Introduction

SURE Universal Ltd collects and processes your personal information in accordance with this privacy policy.  This policy provides you with information regarding our obligations and your rights in compliance with international privacy laws including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

Information That We Collect From You

Information that you provide to us directly through this website might include personal information such as your name, email address.  These details will be processed under the legal basis of legitimate interests.

Data we process on behalf of our health care providers may include information such as name, email address, date of birth, gender, photograph, phone, and health related data.  Our legal basis for this processing is that this is necessary for the performance of a contract, consent may also be obtained where necessary for some of this processing.

We may also collect non personal information that may identify you such as location, IP address, browser type, operating system and other details about the device you are using.

How We Use Your Personal Data

We use your personal data to provide our services to you.  Where you have consented, we may also use your information to send you promotional offers and marketing.  You are free to withdraw this consent at any time.

We always respect your privacy. Your information will never be disclosed or shared with others without your consent, unless required to do so by law.

Sharing or Disclosing Your Personal Data

Whilst we will never disclose or share your data with others without your consent, we use third party processors to provide our services; these companies will process or store your information on our behalf.

We use the following third parties:

• We use Amazon Web Services (AWS) to host our systems and databases in EU based data centres. For more information about Amazon Web Services (AWS), please read their privacy policy at https://aws.amazon.com/privacy/

We ensure all processors acting on our behalf act in accordance with this privacy notice.

Merger, acquisition or sale of all or a portion of company

If the Company is involved in a merger, acquisition or sale of all or a portion of its assets, the Company reserves the right to transfer personal and non-personal data to a party involved in the merger, acquisition or sale, to the extent such information is necessary to carry out the merger, acquisition or sale.

Your Rights under the GDPR

These rights apply solely to all visitors, users, and others who reside in the EU or UK.

Under GDPR you have the right to access personal information that SURE Universal Ltd processes about you.

You can request from us information about –

• The personal data we hold about you
• The categories of personal data concerned
• The purposes of the processing
• Details to whom your personal data has/will be disclosed
• How long we retain your personal data
• If we did not collect the data directly from you, information about the source

You may also request from us the following-

• That we update any incomplete or inaccurate data about you
• Request that we delete your personal data in accordance with GDPR

You may request we action your rights by emailing us at [email protected]

To ensure your data is protected, if we receive a request from you to exercise your rights, we will ask you to verify your identity before acting on the request.

Your Rights under the California Consumer Privacy Act (CCPA)

These rights apply solely to all visitors, users, and others who reside in the USA State of California.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business

or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Non-Discrimination

If you have any questions or requests regarding your rights under the CCPA, please contact us at [email protected]

Security & Safeguarding Measures

All personal data collected is transferred and stored securely, using industry standard encryption protocols, and approved transfer mechanisms.  Please note however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.

Our team is trained on the importance of Privacy and Data Protection and will adhere to our internal policies.

How Long We Retain Your Data

SURE Universal Ltd only retains personal information for as long as is necessary for business or legal purposes.  For further details on our data retention periods please contact us.

Where you have consented to us to use your details for direct marketing, we will keep this data until you notify us or otherwise withdraw your consent.

Children

We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through our Services. 

Links to Other Web Sites

Our services may contain links to other websites not controlled or operated by SURE Universal Ltd. These links do not imply that we endorse these third-party sites. We recommend reviewing those sites directly for information on their privacy policies.

Cookies

A ‘cookie’ is a small text file sent from a website and stored on the user’s computer by the user’s web browser. Upon visiting a site that uses cookies, a cookie is downloaded onto your computer or mobile device.  The next time you visit that site, your device will remember useful information such as preferences, visited pages or logging in options.

Cookies are widely used to add functionality to websites, or to ensure they work more efficiently. Our site relies on cookies to optimise the user experience and ensure the sites services function properly.

We use Google Analytics to provide us statistics on website usage.  The only personal data divulged to Google is your IP address.  You can opt out of Google Analytics following the advice here – https://tools.google.com/dlpage/gaoptout

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies please visit https://www.aboutcookies.org.

Privacy Policy last updated: 16-Feb-2023

This privacy policy (“Privacy Policy”) governs how we, SURE Universal Ltd. (“SURE Universal” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”), such as in the following use cases:

• When you make use of, or interact with, our Website https://www.sureuniversal.com/ (“Website”).
  1. When you visit our forum or blog and “leave a reply”
  2. When you subscribe to our newsletter
  3. When you contact us (e.g. customer support, help, submit a request) and/or schedule a meeting
• When you make use of, or interact with the SURE Universal Smart TV Remote Control mobile software application, and any other mobile software application, that we license (each individually, and collectively, the “App”).
  1. When you download our App
  2. When you sign up for an account, login or use/purchase our services and/or products
  3. When you contact us (e.g. customer support, help, submit a request)
• When you attend a marketing event and provide Personal Data
• When you exchange business cards with us
• When we use the Personal Data of our service providers
• When we use the Personal Data of our customers

The Website and the App are individually and collectively referred to herein as the “Services”.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data or Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Terms of Use and EULA. This Privacy Policy forms part of our Terms of Use which is available at https://www.sureuniversal.com/terms-of-use (“Terms”) and the App’s End User License Agreement which can be viewed from within the App and which you accepted prior to downloading, installing and/or using the App for the first time (“EULA”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms or the EULA.

Table of contents:

• What information we collect, why we collect it, and how it is used
• How we protect and store your personal data
• How we share your personal data
• Additional information regarding transfers of personal data
• Your rights
• Use by children
• How can I delete my account?
• Links to and interaction with third party product
• Log files
• Use of Google Analytics
• California privacy rights
• Our California do not track notice
• Deletion of content from California residents
• How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

2. HOW WE PROTECT AND STORE YOUR INFORMATION

1. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

1. Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 1, we may share your information as follows:

• To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
• If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. 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 transfer or assign Personal Data in connection with the foregoing events.
• Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

2. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

Access from Israel

With respect to the access from Israel, please note that Israel was declared as a country offering an adequate level of data protection by the European Commission. Please read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

External transfers.

Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services or our business partners, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

4. YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

• You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.

• You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
• The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
• The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
• The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

• You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

5. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under eighteen (18), you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

6. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing [email protected]. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, to the maximum extent permitted by law, given the nature of certain features of the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

7. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Site may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). 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.

8. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information

9. ANALYTIC TOOLS

We use analytic tools to understand how our customers and users use our products and services. The terms and privacy policies of such third parties shall apply and, to the extent required, prevail. For example:

• Google Analytics. The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

• Firebase Analytics. We also use a similar tool called “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. In addition, we bring to your attention that:

Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.

10. CALIFORNIA PRIVACY RIGHTS

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 [email protected]. Please note that we are only required to respond to one request per customer each year.

11. OUR CALIFORNIA 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 Site.

12. 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. To remove, please send an email to [email protected]. 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.

13. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected], for general inquiries

Last updated: November 6, 2018