Privacy Policy
OZUNA LIMITED ("Company" or "we" or "us") is committed to
respecting your data privacy and providing transparency
about our data practices. This Privacy Policy (this "Privacy
Policy") explains how we collect, store, use, transfer, and
disclose Personal Data from our users ("you") in connection
with the Company mobile application (and related services)
Universal TV Remote (collectively, the "App"). For all
inquiries, send a message to the email
support@universaltvremote.app
("the Email").
We reserve the right to and may change this Privacy Policy
from time to time. If we make any material changes, we will
notify you by email (sent to the email address specified
when you register), through the App, or by presenting you
with a new version of this Privacy Policy for you to accept,
if we, for example, add new processing activities or collect
some additional Personal Data from you. Your continued use
of the App after the effective date of an updated version of
the Privacy Policy will indicate your acceptance of the
Privacy Policy as modified. In some cases, you will have to
explicitly accept changes to the Privacy Policy to continue
using the App. We encourage you to periodically review our
website for the latest information on our data privacy
practices. If you do not accept the terms of the Privacy
Policy, we ask that you do not use the App. Please exit the
App immediately and delete it if you do not agree to the
terms of this Privacy Policy.
1. PERSONAL DATA AND INFORMATION WE COLLECT ABOUT YOU
We collect the following Personal Data and information from
you:
-
Contact Information such as name, email address, mailing
address, a phone number.
-
Preferences Information you provide such as product or
content interests, or communication or marketing
preferences.
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Usage activity about how you interact with us such as
purchase history, what content you viewed, and which
areas of our site you visited.
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Device and Usage Information that may include
information specific to your mobile device (e.g., make,
model, operating system, advertising identifier, and
similar information); information about your use of
features, functions, or notifications on the device; and
signal strength relating to WiFi or Bluetooth
functionality, temperature, battery level, and similar
technical data.
-
Location Information that allows us to periodically
determine your location, including your location
relative to and within third party merchant locations
- Demographic information such as age and gender
-
Information about your mobile device, such as your
mobile device id (similar to a website IP address),
device type, and mobile service carrier.
We may collect this Personal data and information even if
you are not logged in to the application. For iOS users: You
should be able to adjust the settings on your iOS mobile
device to prevent our collection of Location Information by
disabling the location services feature on your device. For
Android users: You should be able to adjust your settings on
your Android mobile device to prevent our collection of
Location Information be disabling Bluetooth and Location.
Permitting us to access third-party information can help you
to maximize your App experience, and we will handle any such
third-party information in full accordance with this Privacy
Policy.
If the information covered by this Section is aggregated or
de-identified so it is no longer reasonably associated with
an identified or identifiable natural person, we may use it
for any business purpose. To the extent information covered
by this Section is associated with an identified or
identifiable natural person and is protected as personal
data under applicable data protection laws, it is referred
to in this Privacy Policy as "Personal Data".
We use pseudonymization for particular types of Personal
Data. Please bear in mind that provisions of Section 3 do
not apply to pseudonymized Personal Data.
YOUR CONSENT FOR PROCESSING OF YOUR PERSONAL DATA.
By installing the App and creating a profile in the App, (or
by explicitly accepting this Privacy Policy and explicitly
consenting to the processing of your Personal Data) you
explicitly consent that:
-
WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE
THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT
CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING
SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND
OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY
POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU
INFORMATION AND REMINDERS THROUGH THE APP OR TO THE
EMAIL ADDRESS YOU PROVIDED TO US.
-
PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT
CREATION PROCESS OR USE OF THE APP INCLUDES PERSONAL
DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA
(E.G. YOUR NAME AND EMAIL ADDRESS), AND YOUR HEALTH DATA
(E.G. BODY MEASUREMENTS, PHYSICAL ACTIVITY, AND OTHERS).
DEPENDING ON THE DATA YOU PROVIDE, IT MAY ALSO CONTAIN
INFORMATION ABOUT YOUR PERSONAL RELATIONSHIPS.
-
WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD
PARTIES, EXCEPT IF IT IS REQUIRED TO PROVIDE THE SERVICE
TO YOU (E.G. TECHNICAL SERVICE PROVIDERS), UNLESS WE
HAVE ASKED FOR YOUR EXPLICIT CONSENT.
2. HOW WE USE YOUR PERSONAL DATA AND INFORMATION
We may use your information, including your Personal Data,
and by accepting this Privacy Policy you provide us your
explicit consent, for the following purposes:
-
to analyze, operate, maintain and improve the App and
marketing activities, to add new features and services
to the App;
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to assess your needs to determine suitable products or
services;
- to send product updates or warranty information;
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to respond to your comments, questions and requests and
provide customer service;
-
to send you push notifications, both internal and
external. IF YOU DO NOT WANT TO RECEIVE THESE
NOTIFICATIONS, YOU CAN MANAGE YOUR PREFERENCE EITHER
THROUGH YOUR DEVICE OR APP SETTINGS DEPENDING ON YOUR
DEVICE TYPE. YOU CAN ALSO CONTACT US AT the Email.
- to send you marketing communications;
-
to improve our App and marketing efforts to conduct
research and analysis, including for scientific and
academic research purposes; and
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for any other purposes disclosed to you at the time we
collect Personal Data or any other purposes indicated in
this Privacy Policy.
Choice/Opt-Out.
You may opt out of receiving our newsletter or marketing
emails from us by following the unsubscribe instructions
included in each newsletter or marketing email or you can
contact us at the Email.
Social Networks.
We enable you to create a profile and share information such
as messages, photos, and videos with others within your
network. We cannot control the actions of others with whom
you may choose to share your pages and information. Also, we
cannot guarantee that the content you post on our App will
not be viewed by others outside your network.
Any
information (including Personal Data) you share in any
online community area or online discussion is by design open
to the public and is not private unless provided differently
in the App settings. You should think carefully before
posting any Personal Data in any public forum. What you post
can be seen, disclosed to, or collected by third parties and
may be used by others in ways we cannot control or predict,
including to contact you for unauthorized purposes. As with
any public forum on any site, the information you post may
also show up in third-party search engines.
If you
mistakenly post Personal Data in our community areas and
would like it removed, you can send us an email as listed
below to request that we remove it. In some cases, we may
not be able to remove your Personal Data, e.g. for technical
reasons.
Information Obtained from Third Parties.
Unless
it is directly prohibited under applicable law in a certain
jurisdiction, we purchase marketing data about our customers
from third parties and combine it with Personal Data we
already have about you, to create more tailored advertising
and products. Such data never includes any of your personal
data that is considered to be 'sensitive' or falls under the
category of 'special categories of personal data' under
applicable law. We will only use that information for the
specific reason for which it was provided to us. By
accepting this Privacy Policy, you provide your consent for
such processing activities.
3. YOUR RIGHTS
Modification, correction, and erasure.
You are able to
modify, correct, erase and update your Personal Data in the
App account settings or, if that is impossible, by writing
us by the Email.
Access.
You have a right to
access your Personal Data you insert into the App and ask us
about what kind of Personal Data we have about you. You can
do this by using the app settings or by writing to the
Email.
EU residents.
Individuals residing in the
countries of the European Union have certain statutory
rights in relation to their personal data introduced by the
General Data Protection Regulation (the "GDPR"). Subject to
any exemptions provided by law, you may have the right to
request access to Personal Data (including in a structured
and portable form), as well as to seek to update, delete, or
correct Personal data:
-
Rectification of Personal Data and Restriction of
Processing. You are responsible for ensuring the
accuracy of your Personal Data that you submit to the
App. Inaccurate information will affect your experience
when using the App Web Sites and tools and our ability
to contact you as described in this Privacy Policy. If
you believe that your Personal Data is inaccurate, you
have the right to contact us and ask us to correct such
Personal Data by contacting us by the Email. You shall
also have the right to request the restriction of
processing of your Personal Data if you contest the
accuracy of the Personal Data and we need some time to
verify its accuracy.
-
Access to your Personal Data and Data Portability. The
App gives you the ability to access and update Personal
Data within the App and your account settings. You shall
have the right to request information about whether we
have any Personal Data about you, to access your
Personal Data (including in a structured and portable
form) by using your app settings or by simply writing us
by the Email.
-
Erasure of your Personal Data. If you believe that your
Personal Data is no longer necessary in relation to the
purposes for which it was collected or otherwise
processed, or in cases where you have withdrawn your
consent or object to the processing of your Personal
Data, or in cases where the processing of your Personal
Data does not otherwise comply with the GDPR, you have
right to contact us and ask us to erase such Personal
Data as described above. You can use simply write us by
the Email. Please be aware that erasing some Personal
Data inserted by you may affect your possibility to use
the App and its features. The erasure of some Personal
Data may also take some time due to technical reasons.
-
Right to object to the processing of your Personal Data.
You can object to processing your Personal Data and stop
us from processing your Personal data you can simply
write us at the Email. Please be aware that erasing some
Personal Data inserted by you may affect your
possibility to utilize the App and its features.
-
Notification requirements. We commit to notify you
within a reasonable period of time and your data
protection authority within the timeframe specified in
applicable law (72 hours) about any personal data
breaches in the App.
-
Data Protection Authorities. Subject to GDPR, you also
have the right to (i) restrict our use of Personal Data
and (ii) lodge a complaint with your local data
protection authority about any of our activities that
you deem are not compliant with GDPR.
Please keep in mind that in case of vague access, erasure,
objection request, or any other request in the exercise of
the mentioned rights we may engage the individual in a
dialogue so as to better understand the motivation for the
request and to locate responsive information. In case this
is impossible, we reserve the right to refuse to grant your
request.
Following the provisions of GDPR, we might
also require you to prove your identity (for example, by
requesting an ID or any other proof of identity) in order
for you to invoke the mentioned rights, specifically if you
exercise them with respect to special categories of Personal
Data like data about health. This is made to ensure that no
rights of third parties are violated by your request, and
the rights described in this section are exercised by an
actual Personal Data subject or an authorized person.
4. SHARING YOUR PERSONAL DATA AND INFORMATION
Sharing with third parties
We will share your Personal
Data and information with third parties only in the ways
that are described in this Privacy Policy.
We may
disclose your Personal Data:
-
as required by law, such as to comply with a subpoena or
similar legal process.
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when we believe in good faith that disclosure is
necessary to protect our rights, protect your safety or
the safety of others, investigate fraud, or respond to a
government request.
-
if we are involved in a merger, acquisition, or sale of
all or a portion of its assets, you will be notified via
email and/or a prominent notice on our Web site of any
change in ownership or uses of your personal
information, as well as any choices you may have
regarding your personal information.
-
to any other third party with your prior explicit
consent to do so.
We share the information we collect with third-party
business partners who commit to comply with applicable laws
concerning their usage of your Personal Data (for example,
GDPR for the EU residents). Our third-party business
partners may share your Personal Data with their own
third-party business partners, granted they have appropriate
data protection safeguards in place, and use the information
either for themselves or on behalf of their own business
partners to:
- Operate and improve their services;
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Provide you with advertisements and information for
products and services in this app or on other apps or
websites based on variables such as your location, and
assess your level of engagement with them; and
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Carry out other purposes that are disclosed to you and
to which you consent.
Depending on a service you use, we may share some of your
Personal Data and information with third-party business
partners who perform analytical and other tasks for us (in
some jurisdictions such parties may qualify for being a
'processor' under applicable laws).
Our third-party
partners are either EU-based or certified under the EU-US
Privacy Shield Framework that ensures that European data
protection requirements are met. The privacy policy of these
services can be found on their respective websites. Be
informed that some third-party service providers may have
their servers located in the United States.
BY USING
THE APP, YOU CONSENT THAT WE MAY USE COOKIES AND THIRD-PARTY
SERVICES AND COLLECT YOUR USAGE (INCLUDING FOR PROCESSING BY
THIRD-PARTY SERVICE PROVIDERS) AND SOME PERSONAL DATA UNDER
A UNIQUE IDENTIFIER, FOR THE PURPOSES OF TRACKING, ANALYSIS,
AND IMPROVEMENT OF THE APP. BY USING OUR SERVICE, YOU
EXPLICITLY CONSENT TO THE USE AND PROCESSING OF YOUR DATA
COLLECTED AS DESCRIBED ABOVE.
Aggregated
Information.
We may also share aggregated, anonymized,
or de-identified information, which cannot reasonably be
used to identify you. For example, we may share, including,
without limitation, in articles, blog posts, and scientific
publications, general age demographic information, and
aggregate statistics about certain activities or symptoms
from data collected to help identify patterns across users.
5. DATA SECURITY
Security of your Personal Data is important to us. When you
provide your Personal data that is considered to be
sensitive or falls under "categories of special data" under
applicable laws to us, we encrypt the transmission of that
information using secure socket layer technology (SSL). We
follow generally accepted industry standards to protect the
Personal Data submitted to us, both during transmission and
once we receive it.
Among others, we utilize the
following security measures to protect your Personal Data:
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Pseudominization and tokenization of certain categories
of your Personal Data;
- Protection of data integrity;
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Encryption of your Personal Data in transit and in rest;
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Systematic vulnerability scanning and penetration
testing;
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Organizational and legal measures. For example, our
employees have different levels of access to your
Personal Data, and only those in charge of data
management get access to your Personal Data and only for
limited purposes required for the operation of the App.
We impose strict liability on our employees for any
disclosures, unauthorized accesses, alterations,
destructions, misuses of your Personal Data.
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Conducting periodical data protection impact assessments
in order to ensure that the App fully adheres to the
principles of 'privacy by design', 'privacy by default'
and other internationally accepted data protection
principles. We also commit to undertaking privacy audit
in case of Company's merger or takeover.
Bear in mind that no method of transmission, or method of
electronic storage, is 100% secure. Therefore, we cannot
guarantee its absolute security. If you have any questions
about security on our App, you can contact us by the Email.
6. RETENTION AND STORAGE OF YOUR PERSONAL DATA
We will retain your Personal Data for as long as the
application is installed on your mobile device or as needed
to provide you service. If you remove the application, we
will remove your Personal Data and use copies of your
Personal Data as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.
If you wish to cancel your account or request that we no
longer use your information to provide you services, contact
us by the Email. We use servers located in the United States
to transfer, process, and store your Personal Data.
7. CHILDREN'S PRIVACY
General age limitation.
We are committed to protecting
the privacy of children. The App is not intended for
children and we do not intentionally collect information
about children under 16 years old. The App does not collect
Personal Data from any person the Company actually knows is
under the age of 16. If you are aware of anyone under 16
using the App, please contact us by the Email and we will
take the required steps to delete such information and (or)
delete their account.
8. DATA PROTECTION OFFICER
To communicate with our Data Protection Officer, please
contact us via Email.
9. CONTACTING US
General contact details.
If you have any questions or
concerns about your privacy, any provisions of this Privacy
Policy, or any of your rights, you may contact us by the
Email.