Privacy Policy

Last Updated: May 18, 2025

This Privacy Policy describes how Oceanbreeze Concepts PTY LTD collects, uses, and protects your personal information when you use our GateControlX service.

1. Introduction

At GateControlX, we take your privacy seriously. This Privacy Policy explains our practices regarding the collection, use, and disclosure of personal information through our access control system, which includes facial recognition technology, QR code generation, and access logging functionality.

By using our Service, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described, you should not use our Service.

2. Information We Collect

2.1 Personal Information

We collect the following types of personal information:

• Full name
• Unit or residence information
• Phone numbers
• The mobile number a resident messages us from, used to identify them on WhatsApp and SMS
• Mobile device push notification tokens
• Email addresses (for Estate Management)

2.2 Biometric Data

We collect and process facial biometric data for residents to enable facial recognition access control. This includes:

• Facial photographs
• Facial recognition data points/templates

2.3 Access Data

We collect information about access events, including:

• Date and time of access attempts
• Access point/device used
• Success or failure of access attempts
• Type of access (facial recognition or QR code)

2.4 QR Code Data

We generate and track information related to QR codes, including:

• Visitor names
• QR code creation time and expiration
• Usage history of QR codes

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Providing Access Control

• To enable facial recognition for resident access
• To generate and validate QR codes for visitor access
• To verify authorized access to estates and residences

3.2 System Administration

• To maintain user accounts and permissions
• To manage device registration and configuration
• To provide technical support and troubleshooting

3.3 Security and Monitoring

• To maintain access logs for security purposes
• To detect and prevent unauthorized access
• To investigate potential breaches or misuse

3.4 Communication

• To send visitor, access and system notifications via WhatsApp, SMS and mobile app push notifications
• To facilitate communication between Estate Management and residents
• To provide service updates and announcements

3.5 Service Improvement

• To analyze usage patterns and improve functionality
• To develop new features and capabilities
• To generate anonymized statistical data

4. Data Sharing and Disclosure

4.1 Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in operating our service, including:

• Hikvision (for device integration and facial recognition processing)
• Meta Platforms, through the WhatsApp Business Cloud API (to deliver and receive WhatsApp messages, which requires sharing the resident's mobile number and message content)
• BulkSMS (to deliver and receive SMS messages, which requires sharing the resident's mobile number and message content)
• Google, through Firebase Cloud Messaging (to deliver push notifications to the mobile app)
• Cloud hosting and storage providers

These third parties are contractually obligated to keep personal information confidential and use it only for the purposes for which we disclose it to them.

4.2 Estate Management Access

Estate Management has access to resident information, visitor logs, and access data for their specific estate. This allows them to manage residents, monitor security, and ensure proper system operation.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

4.4 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our service of any change in ownership or uses of your personal information.

5. Data Storage and Security

5.1 Data Storage Location

Your information, including biometric data, is stored on secure servers located in multiple jurisdictions where we operate. By using the Service, you consent to the transfer of information to countries that may have different data protection rules than your country.

5.2 Data Security Measures

We implement appropriate technical and organizational security measures to protect your personal information, including:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and monitoring
• Staff training on privacy and security practices

5.3 Data Retention

We retain different types of data for different periods:

• Personal and biometric data: Retained for the duration of service plus 30 days after termination
• Access logs: Retained for a period of 90 days for security and troubleshooting purposes
• QR code data: Retained until expiration or usage, then deleted

6. Your Rights and Choices

6.1 Access and Correction

Residents can view and update their personal information through the Estate Management. Estate Management can access, update, or request deletion of information through our dashboard.

6.2 Biometric Data Consent

Providing facial biometric data is optional but necessary for using facial recognition access. Residents can choose to use QR code access instead if they prefer not to use facial recognition.

6.3 Data Deletion

Upon termination of service or upon request, we will delete personal information and biometric data within 30 days, subject to legal retention requirements.

6.4 Communications Opt-Out

Estate Management can control which types of communications are sent to residents through the dashboard. Residents can turn off push notifications in their device settings, and can stop using the WhatsApp or SMS channels at any time. Messages relating to access and security may still be sent where they are necessary to provide the service.

7. Children's Privacy

Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe we have collected information from your child, please contact us so we can delete the information.

8. International Data Transfers

Your information may be transferred to — and maintained on — computers located outside your country where privacy laws may be different. By using our Service, you consent to this transfer. We will take appropriate measures to protect your personal information in accordance with this Privacy Policy regardless of where it is processed.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify Estate Management of significant changes via email and post a notice on our website. Estate Management is responsible for notifying residents of these changes.

Your continued use of the Service after such modifications constitutes your acknowledgment of the modified Privacy Policy and your agreement to abide and be bound by it.

10. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Oceanbreeze Concepts PTY LTD

Plot 475, Ghanzi, Botswana

P.O.Box 851, Ghanzi, Botswana

Email: [admin@gatecontrolx.com](mailto:admin@gatecontrolx.com) / [admin@obc.org.bw](mailto:admin@obc.org.bw)

Last Updated: May 18, 2025