SERAPHIC Information Technology (Shanghai) Co., Ltd. (“SERAPHIC”) knows how important privacy is to our users, and we strive to be clear about how we collect, use, disclose, transfer, and store (collectively, “process”) your personal information. This Privacy Policy (“Privacy Policy”) explains our personal information processing practices.

This Privacy Policy applies to all SERAPHIC products, software, services and websites (collectively, “Services”). This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, TV, set-top box or other smart device (“Device”) to access our Services.

It is important that you read the Privacy Policy carefully because it provides information on how your personal information is processed anytime you use our Services.

It is also important that you check back often for updates to the Privacy Policy. If we update the Privacy Policy we will let you know in advance of any material changes, by placing a notice on the relevant Services or by e-mailing you, when appropriate. The most current version of the Privacy Policy will always be available here http://www.seraphic-corp.com/privacy. You can check the “Last Updated Date” posted at the top to see when the Privacy Policy was last updated.

Controller of Personal Information

SERAPHIC Information Technology (Shanghai) Co., Ltd., with its principal business address at F6, Guoyang Building, Guoquan Road No. 98, Yangpu District, Shanghai, China, is the data controller of personal information processed through SERAPHIC Services. Details can be found at http://www.seraphic-corp.com/en/about.aspx.

Description of Processing Activities and Legal Grounds for Collection

We collect your personal information for the purposes listed and explained here below.

1. Contact Information We Collect To Provide Services

We collect and store any information you directly give to us in relation to our Services. The information you may provide is listed as follow:

• A number of our Services enable users to create accounts or profiles (“Account”). If you want to set up an account or profile, we will ask you to submit certain information about yourself, such as your name, date of birth and e-mail address.
• If you want to subscribe our newsletters to get our latest news, we will collect your e-mail address and name.
• If you contact our Data Protection Officer to discuss your personal information issues, we will collect information from you regarding the service you require from SERAPHIC. Such information collected may include your name, e-mail address, home address, telephone number, or other unique identifiers that would allow us to identify you.

This personal information is used to provide the Services you request and in order to communicate with you in relation to SERAPHIC Services via different channels (e.g., by phone, e-mail, chat).

This type of data processing is necessary for the performance of the contract (or necessary to conclude the contract) with SERAPHIC (6.1.b GDPR).

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of SERAPHIC Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

You can choose not to provide certain information, but then you may not be able to take advantage of many of our Services. Any information required by law or contract will be marked with an asterisk.

2. Technical Information We Collect To Prevent Copyright Infringement and Security

In addition to the information you provide, we will verify certain elements of information about you and your use of our Services. This information includes:

• device IDs such as mac address, Unique Device ID (“UUID”), or other unique identifiers of your Device;
• IP address (which may tell us your general location);
• whether your Device has been properly licensed to install and run SERAPHIC Services and whether such Services have been altered;

We use your abovementioned personal information to ensure proper licensing and security. For example, we collect the MAC address and UUID of your Device to verify whether your Device has the proper license to install and run SERAPHIC Services, and that the Services have not been altered, so that your privacy is not compromised by hacking or malicious code.

We will use the information to help improve the safety and reliability of our Services; to detect, prevent, and respond to fraud, abuse, security risks, and technical issues that could harm SERAPHIC, our users, or the public.

Information processing in this regard is based on SERAPHIC’s legitimate interest to safeguard its property rights and furnish safe Services to its clients (article 6.1.f GDPR).

This type of personal information is only processed in order to verify the software’s conformity. To the extent permitted by any applicable mandatory laws and regulations, it is stored for as long as you are a user of SERAPHIC Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

3. Advertising

When creating a profile with us, you will be requested if you would like to receive personalized advertising that display interest-based ads for features, products, and services that might be of interest to you.

If you agree we will collect information regarding:

• Clickstream data, which is a record of the web pages you have visited;
• Search data. For example, if you search for “mountain bikes,” you may see an ad for sports equipment;
• Account data. When you create a profile with SERAPHIC you probably enter information about your age and interests. For example, if you list one of your interests as "board games," you may see ads for Scrabble, Monopoly or Life.

Any such processing will be based on if you consent to it (article 6.1.a GDPR).

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of SERAPHIC Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

4. User Experience Improvement Program

This is an optional, fully consensual program you can choose to participate in. If you have agreed to participate in our User Experience Improvement Program, we will collect information regarding your activity on SERAPHIC Services, including:

• favorite webpages and apps, browsing history, search queries, views and interactions with content and ads, purchase activity, activity on third-party sites and apps that use our Services;
• collect statistics on your page views, referring source (for example, referral URLs), browser and standard web server log information;
• advertising identifiers, such as cookie, pixels;
• your interactions with us such as email and text messaging;

If you have agreed to participate in our User Experience Improvement Program, we will use personal information collected under the program to:

• determine your general geographic location, provide localized content, analyze your usage to determine your preferences, and to provide you with customized and personalized features, products, and services that may be of interest to you,
• identify your Internet service provider, and help us to quickly and efficiently respond to inquiries and requests,
• analyze the activity to create statistical and completely anonymized data sets,
• allow you to quickly visit or download your list of favorite webpages and apps and/or your browsing history, or sync them among your different Devices, and
• provide suggested viewing options based on your past viewing choices and habits.

The information collected is not used to identify or contact you. This information processing is based on your consent (article 6.1.a GDPR).

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of SERAPHIC Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

5. Provide, Troubleshoot, and Improve SERAPHIC Services

In order to improve our Services’ functionalities and to rectify any problems in connection or the provision of Service. We may collect the following information:

• device and software characteristics such as SoC model, TV brand, software version number, operating system version, and settings of the Device you use to access the Services;

We use your personal information to provide functionality, analyze performance, fix errors, and improve usability and effectiveness of SERAPHIC Services.

This data processing necessary for the performance of the contract and based, in part, on SERAPHIC’s legitimate interest to improve its Services and provide optimal Services to clients (article 6.1.f GDPR).

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of SERAPHIC Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

In certain cases, we will have a legal obligation to collect and process your personal information. You will be informed of the specific purposes, when the case arises (article 6.1.c GDPR).

Does SERAPHIC Share Your Personal Information?

We may disclose your information internally within our business to the relevant teams, such as, without limitation the customer services team, the legal team, the finance team, the sales team and where you have chosen to receive marketing messages, to the marketing teams. We may only disclose your information to a third party under one of the following conditions:

• Third Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include cloud-based data storage, sending postal mail and e-mail, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, and providing customer service. These third-party service providers have access to personal information only as needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with and as permitted by applicable data protection laws.
• Business Transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the user consents otherwise). Also, in the unlikely event that SERAPHIC or substantially all of its assets are acquired, user personal information will of course be one of the transferred assets.
• Protection of SERAPHIC and Others: We release certain personal information when we believe such release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of SERAPHIC, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• Other than as set out above, you will receive notice when personal information about you might be shared with third parties and you will have an opportunity to choose not to share the information.

Transfers out of the European Economic Area.

WE MAY TRANSFER AND STORE YOUR DATA OUTSIDE THE EUROPEAN UNION (“EU”) AND EUROPEAN ECONOMIC AREA (“EEA”) IN ORDER TO PROVIDE YOU WITH OUR SERVICES (49.1(B) GDPR).More specifically, we may transfer your data to our headquarters at SERAPHIC Information Technology (Shanghai) Co., Ltd., with its principal business address at F6, Guoyang Building, Guoquan Road No. 98, Yangpu District, Shanghai, China for the purposes outlined in this Privacy Policy. We will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection. In particular we will ensure an adequate level of protection and implement the necessary safeguard measure, such as the conclusion of EU standard clauses (for a copy of these clauses please write to: dpo@seraphic-corp.com).

How Secure is Information about Me?

We take protection of your data seriously, we use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

• We use the method of pseudonymization when processing some of your personal information. After pseudonymization, your personal information can no longer be attributed to you without the use of additional information, and such additional information will be kept separately and is subject to technical and organizational measures to ensure that the personal information are not attributed to you;
• We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you or respond to any of your requests relative thereto;
• Our Services offer security features to protect them against unauthorized access and loss of data. You can control these features and configure them based on your needs;
• We restrict access to personal information to SERAPHIC employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations; and
• It is important for you to protect against unauthorized access to your password and to your Devices, and applications.

However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

What about Third-Party Advertisers and Links to Other Websites?

SERAPHIC Services may include third-party advertising and links to other websites or platforms. These third parties may collect information about you when you interact with their content, advertising, and services. Please note that these third parties have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully, and we are not responsible for the security or privacy of any information collected by them.

What Rights Do I Have?

We respect your privacy rights and provide you with reasonable access to the personal information that you may have provided through your use of the Services.

Your Rights

You may request access to the information we collect about you, and request to correct or complete any inaccurate or incomplete information, object to or request the restriction of processing, and the erasure or portability of your information. Your requests will be honored in accordance with the applicable legal conditions.

If you have created an Account with us for our Services, you may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Services.

If you wish to access or amend any personal information we hold about you, or to request that we delete or transfer any information about you that we have obtained from a Service, you may contact us as set forth in the “Contacting Us” section.

At your request, we will have your personal information deleted or blocked in our database. You understand that, your request for deletion will be treated on the basis of the applicable legal conditions and SERAPHIC reserves the right to keep your personal information, or a relevant part of it, in line with this Privacy Policy and as may be necessary for evidentiary purposes.

Further, if you request deletion of your personal information, you acknowledge that you may not be able to access or use part or all of our Services, in which case we may not be able to provide to you some of the features and functionality of the Services.

Moreover, in some instances, under the laws of some jurisdictions, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

Withdrawal of Consent

Generally speaking, when you consent to the processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose. This will not impact the lawfulness of past processing. Similarly, you can unsubscribe from the User Experience Improvement Program at any time and object.

User Experience Improvement Program Information

Depending on the type Device you are using, you may unsubscribe from the User Experience Improvement Program (“UEIP”) by taking one of the below three actions:

• Withdraw through your Device Setting Menu. You may withdraw your consent on UEIP by visiting the “Setting” menu of your Device. First, open “Setting” menu of your Device. Second, open “UEIP” menu in the “Setting” menu. Third, slide the button in “UEIP” menu to the left (which will show “off”).
• Withdraw through Email. In the case where the system of your Device does not have a “Setting” menu or does not have a “UEIP” menu, we would request you to provide us your email address when you subscribe to the UEIP, so that we can send you a notification email regarding your subscription. You may withdraw from the UEIP any time by clicking on the “unsubscribe” link in our notification email.
• Withdraw through your Account Setting Menu. If you have created an Account with us, you may withdraw from the UEIP through your Account setting menu. You may do so by logging in your Account at https://account.srafcloud.com.

Upon your withdrawal from the User Experience Improvement Program, we will stop processing your personal information for the program and delete such information in our database. Please note that to ensure the safety of your data and privacy, we would recommend you create an account with us in order to allow us to identify you and help you quickly.

The Right to Object

You will be requested when you first create an account with us, if you would like to receive commercial communications and/or if you would like to receive targeted advertising.

If you do receive commercial e-mails from us, you may unsubscribe at any time by following the instructions contained within the e-mail or by sending an e-mail to the address provided in the “Contacting Us” section.

Please be aware that responding to or implementing a request may take up to ten (10) business days. Moreover, please note, that you will continue to receive administrative messages from us regarding the Services.

Are Children Allowed to Use SERAPHIC Services?

You must be 18 years of age or older to use our Service. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age. While individuals under the age of 18 may utilize our Service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

How Long Does SERAPHIC Keep Your Personal Information?

We will not keep your personal information for longer than is necessary for the purpose it was collected. This means that data will be destroyed or erased from our systems when it is no longer required.

Personal information is held:

• at least the duration for which the information is used to provide you with Services;
• as may be required under law, a contract, or with regard to our statutory obligations; or
• only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards.

For more detail see the description of our activities.

Changes to This Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with the law.

Your continued use of the SERAPHIC service after any such updates take effect will constitute acknowledgement and acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Policy, you may stop your use of SERAPHIC Services.

At the beginning of this Privacy Policy, you can see when this Privacy Policy was updated and when it took effect.

Contacting Us

If you have any concern about privacy or questions related to data protection at SERAPHIC, please contact our data protection officer, in doing so please include a thorough description of your issues and we will try to resolve them for you. The data protection officer mentioned above can be contacted at dpo@seraphic-corp.com. If you are an individual in European Economic Area, you can also contact our representative at patrice.silvant@seraphic-corp.com.

Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

You may lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal information infringes applicable law.