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Privacy Policy

Privacy Policy

Last Updated: May 12, 2023

Mitsogo Inc. (“Mitsogo Inc.”, “us”, “we”, or “our”) operates the www.mitsogo.com website, www.hexnode.com website, Hexnode UEM- the online Mobile Device Management solution, and the Hexnode UEM mobile applications.

Please note that we may collect Personal Data of individuals who access our Website. We may also process Personal Data on behalf of our customers who avail the Service (“Customers”). In such cases, we process such data on the basis of our Customers’ instructions and act as their Data Processor. If you are an end user of any of our Customers (“End User”), you should review such Customers’ privacy notices to understand how your Personal Data is handled. References to “you” across this Privacy Policy are to users of our Website as well as the Service.

We are committed to safeguarding Personal Data and privacy. This privacy policy (“Privacy Policy”) describes the types of Personal Data we obtain, how we may use that Personal Data, with whom we may share it and how you may exercise your rights regarding our processing of that information. The Privacy Policy also describes the measures we take to safeguard the Personal Data and how you can contact us about our privacy practices.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meaning as in our Terms of Use.

Definitions

Website

Website means the www.mitsogo.com website and www.hexnode.com website operated by Mitsogo Inc.

Service

Service means the enterprise management services provided on behalf of Customers through the Hexnode UEM and associated applications operated by Mitsogo Inc.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Website/Service or from the Website/Service infrastructure itself (for example, the duration of a page visit).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

Data Subject (or User)

Data Subject is any living individual who is using our Website or Service and is the subject of Personal Data.

Types of Data Collected

While using the Website or Service, we may collect, obtain or process data relating to you in a variety of ways, as described below, including Personal Data.

Information Collected From You Directly

When you submit questions, request information, give us feedback, or use the chatbot feature through the Website, we may ask you for data such as your name, postal address, telephone number, and email address so we can respond or follow up. We may also ask you to provide other data relevant to your question, request, or feedback, such as your geographical location, industry, and preferred contact method.

In certain instances, information or materials you post or disclose on the Website through chats, blogs, and other services may be publicly available and may be seen by other visitors on the Website. You should consider this when deciding to disclose any Personal Data or any other information on the Website.

While using our Services, we may obtain data of enrolled devices such as device hardware and software details, location data, network information, user details, Customer’s billing details.

Usage Data

We may also collect Usage Data that your browser sends whenever you use/visit our Website or Service.

This Usage Data may include information such as your computer's Internet Protocol address (IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Website or Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We do not knowingly collect or process Personal Data of children through the Website or Service.

We do not collect any data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data, or any information about criminal convictions and offences through the Website or Service.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Website.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes

Please see our Cookie Policy at https://www.hexnode.com/cookies-policy/ for more information about our use of cookies.

Use of Data

We will only use your Personal Data when the law allows us to. We use the data for the following purposes:

  • To provide and maintain our Website and Service, communicate with you about the Website and Service, and process your request for information
  • To administer and protect our business and the Website and Service (including troubleshooting, testing, system maintenance, support, reporting, and hosting of data)
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Website and Service when you choose to do so
  • To provide customer support
  • To facilitate payment processing
  • To gather analysis or valuable information so that we can improve our Website and Service
  • To monitor the usage of our Website
  • To detect, prevent and address technical issues
  • To enforce our Terms of Use and other legal terms and policies
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
  • To comply with applicable legal requirements, such as government regulations and industry standards, contracts, and law enforcement requests

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

Where applicable laws permit us to, we rely on your consent as a ground to process your Personal Data. If you are based in the European Economic Area (EEA) (or where applicable law does not permit us to rely on your consent to process Personal Data), we rely on the following legal bases for processing your Personal Data:

  • Legitimate interest, which means our interest in conducting and managing our business to enable us to provide you with the best services, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of a contract, which means we process your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • To comply with a legal obligation, which means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

If you are based in the EEA, we generally do not rely on consent as a legal basis for processing your Personal Data, although we will get your consent before sending third party direct marketing communications to you through email or text messages. You have the right to withdraw consent to marketing at any time by contacting us.

We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Retention of Data

Mitsogo Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

In some circumstances, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Cross Border Transfer of Personal Data

The Personal Data that we process may be transferred to countries other than where you are based. For example, we may transfer your Personal Data to India, USA, and the EU, where some of our processors are located. Where applicable law permits such transfer, we rely on consent to transfer such data. If you are based in the EU, we rely on standard data protection clauses that are approved by the European Commission for the transfer of Personal Data outside the European Economic Area as the European Commission has not published adequacy decisions with respect to these recipient countries.

You can find out more information about these transfer mechanisms by contacting us by email at privacy@hexnode.com.

Disclosure of Data

We may share your Personal Data with the parties set out below for the purposes set out in this Privacy Policy.

  • Internal third parties, which are the other companies in the Mitsogo group.
  • External third parties, such as:
    • service providers who provide IT and system administration, analytics, behavioural remarketing and payment processing services.
    • professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
    • regulators and other authorities.

We may also disclose your Personal Data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the manner set out in this Privacy Policy.

Under certain circumstances, Mitsogo Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Security of Data

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, 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 only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Mitsogo Inc. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. . You have the right to object to our processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Mitsogo Inc. relied on your consent to process your personal information

Please note that we may ask you to verify your identity before responding to such requests.

If you wish to exercise any of these rights, please contact us by email at privacy@hexnode.com. If requested to remove data, we will respond within a reasonable timeframe.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you are based in the European Economic Area (EEA), you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please visit http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. to contact your local data protection authority in the EEA.

Representation for Data Subjects in the EU and the UK

We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase Personal Data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/11236276819.

CCPA

The California Consumer Protection Act (CCPA) reserves the right for consumers to request the disclosure of collection and usage of their personal information. It also reserves the right to opt-out from any kind of sale of personal information by the business.

We does not sell personal information. We follow the standards mentioned in this Privacy Policy while handling personal information of any kind. We define all the data we collects under Types of Data Collected section and the usage of said data under Use of Data. You can also read about how third parties make use of cookies from our Cookie Policy.

To request disclosure of any information as described by CCPA, you can mail to us at privacy@hexnode.com.

Links to Other Sites

Our Website may contain links to other sites or services that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Our use and transfer to Services of information received from Google APIs will adhere to Google API Services User Data Policy, including the limited use requirements as defined therein.

Changes to This Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time. When we make only minor modifications, we may do so without notifying you. If we make changes to this Privacy Policy that we believe materially impact the privacy of your Personal Data, we may notify you. We encourage you to periodically review this page for the latest information on our privacy practices. The “Last Modified” date at the top of this Privacy Policy will allow you to quickly know when the last changes were made.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@hexnode.com or by contacting our data protection officer:

Name: Rachana Vijayan

Contact: legal@hexnode.com