1. This privacy policy (“Privacy Policy”) is issued by uCloudlink (Singapore) Pte. Ltd. and its affiliates (“we”, “us,” “our,” or “uCloudlink”) and covers our practices regarding the collection, use, storage, transfer, and other processing of individually identifiable information about you (“Personal Information”) when you contact us, purchase, install, access or use our products, apps, services, or websites (collectively the “Services”).
2. There may be jurisdiction specific provisions of this Privacy Policy for certain countries or regions. Please refer to Local Privacy Terms in Exhibit A for more information.
3. By using the Services, you agree to be bound by uCloudlink’s Terms and Conditions and acknowledge that you have read and understood uCloudlink’s Privacy Policy. This Privacy Policy constitutes a part of uCloudlink’s Terms and Conditions.
4. In order to provide our Services, we collect and process your Personal Information in several ways, including when you:
5. Cookies and similar technologies (e.g. pixels and ad tags) (collectively “Cookies”) are small files which, when placed on your device, enable us to collect certain information, including Personal Information, from you in order to provide certain features and functionality. We and our service providers use Cookies to collect data and recognise you and your device(s). We do this to better understand the effectiveness of our Services and to enhance your user experience. To learn more about our use of Cookies, please find the Cookies Table at the end of this Privacy Policy.
6. Depending on the nature of your interaction with uCloudlink, we may collect, store, and use the below categories of information:
7. In accordance with our contract with you and to perform the obligations under such contract, uCloudlink will use your Personal Information to:
8. In accordance with our legitimate interests to provide an effective and dynamic service, we may use your information to:
9. With your consent, we will process your data to participate in market research related to our products and services. You can withdraw this consent at any time.
10. Except for the following circumstances, uCloudlink and its affiliates will not share your Personal Information with any third party without your consent.
11. uCloudlink and its affiliates may share your Personal Information with its partners, and third party suppliers, such as AWS for data hosting, as well as with other contractors and agents for the following purposes:
. to fulfil uCloudlink’s responsibilities and obligations in the Terms and Conditions and this Privacy Policy; and
. in connection with a merger, sale, or asset transfer.
12. If you pay for your Services using Paypal, Braintree, Paypal or Stripe, you acknowledge and agree that the processing of such payment shall be handled by that third party and will be subject to their terms and conditions and your data will be handled by them in accordance with their privacy policy. You must review these third party terms before proceeding.
13. We put in place contracts with third parties containing appropriate commitments regarding the handling and security of your personal data.
14. uCloudlink or its affiliates may save, store or disclose your Personal Information for the following purposes:
15. Your Personal Information and documents are stored on uCloudlink’s servers and the servers of third-party providers we engage to provide services to us. uCloudlink will take appropriate steps to ensure that any such third party complies with appropriate confidentiality and security measures.
16. Personal Information is stored by Amazon Web Services (AWS), with EU and UK Personal Information being hosted in Ireland and non-EU Personal Information being hosted in Singapore, except for data relating to Chinese users, whose Personal Information being hosted in China.
17. If you are located in the EEA, please see Local Privacy Terms for additional information about the safeguards we take to protect your Personal Information when it is transferred outside of the EEA.
18. 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. For further information about the specific rights you have to access, update, correct or delete your Personal Information, please refer to the relevant local section of the privacy policy below for further information.
19. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.
20. Unfortunately, no security system or system for the transmission of information via the internet can be guaranteed as completely secure. uCloudlink maintains appropriate technical and organizational measures to protect against unauthorized or unlawful processing of Personal Information and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to your Personal Information. To try to prevent unauthorized access, maintain data accuracy and ensure the correct use of information, uCloudlink maintains physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of Personal Information. Only a limited number of persons within our organization are authorized to access, delete or modify your data. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information. uCloudlink evaluates these measures on a regular basis to ensure the security of processing.
21. uCloudlink employees or any of uCloudlink’s contractual partners who have access to your data in order to provide services to uCloudlink or uCloudlink’s customers are contractually obligated to keep such information in confidence and may not use these data for any other purpose than performing their contractual missions for uCloudlink or uCloudlink’s customers.
22. If we recognize that you are not of the age of majority in your country, we will terminate the service and delete your information. We will notify you by app push, email and SMS before terminating the service.
23. We will delete your Personal Information within 60 days of you deleting your account unless we have a legal obligation to retain such data in which case we shall retain such data only for so long as we are required to do so by law.
24. We may amend or update this Privacy Policy from time to time, consistent with applicable privacy laws and principles. We will notify you such changes will notify you by app push or in-app messaging. Your continued use of the Services constitutes your acceptance of our Privacy Policy.
25. If you have any questions about this Privacy Policy or our products, please feel free to give us a feedback. You can reach us by email at:
UK/EU
I. Your Rights Under GDPR and the UK Data Protection Act 2018
Data Controller
For purposes of the General Data Protection Regulation of EU and Data Protection Act 2018 of the UK, the data controller responsible for processing of Personal Information described in this Privacy Policy is:
International Transfer of Personal Information
As described above,[ Hyperlink to ‘Where we Store your Personal Information’ section in Privacy Policy] the Personal Information that we collect from you will be transferred to, and stored at, a destination outside of the UK and EEA. Where we transfer your Personal Information to countries outside of the UK and EEA (as applicable), we do so under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., standard contractual clauses) pursuant to Commission Decision 2004/915/EC or 2010/87/ EU (as appropriate) or in line with any replacement mechanism approved under EU or UK law.
Data Subject Rights
To the extent required by applicable law and subject to legal limitations, you may have the following rights related to our processing of your personal information.
If you are concerned that any of the information we hold about you is incorrect, out of date, or may be used inappropriately, please contact us[ Hyperlink to ‘Contact Us’ section] with your concerns and we will take appropriate steps to amend our records.
uCloudlink is committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that uCloudlink has not been able to assist with your complaint or concern, you have the right to make a complaint with a competent data protection authority in the UK or EU Member State where you reside or where you believe the breach occurred.
| Purpose | Description |
|---|---|
| Authentication | We use cookies to recognize you when you visit our Services. |
| If you’re signed in, cookies help us show you the right information and personalize your experience in line with your settings. | |
| Security | We use cookies to make your interactions with our Services faster, more secure and to help us detect malicious activity and violations of our Terms and Conditions. |
| Preferences, features and services | We use cookies to enable the functionality of our Services, and provide you with features, insights and customized content. We also use these technologies to remember information about your browser and your preferences. |
| Functional | We use cookies to improve your experience on our Services. |
| Analytics and research | Cookies help us learn more about how well our Services and plugins perform in different locations. We or our service providers use cookies to understand, improve, and research products, features and services, including as you navigate through our sites or when you access our website from other sites, applications or devices. We or our service providers, use cookies to determine and measure the performance of ads or posts on and off our website/ app and to learn whether you have interacted with our websites, content or emails and provide analytics based on those interactions. |
| We also use cookies to provide aggregated information to our customers and partners as part of our Services. |