Privacy Policy

Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, SURE Universal Ltd. (“SURE Universal” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”), such as in the following use cases:

  • When you make use of, or interact with, our Website https://www.sureuniversal.com/ (“Website”).
    1. When you visit our forum or blog and “leave a reply
    2. When you subscribe to our newsletter
    3. When you contact us (e.g. customer support, help, submit a request) and/or schedule a meeting
  • When you make use of, or interact with the SURE Universal Smart TV Remote Control mobile software application, and any other mobile software application, that we license (each individually, and collectively, the “App”).
    1. When you download our App
    2. When you sign up for an account, login or use/purchase our services and/or products
    3. When you contact us (e.g. customer support, help, submit a request)
  • When you attend a marketing event and provide Personal Data
  • When you exchange business cards with us
  • When we use the Personal Data of our service providers
  • When we use the Personal Data of our customers
The Website and the App are individually and collectively referred to herein as the “Services”.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data or Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

 

Terms of Use and EULA. This Privacy Policy forms part of our Terms of Use which is available at https://www.sureuniversal.com/terms-of-use (“Terms”) and the App’s End User License Agreement which can be viewed from within the App and which you accepted prior to downloading, installing and/or using the App for the first time (“EULA”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms or the EULA.

Table of contents:

  • What information we collect, why we collect it, and how it is used
  • How we protect and store your personal data
  • How we share your personal data
  • Additional information regarding transfers of personal data
  • Your rights
  • Use by children
  • How can I delete my account?
  • Links to and interaction with third party product
  • Log files
  • Use of Google Analytics
  • California privacy rights
  • Our California do not track notice
  • Deletion of content from California residents
  • How to contact us

 

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect Why is the data collected and for what purposes? Legal basis (GDPR only) Third parties with whom we share your data Period of storage Consequences of not providing the data

When you make use of, or interact with our Website
When you visit our forum or blog and “leave a reply”
  • Full name
  • Email address
  • To post comments in SURE Universal forum
  • To make submissions to SURE Universal forum
Consent

 

Legitimate interest (e.g. to post comments in our forum)

3rd party platforms such as the following:

  • WordPress
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot post comments in SURE Universal forum

Cannot make submissions in SURE Universal forum

When you subscribe to our newsletters
  • Email address
  • Sending newsletters, forum post, blog updates and other marketing communications
The data subject has given consent to the processing of his or her personal data for one or more specific purposes

 

 

Legitimate interest (e.g. send you more information about SURE Universal)

 

3rd party platforms such as the following:

  • MailChimp
  • Mandrill
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot send you newsletters, forum post, blog and marketing communications

 

When you contact us (e.g. customer support, help, submit a request) and/or schedule a meeting
  • Full name
  • Email address
  • Company
  • Position
  • Any other information that you decided to provide/supply us
  • Answer questions
  • Provide support
  • To schedule a meeting with SURE Universal
  • Sending newsletters, updates and other marketing communications
The data subject has given consent to the processing of his or her personal data for one or more specific purposes

 

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

 

Legitimate interest (e.g. provide support and answer your questions)

 

 

3rd party platforms such as the following:

  • Zendesk
  • Hubspot
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot assist you and respond to your query

 

Cannot provide support

 

Cannot schedule a meeting

 

Cannot send you newsletters, forum post and marketing communications

 

 

 

When you make use of, or interact with the SURE Universal Smart TV Remote Control mobile software application, and any other mobile software application, that we license.
When you download our App
  • Full name
  • Email address
  • Permissions are required as our app has some very advanced features:

  • Identity: Subscription billing to ad-free version
  • Location: GPS location- For ads and future IoT
  • Photo/Media/File: Streaming to smart TV
  • Mic: Voice commands in smart TV
  • WiFi: Connecting to smart TV
  • Device ID & Call Info – Muting smart TV when phone rings

  • To download the App
  • To use our SURE Universal platform
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

 

Legitimate interest (e.g. to download the App)

3rd party platforms such as the following:

  • Google Play
  • App Store (iOS)
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot download the App

 

Cannot use our platform

 

When you sign up for an account, login or use/purchase our services and/or products
  • Full name
  • Email address
  • Location
  • Facebook account (if the registration is with Facebook)
  • Creating an account, including verification
  • Processing the order of a service
  • Performing/executing the Agreement
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

 

Legitimate interest (e.g. to perform the Agreement)

3rd party platforms such as the following:

  • Google Play
  • App Store (iOS)
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot create an account

 

Cannot process the service order

 

Cannot perform the agreement

 

When you attend a marketing event and provide Personal Data
  • Full name
  • Email address
  • Company
  • Position
  • Phone number
  • Establishing a business connection
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

 

Legitimate interest (e.g. send you more information about Sure Universal)

3rd party platforms such as the following:

  • Zendesk
  • Hubspot (CRM)
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot establish a business connection

 

When you exchange business cards with us
  • Full name
  • Email address
  • Company
  • Position
  • Phone number
  • Establishing a business connection
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. showing you certain products that you have shown an interest in)

 

Legitimate interest (certain b2b marketing communications)

 

Consent

 

3rd party platforms such as the following:

  • Zendesk
  • Hubspot (CRM)
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot establish a business connection

 

When we use the Personal Data of our service providers and suppliers
  • Full name
  • Email address
  • Company
  • Phone number
  • To contact our service providers
  • Processing the order of the service
  • Performing/executing the agreement
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

 

Legitimate interest (e.g. perform the contract, send contract-related communications)

 

3rd party platforms such as the following:

  • Zendesk
  • Hubspot (CRM)
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot communicate with you

 

Cannot process the order of the service

 

Cannot perform the agreement

 

When we use the Personal Data of our customers
  • Full name
  • Email address
  • Company
  • Position
  • Phone number
  • Providing our products and services
  • Performing the customer agreement
  • Sending newsletters or other marketing communications.
Processing is necessary for the performance of a contract to which our customer is a party.

 

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

 

Legitimate interest (e.g. send you contract-related communications)

 

3rd party platforms such as the following:

  • Zendesk
  • Hubspot (CRM)
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Cannot provide the services

 

Cannot perform the agreement

 

Cannot communicate with you

 

  1. HOW WE PROTECT AND STORE YOUR INFORMATION

 

  1. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

 

  1. Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

 

  1. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
  • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

Access from Israel

With respect to the access from Israel, please note that Israel was declared as a country offering an adequate level of data protection by the European Commission. Please read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

External transfers.

Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services or our business partners, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

  1. YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

  • You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
  • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
  • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
  • The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

 

You can exercise your rights by contacting us at support@sureuniversal.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  1. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under eighteen (18), you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

  1. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing support@sureuniversal.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, to the maximum extent permitted by law, given the nature of certain features of the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

  1. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Site may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

  1. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information

  1. ANALYTIC TOOLS

We use analytic tools to understand how our customers and users use our products and services. The terms and privacy policies of such third parties shall apply and, to the extent required, prevail. For example:

  • Google Analytics. The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Firebase Analytics. We also use a similar tool called “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. In addition, we bring to your attention that:

Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.

  1. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@sureuniversal.com. Please note that we are only required to respond to one request per customer each year.

  1. OUR CALIFORNIA DO NOT TRACK NOTICE

We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Site.

  1. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to support@sureuniversal.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

  1. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at support@sureuniversal.com, for general inquiries

Last updated: November 6, 2018

 

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