NEW BRIGHT PRIVACY POLICY FOR MOBILE APPLICATIONS
New Bright is committed to protecting your personal data and information, and your privacy when using our APP (i.e. software programs for mobile operating systems, commonly called “Mobile Applications” or “APP”) in your mobile device for interactive play with our toy products. Our toy iRobot and DashCam carries with it a built-in HD camera which can transmit all the images and/or video captured to your smart phone or tablet via our Wi-Fi enabled, downloadable APP.
The purpose of our APP is to enable a real-time transmission of the images and/or video captured by the remote camera on the screen display of your mobile device or to activate the touch-screen feature of your mobile device to serve as a remote controller for our toys. Wi-Fi direct technology is used to enable a one-to-one / peer-to-peer (P2P) connection, or a connection of a group of several devices / one-to-many simultaneously.
In order to enable a display of the transmitted images or video on your mobile or tablet screen display, we require your permission for our APP to access to the device camera, microphone and storage functionality of your mobile device.
Please be rest assured, however, that we do not collect your personal data or information through our APP. Our APP also does not employ any third-party analytics or advertising ads, and there is no sharing of user information or data with unauthorized third parties. Further, our APP does not employ any tracking or geo-tagging device so that your consumer behavioral pattern or current location will not be made known to others. In addition, our APP does not ask for any of your financial, account or credit information.
This Privacy Policy explains what our APP will do and how will your personal data or any sensitive information (e.g. photos, video) be handled by us or our APP. By consenting and installing our APP in your mobile device, you agree to the access of our APP to certain designated functional capabilities of your mobile device and that your personal data and/or sensitive information will be handled in the way and manner as set forth in this Policy.
YOUR PERSONAL INFORMATION: WHAT DO WE COLLECT?
As outlined above, we do not normally ask for your personal data or information. Our APP does not need the user specifics or personal data for the APP to function. All our APP requires is your permission for it to assess and activate certain hardware / software functionality of your mobile device in order to display the digital data transmitted from the remote camera (mounted on our toy product) on the screen of your mobile device for viewing purpose.
In order to download our APP, however, you have to assess the APP Store Platforms (such as the Apple App Store or the Google Play Store). We cannot speak for service providers of such platforms whether your personal data or information (e.g. IP address, clickstream data) will be tracked by such service providers for demographic, analytics, statistical, advertising or other business purpose. You should check the privacy policy of such service providers in case of doubt.
We may collect your personal data or information (e.g. your name, phone no., e-mail address) in case you have any specific inquiry or question which requires our response to you personally. Any such personal data or information so collected will be deleted or removed from our file or database within a reasonable time when we have responded to your inquiry or question.
HOW DO WE USE YOUR PERSONAL INFORMATION?
If for whatever reason any of your personal data or information is collected by us, we will keep it in confidence in our database without any disclosure to any third parties SAVE AND EXCEPT —
- to communicate with you or to answer your inquiry or question,
- to comply with any applicable laws, rules, regulations or court orders or to meet any legitimate request or inquiries of law enforcement agencies or government administrative organs,
- for our internal use or legitimate business purpose,
- to prevent or detect any criminal activity, fraud or abuse, or to enforce or defend our rights or the rights of interested parties.
For sensitive information (e.g. photos, video) captured by the HD camera, the images and files will be stored automatically in your mobile device or SD card depending on the internal setting of your mobile device. Our APP will not save any backup file for archive purpose.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not share your personal data or information with any unauthorized third parties SAVE AND EXCEPT the law enforcement agencies, regulators, courts, public authorities or government administrative organs who may have a legitimate and proper use of such data or information.
However, we cannot prevent you or third parties having access of your mobile device from revealing or divulging your personal data or information or sensitive information to others, e.g. by sharing the captured photos on social media (e.g. Facebook).
Also, we cannot speak for the service providers of the APP Store Platforms whether they will share your personal data or information with other third parties. You should check the privacy policies of those service providers if it is a concern to you.
COOKIES AND SIMILAR TECHNOLOGIES
Our APP does not involve the use of cookies, web beacons, unique identifiers or similar technologies for its application. “Cookies” are small pieces of information stored on the browser’s computer’s hard drive for different purposes, such as for authentication, tracking, … etc. A “Web Beacon” is a small file or image embedded in a web page or an e-mail commonly used for e-mail tracking and web tagging for web analytics.
However, we do not know whether cookies, web beacons and/or other unique identifiers will be used by service providers of the APP Store Platforms when you access those platforms for downloading our APP. In case you are in doubt, you should check the privacy policies of such service providers.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
It is our policy not to keep your personal information for any period longer than is reasonably necessary for our business purpose or for complying with legal requirements. Depending on the purpose for which your personal information is collected and/or the use to which it is put, we aim at disposing your personal information in a confidential manner a short period after the purpose / use is served. For instance, we may keep your personal information no longer than three months after answering your inquiry or question. In case of a claim or dispute between you and us, we may keep your personal information for the period when the claim or dispute remains unresolved or when the limitation period for lodging an appeal against any decision by a court or tribunal has not yet expired.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We follow reasonable industry practices and procedures to preserve the privacy, integrity and security of your personal information as we want you to repose complete confidence on using our products. Save for law enforcement, statutory compliance or to meet the lawful order of a court, law enforcement agency, public authority or government administrative organ, we will not release your personal data or information to others. We will review our processes and procedures on a regular basis to prevent any unauthorized access, use, accidental loss or destruction of data.
ANY LINKS TO THIRD PARTIES?
Our APP is not required to link up with other external computer network, platform or integrate with any social network (e.g. Facebook, Twitter) for it to function. Also, our APP does not operate any internal sharing functions or in-APP advertising. However, you have to download our APP from the APP Store Platforms (i.e. the Apple App Store or the Google Play Store) provided by other service providers. You may have to check their privacy policies in case that you are concerned with any collection of personal data or information while surfing those platforms.
ACCESS TO YOUR PERSONAL INFORMATION
You have a right to know what personal data or information we hold about you (if any). You may contact us and identify yourself clearly together with the sort of information you require. We may charge you a reasonable administrative fee to cover our cost of processing your request and of supplying you with the requested information. We need to verify your identity before we will process your request as we wish to ensure that your personal information (if held by us) will not be disclosed to the wrong people. Also, we may not accommodate a request to access info1mation where such request is unreasonable under the applicable law.
RIGHT TO OPT-OUT?
When you download our APP from the APP Store Platform, a message will pop up which requires your express permission for our APP to access certain functional capabilities of your mobile device in order for our APP to operate. You may choose to withhold your permission by declining the acceptance if you repose no confidence on our Privacy Policy or if you still have concern about the way or manner in which your personal information or any sensitive information will be handled. However, our APP will not function as intended without your permission. If you have installed our APP in the first place but wish to opt-out at a later stage, you may simply uninstall our APP by following the instructions available on your mobile device. In the absence of our APP, however, certain toy features will not function as destined.
CHANGES TO OUR PRIVACY POLICY
We may change and update our Privacy Policy from time to time. Any changes to our Privacy Policy will be posted on our web site newbright.com and changes will become effective when they are posted. By continuing to use our products, you are deemed to have acknowledged and consented to such changes.
CHILDREN UNDER THE AGE OF 13
While our APP does not knowingly solicit for data from or market information to children under the age of 13, any parent or guardian who becomes aware that his or her child has provided us with personal data or information without their consent should contact us and we will cause such information to be deleted from our files and database.
HOW TO CONTACT US?
If you have any question regarding our Privacy Policy in relation to our APP, or require any further information about our privacy practices, please contact us by e-mail at sales@newbright.com.
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2017 New Bright Industrial Co., Ltd.