Santok Ltd (“Santok,” “we,” “us,” “our”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.wileyfox.com and/or using the Services you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the “Act”) the data controller is Santok Limited of Santok House Unit L, Braintree Ind. Estate, Braintree Road, South Ruislip, Middlesex, HA4 0EJ.
2. Information We Collect From You
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site www.wileyfox.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, [search for a product], [place an order on our site], [participate in discussion boards or other social media functions on our site], [enter a competition, promotion or survey], [OTHER ACTIVITIES COMMONLY CARRIED OUT ON THE SITE] and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, [OTHER INFORMATION].
- Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
- Technical information, including [the Internet protocol (IP) address used to connect your computer to the Internet,] [your login information,] [browser type and version,] [time zone setting,] [browser plug-in types and versions,] [operating system and platform,] [OTHER];
- Information about your visit, including [the full Uniform Resource Locators (URL),] [clickstream to, through and from our site (including date and time),] [products you viewed or searched for'] [page response times,] [download errors,] [length of visits to certain pages,] [page interaction information (such as scrolling, clicks, and mouse-overs),] [methods used to browse away from the page,] [OTHER] and any phone number used to call our customer service number.
- Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. [In this case, we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data]. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We also may collect other information about you, your device, or your use of the services in ways that we describe to you at the point of collection or otherwise with your consent. You can choose not to provide us with certain types of information (e.g., information we request during Santok Account registration), but doing so may affect your ability to use some Services.
When appropriate, we may also provide just-in-time notices prior to collection of certain data to register you or your device for a service. This is where relevant privacy information appears at the point in time where personal data are collected.
3. How do we use your information?
We use information held about you in the following ways:
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Provide customised content and make recommendations: We may use information we collect to provide you with customised content and make recommendations that are based in part on your past activities on our Services. For example, from time to time Santok can provide you with recommendations about video, music, applications and third-party content that we think will interest you. Your Wileyfox Device provides recommendations about video content you might like. Please visit the settings menu on your device or service for information about privacy choices you may have available to you in connection with these services.
Improve them and develop new products and services: We may use information we collect to understand the way you use the products and services we offer so that we can improve them and develop new products and services. For example, we may use this information to make better-informed decisions about the design of our devices and the selection of Santok and third-party content that is accessible through our devices and services.
4. To whom do we disclose your information?
We will not disclose your information to third parties for their own independent marketing or business purposes without your consent. However, you agree that we have the right to share your personal information with:
Any member of our group, which means our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006
Business Partners. We also may share your information with trusted business partners, including wireless carriers. These entities may use your information to provide you with services you request (e.g., video content provided by Netflix through wileyfox Device), make predictions about your interests and may provide you promotional materials, advertisements and other materials.
[Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others]
Service providers. We also may disclose your information to companies that provide services for or on behalf of us, such as companies that help us with billing or that send emails on our behalf. These entities are limited in their ability to use your information for purposes other than providing services for us.
If Santok Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
5. Your Choices
We offer a variety of choices about how we use your information. You can make choices about whether to receive promotional communications from us by following the unsubscribe instructions included in the communication. In addition, you can also generally make choices in your settings, or by visiting relevant webpages as listed below;
- with respect to targeted advertising that may interest you, for example by AdMob; and
And you may be able to make choices in specific Services or when we give you a just-in-time notice.
6. Keeping your Information Secure?
We have put in place reasonable physical and technical measures to safeguard the information we collect in connection with the Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure. Any transmission of your personal data to our website is at your own risk.
7. Your Rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org or Santok House, Unit L Braintree Industrial Estate, Braintree Road, Ruislip HA4 0EJ.
8. Access to Information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
10. Third-Party Links and Products on Our Services
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Further, some third-party advertisers may use web beacons in their ads in order to collect information about users who view their ads, including through cookies, beacons and similar technologies. Santok does not control the data collection and use practices of these companies.
We also may make available to you certain products or services (e.g. apps available through Santok Apps)
Some of the content, advertising, and functionality on our Services may be provided by third parties that are not affiliated with us. For example:
- We enable you to watch video content provided by companies such as Netflix through Wileyfox Device;
- Third parties develop apps that we make available through the Santok App Store;
- Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them; and
- We enable you to share certain materials on the Services with others through social networking services such as Facebook, Twitter, Google +, and LinkedIn;
If you connect with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information that you allow us to receive when you connect with these services.
Also, please note that if you choose to connect with a social networking service on a device used by people in addition to you, those other users may be able to see information stored or displayed in connection with your account on the social networking service(s) with which you connect.
11. Voice Recognition
You can control your smartphone, and use many of its features, with voice commands.
If you enable Voice Recognition, you can interact with your connected smart devices using your voice. To provide you the Voice Recognition feature, some interactive voice commands may be transmitted (along with information about your device, including device identifiers) to a third-party service provider (currently, Google, Inc.) that converts your interactive voice commands to text and to the extent necessary to provide the Voice Recognition features to you. In addition, Santok may collect and your device may capture voice commands and associated texts so that we can provide you with Voice Recognition features and evaluate and improve the features.
If you do not enable Voice Recognition, you will not be able to use interactive voice recognition features, although you may be able to control your TV using certain predefined voice commands.
You may disable Voice Recognition data collection at any time by visiting the “settings” menu. However, this may prevent you from using some of the Voice Recognition features.
12. Gesture Controls and Facial Recognition
Your Wileyfox Device is equipped with a camera that enables certain advanced features, including the ability to control and interact with your TV with gestures and to use facial recognition technology to authenticate your Wileyfox Account via any digital channel. The camera can be covered and disabled at any time, but be aware that these advanced services will not be available if the camera is disabled.
Gesture Control. To provide you with the ability to control your Wileyfox Device through gestures, the camera mounted on the top of your Wileyfox Device can recognize your movements. This enables you, for example, to move between panels and zoom in or zoom out. We record information about when and how users use gesture controls so that we can evaluate the performance of these controls and improve them.
Facial Recognition. The camera situated on the Wileyfox Device also enables you to authenticate your Wileyfox Account or to log into certain services using facial recognition technology. You can use facial recognition instead of, or as a supplementary security measure in addition to, manually inputting your password. Once you complete the steps required to set up facial recognition, an image of your face is stored locally on your TV; it is not transmitted to Santok. If you cancel your Wileyfox Account or no longer desire to use facial recognition, please visit the applicable settings menu to delete the stored image. While your image will be stored locally, Santok may take note of the fact that you have set up the feature and collect information about when and how the feature is used so that we can evaluate the performance of this feature and improve it.
We do not knowingly collect any personal information from children under the age of thirteen (13) without parental consent, unless permitted by law. If we learn that a child under the age of thirteen (13) has provided us with personal information without parental consent, we will delete it in accordance with applicable law.
Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices, and/or browsing sessions. Cookies serve many useful purposes. For example:
- Cookies can remember your sign-in credentials so you don’t have to enter those credentials each time you log on to a service.
- Cookies help us and third parties understand which parts of our Services are the most popular because they help us to see which pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are better able to adapt the Services and provide you with a better experience.
- Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a Service.
- Cookies help us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites and apps.
- When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies.
Please note, however, that some Services may be designed to work using cookies and that disabling cookies may affect your ability to use those Services, or certain parts of them.
16.Other Local Storage
We, along with certain third parties, may use other kinds of local storage technologies, such as HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings.
We, along with certain third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and certain third parties use beacons for a variety of purposes, including to analyse the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.
By accessing and using our Services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us and by the third parties mentioned above.
17. Do Not Track Signals and Similar Mechanisms
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates, although web browsers incorporate and activate this functionality in different ways, and it is not always clear whether users intend for these signals to be transmitted. There currently is disagreement, including among participants in the leading Internet standards-setting organisation, concerning what, if anything, websites should do when they receive such signals. Santok currently does not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.
18. Country-Specific Features
Please note that one or more of the features described in this Wileyfox Device Supplement may not be available to you depending on where you live.
19. How to Contact Us
Address: Santok House, Unit L Braintree Industrial Estate, Braintree Rd, Ruislip HA4 0EJ
Phone: 020 8839 8888