Effective February 1, 2016
FileWave (Europe) GmbH, and FileWave (USA), Inc. (collectively referred to as "FileWave") provide business, education, and government customers with industry-leading systems management software to effectively, and efficiently, secure and manage devices, applications, and content from one easy-to-use console. FileWave is a complete cross-platform systems management solution that covers both client (desktop) and mobile devices. The privacy considerations for customers who license the FileWave software to perform enterprise-wide mobile device management ("Customers") and the privacy considerations for those on whose mobile devices are being managed ("Individuals") are discussed in this Policy.
FileWave's principal office and data controller is:
FileWave (Europe) GmbH, St. Gallerstrasse 1, CH-9500 Wil, Switzerland. [Fax: +41 (0) 71-914-30-81]
FileWave's primary office in the United States is:
FileWave (USA), Inc., 7320 E. 86th Street, Indianapolis, IN 46256, United States. [Fax: +1 (317) 755-0944].
You may contact FileWave with any inquiries or complaints through either of these two offices or by emailing our privacy department.
Like most internet services, FileWave's website gathers some information automatically for log files, such as ISP, IP address, browser type, regional information (language, time zone, and date and time information), referring and exit websites, and OS. This information is used to manage the site and improve our services across global regions and demographics. FileWave may share this information with our internal marketing department.
When you browse FileWave's website, you are able to do so anonymously. Generally, we don’t collect personal information when you browse — not even your email address. Your browser, however, does automatically tell us the type of computer and operating system you are using. The FileWave website does use "cookie" technology.
When you create an Alliance account, download software, or register for an evaluation Alliance account, we may collect a variety of information, including name, organization name, address, phone number, email address, and organization size.
Monitoring Information. The levels of communication and monitoring functionality between your mobile device or smartphone and the FileWave Console is selected by our Customer who is typically your employer or the company for whom you work as an independent contractor or consultant.
In some instances, our Customer asks us to host the FileWave Console and in other instances our Customer hosts the FileWave Console. When FileWave hosts the FileWave Console, we may collect and/or track certain information that is derived from your usage of the mobile device and may perform other functions. From this console, the administrator can perform partial or complete erasure of data on your device, including restoring the device to its factory default. The information collected and tracked by the FileWave Console depends upon the system configurations chosen by our Customer.
The portions of the FileWave software that allow smartphones and mobile devices to be monitored by the FileWave Console run in the background of the devices. Individuals are notified that these functions may occur, but may not be aware when these functions are occurring in real time. This information is all made available to our Customer via the FileWave Console for our Customer’s use in accordance with its own business uses. Some of the information FileWave collects allows us to perform our support obligations.
FileWave and our partners use cookie and other technologies to remember personal information when visiting websites. Knowing this information helps personalize your experience and offer better customer service. To disable cookies, simply use your browser’s privacy settings to disable cookies. Please note that many features of the website will not be available with cookies disabled.
If you use the FileWave Software, or use a device upon which FileWave has been installed, the following information may be collected:
- Device phone number
- Currently logged on user
- Unique Device identifiers (Serial, IMEI, WWAN, MAC)
- Previously installed software
- Currently installed software
- Application usage (times launched and when)
- Device location (Potentially using; GPS, WiFi, iBeacon, IP, or other technologies)
- Device Name
Emails sent and websites of FileWave may use pixel tags or trackable links. This is to help FileWave better gauge interest and confirm whether emails have been opened. If you prefer not to be tracked, do not click links or images in emails.
Where we store your Personal Information
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Uses made of the Information
We use information about you in the following ways.
Information you give to us.
We will use this information to:
- Fulfill our obligations arising from any contracts entered into between you and us, and to provide you with the information, products and services that you request from us.
- Ensure that content from our site is presented in the most effective manner for you and for your device.
- Notify you about changes to our service.
- Provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about.
Information we collect about you.
We will use this information to:
- Administer our site and for internal operations; including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Improve our site to ensure that content is presented in the most effective manner for you and for your device.
- Keep our site safe and secure.
- Help us improve the services we provide.
- Send promotional emails about our products, and services or other information which we think you may find interesting.
- Respond to any inquiry you have sent to us.
Information we receive from other sources. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above.
We will not sell, distribute or lease your personal information to third parties unless we have your permission. If you have submitted information to us and wish to have it removed from our internal records, please contact us.
Disclosing Personal Information
We may share Personal Information with FileWave subsidiaries or Business Partners to carry out transactions you request, to make our products and services more responsive to your needs, to provide you with information about FileWave and FileWave branded products and services, or for research and analysis. We may also disclose Personal Information in connection with legal orders from law enforcement or other government bodies; as required by law or regulation; to protect the rights of our customers, the public, or others; to protect our own legal rights and responsibilities; or with your consent.
In addition, we may share Personal Information with Business Partners that help FileWave or our subsidiaries carry out transactions you request, customize, analyze and/or to improve our communications or business relationship with you. Such Business Partners may include a payment processor to bill you for services and an email service provider to send out emails or newsletters on our behalf. These communications may include requests relating to our products or services.
We will only share Personal Information with Business Partners who share our commitment to protecting your Personal Information, either by subscribing to recognized Privacy Principles or by written agreement to provide at least the same level of privacy protection as is required by the relevant legal and governmental authorities.
The use, collection and disclosure of personal information may involve FileWave transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws. We may share information with a purchaser of all or part of the companies comprising FileWave or FileWave subsidiaries.
We may aggregate, de-identify and/or anonymize information so that it does not identify you, and share that and other non-Personal Information with third parties for any purpose.
FileWave is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.
FileWave will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for legal or business purposes. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous. If you have an account with FileWave, and you are no longer a customer, your account will be put into a non-customer mode. You may still log in and remove your account’s personal information, or you may submit a written request to us to remove it.
FileWave will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete, and up-to-date to meet the purposes for which it is collected and used. FileWave does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. FileWave therefore relies on you to keep your personal information accurate and current.
You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to FileWave's Privacy Officer and must provide sufficient detail to identify the personal information and the correction being sought. If you have an account with FileWave, you can update your own information by logging in to your "settings".
If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.
Requests for Access
You have the right to access your personal information, subject to limited exceptions under applicable laws, disclosure that would reveal personal information about another person, legal obligations and proprietary rights. FileWave's Privacy Officer will assist you with your request. This includes:
- Identification of and access to any or all of your personal information under FileWave's custody or control.
- An explanation of how that personal information is or has been collected, used or disclosed by FileWave.
- The names of any individuals and organizations to which your personal information has been disclosed by FileWave.
All requests should be made in writing (by mail, fax or email), provide sufficient detail to identify the information being sought, and be directed to FileWave's Privacy Officer. FileWave's Privacy Officer may require further information defining the request more succinctly.
We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or, where additional time is required to fulfill the request, provide written notice of an extension. If FileWave cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you.
A minimal fee may be charged for providing access to personal information, where permitted under applicable law. Where a fee applies, we will inform you of the cost, and request further directions from you on whether or not we should proceed with your request.
FileWave Customers may request to "opt out" regarding retention of Personal Information, and whether their personal information will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized; and have the data deleted. Information about a Customer may be exempted from deletion if this is required by law, or is required for accounting and audit purposes.
Information regarding Individuals is generally controlled by the Customer by whom the Individual is employed or for whom the Individual serves as a consultant or contractor. In such cases, any opportunity to change information or "opt out" is between the FileWave Customer and the Individual.
FileWave (Europe) GmbH, St. Gallerstrasse 1, CH-9500 Wil, Switzerland. [Fax: +41 (0) 71 914 30 81], or
FileWave (USA), Inc., 7320 E. 86th Street, Indianapolis, IN 46256, United States. [Fax: +1 (317) 755-0944].
Email our privacy department.
Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws. If the FileWave Privacy Officer is unable to address your concerns, the issue may be escalated to the office of the CEO or to the relevant Privacy Commissioner or similar regulatory authority for your jurisdiction.
Effective Date and Updates
- We included information about Mobile Apps and the addition of location services for the first time;
- We provided more information about what personal information we collect and why;
- We specified the limited circumstances in which we may collect, use or disclose personal information without your knowledge or consent;
- We identified that implied consent may be valid for the collection, use or disclosure of certain personal information; and
- We added greater detail to various sections so that our policies and practices were made clearer.
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