encrypted as it is transmitted to Headsoft and cannot easily be accessed.

Retention of Personal Data

Your personal data will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by applicable law). However, we will not retain any of your personal data beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Cookies

The TORLIN website and app use cookies to distinguish you from other users of the website and app. This helps us to provide you with a good experience when you browse the service and also allows us to improve our website and/or app. If other TORLIN Products use cookies we will inform you.

This section of the Privacy Policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies. By continuing to use the TORLIN website and/or app, you agree to the use of cookies for the purposes set out in this Privacy Policy.

A cookie is a small file that a website, app or its service provider transfers to your computer’s hard drive, mobile phone or other device, through your web browser (if you agree) that enables the website’s, app’s or service provider’s systems to recognize your browser and capture and remember certain information. We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose Duration More information
[Google Analytics _ga] Used to distinguish users 2 years These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.
https://developers.google.com/analytics/devguides/collection/
analyticsjs/cookie-usage
[Google Analytics _gat] Used to throttle request rates to maintain Website performance 1 minute
[Google Analytics _gid] Used to distinguish users 24 hours

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the relevant website and/or app.

Can the Privacy Policy be changed?

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes by contacting you through a notification in the TORLIN app or through the email contact information you provided when setting up your Headsoft account.

How can I contact Headsoft?

If you have any questions, please contact us at: info@headsoft.cz or info@torlin.cz.