Privacy Policy
Last Updated: July 2021
I. Introduction
1. This privacy notice, including the Local Privacy Terms (“Privacy Policy”), is issued by uCloudlink (America), Ltd. and its affiliates (“we”, “us,” “our,” or “uCloudlink”) and covers our practices regarding the collection, use, storage, transfer, and other processing of individually identifiable information about you (“Personal Information”) when you contact us, purchase, install, access or use our products, apps, services, or websites (collectively the “Services”).
2. There may be jurisdiction-specific provisions of this Privacy Policy for certain countries or regions. Please refer to your Local Privacy Terms for more information.
3. By using the Services, you agree to be bound by uCloudlink’s Terms and Conditions and acknowledge that you have read and understood uCloudlink’s Privacy Policy.
II. How uCloudlink Collects Your Personal Information
4. 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.
5. Cookies and similar technologies (e.g. pixels and ad tags) (collectively “Cookies”) are small files that, when placed on your device, enable us to collect certain information, including Personal Information, from you in order to provide certain features and functionality. We and our service providers use Cookies to collect data and recognize you and your device(s). We do this to better understand the effectiveness of our Services and to enhance your user experience. To learn more about our use of Cookies, please click here.
III. The Types of Personal Information We Collect
6. Depending on the nature of your interaction with uCloudlink, we may collect, store, and use the below categories of information:
· Account details: Name, area of permanent residence, telephone number, or email address(where required). If you do not provide the relevant information, you may not be able to register for an account and enjoy our services, as well as achieve the specific purpose for some particular services;
· Transaction details: information relating to what you have purchased, spending history, and details of payment method. We will also collect the address and contact details for delivery. We do not collect payment card or account details;
· Log information: when you use our Services and with your consent, the system may collect information such as mobile phone sim card permission (for the purposes of the international area code), positioning of the terminal, mobile phone model, mobile phone system version, mobile phone manufacturer, app log, MAC address, AndroidID, app log, and the IMEI number of your mobile device.
IV. How uCloudlink may use Personal Information
7. In accordance with our contract with you and to perform the obligations under such contract, uCloudlink will use your Personal Information to:
· provide you with Services;
· enable you to log in and register an account with uCloudlink;
· notify you about changes to our Service, communicate with you, or provide you with user support;
· distribute user equipment;
· enforce our terms and conditions and policies; and
· administer the services, including troubleshooting.
8. In accordance with our legitimate interests to provide an effective and dynamic service, we may use your information to:
· ensure the security of Services provided to you by uCloudlink including authentication, security, fraud monitoring, archiving, and backup purposes;
· help uCloudlink improve its Services;
· enabling uCloudlink to show you recommended packages in accordance with your area of residence;
· analyze your geographical location to provide better network coverage, and recommended packages and to understand the data traffic status of your location; and
9. 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
10. Except for the following circumstances, uCloudlink and its affiliates will not share your Personal Information with any third party without your consent.
11. 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 the section “How uCloudlink may use Personal Information ”
· to fulfill uCloudlink’s responsibilities and obligations in the Terms and Conditions and this Privacy Policy; and
· in connection with a merger, sale, or asset transfer.
12. If you pay for your Services using Paypal, Braintree, Paypal or Stripe, you acknowledge and agree that the processing of such payment shall be handled by that third party and will be subject to their terms and conditions and your data will be handled by them in accordance with their privacy policy. You must review these third-party terms before proceeding.
13. We put in place contracts with third parties containing appropriate commitments regarding the handling and security of your personal data.
14. 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
15. 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.
16. Personal Information is stored by Amazon Web Services (AWS), with EU and UK Personal Information being hosted in Ireland and non-EU Personal Information being hosted in Singapore, except for data relating to Chinese users, whose Personal Information is hosted in China.
17. If you are located in the EEA, please see Local Privacy Terms for additional information about the safeguards we take to protect your Personal Information when it is transferred outside of the EEA.
VII. How you access and control your Personal Information
18. uCloudlink will do its utmost to take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other Personal Information provided when you use our services. For further information about the specific rights you have to access, update, correct, or delete your Personal Information, please refer to the relevant local section of the privacy policy below for further information.
19. 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
20. 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, and 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 ongoing integrity and confidentiality of Personal Information. uCloudlink evaluates these measures on a regular basis to ensure the security of processing.
21. 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
22. 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
23. 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.
XI. Updates to this Privacy Policy
24. We may amend or update this Privacy Policy from time to time, consistent with applicable privacy laws and principles. We will notify you of such changes will notify you by app push or in-app messaging. Your continued use of the Services constitutes your acceptance of our Privacy Policy.
XII. Contact Us
25. If you have any questions about this Privacy Policy or our products, please feel free to give us feedback. You can reach us by email at:
· supportus@ucloudlink.com, if you are located in the US;
· glocalmeconnect@outlook.com, if you are located in the UK or EU; or
· service@ucloudlink.com, if you are located in other countries or territories.
UK/ EU
I. Your Rights Under GDPR and the UK Data Protection Act 2018
Data Controller
For purposes of the GDPR and the UK Data Protection Act 2018, the data controller responsible for the processing of Personal Information described in this Privacy Policy is:
· to the extent such processing of data relates to purchasing of a Device, Hong Kong uCloudlink Network Technology Ltd.,
· to the extent such processing of data relates to purchasing of mobile WiFi data allowances, uCloudlink (Singapore) Pte. Ltd.
International Transfer of Personal Information
As described above, the Personal Information that we collect from you will be transferred to and stored at, a destination outside of the UK and EEA. Where we transfer your Personal Information to countries outside of the UK and EEA (as applicable), we do so under the European Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses) pursuant to Commission Decision 2004/915/EC or 2010/87/ EU (as appropriate) or in line with any replacement mechanism approved under EU or UK law.
Data Subject Rights
To the extent required by applicable law and subject to legal limitations, you may have the following rights related to our processing of your personal information.
· Right of access – you have the right to ask us to access the Personal Information we maintain about you and be provided with information about how we use and share your information.
· Your right to rectification – you have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
· Your right of erasure – you have the right to ask us to erase your personal data in certain circumstances.
· Your right to restriction of processing – you have the right to ask us to restrict the processing of your information in certain circumstances.
· Your right to object to processing – you have the right to object to the processing of your personal data in certain circumstances.
· Your right to data portability – you have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.
If you are concerned that any of the information we hold about you is incorrect, out of date, or may be used inappropriately, please contact us with your concerns and we will take appropriate steps to amend our records.
uCloudlink is committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that uCloudlink has not been able to assist with your complaint or concern, you have the right to make a complaint with a competent data protection authority in the UK or EU Member State where you reside or where you believe the breach occurred.
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