Privacy Policy

Updated Time: July, 2018

Effective Time: July, 2018

1. Introduction

1.1 Kindly note that uCloudlink Co., Ltd. and its affiliates (“we”, “us” or “uCloudlink”) takes the Personal Information of the user (“you”) very seriously and will take all effective measures to safeguard your privacy.

1.2 uCloudlink may collect your relevant information when you use our products and services.

This Privacy Policy is meant to help you understand how we collect, use, store and share your Personal Information and provide measures to access, update, control and protect these information.

1.3 This Privacy Policy is closely related to our services. Please read it carefully and make the appropriate decision based on the guidelines from this Privacy Policy.

1.4 By using our services, you agree that we may collect, use, store and transfer your information as described in this Privacy Policy. If you do not agree this Privacy Policy, you can terminate the registration or cancel the account.

2. How uCloudlink may collect and use Personal Information

What information uCloudlink may collect

uCloudlink may collect, store and use your information (“Personal Information”) while providing services. Personal Information refers to the information that can be used on its own or with other information to identify an individual, which will be collected when you use our products or services, including user name, date of birth, address, ID number, telephone number, email account, and when and where you use our products and services. If you do not provide the relevant information, you may not be able to register for an account and enjoy our services, as well as achieve the specific purpose for some particular service.

2.1 Information you may provide:

2.1.1 When you register for an account or use our services, you may provide relevant information, such as user name, telephone number, e-mail address, etc.

2.1.2 Information you provided to third parties through our services and stored when you use our services.

2.2 Information shared by third parties:

This refers to your information provided by third parties when they use our services.

2.3 Information collected by uCloudlink

When you use our services, uCloudlink may collect the following information:

2.3.1 Log information: when you use our services, the system may automatically collect technical information via cookies, web beacon or other methods including:

· Device or software information, such as your mobile device, web browser or configuration information provided by other programs to access our services, your IP address, and the version and IMEI number of your mobile device; information your searched or reviewed when you use our service, such as the keyword, the webpage you visited, and other information you surfed or request to provide when you use our service.

2.3.2 Location information: when you have location feature enabled and use location-based apps, we may collect your location information, including:

· When you access our services from the location-based mobile device, we may collect your location information;
· Real-time information from you or other users, including your geographic location indicated in your account information.

2.4 Description of Cookies

2.4.1 To ensure that the site is functioning, to provide you with an easier access experience, and to recommend content that may be of interest to you, we store small data files called cookies on your computer or mobile device. Cookies often contain identifiers, site names, and some numbers and characters. With cookies, websites can store data such as your preferences or shopping baskets. You can manage or delete cookies according to your preferences. We send you cookies to simplify the process of your repeated logins, store your shopping preferences or items in your shopping cart, and so on, to provide you with shopping preferences, help you optimize the selection and interaction of advertisements, and help you judge your login status and security of account or data.

2.4.2 In addition to cookies, we will also use other technologies such as web beacons and pixel tags on our websites. For example, the email we send to you may contain an address link to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve customer service and experience. Web beacons are usually transparent images embedded in websites or emails. With the pixel tag in the email, we can tell if the email was opened. If you do not want your activity to be tracked this way, you can unsubscribe from our mailing list at any time.

2.4.3 We do not use cookies for any purpose other than those described in this Privacy Policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer. Most web browsers automatically accept cookies, but you can usually modify your browser's settings to reject cookies, depending on your needs; you can also clear all cookies saved in the software. However, if you do this, you may need to personally change your user settings each time you visit the site, and the information you previously recorded will also be deleted and may have an impact on the security of the services you use.

How uCloudlink may use Personal Information

2.5 uCloudlink will use your Personal Information based on the following legitimate purposes.

2.5.1 Provide you with services；

2.5.2 Used for authentication, security, fraud monitoring, archiving and backup purposes to ensure the security of products and services provided to you by uCloudlink;

2.5.3 Help uCloudlink improve products and services;

2.5.4 Help uCloudlink know more about your access to and use of our services to fulfill your personalized requests, such as language settings, location settings, personalized support and instruction or other aspects.

2.5.5 Participate in market research related to our products and services;

2.5.6 analyze your geographical location to provide better network coverage.

2.6 To improve user experience and our services and other purposes with your consent, to the extent permitted by law, uCloudlink may apply the information collected from specific service through aggregate or personalized methods to other services. If uCloudlink provides the relevant options in related services, you can also authorize us to access these information provided and stored.

2.7 We may use user portrait formed by your information to share with partners who provide advertisement and analysis services to improve the effective target rates of advertisement and service information without recognizing your personal identity. Unless agreed by you, we will not share your personal information with partners who provide advertisement and analysis services.

3. How uCloudlink may share, transfer, disclose your Personal Information

How uCloudlink may share Personal Information

3.1 Except for the following circumstances, uCloudlink and its affiliates will never release your Personal Information to any third party without your consent.

3.1.1 uCloudlink and its affiliates may share your Personal Information with its partners, and the third party supplier, contractor and agent (they may not in your area) for the following purposes. If uCloudlink or its affiliates share your Personal Information with third parties as above. We endeavor to ensure third parties are in compliance with this Privacy Policy and other applicable security measures when they use your Personal Information
· Provide you with services；
· Carry out the purposes as described in section “How uCloudlink may use Personal Information ” 
· Fulfil the responsibilities and obligations in the User Agreement and this Privacy Policy;
· Understand, maintain and improve our service;

3.1.2 uCloudlink or its affiliates may save, store or disclose your Personal Information for the following purposes:
· Comply with applicable laws and regulations and safeguard public interest; 
· Comply with court orders or regulations of other legal procedures;
· Comply with regulatory requirements of relevant government departments;

· protect the legal rights, personal/real property, or personal safety of our Users and uCloudlink’ s employees.

4. Where we store your personal information

Your personal information and documents is stored in uCloudlink’s server and servers’ of third party provider we engaged to provide service to us. uCloudlink will ensure such third party to comply with this Privacy Policy and other appropriate confidential and security measurement that requested by uCloudlink when they use your personal information.

5. How you access and control your Personal Information

5.1 uCloudlink will do its utmost to take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other Personal Information provided when you use our services.

5.2 you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.

5.3 you can cancel your account in accordance with the provision stated in “Notes on the cancellation of uCloudlink account". After you cancel your account, your personal information will only be removed from the front system of uCloudlink's associated website and we will keep it irretrievable, accessible, or anonymized.

6. How uCloudlink protect Personal Information

6.1 uCloudlink only retains your Personal Information for the time period necessary for the purposes described in this Privacy Policy and as required by applicable laws and regulations.

6.2 uCloudlink uses various management policies (such as establishing information security system; signing a confidentiality agreements with information management employees; allowing only work-related employees to access the information collected; and other similar policies) and security techniques, procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) and periodical audit to prevent the loss of information, improper use, and unauthorized reading or disclosure. For example, in some services, uCloudlink uses encryption technology (such as SSL) to protect the Personal Information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to guarantee 100% security of information, even if all efforts are made to strengthen security measures. You need to understand that the systems and communication networks you use to access uCloudlink services may be subject to problems that are beyond uCloudlink’s control.

6.3 If uCloudlink is informed that the security of the data it has acquired and stored is compromised or the user's nonpublic information is disclosed to an unrelated third party due to external acts (such as hacker attack), uCloudlink will take reasonable actions (including but not limited to internal investigations, reporting and notification to law enforcement agencies, and cooperation with the law enforcement agencies) as it may consider appropriate, notwithstanding any disclaimer in this Policy. In parallel, uCloudlink will take legal and reasonable steps as it deems appropriate to notify the relevant users, informing them of the information disclosed and the extent to which we are aware of such situations.

7. Protection of minors’ Personal Information

Anyone who is identified to be a minor customer must obtain the consent and instruction from his or her parents or guardians to use our products and services.

If you are a minor, you shall obtain the agreement of your legal guardian before providing your Personal Information.

8. Scope of this Privacy Policy

Except as otherwise herein provided, all expressions in this Privacy Policy have the same meaning stated in the User Agreement.

8.1 This Privacy Policy is not applicable to the following circumstances:

8.1.1 Information collected by third party services (the third-party websites included) through our services;

8.1.2 Information collected by other advertising companies to serve advertisements through our services;

8.2 You shall accept the terms of use and the Privacy Policy (it is not bound by this Privacy Policy, please review their terms of use carefully) of third parties when you use their social media sites or other services (including the Personal Information you provided).

8.3 This Privacy Policy is only applicable to the information collected by uCloudlink but not applicable to the services or the use of information provided by third party. uCloudlink is not responsible for how the third parties use your Personal Information.

8.4 If this Privacy policy is in conflict with the personal information regulation of the country or territory where the user locates, the aforementioned regulation shall prevail.

9. Updates to this Privacy Policy

We may amend or update this Privacy Policy from time to time. You will be able to see our last updated privacy policy, along with its revision date. If there are material changes to your rights under this Privacy Policy, we will notify you through agreed method of contact before the revised version takes effect. By continuing to use our services, you agree to the bounds of the revised version of this Privacy Policy.

Any notice from uCloudlink will be sent to the email address, phone number, and/or mailing address left when you register for an account or purchase of our product, or pushed directly through mobile phone system. If sent via electronic methods, notice shall be deemed served when your device or the used electronic system receives the message; if sent by courier, it shall be deemed served on the third day after sending out.

If you have any questions, comments, suggestions or doubts about this Privacy Policy or our products, please feel free to give us a feedback. Contact us:

1)     E-mail address: service@ucloudlink.com

2)     Telephone No.: 400-699-1314