Virtoo by LG Privacy Policy

 

Last modified: July 9, 2018

 

This privacy policy (“Privacy Policy”) governs how we, Screenovate, use the information that we collect, receive and store, in connection with your use of the Virtoo by LG Software, and the choices you may make with respect to that.  

 

BY ACTIVATING AND/OR BY USING THE SOFTWARE, YOU EXPRESSLY AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. ANY USE OR CONTINUED USE OF THE SOFTWARE CONSTITUTES YOUR BINDING AGREEMENT AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, YOU MAY NOT ACTIVATE, ACCESS OR USE THE SOFTWARE IN ANY MANNER WHATSOEVER. YOU AFFIRM THAT YOU ARE OF LEGAL AGE IN YOUR JURISDICTION TO FORM A BINDING CONTRACT, BUT IN ANY EVENT OVER EIGHTEEN (18) YEARS.

 

1        END USER LICENSE AGREEMENT: 

 

The Software is subject to our end user license agreement (“EULA”) located at virtoobylg.screenovate.com/terms. This Privacy Policy forms a binding part of the EULA. All capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

 

2        MODIFICATIONS:

 

We reserve the right, at our discretion, to amend this Privacy Policy at any time, by updating this Web page (virtoobylg.screenovate.com/privacy), which will be reflected in the “Last Modified” date above, without the need for any notice to you. Your continued use of the Software following such update constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

 

3        WHAT TYPE OF INFORMATION WE COLLECT:

 

3.1        Non-Personal Information:

 

The first type of information we collect is aggregated, anonymous, non-personally identifiable, information which may be made available or gathered via the users’ use of the Software ("Non-Personal Information"). We are not aware of the identity of the user from which the Non-Personal Information is collected. Such Non-Personal Information may include (but is not limited to) the following examples: Type of operating system, Software version, type of device, date/time stamp, language preference, click-stream, event-stream, referral/exit pages, page views, high level geo-location (region/country/city), errors, crashes, etc. Please note that if we link Non-Personal Information to Personal Information we shall treat it as Personal Information as long as it is linked.

 

3.2        Personal Information:

 

The second type of information is individually identifiable information, namely information that identifies an individual or entity or may, with reasonable effort, identify an individual (“Personal Information”). We may collect Personal Information through the Software. The Personal Information we may collect, may include the following:

 

3.2.1      ‘Contact Us’ Information and other forms. If you contact us in any manner, including by sending us “Contact Us”, support, feedback or any other request or notification, whether by submitting an online form that we make available or by sending an email to an email address that we display, or in any other manner, you may provide us with certain information such as your name and email address. 

 

3.2.2       Identifiers. We may collect certain identifiers, such as online identifiers, device identifiers, client identifiers and IP addresses. In case we collect identifiers that are considered under applicable law as Personal Information, we shall treat them as such.

 

3.2.3       Account. In some cases, you may be offered to register and create an account. If you create an account, you may be requested to provide us with Personal Information, such as full name, phone number, private password, e-mail address, physical address, photo etc. You may also register through an existing third-party account accounts such as Google+ or Facebook and in such event the third-party account may provide us with access to certain information about you as is stored therein (e.g. full name, e-mail and any additional information which you authorize).

 

3.2.4       Purchases. The Software may include an option to purchase certain features, products or services from us. If you choose to make a purchase, our third-party payment providers may require sufficient information from you to complete the transaction. Such information could include a credit card number and related account and billing information, invoice related information, and other data required to process the order. We will use the tools, software or services of third-party payment providers to process transactions on our behalf, in which case you acknowledge and agree to review and be bound by the terms of use and privacy policy of said third-party service provider.

 

3.2.5       Mobile Device Location Data. We may provide certain location-based services (“Location Services”) in connection with the Software that are dependent on data related to the geographic location of your mobile device on which the Software is installed (“Location Data”). If you choose to participate in these Location Services, you agree that we may collect or obtain your Location Data. You should be able to use the settings on your mobile device to turn off location-sharing features.

 

4        HOW WE MAY USE THE INFORMATION WE COLLECT:

 

4.1           The Personal Information we collect may be used (via any applicable communication channel, including e-mail, SMS etc.) for the following purposes: (i) to correspond with you and attend your requests; (ii) to provide, secure, support and improve the Software and associated services; (iii) to support or carry out the transactions you have requested; (iv) to send you communications (including marketing and advertisement communications) that you request or that we believe may be of interest to you; (v) to identify and authenticate your access to the parts of the Software you are authorized to access; (vi) to customize your experience with respect to the Software; and/or (vii) any other purpose with your prior consent.

 

4.2           The Non-Personal Information we collect may be used for any purpose as we find appropriate.

 

5        HOW WE MAY COLLECT YOUR INFORMATION:

 

5.1           Cookies and Other Tracking Technologies. Our Software may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to provide functionality and services associated with the Software and to present you with information that is customized for you. We may also use third party tools and related cookies. A “cookie” is a small text file that may be used, for example, to collect information about activity on a website. Certain cookies and other technologies may serve to recall Non-Personal Information, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

 

5.2           Beacons and pixels. We may use certain web beacons on our Software.  You can make some web beacons unusable by rejecting cookies in your web browser. When you use the Software or visit our websites, we may also use pixel tags (also called "clear" gifs), tracking links and/or similar technologies to note some of the pages you visit on our websites.

 

5.3           Support logs. We may store log files on your device for support and debug purpose. We may request you to send such logs to us as part of a support / feedback handling flow. These logs may contain Personal Information related to your individual usage of various features of the Software. Please be aware of this and don't send us log files if you feel they may contain sensitive information.

 

5.4           Data Processing Services.  The Software may use third party tools and/or services, such as analytics and/or logging and/or error reporting and/or support and/or feedback and/or survey and/or marketing and/or other types of data processing tools and/or services, to collect information related to the Software and/or its use (“Data Processing Services”).

 

5.5           Google Analytics. One of Data Gathering Tools we use is Google Analytics. To learn more how Google uses data from our use of Google Analytics Cookie we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also encourage you to review the Google Analytics' currently available opt-outs for the web tool available at:  https://tools.google.com/dlpage/gaoptout/.

 

6        HOSTING:

 

We do not necessarily host the Software, or any part of it, ourselves. Hosting may be done by third party service providers that we engage. This means that data you may provide us or that we may collect from you may be hosted with such third-party service providers on servers that they own or control. Regardless of where such third-party service providers are located, their servers may be located anywhere in the world. Your data may even be replicated across multiple servers located in multiple countries.

 

7        TRANSFER OF DATA:

 

We may store, process, transfer and/or share your information in the United States or in other countries, all subject to this Privacy Policy and applicable law. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your information.

 

8        WITH WHOM DO WE SHARE YOUR INFORMATION:

 

8.1           We may disclose and/or share your Personal Information, including in other regions and/or countries as follows: (a) to third party service providers, such as hosting partners and/or Data Processing Services partners in order to support our business operations; (b) if we have a good faith belief that disclosure and/or sharing of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our EULA and/or separate contracts (if applicable) with you, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; and/or (iv) protect against harm to the rights, property or safety of Screenovate, our users, yourself or the public; and/or (c) to our co-branding partner, LG ELECTRONICS INC. and/or its Affiliates, for any purpose permitted under this Privacy Policy.

 

8.2           We may disclose and/or share Non-Personal Information (with or without compensation) to any third party as we find appropriate (including in other regions and/or countries).

 

8.3           In order to offer you a more consistent and personalized experience in your interactions with us, information collected through one source may be combined with information we obtain through other sources. 

 

9        INFORMATION RETENTION POLICY AND USER RIGHTS:

 

9.1           Information Retention. We may retain the Personal Information we collect for as long as needed to provide the services associated with the Software and to comply with our legal obligations, resolve disputes and enforce our agreements, subject to applicable law. We may retain Non-Personal Information for as long we find appropriate, subject applicable law.

 

9.2           Opting Out. You may choose not to receive future promotional, advertising, or other communications from us by selecting an unsubscribe option in the communication interface (if available, for example, link at the bottom of each email that we send) or by contacting us at legal@screenovate.com. Please note that even if you opt out of receiving the foregoing communication, we may still send you a response to any “Contact Us” request as well as administrative communications (for example, in connection with a password reset request) that are necessary to facilitate your use of the Software.

 

9.3           User Rights. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose to provide Personal Information, you may access, amend, update, delete or transfer such Personal Information through the appropriate interface in the Software (if available) or by contacting us at legal@screenovate.com. In the event you make such request, note that we may require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take up until one (1) month, all in accordance with applicable privacy laws. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply. If you choose not to provide mandatory Personal Information, you may be unable to access the Software or certain parts of the Software. Please note, however, that we may not be able to fulfill your above requests in one of the following circumstances: (i) as required or permitted under applicable laws; (ii) for legitimate business purposes; and/or (iii) unreasonably repetitive requests that require disproportionate technical efforts and resources, for example, developing a new system or fundamentally changing the current practices.

 

10      LINKS TO THIRD PARTIES:

 

The Software may enable you to interact with or contain links to third party services, and/or websites and/or applications and/or operating system, and/or your accounts with third parties (“Third-Party Services”). 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.

 

11      MINORS INFORMATION:

 

The Software is intended for users who are of legal age in their jurisdiction, but in any event over eighteen (18) years. If you are under legal age in your jurisdiction or under 18 years of age, you may not use the Software. If we learn that we have collected Personal Information from a child under 18 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at legal@screenovate.com.

 

12      SENSITIVE PERSONAL INFORMATION:

 

Please refrain from providing us with any sensitive personal information, such as information about your medical or health records, political, religious or philosophical beliefs, criminal offences (alleged, or committed), criminal conviction background, racial or ethnic origin, trade union membership, sexual orientation, sexual history, behavior or any other data that may be sensitive for you.

 

13      SECURITY:

 

The security of your information is important to us. We follow generally accepted industry standards to protect the information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Software, you can contact us at legal@screenovate.com. Further, in the event of a data breach, in which we discover your information is at material risk, we will notify you through the Software or in other ways we find appropriate. Also, we strongly recommend you take appropriate measures to protect your Personal Information by doing the following: (i) if you set an account with us, please make sure you take appropriate measures to secure it (e.g. set strong password, update your password from time to time and don’t expose it to third parties); (ii)  keep the Software up to date; and/or (iii) contact us immediately in case you are aware of any data breach and/or security vulnerability with respect to the Software.

 

14      MERGER, SALE OR BANKRUPTCY:

 

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 disclose, transfer or assign the information collected and/or processed hereunder in connection with the foregoing events.

 

15      CALIFORNIA PRIVACY RIGHTS:

 

15.1        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 Services.

 

15.2        Personal Information Disclosure. 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 legal@screenovate.com. Please note that we are only required to respond to one request per customer each year.

 

15.3        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.  If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.  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.

 

16      CONTACT US:

 

If you have any questions or comments about this Privacy Policy and/or requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at:

 

To: Screenovate Technologies Ltd.,

Attn: Data Protection Officer

Address: Screenovate Technologies, Ltd., 34 Jerusalem Rd., Raanana-43501, Israel

E-mail: legal@screenovate.com.

 

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN. BY USING THE SOFTWARE, YOU EXPRESSLY CONSENT TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE, DO NOT USE THE SOFTWARE.