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We, VORTEX, will follow the concerned regulations and protect your online privacy with our best efforts. This Privacy Policy explains why and what information VORTEX will collect and/or process, and how VORTEX will deal with it. If you have any questions, please contact your service provider.

Your personal data - what is it ?

”Personal data” means data includes, but is not limited to

• User contact details, names, emails
• video and audio data collected from VORTEX and managed by you
• analytics data derived from video and audio data
• logs generated by VORTEX
• Cookies

What roles do we play in processing your data ?

We are the data controller with respect to processing your data. This means that we decide how your personal data is processed and for what purposes. We understand that you care how your personal data is used and shared, and we will deal with it carefully and responsibly.

Your Consent Matters

We will access and process your personal data only if you provide your explicit consent beforehand. You are not under any obligation to provide us any personal data. However, please note that without certain personal data, we may not adequately provide you with our full range service of VORTEX.

The lawful basis for us to access or process your personal data is as below :

1. based on your explicit consent ;
2. as necessary for us to enter into and to perform our contract with you ;
3. as necessary for us to improve, develop, trouble shooting and maintain the service.
4. as necessary for us to comply with our obligation under the regulations ;
5. as necessary for our legitimate interest of transmitting your personal data for internal administrative purposes within our group companies to ensure our network security and to prevent fraud. We have determined that such use of your data is not overridden by considerations of your interests and rights of freedom.

Cookies

We receive and store certain types of data whenever you interact with us. For example, we use "cookies," which are unique identifiers that we transfer to your device for recognizing your device by our systems. When your web browser accesses our web pages, advertisements and other websites on our behalf, we gather certain types of data, such as Internet protocol (IP) address, device ID or token, unique identifier, device type, referral URL, computer and connection data such as browser type and version, your browsing history and your web log information.

You may refuse the use of cookies by selecting the appropriate settings on your browser. Visit www.allaboutcookies.org for details on how to delete or reject cookies. Please note that, however, this may make you unable to use the full functionality of our web services.

Why VORTEX Accesses Your Device

The app will access the following components or information from your mobile devices to perform full app functions :

• Phone status and UD

  We collect phone status and UID to analyze usage status, and improve our services.

• Camera

  The camera is used for QR code scanning.

• Microphone

  The microphone is used when you use 2-way audio in the app.

• Location (approximate location based on Internet hot spot)

  We collect the approximate location based on Internet addresses for data analysis and research to improve our services.

• Internet

  VORTEX requires an internet connection to be accessed.

• Prevent mobile phone from hibernating

  When streaming video, this function will keep the screen on.

What Information We Collect and How We Use It

We collect and use the following information to provide, improve and protect our services :

Essential Service Information

VORTEX will use Essential Service Information to run the cloud service. Essential Service Information refers to the minimum data required to confirm your identity when you wish to access your devices and personal data via VORTEX. This data includes your account name and device ID linked to your account at VORTEX

Your email address will also be used in, including but not limited to, the following cases :

1. Activate the account you create for VORTEX.
2. Notify you when we renew our Privacy Policy and Terms of Use.
3. Notify you about service updates, service interruptions (service temporarily offline) and the payment status for VORTEX.

Information or Content Sharing

Your personal data will be treated as strictly confidential and will only be shared with the categories of data recipients listed below. We will not share your data with third parties outside the Company without your consent.

We may disclose your personal data to :

• Our affiliated entities within our global group of companies to provide you services, to serve our internal administration purposes, to detect and prevent data breaches, illegal activities and fraud, and to maintain the integrity of our information technology systems.
• Third party service providers whom we sub-contract to help us provide our services to you, and those who assist us in detecting and dealing with data breaches, illegal activities and fraud.
• Government, courts, or law enforcement agencies to comply with our obligations under relevant laws and regulations, to enforce and defend our policies and contracts with you, to respond to claims, or used as a response to verified requests relating to a government, criminal investigation, suspected fraud, or illegal activity that may expose us, you, or any other of our customers to legal liability.
• Third parties involved in legal proceedings, under a court order, or substantially similar legal procedure requiring us to do so.

How long do we keep your personal data ?

We keep your personal data for no longer than reasonably necessary for the given purpose that your data is used for. If you offer us or have given consent to process your data, we will process your data for no longer than one year. Notwithstanding the above, we may retain your personal data as required by law to assist judicial investigations, and to initiate or defend legal claims for the purpose of civil, criminal or administrative proceedings. If none of the above grounds applies, we will delete and dispose of your data in a secure manner according to our data protection policy.

Your rights and your personal data

Unless subject to an exemption under the concerned regulations, you have the following rights with respect to your personal data :

• The right to request a copy of your personal data ;
• The right to request that we correct the data, if it is found inaccurate or out of date ;
• The right to request that we erase your personal data where it is no longer necessary for us to retain such data. If you choose to delete your account, we will erase your personal data within one month. However, in case of technical difficulty, you will be notified and the complete erasure may take up to two months ;
• The right to withdraw your consent to processing at any time ;
• The right to request that we provide you with your data and where possible, to transmit that data directly to another data controller ;
• The right, where there is a dispute in relation to the accuracy or the lawfulness of our processing of your personal data, to request that a restriction is placed upon further processing of your data ;
• The right to object to us using your personal data to engage in direct marketing ;
• The right to lodge a complaint regarding our processing of your data with the competent authority of the European Union member state where you reside or in which your data is processed.

After receiving your request, we will evaluate your request and inform you how we intend to proceed with your request. Please note that, in accordance with applicable laws and regulations, we may withhold access to your data or decline to modify, erase, port, or restrict the processing of your data.

Transfer of your personal data abroad

Because VORTEX is a global service, we must be able to transmit your data to other countries within our worldwide service host servers for the reasons set forth above. In making such international data transfers, we will ensure the protection of your personal data by applying the highest levels of security required by the applicable data protection regulations.

Further processing

Before we use your personal data for a new purpose not covered within this data privacy policy, we will provide you with a new notice explaining this new usage prior to commencing. In such cases, we will find a lawful basis for the further processing and seek your prior consent to such further processing.

Security

We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, and loss of access. Some of the safeguards we use are data pseudonymization, data encryption, firewalls and data access authorization controls. We take data security very seriously, therefore the security mechanisms used to protect your data are checked and updated regularly to provide the most effective protection against abuse.

If you believe that the security of your data has been compromised, or if you would like to know more information on the measures we use to protect your data, please contact your service.

Privacy of data subjects under the age of 16

Our products and services are not targeted to persons under the age of 16. We do not knowingly collect or process personal data from persons under the age of 16.

Limited Liability

We will do our utmost to protect users' personal data. Should a data breach occur, we will notify our users and take every effort to remedy it ASAP.

We will in no event be liable under this Privacy Policy and the services to you for any indirect, incidental, special, consequential or punitive damages, whether foreseeable or unforeseeable, of any kind whatsoever, whether based on warranty, contract, tort (including negligence) or any other legal equitable theory, even if it has been advised for the possibility of such damages. Our aggregate liability to you for losses, damages, costs, expenses, and other amounts arising out of or relating to this Privacy Policy and the services, regardless of the theory of liability, will in no event exceed the amount paid by you in the last 12 months.

Changes

We reserve the right to revise this Privacy Policy and will release the most current version on our Website.