1) Definitions

• Service: The Emi Sathi Provides Mobile Device Management Service.
• Personal Data: Personal data means data about a living individual who can be identified from that data (or from that data and other information in our possession or likely to come into our possession).
• Usage Data: Usage data is automatically collected data either generated by the use of the Service or from the Service infrastructure itself (e.g. the duration of a page visit).
• Data Controller: The Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
• Processing: Processing means any operation or set of operations performed on personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction or erasure of personal data. The terms “Process”, “Processed” shall be interpreted accordingly.
• Data Processor (or Service Provider): Processor (or Service Provider) means any natural or legal person who processes data on behalf of the Data Controller. We may use the Services of various Service Providers to process your data more efficiently.
• Sub-processor: Sub-processor means any subcontractor engaged by us or our affiliates to assist us in fulfilling our obligations in relation to the provision of the Subscription Services under the Contract. Subcontractors may include third parties or our affiliates, but exclude any EMI SATHI employee or consultant.
• Data Subject (or User): The data subject is any living person who uses our Service and is the subject of personal data.
• Personal Data Breach: Personal Data Breach means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed by us and/or our subsequent subcontractors in connection with the provision of the Subscription Services. “Personal Data Breach” does not include unsuccessful attempts or activities that do not compromise the security of personal data, including unsuccessful login attempts, pings, port scans, denial of service attacks and other network attacks on firewalls or networked systems.

2) What is Personal Data?

The term “personal data” is the key to the RGPD’s enforcement: it applies whenever a data processing operation involves personal data. Personal data is any information relating to an identified or identifiable natural person (Art.4 RGPD). Personal information is information that identifies you or that can be combined by us or our Service providers and affiliates with other information to identify you. This information may include your first and last name, email address, home address, telephone number, location data, Internet Protocol (IP) address, cookie ID, image, and may include your age, income and other similar information when associated with you. Personal information may also include details such as whether you have opened our promotional emails or how you have used our website, if we can associate this personal information with you.

3) The Information We Collect

A. Personal data provided by the user for which Emi Sathi is Data Controller:

• Account Information: Email, first name, last name, number of licenses, end of subscription, company address, company phone number, company name, company country, email address for accounting, email address for Google API Service.
  • Purpose: To provide the Service (login, billing, use of Google APIs).
  • Storage Period: All personal data is deleted 6 months after the account is deleted in order to be able to reinstate the account in case of error. Primary contact details will be stored for 5 years after account deletion for billing tracking purposes, if applicable.

B. Personal data collected automatically and for which Emi Sathi is Data Controller:

• Dashboard Action Logs:
  • Purpose: To ensure account security.
  • Storage Period: Deleted 6 months after account deletion, or 2 years after the end of the subscription.
• ID of the company using the Google API Service:
  • Purpose: To provide the Service (use of Google APIs).
  • Storage Period: Deleted 6 months after account deletion, or 2 years after the end of the subscription.
• Devices: Manufacturer, technical identifiers, IP, SIM identifiers (ICCID, IMEI, phone number), installed applications, operating system version, system signature, GPS status.
  • Purpose: To provide the Service (monitoring and management of listed devices).
  • Storage Period: Deleted immediately on effective reset of the device; anonymized 6 months after account deletion, or 2 years after the end of the subscription (all references to personal data are removed).

C. Personal data provided by the Customer and for which Emi Sathi is a Data Processor (see our DPA):

• Managers’ Contact: Manager’s email.
  • Purpose: To allow different managers to log in to the account and to ensure account security.
  • Storage Period: Deleted immediately if the Customer deletes the Manager; deleted 6 months after account deletion, or 2 years after the end of the subscription.
• Devices (Naming): Device name.
  • Purpose: To assign a named device to a named user.
  • Storage Period: Deleted immediately upon an effective reset of the device; anonymized 6 months after account deletion, or 2 years after the end of the subscription (all references to personal data are removed).
• Wi-Fi Networks: List of Wi-Fi networks with password, Wi-Fi EAP certificate.
  • Purpose: To allow devices to connect to corporate Wi-Fi networks.
  • Storage Period: Deleted immediately when the network is deleted; deleted 6 months after account deletion, or 2 years after the end of the subscription.
• Policies (Configurations): Selected and saved configurations for a group of devices.
  • Purpose: To ensure control of registered devices.
  • Storage Period: Deleted immediately upon deletion of the policy; anonymized 6 months after account deletion, or 2 years after the end of the subscription (all references to personal data are removed).
• Users: Email, name, directory name, associated device, custom fields.
  • Purpose: To assign devices to named users.
  • Storage Period: Deleted immediately if the Customer deletes the user; anonymized 6 months after account deletion, or 2 years after the end of the subscription (all references to personal data are removed).
• Applications on the Store: Data to manage private applications without going through the Google Play Store.
  • Purpose: To manage private applications.
  • Storage Period: Deleted immediately when the application is deleted; deleted 6 months after account deletion, or 2 years after the end of the subscription.

D. Location Data

We may use and store information about the location of devices (last 50 location points) only if you grant permission to do so. We use this data to provide features of our Service.

Note: Location tracking Services are designed to be used only on company-owned devices. If you have been invited by your company to add a work profile to your personal device, then we do not collect any personal information related to the private use of your device (outside of the work profile). You can disable location authorization or not grant it the first time if you do not wish to share location.

4) Difference between Personal and Company-Owned Mobile Devices

If you have been invited by your company to add a work profile to your personal device, then we do not collect any personal information related to the private use of your device (outside of the work profile).

5) Purposes of Processing Personal Data

• To Provide and Improve the Subscription Service: We use your account information and customer data to provide you with products and Services. For example, we use the email address you provide during product registration to create your user account. This data is used to develop and improve our products and Services.
• To Secure and Protect Our Products and Emi Sathi Users: We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements, verify user accounts, detect product abuse, and prevent unauthorized registrations.
• To Provide Technical Support as Part of a Support Ticket: Authorized support agents, from an approved workstation, can access your console using a secure password to assist you and resolve technical issues. At no time will our support team ask you for your login credentials or password. You can object to this access by informing the support team, although doing so may prevent our agents from connecting to your account.
• To Communicate with You About the Services: We use the data you provide when registering for the Subscription Service to contact you via email or in-app notification regarding billing, account management, event invitations, newsletter mailings, technical and sales literature, updates to our Customer Service Terms of Use or other legal agreements, and security notifications.
• To Improve Our Customer Relationship Management: We may monitor and record communications with you (such as telephone conversations and emails) for quality assurance, training, fraud prevention, and compliance purposes.
• To Facilitate Social Networking: Our websites include social networking features (e.g., the LinkedIn or YouTube “Like” button and share widgets) that may collect your IP address and browsing behavior. These features are hosted by third parties or directly on our websites and are governed by their respective privacy policies.

6) Security Measures for Personal Data

We are committed to maintaining the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect the information we process and store. For example, we restrict access to this information to authorized employees and data processors who need to know it in order to operate, develop, or improve our application. Although we strive to provide reasonable security for the information we process and store, no security system can prevent all potential security breaches.

We use various security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. All personal data is protected by appropriate physical, technical, and organizational measures. To learn more about security at Emi Sathi, please visit our dedicated security page.

7) Use of Cookies

Cookies are small text files stored in your browser directory that allow site owners to understand how visitors use their site, remember user IDs, and store user preferences. They are one of the primary tools that enable us to provide secure and efficient Services. Essential cookies are required for the proper functioning of our Site and Services (such as navigation and secure access). Preference cookies are used to remember your preferences and recognize you when you use our Services again. Statistical cookies help us understand how visitors interact with our Services. Finally, marketing cookies display ads relevant to our visitors.

You can disable cookies at any time, except for those necessary to provide our Services. Disabling cookies may affect certain functionalities of our Site or Services.

8) Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes by posting the new Privacy Policy on this page. You should check this Privacy Policy periodically, as your continued use of our Services constitutes your acceptance of any changes.