PRIVACY NOTICE
Last update: 1 November 2023
This privacy notice informs you about how we collect, use, and disclose your personal data. It also describes the choices that you have with regard to your personal data.
Please read this privacy notice carefully before submitting your personal data to us.
1. ABOUT OUR WEBSITE AND THIS PRIVACY NOTICE1
2. WHAT DATA DO WE COLLECT?2
3. HOW LONG DO WE STORE YOUR DATA?3
4. HOW DO WE DISCLOSE YOUR DATA?3
5. HOW DO WE PROTECT YOUR DATA?4
6. HOW CAN YOU CONTROL YOUR PERSONAL DATA?4
7. CONTACT5
1. ABOUT OUR WEBSITE AND THIS PRIVACY NOTICE
In this section, you can find some general information about our website and this privacy notice.
1.1 About the Notice. This Privacy Notice (the “Notice”) governs the processing of personal data collected from individual users (“you” and “your”) through the website www.remarksec.com(the “Website”). This Notice does not cover any third-party websites, applications, software, or services that integrate with the Website or any other third-party products and services.
1.2 Data controller. The Website is owned and operated by Shobai LLC having a registered address at 5205 Flushing Avenue, 211, Maspeth NY 11378, the United States of America (“we,” “us,” and “our”). We act in the capacity of a data controller with regard to the personal data that you provide us with.
1.3 Minors. We do not target minors or collect personal data fromthem. If you become aware a child’s personal data has been provided to us without valid consent of the parent or legal guardian of the child, please contact us immediately.
1.4 Term and termination. This Notice enters into force on the effective date indicated at the top of the Notice and remains valid until terminated or updated by us.
1.5 Amendments. We may change this Notice from time to time, if necessary to address the changes in our business practices, the Website, or laws, regulations, and standards applicable to us. The amended version of the Notice will be posted on this page and, if we have your email address, we will send you information about all the changes implemented by us. We encourage you to review our Notice regularly to stay informed.
2. WHAT DATA DO WE COLLECT?
In this section, we provide an overview on what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use the Website, and how we communicate with you.
2.1 We comply with data minimisation principles and, therefore,use your personal data for limited purposes, as explained in this Notice. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.
2.2 Sources of personal data. We obtain your personal data from the following categories of sources:
• Directly from you. For example, if you submit your personal data when completing our forms or contacting us; and
• Directly or indirectly through your activity on the Website. When you use the Website, we automatically collect analyticsinformation about your use of the Website.
2.3 What personal data do we collect directly from you?
• User account. If you decide to use our services, you will be invited to create a user account on the Website. Through the account registration form, we collect your full name, email address, address, and phone number. If you upload or generate any files through your user account, we may have access to those files. We use such data to register and maintain your user account, process your requests, provide you with the requested services, contact you if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate interests’ (i.e., administering our business). We store such data in our systems until you delete your user account.
• Contact form. When you submit our contact form available on the Website, we collect your first name, last name, email address, and any information that you include in your message. We use such data to respond to your inquiry and provide you with the requested information. The legal basis on which we rely is ‘your consent’. We will store the data that you provide us with until you stop communicating with us and in any case no longer than 1 year.
2.4 What personal data do we automatically collect while you are using the Website?
• Analytics data. While you are browsing on the Website, we collect analytics data that allows us to see what kind of users access and use the Website, which parts of the Website you find interesting, improve our content, improve our services and develop new ones, and investigate and prevent security issues and abuse. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyze, improve, and protect our Website) and ‘your consent’ bases. The analytics data that we collect includes:
• Session statistics;
• Your device type;
• Your operating system;
• Your browser name and version;
• Approximate location; and
• Your other online behavior.
2.5 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”), unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
2.6 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation (for example, respond to your inquiry). Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
2.7 Your feedback and de-identified data. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will remove all personal data that is not necessary for keeping such records. Also, we may use and share with third parties de-identified data for the purpose of facilitating research. Such data does not allow us to identify you as a natural person and, therefore, is not considered to bepersonal data.
3. HOW LONG DO WE STORE YOUR DATA?
Below, we explain for how long we keep your data in our systems and how we delete it.
3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Notice or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will securely delete it from our systems.
3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Notice.
3.3 Storage as required by law. When we are obliged by law to store your personal data for a certain period of time (e.g., for keeping accounting records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
4. HOW DO WE DISCLOSE YOUR DATA?
In this section, you can find information about third parties that may have access to your personal data.
4.1 Disclosure to data processors. If necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services.
4.2 List of data processors. The data processors that may have access to your personal data are:
• Our cloud storage, analytics, and mailing service provider Google LLC located in the USA;
• Our Website hosting service provider Google located in the USA;
• Our analytics service provider Google Analytics located in the USA;
• Our mailing service provider Google located in the USA; and
• Our independent contractors and consultants.
4.3 Authorized disclosure. If you authorize us to do so by means of informed consent, we may share your personal data with specified third parties. We will take reasonable safeguards (e.g., data transfer agreements) to ensure that your data will be further processed in accordance with the strictest data protection standards and the applicable laws.
4.4 International transfers. Some of our data processors may be based outside the country where you reside. In case it is necessary to make an international transfer of your personal data, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection.
4.5 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it forbusiness improvement purposes, responding to lawful requests from public authorities, or developing new services.
4.6 Legal requests. If requested by a public authority, we will disclose information about the users of the VideoFix to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
4.7 Sale of personal data. We do not sell your personal data.
5. HOW DO WE PROTECT YOUR DATA?
Here you can find information on how we protect your data against breaches.
5.1 Security measures. We implement up-to-date industry appropriate technical and organizational information security measures that protect your personal data from loss, misuse, unauthorized access and disclosure. Our measures include:
a) Maintaining adequate access control mechanisms (e.g., two-factor authentication, password protection, and limited access);
b) Encryption;
c) SSL certificate;
d) Limiting access to personal data; and
e) Conducting regular information security audits.
5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannotand will not be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. Our liability will be limited to the highest extent permitted by the applicable law.
6. HOW CAN YOU CONTROL YOUR PERSONAL DATA?
Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.
6.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:
• Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
• Right to rectification: you can rectify inaccurate personal data that we hold about you;
• Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
• Right to restriction: you can ask us to restrict the processing of your personal data;
• Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
• Right to object: you can ask us to stop processing your personal data;
• Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
• Right to complaint: you can submit your complaint regarding our processing of your personal data.
6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of this Notice and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.
6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
7. CONTACT
If you have any questions about this Notice, your rights, or our data protection practices, please contact us by email: info@remarksec.com .
Alternatively, you can send us a letter to the following address:Shobai LLC, 5205 Flushing Avenue, 211, Maspeth NY 11378, the United States of America.
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