Actuate Privacy Policy

Actuate Privacy Policy

Aegis Systems, Inc. d/b/a Actuate (“Actuate” or “we” or “our”) recognizes that your privacy is important. Actuate does not rent, sell or trade your personal information and data to anyone. This Privacy Policy describes the information we collect, how we collect it, and how we use and share it in connection with Actuate’s website (“Website”), software (“Software”), service offerings (“Services”), and your Authorized Cameras and mobile devices (collectively “Devices”). This Privacy Policy also describes Actuate’s information processing activities on behalf of third parties and your choices regarding use, access, and correction of your personal information.

1. Who We Are

Actuate is an artificial intelligence-based intruder detection software company. Actuate effectively monitors spaces for people and weapons and sends a real-time alert with video of the person with a weapon to your mobile device or Video Management System (“VMS”). Actuate effectively protects facilities by detecting people and weapons using your existing security cameras, eliminating the need for new hardware.

2. How Our Software Works

Actuate is a software-only solution that uses existing security cameras. Actuate uses existing Information Technology (IT) assets. This means that no Actuate code is installed in the customer network. Instead, the Actuate platform integrates with the existing VMS software and uses the VMS’s Application Programming Interface (APIs) or Software Development Kit (SDK) to pull video and send alerts to customers. Alternatively, Actuate integrates directly with selected cameras, as needed and on a case by case basis.

All communication occurs through already implemented and already approved software channels. Actuate communicates with the VMS using the highest level of security supported by each platform, including provider-specific and customer-specific authentication as well as encrypted Virtual Private Networks (VPN) when selected by a customer.

In all cases, Actuate uses unique authentication for each customer. The Actuate platform stores no video or images unless a weapon and a person is detected. All other video received by the system is deleted immediately after being analyzed. When a threat is identified, images are stored only to support sending high-quality alerts.

Actuate does not perform facial recognition or any other type of analysis of humans present in a video feed. Actuate only looks for physical threats such as weapons.

Actuate uses Amazon Web Services (AWS) and Microsoft Azure to host its AI engine. AWS and Azure are trusted by global organizations in the industry and they market best in-class cybersecurity processes and teams.

 

NOTE: PRIVACY LAWS IN YOUR STATE MAY IMPOSE CERTAIN OBLIGATIONS ON YOU AND YOUR USE OF SECURITY CAMERA OR OTHER CAMERA-ENABLED PRODUCTS. YOU (NOT ACTUATE) ARE SOLELY RESPONSIBLE FOR ENSURING THAT YOU COMPLY WITH ANY APPLICABLE LAWS WHEN YOU USE SUCH CAMERA-ENABLED PRODUCTS. FOR EXAMPLE, YOU MAY BE REQUIRED TO DISPLAY A NOTICE THAT ALERTS VISITORS THAT YOU ARE USING A SECURITY CAMERA OR OTHER CAMERA-ENABLED PRODUCTS THAT ARE RECORDING AUDIO AND VIDEO. PLEASE ALSO CONSIDER THAT RECORDING AND SHARING OF VIDEO THAT INVOLVES OTHER PEOPLE MAY AFFECT THEIR PRIVACY RIGHTS.

 

3. Information AI Collects

In General: When you use our Website(s), Software, Service(s), and your Device(s) you may be asked to provide personal information such as:

• Name and/or business name;
• Home address and/or business address;
• Home, business, and/or mobile telephone number;
• Email address;
• Credit, debit, or other payment account number and related information;
• Date of birth or other identifying personal characteristics;
• Social Security Number;
• Emergency contact list information about others; and
• Personal identification code.

Software Specific: Our Software or Service(s) may collect additional information such as:

• Audio, video, and still-image recordings from your Authorized Cameras;
• Geolocation and GPS information including physical location of your Authorized Cameras and mobile devices by using satellite, cell phone tower, or Wi-Fi signals;
• Motion detection, accelerometer activity, and climate conditions surrounding your Authorized Cameras;
• Monitoring event information on your Authorized Cameras; and
• IP addresses, internet service provider (ISP), date/time stamp, and/or other event data which is automatically collected and stored in log files.

Personal data not actively collected or processed:

• Actuate does not actively collect or otherwise process special categories of data including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.
• Actuate does not actively collect and process personal data relating to already registered criminal convictions and offenses.

4. How Actuate Collects Information

Your personal and non-personal information is collected in various ways in connection with our Website(s), Software, Services, and your Devices.

In many cases you give information directly to us. For example, you may be required to provide us personal information when:

• Registering for the Services or an account with us;
• Activating our Software on your Devices;
• Signing up for special offers from Actuate and selected third parties;
• Submitting a paper form or transmitting information to us online or via telephone;
• Submitting your credit card or other payment information;
• Receiving our Services including talking with sales representatives, service technicians, and customer service and monitoring centers (some of which may be recorded to ensure Services quality and to maintain an accurate record of our communications with you); and
• Visiting and interacting with our Website(s).

We may also collect your information using cookies or similar technologies to analyze trends, administer our Websites, track users’ movements around our Websites, and to gather demographic information about our users as a whole, for example:

• Mobile Application: We may collect information such as registration and activation information from our mobile application(s) associated with our Services and your Devices.
• Device Data: We may collect various types of data and event information from your Authorized Cameras by using its image sensory features that it may contain.
• Cookies: We may receive and store certain information about your browsing preferences by using Actuate and third-party cookies. Cookies are small text files placed on your computer to customize your experience.
• Web Beacons: We may collect information about your browsing activities by using web beacons. Web beacons are transparent graphic pixels that are placed on web pages that enable us or a third party to track your actions on our website(s) and deliver interest-based advertisements.
• Local Stored Objects: We may store information about your browsing activities through locally stored objects by using technologies such as “Flash cookies” and HTML5 (“LSOs”). LSOs tack your actions and store information about your preferences and can be used by third party partners to deliver interest-based advertisements.
• Social Media Features: Our website(s) include social media features that may collect your IP address of the page you are visiting and may set a cookie to enable the feature to function properly. These features are either hosted by a third party or hosted directly by us.
• Log Files: We gather certain information automatically and store it in log files. This information may include IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data.
• Software: When you use our Software and use our Services, we may automatically collect information on the type of Authorized Cameras, VMS, and mobile device you use, operating system version, and the unique device identifier (UDID). We collect your location-based information as part our Services to identify your location for dispatching or sharing with emergency service providers. We will only share this information with third party services for the sole purpose of providing you our Services.

5. How Actuate Uses Your Information

We may use the personal and non-personal information you provide us for our business purposes, including:

• Setting up your Services including establishing your Actuate account and business profile;
• Providing your Services including sending alert notifications about security events;
• Processing payments for your Services;
• Contacting you regarding your Services and responding to your inquiries and comments;
• Enhancing, improving, or modifying our Website and Services;
• Developing new Software and Services;
• Conducting data analysis, including fraud monitoring and prevention;
• Providing marketing and promotional materials;
• Customer retention, feedback, and reactivation programs;
• Engaging in lead generation activities; and,
• If you submit any information to us relating to another person, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. We will only use that information for the specific reason for which it was provided to us.

6. How Actuate Shares Your Information

Actuate may share your information in the following ways:

• Third Party Providers: We do not sell your information to third parties for their own marketing purposes. We may share your information with partners and service providers to provide some of our Services and to complete our business purposes as described above. Before we share personal information, we enter into written agreements with the business partners which contain data protection terms that safeguard your data. These companies may use your personal information only as necessary to provide these services to us, except as otherwise authorized by you for another purpose. We will also enable you to revoke any such authorization in a manner equivalent to that by which you provided it or by otherwise contacting us as provided below, if you no longer want us to share your personal information for such purpose.
• Emergency Services: To provide our Services, we will share your information with persons designated in your contact list and third-party service providers including, but not limited to alarm monitoring service providers, police departments, fire departments, and emergency medical services, only if you authorize us to do so in writing.
• Legal Authorities: We may also disclose your information for legal reasons including to comply with a subpoena or court order or similar legal process, to cooperate with law enforcement, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• Transfer in the Event of Sale or Change of Control: We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.
• Cross-Border Transfer: We may transfer, store, and/or access your information electronically or in hard copy in the United States or Canada. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. Such information is subject to the laws of the country in which it is transferred, stored, or accessed.

7. How Actuate Obtains Consent

Each time you provide any personal information to us through our Website, Software, Services, or your Device(s), you consent to the collection, use, and disclosure/sharing such information according to this Privacy Policy. Where required, consent for the collection, use, and disclosure/sharing of your information may be obtained either expressly or implied. Your express consent may be given in writing, verbally or electronically. Your implied consent may be given through an action you have taken, such as supplying your personal information for a specified purpose. If you do not notify us, we will consider you to have consented to our continued use and disclosure/sharing of your personal information. Revoking consent to collection, use and/or disclose/share your information for certain purposes may affect our ability to provide you with Services. You may contact us using the information below.

8. How Actuate Protects Your Information

Actuate limits access to your personal information and seeks to use reasonable organizational, technical and administrative measures to protect your information from loss, misuse and unauthorized access, alteration, disclosure or destruction in accordance with applicable law. Unfortunately, no information transmission or storage system can be guaranteed to be one hundred percent (100%) secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately using the information below.

Actuate bears no responsibility for impairment incurred due to unpredictable factors or factors unrelated to management of Actuate; damages caused by interruption, outage, data loss, or unauthorized access caused by such impairment; and damages related to the users of Actuate’s Services.

9. How Actuate Stores Your Information

We may store your personal data in data centers in the United States, cloud storage solutions, or on our premises, including our corporate office. In order to ensure the adequacy of protection of data that we transfer to our third-party services providers we have reviewed the data protection certifications and commitments of these providers, and where applicable, concluded data sharing and processing agreements. You may be entitled to review our data sharing and processing agreements if you contact us per the contact details provided at the end of this Privacy Policy.

10. Interruption of Website

From time to time, Actuate may carry out system maintenance on its Website with or without prior warning. We will do our best to keep these maintenance windows to a minimum but Actuate cannot be responsible for any damages caused to you in relation to this maintenance or Website outages.

11. How to Update and Access Your Information

You have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. You are responsible for ensuring the information you provide when using our Website, registering for our Services, using our Software, and registering/activating your Devices is accurate. To access, review or update your information for accuracy contact us using the information below. Upon request we will provide you with information about whether we hold any of your personal information. We will respond to your request within a reasonable timeframe.

12. How Actuate Retains Your Information

We will retain your personal information for as long as your account is active or for the period necessary to fulfill the purposes outlined in this Privacy Policy and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

13. California Privacy Rights

Actuate collects various types of personal information about you as described in this policy. Under California law, Actuate customers who are residents of California may request certain information about Actuate’s privacy practices including the personal information Actuate has collected, where it was sourced from, what it is being used for, whether it is being disclosed to third parties for business purposes, sold to third parties, and to whom it is being disclosed or sold in the previous twelve (12) months. To learn more about your California privacy rights, please review our supplemental California Privacy Notice at the end of this Privacy Policy.

14. How Actuate Notifies You of Privacy Policy Changes

We may update this Privacy Policy to reflect changes to our information practices. If we make material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. Your continued use of this Website or use of Comfort Eats’ services constitutes consent to all such changes.

15. How to Contact Actuate

Actuate is here to help you and answer any questions you have. You can contact us about this Privacy Policy by writing or emailing us at the address below:

Attn: Ben Ziomek
Aegis Systems Inc d/b/a Actuate
10 Grand Central
155 E 44th St. 6th Floor
New York, New York 10017

info@actuate.ai

16. Effective Date

This Privacy Policy is effective as of April 8th, 2020.

 

CALIFORNIA RESIDENTS

If you are a resident of California, this California Privacy Notice applies to you and supplements Actuate’s main Privacy Policy. This California Privacy Notice is intended to provide certain additional information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”).

“Personal Information” as used in this California Privacy Notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Personal Information does not include publicly-available information and certain other information that is regulated by other applicable laws.

We do not sell or monetize our users’ Personal Information in the traditional sense (i.e., get paid to share your Personal Information). However, the CCPA defines the term “sale” very broadly, and it likely includes the sharing of Personal Information with third parties.

1. Your Rights

• Right to Know

You have the right to request that we provide certain information to you about our collection of your Personal Information. Such information shall cover the twelve (12) month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of Personal Information we have collected about you;
• The categories of sources from which we have collected your Personal Information;
• Our business or commercial purpose(s) for collecting or selling your Personal Information
• The categories of third parties with whom we have shared your Personal Information; and
• The specific pieces of Personal Information we have collected about you.

You have the right to request that we provide certain information to you about our disclosures and sales of your Personal Information. Such information shall cover the twelve (12) month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following: 

• The categories of Personal Information we have collected from you;
• The categories of Personal Information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold; and
• The categories of Personal Information that we disclosed about you for a business

You may only make a verifiable “Right to Know” request twice within a twelve (12) month period. 

• Right to Opt-Out

We never monetize your Personal Information, however, we may share it with certain strategic partners, social media partners, advertising partners and networks, and other third parties that provide offers we think may be of value to you as discussed below, which could be considered a “sale” under the CCPA. You have the right at any time to opt-out of this sharing and the potential sale of your Personal Information by emailing info@actuate.ai.

• Right to Delete

You have the right at any time to request that we delete your Personal Information. However, in some cases we cannot delete all or some of your Personal Information as required or permitted by applicable laws.

• Right to Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA, such as by denying your Software and Services, charging you different rates or prices, including use of discounts or penalties, or suggesting or providing a different level of Services or quality of Software to you. However, we may charge a different price or provide a different level or quality of Software and Services if the price or difference is directly related to the value provided to you by your Personal Information.

We may from time to time offer you financial incentives, including payments to you as compensation, for collecting, selling, or deleting your Personal Information. We also may offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided to you by your Personal Information.

• Contact

To submit a request to exercise your “Right to Know” or “Right to Delete” rights provided in this California privacy notice, please email info@actuate.ai to submit your request. We will evaluate the request and take action where required to do so. If you have an Actuate account, we may direct you to your account in order to fulfill your request where applicable.

Depending on the nature of your request, we may have to verify your identity when you contact us. We may do this by asking you to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. 

We endeavor to respond to your request as soon as we can.  If we are not able to respond to your request within forty-five (45) days, we will let you know that we may require additional time (up to ninety (90) total days).

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provide written proof to us that he or she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please email us at info@actuate.ai.

2. Information We Collect

• If You are a Visitor to Our Website or Interact With Us:

We have collected the following categories of Personal Information from consumers in the last twelve (12) months:

• Identifiers(such as your name, address, email address, telephone number, unique device identifiers for mobile devices or tablets, visitor identification number, and IP address);
• Commercial information(such as Software and Services you considered, or other purchasing or consuming information);
• Internet or other electronic network activity(such as information about your interaction with our site, your browser type, computer or device type, visitor identification number, operating system version, the website you navigated from to reach out site, timestamp information about your visit to our site, the pages on our site that you view, and the name of your internet service provider);
• Geo location data(such as your approximate location based on IP address); and
• Inferences(such as creating a profile about your preferences based on your interaction with us and our website)

Our sources for this information:

• We receive this information directly from you when you provide it to us, participate in our contests, surveys, promotions, or other activities, and when you communicate with us.
• Some of this information is collected automatically when you visit our Website.
• We receive some of this information from our advertising network partners.

Our business purposes for collecting this information:

• To operate and improve our business, Software and Services, Website, and Devices.

Third parties we disclose this information to:

• Certain third parties help us to host our Website, send email updates about the Website, provide marketing and advertising services for us, and remove repetitive information from our user lists.
• Any other person or entity we reasonably think is customary, necessary or advisable for the business purposes disclosed in our Privacy Policy or to whom we are obliged by applicable law or regulation to make the disclosure.

If You Are an Actuate Customer:

In addition to the information above, if you have purchased Actuate Software or Services in the last twelve (12) months, we have collected the following categories of Personal Information: 

• Identifiers(such as your login credentials);
• Commercial information(such as your purchase history and information about your Software usage);
• Protected classification characteristics(if you respond to our optional customer surveys, we may ask about information such as your ethnicity);
• Financial Information(such as your payment information when you make a purchase);
• Internet or other electronic network activity(such as information about your and your Devices’ interaction with our network, your interaction with our Website, your visitor identification number, and your Software usage);
• Audio, visual, and similar information(from Authorized Cameras); and
• Inferences(such as a profile based on information reflecting your activity and preferences). 

Our sources for this information:

• We receive this information directly from you when you purchase, setup and use our Software and Services, and when you communicate with us.
• We sometimes combine information that you voluntarily provide to us with information that we automatically collect when you visit our Website or interact with our Software and Services.

Our business purposes for collecting this information:

• To deliver our Software and Services to you;
• To send you alarm alert notifications and important service information about our Services;
• To communicate with you about our Software and Services;
• To send you updates about new Software and to suggest Software and services to you that we think you may be interested in;
• To provide monitoring services to you;
• To detect, prevent or otherwise address fraud, security or technical issues; and
• To operate and improve our business, Software and Services, Website, and Devices.

Third parties we may disclose this information to:

• Third Party Providers: We do not sell your information to third parties for their own marketing purposes. We may share your information with partners and service providers to provide some of our Services and to complete our business purposes as described above. Before we share Personal Information, we enter into written agreements with the business partners which contain data protection terms that safeguard your data. These companies may use your Personal Information only as necessary to provide these services to us, except as otherwise authorized by you for another purpose. We will also enable you to revoke any such authorization in a manner equivalent to that by which you provided it or by otherwise contacting us as provided below, if you no longer want us to share your Personal Information for such purpose.
• Emergency Services: To provide our Services, we will share your information with persons designated in your contact list and third-party service providers including, but not limited to alarm monitoring service providers, police departments, fire departments, and emergency medical services, only if you authorize us to do so in writing.
• Legal Authorities: We may also disclose your information for legal reasons including to comply with a subpoena or court order or similar legal process, to cooperate with law enforcement, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• Transfer in the Event of Sale or Change of Control: We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.
• Cross-Border Transfer: We may transfer, store, and/or access your information electronically or in hard copy in the United States or Canada. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once it is received. Such information is subject to the laws of the country in which it is transferred, stored, or accessed.