- You should read this policy in full, but here are a few key things we hope you take away from it:
- AquaEasy will never sell your data.
- When you choose to onboard with us, we ask you for your name, email, phone number and preferred language so that we can keep your account secure and be able to provide you a customized experience based on your region.
- When you use AquaEasy (either via Web or Android App), we collect some personal information from you like the type of device you’re using and your IP address. We use this data to make decisions on what type of screens do we need to support and the range of Operating System versions.
- We save the data coming from your farm e.g., location of your farm, water quality parameters, employee names and their roles. This data is controlled by you and can be edited or deleted at any time. The data can also be exported and provided to you on request
- We also use the water quality information to run analytics thereby helping you make better decisions.
- If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you. You can contact us at email@example.com.
2. What is Personal Data?‘Personal data’ means all the information that relates to an identified or identifiable natural person (that is, an individual) – for example, your name, telephone number, email address and street / mailing address
3. GENERAL INFORMATION ABOUT HOW WE PROCESS PERSONAL DATA3.1 Standard of data protection laws
Some countries in ASEAN do not yet have data protection laws. If you live in such a country we generally aim to protect your personal data as if there were data protection laws that apply to you.
The data protection laws in some countries in ASEAN are different from the data protection laws in other countries in ASEAN. We generally aim to protect your personal data as if the strictest standard of data protection law applies to you.
3.2 General principles that we apply when we process personal data
We collect personal data about you only for specific and legitimate purposes. We notify you about those purposes and we process such personal data only in ways that are compatible with the specific and legitimate purposes that we tell you about. We process personal data about you lawfully and fairly.
We only collect personal data about you that is adequate and not excessive in relation to the purpose(s) for which we process it. We take care to make sure such personal data is accurate and relevant and, where necessary for the purposes for which we process it, we keep it up-to-date. We retain personal data about you only for so long as we need to do so for legal and business purposes. For so long as we retain such personal data we make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
3.3 Lawful bases of processing
We want to treat all of the individuals with whom we interact equally, but sometimes we cannot do so because of the way we must apply the laws. In Singapore, the data protection law requires us to obtain your consent before we collect, use, disclose and store (collectively, ‘Process’) personal data about you, except where there is an exception to the requirement for consent. For example, we do not need consent to process personal data to respond to an emergency that threatens someone’s life, health or safety.
Elsewhere in ASEAN, the data protection laws lay out the lawful bases on which we may process personal data about you. Broadly, these are:
- where processing personal data is necessary for us to fulfil a contract we have with you – for example, where we have provided you with a product warranty – or in order to take steps at your request prior to entering into a contract
- where the processing is necessary for us to comply with a legal obligation to which we are subject
- where the processing is necessary to protect your vitally important interests, including your life and health
- where the processing is necessary for our legitimate interests or the legitimate interests of a third party, except where such legitimate interests are over ridden by your fundamental rights and freedoms and/or
- where we have your consent to process personal data about you
4. Personal Data we collectWe collect personal data from you when you provide consent to us. With your prior consent, the personal data which AquaEasy may collect about you including but not limited to the following:
- Basic Account Information: This includes a display name, a username, a password, an email address (for important communications related to your account) and phone number (to send you important water quality alerts)
- Farm Information: Basic farm information, such as name of your farm, number of ponds, name of the ponds, area, and location of the ponds
- Photos and videos shared by you on the AquaEasy platform
- Location Data to provide you accurate weather reports and contextual information
- Water Quality Data collected for your ponds using our sensors
- Farming Operations Data entered in our system to manage your Farm
- Log Data such as IP Address, browser type, mobile phone type, pages visited, search terms
5. How do we use your Personal Data?With your prior consent, we will collect and use your personal data for the purpose of carrying out our business including but not limited to the following:
- To enable you to access and/or use any service we provide, our website(s) and/or mobile applications
- To verify your identity when you access and/or use any service we provide, our website(s) and/or mobile application
- To process your personal data for purposes such as accounting, billing, and auditing
- Products and services development
- Customer services and administration including registering and managing warranties, responding to complaints, enquiries, comments, and requests, performing after-sales services, assessing, and responding to consumer or product reviews
- Surveys, service satisfaction, feedback, market research, sales promotions, and marketing activities
- Technical administration of our website(s) or mobile application
- Complying with laws and our legal obligations
6. Disclosure of Your Personal DataWe work together with several third parties including our related companies. We have chosen these third parties carefully to keep your personal data safe. We may need to disclose to, or share your personal data with these third parties, some of which may be located overseas, including but not limited to the following:
- To our holding company, subsidiaries, associated, affiliates and/or related companies within Bosch group of companies in other jurisdictions where reasonably necessary for the various purposes for which we use such personal data;
- To third parties such as our authorized agents, representatives, intermediaries, contractors, independent contractors, product dealers/distributors/representatives (including through their online platforms/marketplaces), third party service providers, mobile application service providers, external advisors and consultants to provide services including but not limited to hosting services, programming services, sales and marketing services, data analytics, legal services, media agency services, maintenance and repair of product services and/or customer contact center services to us and/or for and on our behalf – in these cases, the third party service provider is under contractual arrangements with us that require the service provider to ensure that your personal data is protected and not used by the service provider for any purpose other than providing the specific contracted service;
- To any social media website(s) or mobile application such as Facebook, Instagram, and LINE for the purpose to create customized audiences for targeted marketing; and
- we are required or authorised by law to disclose it
7. Quality and Security of Your Personal Data
- We strive to do our best to protect your personal data and take reasonable steps and efforts to ensure that the personal data we collect are accurate, up-to-date, and complete, and when being used or disclosed, relevant for the purpose of the use or disclosure. However, please help us to maintain the quality of your personal data by updating the data if you believe that the personal data which AquaEasy holds about you may be inaccurate, incomplete, out-of-date, or irrelevant
- We have appropriate security measures in place to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business ‘need to know’. They will process your personal data only on our instructions.
- We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of an actual or suspected personal data breach where we are required by contract or law to do so.
- We encourage you to be careful and protect your personal data when using our website(s) or mobile application. In the event of cyber-crime, loss, or damage of your personal data that is beyond our reasonable control, we will not be held responsible for such actions in any manner whatsoever directly or indirectly
- If we have provided (or you have chosen) a password which allows you to access various parts of our website(s) or mobile application, you are responsible for maintaining the confidentiality of that password. We request you not to disclose the use of the password to any third party in any manner whatsoever directly or indirectly
- Our security procedures, if necessary, will be continually enhanced as and when new technology becomes available
- We are also committed not sell or rent your personal data with any third parties
8. Data processing on the website
- Our website(s) or mobile application uses a browser feature known as “cookies”. When you visit our website(s) or mobile application, our web server(s) will automatically record the following information:
- date of the access;
- time and length of the access;
- URL of the linking website or mobile application;
- name of your internet service provider;
- websites or mobile application you actually visit;
- files accessed;
- browser type and version;
- operating system;
- IP address (anonymized)
9. Your Right to access, complete, correct, update, and transfer your Personal Data
- You may generally access or request personal data which AquaEasy holds about you, and you may request us to correct, update, delete, suspend and/or anonymize your personal data which you believe is inaccurate, out-of-date, incomplete, irrelevant, or misleading
- To make such request, please contact our Data Protection Officer at the particulars provided below. We may need to ask you a few questions to verify your identity before we can respond to your request. If we are unable to provide access to, or correct or update your personal data, we will inform you in writing of our reasons and how you may take the matter further if you are not satisfied with our decision
11. How long AquaEasy will keep your Personal dataWe will take reasonable steps and efforts to ensure that we will keep your personal data for the duration of the contractual obligations or as required by the relevant laws.
12. Protection of minorsIf you are below age of majority which is 21 years old, please do not send any of your personal data to us without consent from your parents or legal representatives.
14. Contact Details for questions relating to your Personal dataIf you have any questions about how AquaEasy handles your personal data, or if you are concerned that we may have breached your privacy and wish to make a complaint, please put your complaint in writing and send it by mail or email to our Data Protection Officer using the details below. We will investigate your complaint and will notify you of a decision in relation to your complaint as soon as practicable after it has been made.
Data Protection Officer, ASEAN Region
Robert Bosch (S.E.A.) Pte. Ltd.
11 Bishan Street 21
By email: firstname.lastname@example.org