Hawkeye Security Group Privacy Policy

At Hawkeye Electronic Security Limited (referred to as "we" and "us" in this policy), we prioritize your privacy and are committed to handling your personal data responsibly. This privacy policy describes how we collect, use, disclose, and protect the personal data of individuals who interact with us and utilize our services (referred to as "you" in this policy), as well as outlines your rights concerning your personal data.

We encourage you to read this policy to understand how we manage your information. If you have any questions or concerns about our practices, please reach out to us using the contact details provided at the end of this policy.

1. Data Controller Details

Hawkeye is a leading provider of electronic security systems and services in Jamaica, focusing on design, installation, and servicing for residential, commercial, and industrial applications. We offer complete solutions from system design to installation, along with free security audits and surveys, and reliable after-sales support.

Hawkeye serves as the data controller for the personal data you share with us, and we take full responsibility for safeguarding this information. If you have any questions or concerns regarding our privacy policy or data protection practices, please reach out to us using the contact details provided below:

Head Office

14 Belmont Road,

Kingston 5,

Jamaica

Telephone: (876) 926-HAWK (4295)

info@hawkeye-group.com]

[dpo@hawkeye-group.com

2. Privacy Policy Scope

This privacy policy applies to the various solutions within the Hawkeye Security Group:

• Hawkeye Security

• Ranger Protection and Security

• Hawkeye Electronics and Specialized Solutions

3. Types of Personal Data We Collect and Process

Personal Data

• Name

• Postal address

• Email address

• Telephone number

• Date of Birth

• Driver’s license information

• Emergency contact details

• Payment information

Vehicle Tracking Data

• GPS coordinates and tracking history of vehicles

• License plate numbers Security Data

• Video footage or images from security cameras

• Property and premises layout information

• Access codes and logs (entry/exit times)

• Records of security incidents, including details of individuals involved

4. Purposes for using personal data

Hawkeye processes personal data for various purposes to provide products and services as requested by you, comply with legal obligations, and support our business development and growth. These purposes include:

Purposes for using personal data	Lawful Basis
To provide the necessary services and products to you, which includes: • monitoring, investigating security incidents, and responding to emergencies. • Vehicle tracking services • Electronic security services • Remote technical services • Guarding services	Performance of a contract with you.
To manage our relationship with you, which includes: • sending service emails and communications as part of our contractual agreement. • notifying you about changes to our terms and conditions. • notifying you of changes to our privacy policy	(a) Performance of a contract with you. (b) Legal obligation
To provide customer services such as: • receiving and responding to servicesrequests, issues, and concerns. • providing information to queries. • receiving feedback and compliments	Performance of a contract withyou.
To enable direct marketing to: • inform you about new products andservices that may interest you. • inform you about promotions, offers,competitions or events that may interestyou. • personalise and improve yourexperience.	(a) Consent (b) Legitimate interests pursuedby Hawkeye to ensure wecan market and sell ourproducts.
To develop and improve our products andservices through insights about and from ourcustomers.	Legitimate interests pursued byHawkeye to ensure our productsand services are valuable to ourcustomers.
To ensure our platforms and websites remainsafe and functional and to prevent fraudulentactivity (e.g. troubleshooting, testing, systemmaintenance, monitoring, and reporting)	Legitimate interests pursued byHawkeye to keep ourinfrastructure functional andsafe.
To comply with legal obligations to which weare subject. Such as: • sharing information with regulatory andother official bodies lawfully andproportionately • retaining information to meet statutoryrequirements	Legal obligation
Establishing, exercising or defending our legalrights in connection with litigation cases orregulatory investigations.	Legitimate interests pursued byHawkeye to defend itself andprotect its legal position.

5. Third Parties

In certain situations, Hawkeye may need to share your personal data with third parties who assist us in delivering products or services or support our business operations.These third parties may include:

• Third-party suppliers, subcontractors, service providers, or vendors

• Professional advisers and consultants

• IT service providers, including enterprise resource planning and cloud-based software providers

Additionally, we may share personal data with other third parties such as:

• Insurance companies and brokers

• Law enforcement agencies, such as the police

• Public Authorities and Regulators

• External Auditors

Hawkeye takes care to select third parties carefully and enters into written agreements that align with applicable data protection laws when sharing personal data. This ensures that your personal information remains protected and used appropriately by these third parties.

6. Where your data is stored

To support our business operations effectively and efficiently, it is possible that data may be stored and processed in countries outside of Jamaica. When we transfer personal data internationally, we strictly adhere to applicable laws and regulations. We ensure that there is an adequate level of protection for personal data as it moves from Jamaica to another country or territory.

Hawkeye does not transfer personal data to a country with inadequate data protection measures unless we have established a transfer mechanism that is recognized by law.

We also implement additional technical, organizational, or contractual measures to ensure your personal information is adequately protected. This approach enables the security and protection of your personal data, regardless of where it is located or transferred to.

Personal data is currently stored in Jamaica, United States of America, and Canada.

For details about the safeguards we implement for the international transfer of personal data, please reach out to our Data Protection Team at [dpteam@hawkeye-group.com].

7. Your Rights

Under data protection laws such as the Jamaica Data Protection Act, individuals have various rights, and Hawkeye will take appropriate steps to facilitate and fulfill these rights. You have the right to:

• Request access to the personal data we hold about you and receive copies of this information.

• Request the correction or rectification of any inaccurate or incomplete personal data we hold about you.

• Stop or prevent the processing of your personal data under certain circumstances.

• Transmit the personal data you provided to us to another data controller in astructured, commonly used, and machine-readable format.

• Request not to be subject to decisions based solely on automated processing, including profiling, that significantly affects you.

• Provide consent for direct marketing communications or opt out where applicable.

• Withdraw consent at any time.

• Lodge a complaint with the regulator about how we handle or process your personal data.

To exercise these rights, please contact our Data Protection Team at [dpteam@hawkeye-group.com].

8. Retention of personal data

Hawkeye will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, which includes meeting legal and contractual requirements outlined in this privacy policy. Your personal data will be held for as long as you are a customer or hold an account with us.

Typically, we will retain personal data for up to 7 years after your contract ends with us. However, certain data may be deleted before or after this time based on the category of the data and in accordance with our commercial legitimate interests, legal obligations, and internal data retention schedule. If you have any questions about how we retain your data, please contact our Data Protection Team for more information.

9. Security

Hawkeye has implemented robust technical and organizational measures to safeguard your personal data and prevent accidental loss, unauthorized access, alteration, or disclosure. Some of the measures we have in place include:

• Firewall and network security frameworks

• Encryption of data both at rest and in transit

• Robust access control management and auditing

• Regular security updates and patches

• Anti-malware controls

• Ongoing security awareness training for our staff

Access to your personal data is restricted to authorized personnel who require it to perform their duties, and all individuals with access are bound by strict confidentiality obligations. We have established procedures to promptly address suspected or actual personal data breaches and will notify you and the relevant regulatory authorities where required.

10. Use of Cookies

Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website.

We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally, as it is statistical data. This statistical data does not identify any personal details whatsoever.

You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

11. Third Party Links

Hawkeye's website or services may contain links to third-party websites or services that are not operated or controlled by us. These third-party sites have their own privacy policies and practices, which may differ from ours.

We encourage you to review the privacy policies of these third parties before providing any personal information or engaging with their websites or services. Hawkeye is not liable for any harm or damages arising from your use of third-party websites or services linked from our platform.

12. Personal Data pertaining to Children

Hawkeye does not knowingly collect personal data from children under the age of 18 without parental consent. If we become aware that we have inadvertently collected personal information from a child without proper consent, we will take immediate steps to delete such information from our systems.

We encourage parents and legal guardians to actively monitor and supervise their children's online activities to ensure their privacy and safety. If you believe that we may have inadvertently collected personal information from a child, please contact us immediately so that we can address the issue promptly.

13. Change of Ownership

In the event that Hawkeye undergoes a merger, acquisition, or sale of all or a portion of its assets, customer information, including personal data collected through our services, may be transferred to the acquiring entity. This transfer of data would be subject to appropriate confidentiality arrangements and in compliance with applicable data protection laws. In such circumstances, we will notify you via email or prominent notice on our website before your personal information is transferred and becomes subject to a different privacy policy.

14. Contact and Complaints

Hawkeye maintains high standards in collecting and using personal information and takes complaints seriously. We encourage individuals to share any concerns about unfair, misleading, or inappropriate data practices and welcome suggestions for improvement. Contact our Data Protection Team at: [dpteam@hawkeye-group.com]with any questions or feedback.

If you remain dissatisfied with our response to your complaint or how we handle your personal data, you have the right to lodge a complaint with the Office of the Information Commissioner. You can report your concerns to them via email at info@oic.gov.jm or by calling 876-920-4390. Visit their website at: https://oic.gov.jm/contact15.

15. Revision of this notice

This notice will be periodically reviewed to reflect changes in processing activities andregulatory requirements. Hawkeye will publish and notify users of updated privacypolicies to ensure awareness of changes to our practices.

Last Update: April 30th, 2023