Last Updated: May 2021
II. How uCloudlink Collects Your Personal Information
1. In order to provide our Services, we collect and process your Personal Information in several ways, including when you:
· Register for an account or use our Services;
· Visit our website/app or correspond with us by mail, telephone, or email;
· Provide your contact details to our marketing department requesting relevant and useful information about our Service through submission forms, or by telephone or e-mail;
· Conclude a transaction with us; or
· Contact us or provide information on social media channels.
III. The Types of Personal Information We Collect
1. Depending on the nature of your interaction with us, we may collect, store, and use the following categories of information:
· Account details: name, area of permanent residence, ID or passport number (where required), telephone number, international area code of your SIM card and email address. If you do not provide the foregoing information, you may not be able to register an account or enjoy our Services;
· Transaction details: your purchase history, payment method and payment result. We will also collect address and contact details for delivery. We do not collect payment card or account details.
· Log information: when you use our Services, the system may automatically collect information such as MAC address, and the model, manufacturer, system version, position, Android ID, IMEI number and APP logs of your mobile device.
IV. How Will uCloudlink Use Your Personal Information
1. In accordance with, and to perform our contract with you, uCloudlink will use your Personal Information to:
· provide the Services to you;
· enable you to login and register an account with uCloudlink;
· notify you of changes to our Service, communicate with you or provide you with user support;
· deliver your purchased device to you;
· enforce our terms and conditions and policies; and
· administer the provision of our Services, including troubleshooting.
2. In accordance with our legitimate interests to provide effective and dynamic Services, we may use your information to:
· ensure the security of Services provided to you by uCloudlink, including for authentication, security, fraud monitoring, archiving and backup;
· help uCloudlink improve the quality of our Services;
· enable uCloudlink to show you recommended data packages in accordance with your area of residence; and
· analyze your geographical location to provide better network coverage, recommended data packages and to understand homepage location traffic.
3. With your consent, we will process your data to participate in market research related to our products and Services. You can withdraw this consent at any time.
V. How uCloudlink May Share, Transfer, Disclose Your Personal Information
1. Except for the following circumstances, uCloudlink and its affiliates will not share your Personal Information with any third party without your consent.
2. uCloudlink and its affiliates may share your Personal Information with its partners, and third-party suppliers, such as AWS for data hosting, as well as with other contractors and agents for the following purposes:
· to provide you with the Services;
· to carry out the purposes as described in section “How will uCloudlink use your Personal Information ”
· in connection with a merger or an equity or asset transfer.
4. We put in place contracts with third parties containing appropriate commitments regarding the handling and security of your personal data.
5. uCloudlink or its affiliates may save, store or disclose your Personal Information for the following purposes:
· To comply with applicable laws and regulations and safeguard public interest;
· To comply with court orders or regulations of other legal procedures;
· To comply with regulatory requirements of relevant government departments; and
· To protect the legal rights, personal/real property, or personal safety of our users and uCloudlink’s employees.
VI. Where We Store Your Personal Information
1. Your Personal Information and documents are stored on uCloudlink’s servers and the servers of third party providers we engage to provide services to us. uCloudlink will take appropriate steps to ensure that any such third party complies with appropriate confidentiality and security measures.
2. Personal Information is stored by AWS in Singapore or in the United States of America.
VII. How You Access and Control Your Personal Information
2. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.
VIII. How uCloudlink Protects Your Personal Information
1. Unfortunately, no security system or system for the transmission of information via the internet can be guaranteed as completely secure. uCloudlink maintains appropriate technical and organizational measures to protect against unauthorized or unlawful processing of Personal Information and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to your Personal Information. To try to prevent unauthorized access, maintain data accuracy and ensure the correct use of information, uCloudlink maintains physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of Personal Information. Only a limited number of persons within our organization are authorized to access, delete or modify your data. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information. uCloudlink evaluates these measures on a regular basis to ensure the security of processing.
2. uCloudlink employees or any of uCloudlink’s contractual partners who have access to your data in order to provide services to uCloudlink or uCloudlink’s customers are contractually obligated to keep such information in confidence and may not use these data for any other purpose than performing their contractual missions for uCloudlink or uCloudlink’s customers.
IX. Protection of Minors’ Personal Information
If we recognize that you are not of the age of majority in your country, we will terminate the service and delete your information. We will notify you by app push, email and SMS before terminating the service.
X. Data Retention
We will delete your Personal Information within 60 days of you deleting your account unless we have a legal obligation to retain such data in which case we shall retain such data only for so long as we are required to do so by law.
XII. Contact Us
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