LOTUS Microsystems (hereinafter “LOTUS Microsystems”, “we”, “us” or “our”) is the company acting as the data controller in connection with any personal data collected or received by LOTUS Microsystems arising from your use of any LOTUS Microsystems products, services, applications, websites (including any e-commerce stores) and contact centres made available to you. LOTUS Microsystems is responsible for ensuring that the processing of personal data complies with this Policy.
1. Personal data that we collect
What personal data does LOTUS Microsystems collect and where does this personal data come from?
LOTUS Microsystems may collect personal data about you in several different ways which are explained below. Please take care when submitting personal data to us, particularly when completing free text fields or uploading content, documents and other materials. Some of our services are automated and we may not recognise that you have accidentally provided us with incorrect or sensitive personal data. You can always contact us to correct incorrect data (see section 12 below).
A. Personal data that you provide us
Whenever you interact with LOTUS Microsystems, you may be asked to provide us with personal data relating to you. For example:- Some of our applications or services require you to create an account. When creating your account(s), we may ask you to provide a range of personal data, such as your name, contact details, applicable device ID(s) relating to the devices you are using to access and receive particular applications and services, interests and account and marketing preferences and your current mobile network operator- When you contact our customer service centres for assistance (by any means of communication including written communications or via our website(s), support forums, telephone, email, SMS or our social media channels), and keep personal data about the particular communication, where this is permitted by applicable law. The personal data collected may include your name, the product(s) you bought, the reason why you contacted us, applicable device ID(s) relating to your particular product(s) and the advice we gave you so we can track the resolution of any customer service issues and for customer service training purposes- When you visit us at a public event, such as a trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for personal data, such as your business card, name, contact details, interests and marketing preferences- When you use our applications and services or other platforms, we may receive content that you choose to upload, such as product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive.
B. Personal data we collect when you use our websites, products, services and applications
In order to improve and provide a better user experience, some of our websites, internet-enabled products and applications and services provide LOTUS Microsystems with personal data about your use of them, including:- Details of your usage patterns, content (including any advertisements) that you view and interact with. For example, when you use our websites, we may collect personal data about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket- Service, product or server logs which hold technical personal data about your use of our service, product or websites, such as your IP address, device ID(s), domain, device and application settings, errors and hardware activity. We may use your IP address to determine your location/country of origin
C. Personal data we collect from other sources
We may also collect personal data from publicly available sources and third parties, including:- When you seek to make a purchase from us, we may carry out credit and financial checks to ensure payment is not made fraudulently and that you have a suitable credit rating- If you purchase products or services from partner retailers, we may receive certain information about your purchase from that retailer, such as your contact information and time of purchase- Information we collect in relation to social networks.
2. How LOTUS Microsystems uses your personal data
How does LOTUS Microsystems use your personal data and what is the legal basis for processing this personal data?LOTUS Microsystems uses the personal data you provide or which we collect mainly for these purposes:
A. Service provision
When we are using personal data to offer our products and services to you, the processing is based on a contract between you and LOTUS Microsystems. We may use personal data to:- provide you with a product or service you have requested, including any back-up and restore service- provide you with software updates which may contain critical security and functionality patches that make your device more secure and protect the personal data on the device- facilitate and process your searches and requests for information when you contact us about LOTUS Microsystems and its products and services- provide our checkout assistance service. When you use our applications and services including any online e-commerce stores, details of any products that you seek to purchase and your email address may be collected as you fill in the checkout form. If you do not complete your purchase, we and/or our authorised fulfilment partner(s) may contact you using these details to offer our assistance (in case, for instance, you were experiencing technical difficulties that prevented you from completing a transaction). This is an optional service. You can choose not to receive our checkout assistance emails at any time by following the link at the bottom of each assistance email.
B. Product and service development
We work constantly to make our products and services better. We base this processing on our legitimate interests to develop our products and services, to better meet customer requirements, to ensure quality, to develop identity management, and to strengthen network and information security. We may use personal data to:create and manage customer database(s) of our users, including basic account information (such as your name, address, contact details), applicable device ID(s) (relating to the devices you are using to access and receive particular applications and services), related product or service usage information and customer preference information as provided by you from time to time. As part of our on-going customer relationship management activities, we may consolidate several databases into one or otherwise link separate databases to more effectively manage your accountsask for your opinions on LOTUS Microsystems products and services and conduct product surveysimprove and enhance existing LOTUS Microsystems products, services and applications and develop new offerings, recommendations, advertisements and other communications and learn more about customers’ shopping preferences in general.
C. Marketing and advertisement
When we use personal data for marketing purposes, we base the processing on our legitimate interests to know our customers, keep you up-to-date about LOTUS Microsystems's latest products and services and to personalise your customer experience. In some cases, we base marketing on your prior consent, e.g. for sending marketing messages. We may use the personal data we collect and/or any personal data about you which is shared with us for marketing purposes, e.g. from other companies whose products, applications and services you also use. In particular, we may:
- provide you with product and service updates, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging, text message (SMS) or other means, if you have consented or if we are otherwise permitted to do so under applicable law
- ensure that you benefit from any relevant special offer or promotion- hold prize draws, contests and other promotional offers- create user group profiles or segment data and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services, which we may share with third parties and/or make available to the public
- use product reviews, comments or content you have uploaded and made publicly visible in our websites or services to link to, publish or publicise elsewhere, including in our own marketing. Each time you create or reply to a post or thread on a website forum from LOTUS Microsystems, in addition to providing this forum service, we may also record the forum name and the time and date of your post or thread with your account details. We do this to better understand the ‘typical users’ of our forums and to select or tailor our marketing communications to reflect your forum activity. We do not use the actual content of your forum posts or threads for purposes of sending marketing communicationsIf you want to know more about our marketing communications, our use of customer profiles and how to opt-out, see section 6 below for more details.
D. Fraud prevention and investigation
LOTUS Microsystems may use personal data to prevent fraud and to investigate violations or our policies. For example, we may use your device information such as your device ID(s) to ensure that any vouchers or discounts relating to any promotions or campaigns are not being redeemed fraudulently, and to check that a payment is not made fraudulently. In this case, we base the processing of personal data on our legitimate interest to prevent fraud and to provide benefits only to our customers. We may also use personal data to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies. We may use your personal data to enforce or defend the legal rights of LOTUS Microsystems or the terms and conditions of any LOTUS Microsystems product or service. In this case, we base the processing on a legal obligation to which LOTUS Microsystems is subject or on our legitimate interest to defend our legal rights.
E. Other purposes
We may use your personal data for other purposes - for staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other customer support centres. We base this processing on our legitimate interest to ensure the quality and efficiency of our customer service- to link or combine the personal data that we collect from the different sources outlined above. This processing is based on our legitimate interest to provide a better customer experience and service. Personal data may be linked via a unique identifier, such as a cookie or account number. Alternatively, we may decide to combine two or more databases into a single database of customer information. We may link or combine personal data for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to provide more seamless customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts. If you want to know more about our use of customer profiles, see section 6 below for more details.
3. Sharing personal data about you
How is personal data about you shared within LOTUS Microsystems and with 3rd parties?
A. Sharing of personal data by LOTUS Microsystems
In general, LOTUS Microsystems does not disclose personal data about you to third parties without your consent. However, there are exceptions:-Our service providersWe may use third party service providers to provide certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include billing and fulfilment partners, data analytics providers who process personal data on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services, provide back-up services and provide customer services.
When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.
- Third Party Advertising Partners
- Third party newsletters If you request or agree to receive information or newsletters from one of our business partners, we may provide that third party with your details so that they can contact you and/or respond to your request.
- Legal and business purposesWe may use and/or disclose personal data to third parties
- when we have a good faith belief that sharing the personal data with government bodies and law enforcement agencies is necessary to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodieswhen we are defending or enforcing the legal rights of LOTUS Microsystems or the terms and conditions of any LOTUS Microsystems product or service and sharing the personal data with third parties, including professional advisors, will be beneficial for our legal position
- in connection with a corporate event such as a merger, business acquisition or insolvency situation, when sharing the personal data with a prospective third party purchaser or seller, and its and our professional advisors, is necessary
- Anonymous statistics
We prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes as outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third party (such as our partners, advertisers, industry bodies, the media and/or the general public)
B. Sharing of personal data provided by you
A number of our applications and services allow you to upload and share messages, photos, video and other content and links with others and/or create a publicly accessible profile for your account. For example:
- The communities and forums area (where applicable) of our websites allows you to post comments (with your account name), which are visible to other users of that service
Other services allow you to share a link which if clicked on may allow the recipient to access your uploaded content
4. International transfers of your personal data
How does LOTUS Microsystems transfer personal data about you to other countries?For the purposes explained in this Policy, your personal data may be transferred third parties in countries which do not have the same level of data protection laws as those in the country where you are located. LOTUS Microsystems uses a variety of legal mechanisms, including EU Standard Contractual Clauses, to help ensure that your rights and protections will travel with your data. This is why each of our authorised data processors will comply with LOTUS Microsystems’s internal policy relating to processing of personal data which complies with the key data protection principles of fair handling of personal data and ensuring adequate level of protection of personal data.
5. Marketing communications and how to change your preferences
How does LOTUS Microsystems use your personal data to send you communications and how can you change your marketing preferences?
A. Marketing communications
When you provide us with contact details, such as when you purchase a product, contact our customer support call centres or create an account for one of our services, you may be given the opportunity to opt-in to (or in certain cases where applicable law allows, opt-out of) receiving various newsletters and other communications from LOTUS Microsystems. These communications may include, for instance, details about the latest LOTUS Microsystems products and services, including upgrades and special offers in which you may be interested. You can change your marketing communication preferences at any time:a. If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the email. But note that:b. If you use more than one email address to shop or contact LOTUS Microsystems, you will need to unsubscribe separately for each email addressc. This method will only unsubscribe you for emails. You will need to separately unsubscribe for other types of marketing communications you received. If you have registered with any applications and services provided by LOTUS Microsystems and have your own account, you may log in and amend your marketing communication preferences in the account settings page or areae. For managing other types of communication, such as push-notifications in apps, please go the app specific settings to make the changes
B. Customer profiles
As described above, we may create user group profiles or segment data to better understand our customers and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services. This processing is based on our legitimate interest to understand our customers better and to provide you with products and services that are better suited to your needs. We may also link or combine personal data to provide you with better personalised services, content, marketing and adverts. When we use customer profiles for direct marketing purposes, you have the right to object to this kind of personal data processing at any time you wish to do so.
C. Important information and service messages
Occasionally, we may send you important information (including via text message, push notifications, email) regarding essential software updates, changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations to provide warranty or after sales repair services. These important product and/or service communications are not affected by your marketing communication preferences.
6. Security of your personal data
How does LOTUS Microsystems protect your personal data and what can you do to protect yourself?
// What we do to protect your personal dataWhile LOTUS Microsystems can’t guarantee that unauthorised access will never occur, rest assured that LOTUS Microsystems takes great care in maintaining the security of your personal data to prevent unauthorised access to it, through the use of appropriate technology and internal procedures. We take a number of steps to protect your personal data from unauthorised access, use or alteration and unlawful destruction and disclosure, including where appropriate:-
Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive personal data, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us)
- Limiting access to the personal data we collect about you (for instance, only those of our personnel who need your personal data to carry out our business activities are allowed access)
- Putting in place physical, electronic and procedural safeguards in line with industry standards
// What should you consider regarding sharing content and links via LOTUS Microsystems's applications?- Please be aware that any content and links that you share via Qpitech’s applications and services might, for instance, be forwarded by your recipients to others. You should always exercise discretion when using such applications and services- We ask our users to take responsibility for protecting their own privacy online and to also respect the privacy of others. Participants in any communities, forums and message boards are prohibited from disclosing their own personally identifying information other than their own online IDs- Disclosure of phone numbers, addresses, age or other personally identifying information that may breach someone else’s privacy is prohibited. Encouraging or asking users to publicly disclose their personally identifying information is also prohibited
// What you should do to protect your personal dataAs general best practice on the internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:
- Do not use trivial passwords (such as single dictionary words)
- Do not use the same password for multiple accounts
- Do use very long passwords (at least 10 characters, but preferably much longer)
- Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
- Do keep passwords securely (never written down, or shared with anyone) and changed periodically
- Some of our websites may contain links to other third party websites that are not operated by LOTUS Microsystems
- While LOTUS Microsystems tries to link only to sites that share LOTUS Microsystems’s high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those third party websites. We strongly encourage you to view the privacy and cookie policies displayed on those third party websites to find out how your personal data may be used
7. Cookies & Tracking
What are cookies and how are they used?Our websites use industry-wide technologies, such as “cookies”, to collect information about the use of our websites and email communications. For instance, these technologies may tell us which visitors clicked on key elements (such as links or graphics) on a website or email and recognise your browser the next time you visit our websites. Cookies allow us to customise your experience to better match your interests and preferences, or to simply facilitate your signing in to use the services. Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. However, if you block or erase cookies, we may not be able to restore any preferences or customisation settings you have previously specified, and our ability to personalise your online experience would be limited. Please refer to your browser instructions to learn more about these functions.
8. Access to your personal data and your rights
9. Retention of personal data
How long will LOTUS Microsystems keep your personal data?
We will only retain your personal data for as long as is reasonably necessary for the various purposes set out in section 2 above or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of personal data relating to our customers and/or any commercial transactions with them. Should any personal data held by us no longer be required by us for any of the purposes set out in section 2 above, we undertake to take reasonable steps to destroy or de-identify any personal data after a reasonable period of time has elapsed. If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact your local data protection authority
10. Children’s privacy
What does LOTUS Microsystems do regarding children’s personal data?
LOTUS Microsystems considers a child to be anyone under the age of 16. We do not knowingly seek or collect personal data from or about children in contravention of any applicable laws and regulations. If LOTUS Microsystems becomes aware that personal data that has been submitted to it relates to a child in contravention of any applicable laws and regulations, LOTUS Microsystems will use reasonable efforts to delete that personal data from its files as soon as possibleEnsure, where deletion is not possible, that this personal data is not used further for any purpose, nor disclosed further to any third partyAny parent or guardian with queries regarding our processing of personal data relating to their child should contact us using the details provided in section 12 “Contact Us” below.
11. Local or Country-Specific Notices
Are there any local or regional differences to LOTUS Microsystems’s personal data handling?
A. California Residents Privacy Rights Notice
California residents have the right to receive: a) information identifying any third party company(ies) to whom LOTUS Microsystems may have disclosed, within the past year, personal data pertaining to you related to direct marketing purposes; and b) a description of the categories of the personal data disclosed. Please email your request to us using the details provided in section 12 below.
B. Notice for Australia Residents
In relation to Section 5 “International transfers of your personal data” above, we will disclose your personal data to parties in a number of countries, including Singapore, New Zealand, the United States of America, Japan, the United Kingdom, Sweden, Ireland and Belgium. From time to time we will need to disclose your personal data to parties in other countries, not on this list. This will be on an ad hoc or case by case basis and for the purposes for which we collected your personal data. Complaints: If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia). We will deal with complaints as follows:
Step 1: let us knowIf you would like to make a complaint, let us know by contacting us or use the details set out in section 12 “Contact Us” below.
Step 2: an investigation of the complaintYour complaint will be investigated by us. A response to your complaint will be given in writing within a reasonable period.
Step 3: contact OAICWe expect that our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information
Commissioner as follows:
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing
Tel: 1300 363 992
Address: Director of ComplianceOffice of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
C. Notice for New Zealand Residents
Nothing herein shall limit the rights of customers under the Privacy Act 1993. All instructions regarding your data and queries will be followed up and answered by us as soon as possible.
D. Notice for Malaysia Residents
E. Notice for Singapore Residents
LOTUS Microsystems will generally be able to respond to such queries and/or requests within 30 days. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, LOTUS Microsystems may not be able to continue to provide its products and/or services to you.
12. Contact us
How can you contact LOTUS Microsystems about your personal data?If you need further assistance or would like to make a comment, please contact us online or at LOTUS Microsystems, Stamholmen 153, DK-2650 Hvidovre, Denmark.