SUNCOMM - Privacy Policy

1. Introduction
2. Certain Terms
3. Personal Data Collection
4. Cookies, Web Beacons and Other Analysis Tools
5. How We Use Your Information
6. How We Disclose Your Information Outside SUNCOMM
7. What Data Protection Settings Are Available
8. Retention of Personal Information
9. Your Rights
10. Accessing, Reviewing and Changing Your Personal Information
11. Third-Party Services
12. Individuals Located in the EEA or Switzerland
13. Privacy of Children Online
14. Limitation of Liability
15. Changes to This Privacy Policy
16. Contact Us

1. Introduction

SHENZHEN SUNCOMM Industrial CO., LTD (collectively, “SUNCOMM” “we” “us,” or “our”) takes your privacy seriously. If you are a visitor to SUNCOMM Website, a recipient of SUNCOMM communications or a customer of SUNCOMM then except as expressly set forth below, this Privacy Policy applies to your use of such Website or Service. This Privacy Policy describes how we collect, use, disclose, transfer, and otherwise process your Personal Information. It also tells you about your rights with respect to your Personal Information, and how you can reach us to update it or get answers to questions you may have about our privacy practices.

2. Certain Terms

This Privacy Policy covers the processing of Personal Information related to SUNCOMM products and services (“Services”), including:

• SUNCOMMhardware products (“Products”),
• website(s) that may be accessed at https://www.suncomm.com/(“Site”),
• services, including technical support and services accessible through the Site(s) (“Web interface”),
• software that may be downloaded to your smartphone or tablet to access services (“Mobile Apps”), and
• subscription services

Other definitions:

• Anonymization: By modifying the data, identification of a natural person is no longer possible.
• Activity data: Data stored about the user's activities.
• Analytical tools: Programs allowing analyses of user behavior.
• Cloud: Use of IT infrastructures and services that are not kept locally but are hired as a service and can be accessed via a network (e.g. the internet).
• Cookies: Cookies are small text files that are stored on your computer or in your browser.
• Devices: A (portable) object, such as a smartphone, tablet, notebook, or PC, used to access apps or programs and information services.
• IP address: An address within the computer network based on the Internet Protocol (IP). This address is assigned to the device and thus allows the device to be addressed and so accessed.
• MAC address: Address of each individual network adapter.
• Personal data: This information relates to a specific or identifiable natural, living person.
• Malicious software: Programs developed to cause damage to a device.

3. Personal Data Collection

3.1 How We Collect Personal Data

We obtain personal information relating to you from various sources such as described below. For the purpose of this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the Service.

1. Personal Information We Collect Directly from You
   • Registration is required in order to use the Services, we may ask you to provide certain Personal Information when you create an account on SUNCOMMor install and register to SUNCOMM-marked software(s), register a product, complete a survey, or sign up to be on our mailing list. We may ask you to submit the following types of Personal Information: first and last name, country, email address, product serial number, date of purchase, telephone number, shipping address, and proof of purchase. We may also collect additional personal information such as your interests or hobbies, your gender or age.
   • Information you voluntarily share or post. We may collect Personal Information that you provide in SUNCOMMand SUNCOMM-marked software(s), or post in a public space on our website, such as message boards.
   • Customer support. We may collect information through your communications with our customer support team or other communications that you may send us and their contents.
   • Payment details We may collect credit card and billing information, including credit card number, billing address, credit card expiration date and credit card security code to process your order.
   • Other Information We may collect other information from you that is not specifically listed here. We may use any such information in accordance with this Privacy Policy or as otherwise permitted by you.
2. Personal Information We Collect from Your Interactions with Our Products and Services
   • Cookies and Tracking Technologies We use automatic data collection tools like cookies, web beacons, google analytics and other tracking technologies in our products to collect data and related information, including IP addresses, device identifiers, advertising identifiers and other information about your device, system and application software and peripherals. We may collect information about your browser and what sites you visit. We might also look at how and how often you use one of our applications and certain features. Third parties may also collect information using cookies. To learn more about our cookie policy, click here.
   • Product Usage We collect information related to the use of our products and devices and statistics about the performance of your SUNCOMM This information includes Inter SUNCOMMspeed, storage information, error rates, and other performance information.
3. Personal Information We Obtain from Other Sources
   • Ads and Social Media Platform. We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as "Likes", profile information gathered from social networking sites or the fact that you viewed or interacted with our content.
   • Third-Party Personal Information. If you choose to provide us with a third party's Personal Information (such as name, email, and phone number), you must ensure that you have the third party's permission to do so. Examples include but not limited to providing us with the names and images that you associate with account users, forwarding reference or marketing material to a friend, or sending job referrals.

3.2 Purposes of Processing

SUNCOMM processes Personal Data for the following purposes and based on the following legal grounds:

• For the performance of SUNCOMM This element covers all technical and commercial processes required to carry-out user requests.
• Processing is necessary to perform a contract with the User, or in order to conclude one.
• For correct operation of our products and services through internal data analysis.
• For convenient and straightforward use of our products and services.
• To improve the Site, personalize the user experience, and enhance user interactions with the Site.
• Processing is based on SUNCOMMlegitimate interest to conduct its business, improve its product and service offerings, and facilitate communication.
• Promotional communications.
• Processing is based on your consent.
• For linking various user accounts (i.e. the SUNCOMMaccount with other social media or email accounts) and extracting information for specialized requested services.
• To provide customer service and ensure the security of our operations.
• Processing is based on the legal obligation to ensure the confidentiality of processing and SUNCOMMlegitimate interest to secure its operations.
• To offer you optimized advertising and product information.
• To confirm identity and prevent fraud.
• Processing may be requested by some judicial process or governmental agency.

3.3 Legal Basis of Storing Personal Data

• Consent

Your consent is required for the processing of certain data. In these events we will inform you expressly about the situation and provide you with the opportunity to allow us to process this data.

In these cases we will inform you about the purpose of the data processing and about your right of revocation.

•  
• Storage and deletion periods

We store personal data only to the extent required to fulfill the purpose. The storage period depends on legal requirements and the duration of the contractual relationship.

Should the data no longer be used, it will be anonymized and/or deleted in accordance with legal regulations.

Should you wish to have your data deleted, please note that we are able to block your data immediately but for legal reasons or due to technical restrictions it may take up to 180 days to permanently delete your data from the live systems.

Further, please note that after the confirmation of your deletion request it is not possible to restore your data.

4 Cookies, Web Beacons and Other Analysis Tools

We use cookies to enhance and simplify your visit; namely, in order to offer easier surfing on the Website, to make login easier, for internal security purposes, system administration to tailor advertisements to your preferences and the like. Cookies are small data files stored on the hard disk of the users' computer. In addition to cookies which send information to us, we also use cookies which collect information and send it to third parties. An example of this is Google Analytics. Some of our cookies may collect and store your Personal Data, such as your name or email address. If you do not wish to accept cookies from the Website please either disable cookies or refrain from using the Website.

We may also use web beacons. Web beacons allow us to understand if a certain page of the Website was visited or if an email was opened or if advertising banners on other websites were effective.

In addition, we use the following third-party tools for marketing purposes and to make your visit to our websites or the use of our products/services more user-friendly. The analytical tools include Google Analytics 360 etc.

Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies, but note that doing so does not necessarily affect third party flash cookies used in conjunction with our Website. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Website and you may not be able to access or use some or all areas and functionalities of the Website.

5 How We Use Your Information

SUNCOMM uses your Personal Data and usage information to offer and provide our products and services and to support our core business functions. These include order or service fulfillment, customer service, internal business processes, marketing, including contests and sweepstakes, authentication, loss and fraud prevention, public safety and legal functions. Some examples include:

• To fulfill your requests for products and services and communicate with you about said requests;
• To send you notifications concerning shipment information;
• To register your account on the Website;
• To administer surveys, contests, sweepstakes and promotions;
• To provide customer service;
• To help us improve and customize the Website;
• To send you information about our products, services, promotions, contests and sweepstakes; and
• To protect the security or integrity of the Website and our business.

6 How We Disclose Your Information Outside SUNCOMM

SUNCOMM DOES NOT SELL OR RENT YOUR PERSONAL DATA TO ANY THIRD PARTIES WHATSOEVER.

6.1 Service Provider and Vendors

We also may share Personal Information with our service providers who perform services on our behalf based on our instructions and in compliance with appropriate confidentiality and security measures. Examples of services include: processing of orders and credit card transactions, sending marketing communications, sharing your email address to assist us with sales-related efforts or post-sales support, and providing customer support.

6.2 Legal Requirement and Protection of Our Company and Others

We may share information for legal reasons. We will share Personal Information with companies, organizations or individuals outside of SUNCOMM if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• meet any applicable law, regulation, legal process or enforceable governmental request
• enforce applicable Terms of Use, including investigation of potential violations
• detect, prevent, or otherwise address fraud, security or technical issues or
• protect against harm to the rights, property or safety of SUNCOMM, our users or the public as required or permitted by law.

6.3 Business Transfers

We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of SUNCOMM or as part of a corporate reorganization or other change in corporate control, which is consistent with this Privacy Policy.

7 What Data Protection Settings Are Available

We intend to protect the Personal Information entrusted to us and treat it securely in accordance with this Privacy Policy. We maintain administrative, technical and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. SUNCOMM products are not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the SUNCOMM. This includes not sharing your passwords.

If you participate in a discussion forum, local communities, or chat room on a SUNCOMM website, you should be aware that the information you provide there (i.e. your public profile) will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither SUNCOMM nor you have control over. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. SUNCOMM is not responsible for the Personal Information or any other information you choose to submit in these forums. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

8 Retention of Personal Information

We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it or when you request its deletion, unless we are allowed or required by law to keep the information for a longer period. We complete periodic reviews of our databases, and have established time limits for certain data deletion, considering the type of services provided in the context of the Products and Services, the length of our relationship with you, mandatory retention periods, and the statute of limitations.

9 Your Rights

You have the following rights in connection with your personal data, subject to possible legal restrictions:

• Right to update your account. Through your account settings, you can update and change your Personal Information, such as preferences. your account. However, we may maintain the original information for necessary.
• Right to restriction of processing. You have the right to restrict the processing of your personal data. For example, you can choose whether you will receive our marketing and promotional emails or not. You can press the “unsubscribe” button at the end of the email or contact us at frank@suncomm.comto file a request. However, if you delete your account, you may not be able to fully use the Service.
• Right to erasure. Should you wish to delete your data, you have the option to do so in the administration section of our software. We will then erase your data in accordance with legal requirements. Additionally, we would like to point out that we are able to block your data immediately. But due to technical restrictions it may take up to 180 days to permanently delete your data, provided there are no legal obligations and statutory rights preventing deletion.

10 Accessing, Reviewing and Changing Your Personal Information

Using the Products/Services, you can access and edit your own personal information provided to us. The information that you can access through the Products/Services may change for the change of Products/Services. When you change information or delete your account, we may maintain a copy of the original information in our records. Because the original information may be still necessary to fulfill the purposes outlined in this Policy. Also, it is also permitted by applicable law. Additionally, we may use any anonymized or aggregated data that is derived from your personal information after you update or delete it. However, we will not do so in a way to personally identify you.

11 Third-Party Services

The Service may contain features or links to websites and services provided by third parties. If you click on a link to a third-party site, you will be taken to websites we do not control. Any information provided on third-party sites or services may be disclosed directly to the operators of such services, which is subject to those operators’ policies. Please read the privacy policy of other websites carefully. We are NOT responsible for these third-party sites or services to which links or access are provided through the Service.

In addition, the third parties may also integrate SUNCOMM Products and Services into their products and services. We are NOT responsible for this integration.

12 Individuals Located in the EEA or Switzerland

If you are located in the European Economic Area (“EEA”), we process your Personal Information for the purposes listed under 3above based on the following legal grounds:

1. You have consented to the use of your Personal Information. For example, we may seek to obtain your consent for our uses of cookies when you visit our website, or to send you marketing communications.
2. We need your Personal Information to provide you with Products and Services requested by you, or to respond to your inquiries.
3. We have a legal obligation to use or disclose your Personal Information, for example, if we are responding to a legal process or an enforceable governmental request.
4. We (or a third party) have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for things like:
   • Providing, maintaining, and improving our Services to meet the needs of our users
   • Developing new products and features that are useful for our users
   • Understanding how people use our Services to ensure and improve the performance of our Services
   • Customizing our Services to provide you with a better SUNCOMMuser experience
   • Marketing to inform existing customers about our Services
   • Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services
   • Protecting against harm to the rights, property or safety of SUNCOMM, our users, or the public as required or permitted by law
   • Performing research that improves our services for our users and benefits the public
   • Fulfilling obligations to our partners like developers and rights holders; and
   • Enforcing legal claims, including investigation of potential violations of applicable Terms of Use.

We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. In particular, we use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses. You may contact us as specified below to obtain a copy of such document.

You have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

In addition, if we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

SUNCOMM is the entity responsible for the processing of your Personal Information, and you may exercise your rights to your Personal Information by emailing us at: frank@suncomm.com.

13 Privacy of Children Online

Our Products and Services are meant for adults. We do not introduce children under the age of 16 without parental consent to set up SUNCOMM accounts on purpose. If you believe that we may have collected Personal Information from someone under 16, please let us know with the methods described in the Contact Us section and we will delete such information from our records.

14 Limitation of Liability

EXCEPT WHERE PROHIBITED BY LAW, UNDER NO CIRCUMSTANCES SHALL SUNCOMM BE LIABLE FOR DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES (EVEN IF SUNCOMM HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), RESULTING FROM ANY ASPECT OF SUNCOMM USE OF THE PERSONAL DATA OF ANY THIRD PARTY PROVIDED BY YOU AND/OR YOUR COMPANY. THESE LIMITATIONS SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW.

In some jurisdictions, some of the foregoing limitations may not apply.

15 Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. We recommend that you visit these pages periodically to be aware of and review any such revisions. If we make material changes to our Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our websites or sending you a notification.

16 Contact Us

If you have any questions, comments or complaints about this Privacy Policy and our privacy practices, or would like to update your privacy preferences, please contact us at: frank@suncomm.com or write to us at: SHENZHEN SUNCOMM Industrial CO., LTD, 601, Block A1, Building A, Yinfeng Industrial Park, Hangcheng Avenue, Sanwei Community, Hangcheng Street, Shenzhen, Guangdong, China

This SUNCOMM Privacy Policy was revised and posted as of November 1, 2022.