Pelion Global Privacy Statement

Introduction

This Pelion Privacy Statement (“Privacy Statement“) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data“), and to learn about your rights and choices regarding our processing of your Personal Data.

A reference to “Pelion”, “we,” or “us” is a reference to Pelion IOT Limited with its principal place of business at St. Vincent Plaza, 319 St.Vincent Street, Glasgow, G2 5LD, Scotland, United Kingdom.

Scope

Pelion is the controller of your Personal Data as described in this Privacy Statement.

For the avoidance of doubt, this Privacy Statement does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including where we offer to our customers various cloud products and services.

Types of Processing Activities

This Privacy Statement applies to the processing of Personal Data collected by us when you:

 

Personal Data We Collect

  1.  Directly from you

The Personal Data that we collect directly from you includes the following:

If you provide us with any Personal Data relating to other individuals, you must explain to those individuals that their Personal Data will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or if you otherwise wish to exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contact Us” section below.

We also collect information about you from other sources and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers and create more tailored advertising to provide products and services that may be of interest to you. In particular, we collect Personal Data from third party providers of business contact information, including professional contact details, employment-related information (such as job titles) and device / location-related information (such as IP addresses) for purposes of targeted advertising, delivering relevant email content, event promotion and profiling.

We obtain information through partners, vendors, suppliers and other third parties. These enterprises largely fall into the following categories: partners, hosts or vendors at events or trade shows, research partners and enterprises that deploy the Pelion technology or third-party offerings that include Pelion technology. We might also obtain information through a partner as part of our business operations. This kind of data is used for work such as improving algorithms and data models, product testing and improvement, enhancing existing products and developing new capabilities and features.

Why and How We Use Your Information

We collect and process your Personal Data for the purposes and on the legal basis identified in the following:

Where we need to collect and process Personal Data under a contract we have entered or will enter into with you, and you fail to provide the required Personal Data when requested, we may be unable to perform our contract with you.

When and how can Pelion share your Personal Data?

Sharing with third parties

We share information with the following third parties:

Sharing within Pelion

We share your information across the Pelion corporate group to provide, maintain and develop our products and services. Pelion employees will only access the information to the extent necessary to achieve the particular purpose(s) and perform their job.

We also share information that is not Personal Data, such as anonymized or aggregated information, for purposes such as analysis, identifying trends in the areas of our products and services and to help research and develop new Pelion products and services.

Data Aggregation and Analytics

We collate your Personal Data which you provide to us, or we collect and use it anonymously for analytics, benchmarking and to effectively monitor our website and improve your user experience.

How long do we retain your information for?

We retain Personal Data for the period necessary to:

Retention periods can vary significantly based on the type of information and how it is used, and our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When Personal Data is removed from our systems, it will be deleted or destroyed using appropriate security protocols so that it cannot be reconstructed or read.

If you are located in a European Union member state and certain other countries, you have the following additional rights:

Access and/or have your information provided to you

You can request a copy of the Personal Data we are processing about you.

Change or correct

You can ask us to change, fix or update information about you (for example, if it is incomplete or inaccurate).  

Delete 

You can ask us to delete Personal Data about you.

Restrict or limit use

You have the right to ask us to restrict our processing (i.e., stop any active processing) of your Personal Data (for example, if the information about you is inaccurate).

Data portability 

In certain circumstances, you have the right to obtain Personal Data we hold about you in a structured, electronic format, and to transmit such data to another company.  

Object

You have the right to object to Pelion using your Personal Data in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). See below for information about how to unsubscribe to direct marketing.

Opt-out

You can withdraw your consent to certain data processing, including for marketing messages that you receive from us. 

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please note that these rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.If you have unresolved concerns, you have the right to complain to a data protection authority as described below. Individuals based in the UK, or the EEA can make a Data Subject Access Request by following this link.

International Transfer of Personal Data

Your Personal Data may be collected, transferred to, and stored by us in the United States and by our affiliates and third parties disclosed above, that are based in other countries.

Therefore, your Personal Data may be processed outside your jurisdiction, and in countries that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area (EEA). We ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission.

Children’s Privacy

We will not knowingly collect Personal Data from children under the age of 13 years.  On occasion Pelion does run campaigns to encourage the use of technology for children under the age of 13.  Such campaigns are strictly for educational purposes only.  Any information collected by Pelion of participating children under the age of 13 is done with the consent of the parent or legal guardian and the data collected is strictly segregated and deleted immediately after the end of any such campaign.

Changes

We may modify this Privacy Statement at any time. If we make changes to this Privacy Statement, then we will post an updated version of this Privacy Statement on our website. We will specifically notify you by email about any material changes to this Privacy Statement.  

Contact Us

If you believe we have used your Personal Data in a way that is not consistent with this Privacy Statement or your choices, or if you have any questions or comments about this Privacy Statement, please contact Pelion Legal by emailing [email protected]  Any request will be evaluated and completed in accordance with applicable data protection law, including verification of the requestor’s identity. Alternatively, please contact us at the following address:

Head of Legal

Arm Cloud Services Limited

c/o Brodies LLP

110 Queen Street

Glasgow, G1 3BX

United Kingdom

Pelion IoT Limited
St. Vincent Plaza
319 St. Vincent Street
Glasgow
G2 5LD
Scotland
United Kingdom

Filing a complaint

If you have a complaint about this Privacy Statement or any aspect of how we use your Personal Data, then please contact us first. If you are not satisfied and are located in within the European Economic Area, then please contact your local data protection authority. If you are based in, or the issue relates to, the UK, you can contact the UK Information Commissioner’s Office at the following address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Alternatively, you can use an online form via the Information Commissioner’s website (https://ico.org.uk/concerns).

If you are based in, or the issue you would to complain about took place elsewhere in the EEA, please visit this website (http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061) for a list of local data protection authorities in other EEA countries.

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