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Starview Asia companies are joint controllers of your data. Please find the details of each company belonging to Starview Asia and their contact details in our website at https://starviewint.asia/contact/.

2.1. Information we collect automatically through Teltonika websites, services, applications or our emails

When you visit our website such as https://teltonika-iot-group.com/, interact with our emails, use our service or use our mobile applications we use cookies to collect certain information automatically from your browser or device through the use of cookies and pixels from tools such as Google Analytics and Google Ads. Our use of cookies is discussed in more detail in our cookies policy which is available here. More details about automatically collected analytics data read in 3.1. Analytics

The information we collect automatically includes:

• persistent identifiers (IP addresses, browser type, Internet Service Provider (ISP), referrer URL, exit pages, operating system, date/time stamp);
• usage data (information how you interact with our web page);
• diagnostic data (mouse movement, searches, visited web pages)
• approximate location (e.g., nearest city or town);
• log data (our web servers keep log file that record data each time a device access them).

We use this information for conducting analytical and profiling activities, which include improving the efficiency of our internal processes and procedures and overall quality of the products and services that we provide, and creating customer profiles to prepare relevant products and services.

Legal basis for collecting this information is our legitimate interest to improve products, services or offerings to give our clients, site visitors could get best possible experience.

Additionally, we partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay, enabling us to enhance and market our products and services. The legal basis for collecting data through Microsoft Clarity is user consent. Website usage data is captured using first- and third-party cookies and other tracking technologies to assess the popularity of products/services and online activity. This data is also used for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, please refer to the Microsoft Privacy Statement.

2.2. Direct marketing

We use your email which you provide when subscribing to our newsletter or when you send us an enquiry for the purpose of sending you our updates, offers and other marketing material. We may also ask you to complete a customer survey or send other messages related to our business.

Legal basis to use your email for this purpose is your consent, when you provide your email address by subscribing to our newsletter, or our legitimate interest to expand our business and inform our customers about news related to Teltonika, when you provide your email to us for using our services.

You may disagree with such use of your email at any time by clicking “unsubscribe” in the message you receive from us.

2.3. Remarketing

We use LinkedIn and Facebook tags on our websites. These tools allow us to analyse the interaction between our websites and these social networks. Personalised user data may be used for remarketing purposes on these platforms. The legal basis for the use of this data for remarketing purposes is your consent, which you express by accepting our website cookie consent, which is obtained when you either select “Allow All” or specifically opt to enable “Targeting Cookies” during the course of their interaction with the website.

2.4. Management of client relationships and related processing

Teltonika’s focus is the B2B market, but we must collect personal data of employees or representatives of our clients.

If you act in the capacity of an employee or a representative of our client (or a potential client) and communicate with us or otherwise have relations with us, we may process your contact and other details such as first name, last name, job title, organization, phone number, email address, payment identifiers, and any other personal information you provide to us in your communication (alone or in combination with other data we source) for various purposes relating to our business activities, such as:

• to enter into a sales or service contract with you or the organization for which you work;
• to communicate with you in relation to the contract we have entered into with you or with the organization for which you work;
• to bill and collect money owed to us by you (or the client you represent). This includes sending you emails, invoices, receipts and alerting you if we need to clarify information about payments;
• to follow up after correspondence (live chat, email or phone inquiries);
• to communicate with you about our products and provide customer support;
• to verify financial transactions and undertake compliance screening checks;
• to cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data;
• to protect personal property or ensure safety, and pursue remedies available to us and limiting our damages;
• to share content of your communication with our customer services representatives to ensure we deliver high-quality service, assist in the training and development of Teltonika representatives, and generally improve our customer service to you.

We may collect personal information about you (e.g., your position, specialty and publications) from publicly-available resources and combine it with personal data we have collected about you, to enhance our customer profile of you in support of our sales and marketing activities.

Depending on the specific actions we take during use of your personal data, processing of your personal data is based on one of the following legal bases, i.e.:

• when processing is necessary for the performance of a contract or in order to take steps at prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary for the purposes of the legitimate interests pursued by us or a third party. Most commonly, we process personal data to pursue legitimate interests of improving, maintaining, providing, and enhancing our technology, products, and services, and ensuring the security of the products and services, as well as supporting our marketing activities;
• when you give us your consent.

2.5. Provision of our services

When you use our services, the data controller of your personal data is generally your employer or other entity which is using our products and services. In these cases, we generally act as the data processor in accordance with the data processing agreement concluded as part of our agreement with the customer regarding provision of service.

However, there are certain limited types of personal data which we process in the capacity of a data controller. When you use our product service platforms, we may automatically collect or receive certain information about your device and usage of the service. We use cookies and other tracking technologies to collect some of this information. The personal data we collect may include:

• account log-in credentials (such as your email address, username and password);
• user experience data (user interaction with the system, such as your visited pages or mouse movements);
• device information (your IP address, your operating system, your browser ID, and other information about your system and connection);
• log data (our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the service (such as the date/time stamps associated with your usage, viewed pages and files, searches and other actions you take);
• movement data;
• other service-related data.

We use the aforementioned personal data in order to enable you to use our services and functionality of Teltonika products and systems. We may also use the personal data to conduct usage analysis, implement improvements, and make business decisions. The personal data may also be used to provide you with service support and ensure stability of our service.

The legal bases we rely on to process data for the above mentioned purposes are necessity to perform contract (when we seek to ensure availability and functionality of our services) and our legitimate interests to improve our services (when we conduct usage analysis).

2.6. Technical support

In order to provide technical support, we may collect and process certain personal data in accordance with the General Data Protection Regulation (GDPR). This data is collected solely for the purpose of assisting you and improving our support services.

• Teltonika Helpdesk platform. If you are a partner employee registered on our Helpdesk platform, we collect personal data such as your name, surname, and email address to create and manage your user account.

The use of our Helpdesk platform by business partners is governed by our Data Processing Agreement (DPA) https://teltonika-iot-group.com/policies-certificates/data-proccesing-agreement, which outlines the responsibilities and obligations of both parties regarding the processing of personal data. This agreement ensures compliance with the General Data Protection Regulation (GDPR) and defines the security measures in place to protect the data collected. By using our Helpdesk platform, our business partners acknowledge and agree to the terms set forth in the DPA, ensuring that all personal data is processed lawfully, transparently, and securely.

• Remote Assistance and Network Diagnostics. To facilitate troubleshooting and resolve network-related issues, we may require specific technical information, including remote access details, network diagnostics, and device configurations. Additionally, we may request details about your use case, the products in use, company operations, or other relevant data necessary to fully understand and resolve your inquiry. All data collected is handled securely and only used for the intended support purpose.
• Customer User Impersonation. In certain cases, our technical support team may need to impersonate a customer user account to diagnose and resolve technical issues effectively. This action will only be performed if the customer explicitly requests support and provides clear, documented consent. User impersonation is strictly limited to the scope necessary for troubleshooting and is conducted under secure access controls to protect customer data and privacy. All actions taken during impersonation are logged and monitored to ensure compliance with GDPR and security best practices.
• Community forum. You can receive technical support through our Community Forum, where users can discuss issues and share solutions. To create a new topic or participate in discussions, you must first register by providing your name and email address.

If our support engineers determine that additional assistance is needed and requires the disclosure of private information, you will receive a personal email with the invitation URL to provide more detailed information. This ensures that sensitive details are not shared publicly on the Community Forum. To facilitate this support process, we use a third-party service provider, HubSpot, which helps us securely manage communication and support requests. All data submitted through this form is stored on secure servers located within the European Union (EU).

•  Hot Line Support. You may contact our Hotline for technical assistance. During the call, our support team may ask you to provide personal information, e.g.: if your company is our Partner to verify your identity and process your request effectively. If we do not have a direct business relationship with you, we will only provide basic support and we will not collect or store any additional personal data.

For partner calls, relevant details may be shared through our internal communication systems to facilitate efficient management and tracking of inquiries. This ensures that each request is directed to the appropriate internal teams. Data may be shared among relevant departments within our company, such as Sales, Technical Support and any other teams involved in assisting with client inquiries.

We put our best efforts to keep your data safe and always require the high level of security and confidentiality from our employees, partners and service providers. We will only disclose your personal information to third parties in compliance with the law, including in the following circumstances:

3.1. Analytics

Teltonika uses third-party web analytics services on our website, such as Google Analytics. These analytics services may collect information about your activities on our sites to help us analyse how visitors use our website, improve usability and customer experience. Google Analytics may record clicks, mouse movements and scrolling activity, other activities that you voluntarily complete on our Sites. You can opt-out of Google Analytics by installing Google’s browser add-on.

We use LinkedIn and Facebook tags on our websites. These tools allow us to analyse the interaction between our websites and the most popular social networks.

We use Sentry and Firebase services on our applications. These platforms are used for infrastructure and crash log gathering to ensure continuous access.

We also use HubSpot and Hotjar services on some of our websites. This system allows us to analyse the actions you voluntarily take on our websites and to aggregate data from the different analytics and communication tools mentioned in this Privacy Policy on a single platform.

3.2. Email communication

We use MailerLite mailing system for our email marketing.

Your email address and other data will be stored on MailerLite’s servers in Germany, European Union.

With the assistance of the MailerLite cookies, we can analyse the performance of our newsletter campaigns. MailerLite will capture data about your interactions with our emails, such as which links you click within an email. It does by automatically placing single-pixel gifs, also known as web beacons, in every email. For more detailed information please read MailerLite privacy policy here: https://www.mailerlite.com/legal/privacy-policy

3.3. Subcontractors

Teltonika shares your personal data with other partners when services are provided by partners authorized by Teltonika. For example, before sending your order from Teltonika, we must share your information with our logistics provider to arrange shipment.

Your personal data may also in some cases be shared with various types of professional providing services to us, such as auditors, lawyers, financial consultants and other service providers.

3.4. Corporate transactions

If we are participating in a corporate transaction such an acquisition or a sale or are otherwise involved in any capacity in any such transaction, your personal data may be shared with entities involved in the transaction, including sellers, buyers, or other investors, as well as consultants related to the relevant transactions.

In addition, as a global company, we may share your personal data with Teltonika’s affiliates and subsidiaries, divisions, and groups worldwide.

3.5. For legal reasons

In response to a legal request, if we have a good-faith belief that the response is required by law, we may share your personal data with public authorities, courts, legal officers, government entities, law enforcement agencies etc.