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1. Introduction and Scope

This Privacy Notice applies to the use of the website rmm.keenetic.com ("Website").

2. Data Controller

The responsible data controller for any personal data collected and processed in connection with the use of the Keenetic RMM Website is Keenetic Pte Ltd, a company duly incorporated under the laws of Singapore, with its principal address at 128 Tanjong Pagar Road, 088535 Singapore (hereafter "Keenetic", "we", "us", or "our").

3. Contact Details

If you have any questions etc. about or in connection with this Privacy Notice or would like to complain about our handling of your personal data or exercise any of your rights (see Section 9 below), please contact us by using one of the following contact details:

Keenetic Pte Ltd, 128 Tanjong Pagar Road, 088535 Singapore; rmmsupport@keenetic.com .

4. Data Subjects

This Privacy Notice applies to the collection and processing of personal data of users of the Website.

5. Categories of Data, Purposes of the Processing and Legal Basis

5.1. The Appendix Personal Data and Cookies contains detailed information on: 

• the categories of personal data we collect from you or from third parties (e.g., public authorities or public resources) in addition to other personal data that you actively provide to us (e.g., when you send an email to us);
• the purposes for which we process these personal data; and
• the legal bases for the collection and processing of your personal data (unless otherwise provided, e.g., at the time we collect the data from you) we collect and process your personal data.

5.2. Please note that we process your personal data for other purposes only if we are obligated to do so on the basis of legal requirements (e.g., transfer to courts or criminal prosecution authorities), if you have consented to the respective processing or if the processing is otherwise lawful under applicable law. If processing for another purpose takes place we will provide you with additional information.

5.3. You may choose not to provide certain types of personal data to us, unless the provision of personal data is required for the performance of a contract you conclude with us (e.g., to provide you with products and services you ordered). If you choose not to provide certain types of personal data, our ability to provide you with, and your ability to make use of, the Website or their features and services may be affected. 

6. Recipients and Categories of Recipients

Any access to your personal data at Keenetic is restricted to those individuals that have a need to know in order to fulfill their job responsibilities.

Keenetic will transfer your personal data for the respective purposes to the recipients and categories of recipients listed below:

6.1. Within the Keenetic group: We share your personal data with other Keenetic group companies as to provide you with information you have requested via the Website for the legitimate interests of Keenetic.

6.2. Service Providers (within and outside the Keenetic group): We use service providers to provide services and products on our behalf and will share your personal data with them as necessary for the provision of the services and products. Our service providers are contractually obligated to process such data on behalf of Keenetic under appropriate instructions as necessary for the respective processing purposes and to appropriately protect your personal data. Our service providers may not otherwise process or share your personal data, except as permitted by law. We use service providers to communicate news and deliver promotional and transactional materials to you, including personalized online and mobile advertising. 

6.3. Governmental authorities, courts, external advisors, and similar third parties that are public bodies as required or permitted by applicable law, in order to: (i) ensure compliance with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Keenetic, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.

7. Cross-Border Data Transfer

7.1. We transfer your personal data outside the country you are located. Some recipients of your personal data are located in another country, namely: Hong Kong, or some of the locations of non-European Keenetic group companies.

7.2. Some recipients are certified under the EU-U.S. Privacy Shield. In each case, the transfer is thereby recognized as providing an adequate level of data protection.

7.3. By way of entering into appropriate data transfer agreements or other adequate means,  we have established that all other recipients will provide an adequate level of data protection for the personal data and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.

8. Retention Period

8.1. Your personal data is stored by Keenetic and/or our service providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws. When Keenetic no longer needs to process your personal data, we will erase it from our systems and/or records and/or take steps to properly anonymize it so that you can no longer be identified from it unless we need to keep your information to comply with legal or regulatory obligations to which Keenetic is subject. 

8.2. We will retain your contact details and interests in our products or services for a longer period of time if Keenetic is allowed to send you marketing materials. Also, we typically erase contracts, communications, and business letters containing personal data, or we redact personal data from such documents, 10 years after their termination or creation, as such data may be subject to statutory retention requirements, which often require retention of up to 10 years. In addition, if a judicial or disciplinary action is initiated, the personal data will be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.

9. Your Rights

9.1. If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Under the conditions set out under applicable law, you have the following rights:

9.2. Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed.

You have the right to obtain a copy of the personal data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.

9.3. Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

9.4. Right to erasure (right to be forgotten): You have the right to ask us to erase your personal data.

9.5. Right to restriction of processing: You have the right to request the restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

9.6. Right to data portability: You have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those personal data to another entity without hindrance from us.

9.7. Right to object:

Please note that the aforementioned rights might be limited under the applicable national data protection law. Keenetic remains the universal point of contact for your execution of these rights.

Please refer any of your questions to rmmsupport@keenetic.com.

In case of complaints, you also have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence or alleged infringement of the applicable law.

10. Cookies and similar technologies

10.1. Cookies. When you use the Website, we send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits of our website. Your web browser may provide you with some options regarding cookies. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize the features of the services provided via the Website to their fullest potential. We use third party cookies in connection with the services provided via the Website as well. For instance, we use Google Analytics to collect and process certain analytics data. We do not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who visit our website or use the services provided via our website. 

10.2. How we use cookies and similar technologies, in particular, for profiling. We use cookies and automatically collected information to: (i) personalize our Website and the services provided via our Website, such as remembering your information so that you will not have to re-enter it during your use of, or the next time you use, our Website and the services provided via our Website; (ii) provide customized advertisements, content, and information on the basis of profiling; (iii) monitor and analyze the effectiveness of our Website and the services provided via our Website and third-party marketing activities on the basis of profiling; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities offered through our Website and the services provided via our Website (profiling). Tracking technology (profiling) also helps us manage and improve the usability of our Website, (i) detecting whether there has been any contact between your computer and us in the past and (ii) to identify the most popular sections of our Website.

10.3. For detailed information regarding cookies and related data processing activities please refer to the Appendix Personal Data and Cookies.

11. Changes to this Website Privacy Notice

This privacy notice may require an update from time to time – e.g. due to the implementation of new technologies or the introduction of new services or features. We reserve the right to change or supplement this Website Privacy Notice at any time. We will publish the changes and/or inform you accordingly (e.g., via email).

12. Applicable Law and Jurisdiction

These Website Privacy Notice is governed and construed in accordance with the laws of Singapore. As a website user, you agree to submit to the exclusive jurisdiction of the Courts in Singapore with respect to any legal proceedings that may arise in connection with the website or any of our Products and/or Services, or from a dispute as to the interpretation or breach of this  Website Privacy Notice.

13. Appendix

Personal Data and Cookies

We process the following personal data in connection with your use of the Website as detailed in the following:

We use the following cookies:

*For data processing activities based on legitimate interests: Further information on the balancing test performed are available upon request to rmmsupport@keenetic.com.