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ubiDesktop Ltd Privacy Statement

Version date 24/05/2018

This Privacy Policy describes how ubiDesktop Ltd and its affiliates ("ubiDesktop", "we", "our" or "us") collect, use, and share information in connection with your use of our website and services (collectively, the "Services").

This Privacy Policy (the "Privacy Policy") does not apply to information our customers may process when using our Services.

For the purpose of the relevant data protection regulations, the company in charge of your information (as known as the Data Controller) is ubiDesktop Ltd of 41 Devonshire Street, G.F. , London, W1G 7AJ.

Our registration number with the Information Commissioner’s Office UK is ZA425419.

Information we collect from you
1. INFORMATION YOU PROVIDE:
  1. Account Registration. When you register for an Account, we ask for your contact information, such as full name, company details (if any), address, email address and mobile telephone number.
  2. Desktop Sharing. If you choose to share the management of your virtual desktop(s) with another person (eg. friend, employee, colleague, etc.), we also collect his email address so that we can send him an invitation to sign up for our Services.
  3. Payment Information. When you provide payment details to pay for your subscription by credit card this information is passed directly to our payment service provider over an encrypted link and is never stored on our system; however, we have access to, and may retain, certain information through our third-party payment processor.
  4. Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
  5. Further Identification. In order to prevent credit card fraud or identity theft, we may, in some cases, require you to provide us with a copy (scan/photo) of your passport or ID card together with a copy (scan/photo/screenshot) of the front side of the credit card used. These documents are deleted after three weeks.
2. INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES:
  1. Cookies and other Tracking technologies. When you use our Services, we collect certain information automatically from your device. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area ("EEA"), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.
  2. Usage of our Services. When you use our Services, we collect information about your engagement with and utilization of our Services, such as processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
3. INFORMATION WE MAY RECEIVE FROM THIRD PARTIES:
  1. Third-Party Partners. We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.
How we use information
1. Providing Services. When you register with us, we use information to create an Account and provide you with access to Services.
2. Processing Orders. When you place an order, we use information to process the transaction and calculate the sales taxes (eg. VAT) which may arise in your country.
3. Customer Care. When you ask for technical support or enquire about our Services, we use information to respond to you.
4. Service Improvement We use information to compile aggregated statistics about the operation and use of the Services and carry out research and development to improve our Services.
5. Notifications. We use information to send you technical alerts, maintenance notices, reports, updates, security notifications and other Service-related communications.
6. Marketing. If you have given your consent, we use information to send you marketing and promotional comunications.
7. Fraud prevention. We use information to investigate and prevent fraud, unauthorized access or use of Services, breaches of terms and policies, and other wrongful behavior.
8. Terms enforcement. We use information to enforce our Terms of Service or other legal rights.
9. Law compliance. We use information to comply with laws, regulations, legal processes, or governmental request.
How we share information
1. Service Providers. We will share certain information with third-party service providers which help us to provide our Services to you. These providers are in charge of sending email and SMS, providing customer care services, handling credit card transactions, providing marketing assistance and data analysis, etc. In choosing to work with any such third parties, we will always ensure that the security policies and confidentiality arrangements of those third parties adhere to the same requirements we ourselves impose and expect, as a minimum. No ownership rights to the data will be transferred to any third party.
2. Aggregate Information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you.
3. Registering through a Referral. If you sign up for our Services through a referral from a friend or our affiliates, we may share information with your referrer to let them know that you used their referral to sign up for our Services.
4. Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
5. As required by Law and similar disclosures. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
6. With your Consent. We may share information with your consent.
Legal basis for processing personal information
1. We will normally collect personal information from you only where we need the personal information to perform a contract with you; where the processing is in our legitimate interests and not overridden by your rights; or where we have your consent to do so. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Third-Party Services
1. You may access other third-party services through the Services, for example by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.
Security
1. We take security and privacy seriously. We will endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. We adopt appropriate, industry standard data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction. For further details of the some of the security measures we have implemented, please see HERE. Where we utilise third parties to help provide our services, we will always ensure that the security policies and confidentiality arrangements of those third parties adhere to the same requirements we ourselves impose and expect, as a minimum. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the ubiDesktop website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Please note that the internet is not a secure medium and although we will do our best to protect your data, we cannot guarantee the security of any data transmitted through our Services. Any transmission is at your own risk.
Data retention
1. We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Access
1. If you are a registered user, you may access certain information associated with your Account by logging into our Services. If you terminate your Account, any activity on your Account prior to deletion may remain stored on our servers and may remain accessible to us. To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit ubiDesktop's ability to comply with a legal obligation; inhibit ubiDesktop's ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to ubiDesktop or a third party.
Your Data Protection rigths under the GDPR
1. Access to or update your personal data. You can access to, update or amend your information by visiting the "Account" section on our Website. For data not updateable through this section, you will need to contact us.
2. Withdrawal of consent. Where we rely on your consent to process your personal information, you have the right to decline consent and/or if provided, to withdraw it at any time. You can exercise this right by emailing privacy@ubidesktop.com. This will not affect the lawfulness of processing prior to the withdrawal of your consent.
3. Data Erasure. You can ask us to delete your personal data, you can exercise this right by emailing privacy@ubidesktop.com. However, there may be circumstances where we are legally entitled to retain it.
4. Objection and Restriction. You can object to further processing or restrict the processing of your personal information in certain circumstances. You can exercise this right by emailing privacy@ubidesktop.com.
5. Portability. You can ask us to provide your information in a structured, commonly use and machine-readable form (limited to data that you have provided to us), again you can exercise this right by emailing privacy@ubidesktop.com.
6. Make a Complaint.You may make a complaint about our data processing activities to a supervisory authority. In the UK this is the Information Commissioner's Office (ICO). Further details can be found on their website at https://ico.org.uk.
Data Transfers
1. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us, one of our group companies or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. For a full list of subprocessors and details of the adequate safeguards in place in respect of data transfers outside the EEA, please see HERE
Your Choices
1. You can use some of the features of the Services without registering, thereby limiting the type of information that we collect. You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes. Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Services may no longer work for you. You will continue to receive advertising material but it will not be tailored to your interests.
Children's Privacy
1. Our Services are available for purchase only for those over the age of 16. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 16. If you know of or have reason to believe anyone under the age of 16 has provided us with any personal data, please contact us.
Change to this Privacy Policy
1. This Privacy Policy may be modified from time to time, so please review it frequently. Changes to this Privacy Policy will be posted on our website. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will notify you through our Services, by email or other communication.
Contact
1. If you have any queries relating to this Privacy Policy or ubiDesktop’s use of your personal data, please contact us at privacy@ubidesktop.com or by writing to us at ubiDesktop Ltd, 41 Devonshire Street, G.F. , London, W1G 7AJ.