Ultrahaptics Limited (“We“) are committed to protecting and respecting your privacy.
For the purpose of the Regulation (EU) 2016/679 (the General Data Protection Regulation) (the “Regulation”), the data controller is Ultrahaptics Limited, with its registered office at The West Wing, Glass Wharf, Bristol, England, BS2 0EL.
1. CONTACTING US
Questions, comments and requests regarding this Policy or the treatment of your personal data (including requesting any correction, amendment or update to, or deletion of, your information) are welcomed and should be addressed to Data Protection at Ultrahaptics Limited, The West Wing, One Glass Wharf, Bristol, England, BS2 0EL or firstname.lastname@example.org.
2. INFORMATION WE COLLECT
Information we hold about you will be held no longer than necessary for the purposes listed at Paragraph 3.
We will collect and process the following data about you:
- Information you give us: This is information about you that you give us by filling in forms on ultrahaptics.com (our/the “site“) or by corresponding with us by phone, e-mail, in person at public demonstration events or otherwise. It includes information you provide when you subscribe to our newsletter, sign up for our Evaluation Kit, order one of our development kits, register to use our Sensation Editor tool, sign up for our academic program, or register your interest in, sign up for or pre-order any of our other software or hardware, register to use our site, search our site, place an order for software or hardware, whether through us, or through a third party vendor, apply for a job (including by sending in your CV), and when you report a problem with our site (including by raising a support ticket). The information you give us may include your name, job title, address, e-mail address, phone number, debit or credit card information, educational institute (in the case of signing up for our academic program), personal description and qualifications (in the case of applying for a job).
- Information we collect about you: With regard to each of your visits to our site, including when you access and use the Developer Area at developer.ultrahaptics.com, we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer or other electronic device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and the type of electronic device used;
- information about your visit, including details of the pages you visit, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
- Information we receive from other sources: This is information we receive about you if you use any of the other websites we operate, the other services we provide, or from sources not linked to us including:
- any information you have published on LinkedIn, which may be used to contact you regarding potential roles with us; and
- information that you have provided to external recruiters and given your consent to them to share with us for recruitment purposes.
Please note that we use a service provided by a third party, Nalpeiron Inc. (“Nalpeiron”) in relation to use of Sensation Editor:
- to verify on startup of Sensation Editor that your use of Sensation Editor is authorised. At that stage, Nalpeiron will assign a unique identifier (“UID”) to the electronic device on which you are using Sensation Editor, and will collect and store the UID and details of the verification/check, which will be recorded and associated with the UID;
- if relevant, to verify that your use of paid-for features within Sensation Editor is authorised. At that stage, Nalpeiron will collect and store details of the verification/check, which will be recorded and associated with the UID;
- to collect information about the technical specifications of the computer or other electronic device being used to run Sensation Editor, including (but not limited to) details of the operating system or type of device, screen resolution, the graphics card and speed of the processor; and
- to collect usage data, which will be associated with the UID, including (but not limited to) which buttons or features are used most frequently and in which order. We will not collect information that would allow us to reconstruct a user’s output. Although we would collect information recording that, for example, after selecting item “J”, a user adjusted controls “C1” and “C2” away from their default values, we would not collect the fact that, for example, “C1” was set to “yellow” and “C2” was set to “33”.
As part of the service provided by Nalpeiron, your IP address will be collected and processed, but only for the purposes of collating your country of origin.
The following types of cookies may be used by Ultrahaptics:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, or to put items of software in your shopping basket and use our check-out process).
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the information below:
Purpose: Used to override any security restrictions based on the IP address the visitor is coming from.
More information: https://support.cloudflare.com/hc/en-us/articles/200170156-Whatdoes-the-Cloudflare-cfduidcookie-do This cookie does not store any personally identifiable information. It is strictly necessary for site security operations and cannot be turned off.
Cookie: Google Analytics
Purpose:Analytics.js cookies _ga and _gid are used to distinguish users and measure how users interact with website content. Analytics.js cookie _gat is used to throttle request rate.
Purpose:Used to verify who the user is.
4. USES MADE OF THE INFORMATION
We use information held about you in a number of ways, set out in more detail below. We use this information:
- where we have an appropriate business need to relating to the operation and promotion of our business. In doing so, we balance these appropriate business needs (set out below) with your right to have your information treated in a way which does not unreasonably prejudice your interests;
- where we have a contract with you, in order to perform our contractual obligations; and
- where required to do so, in order to comply with legal obligations which apply to us.
- Information you give to us: We will use this information:
- to enter into agreements with you, to carry out our obligations arising from any such contracts entered into between you and us, to provide you with the information, products and services that you request from us, and to engage with you in relation to the provision of your services to us under any such contracts;
- to enable our third party vendors to carry out their obligations arising from any contracts entered into between you and them and to provide you with the information, products and services that you request from them. This includes the sharing of your information with our third party vendors to facilitate any purchase by you of hardware;
- to notify you about changes to our service in relation to a contract that we have with you.
- With your prior permission we will also use this information for Marketing Purposes, including:
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to contact you with questionnaires about our goods or services so that we may carry out market research and analysis to improve those goods and services;
- to provide you with information about goods or services we feel may interest you.
- Information we collect about you: We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer or other electronic device;
- to allow you to participate in interactive features of our service, if and when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- Information we receive from other sources: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive) and the following purposes:
- to allow us to understand the demographics of our users and their equipment;
- to improve our software (including Sensation Editor) and services;
- to contact you via LinkedIn regarding potential roles at Ultrahaptics;
- to verify that your use of our software (including Sensation Editor), and/or your use of paid-for features within our software (including Sensation Editor), is authorised.
5. DISCLOSURE OF YOUR INFORMATION
You understand that we may share your information with:
- Any member of our group, which includes our ultimate holding company Ultrahaptics Holdings Ltd and, its subsidiaries (as defined in section 1159 of the Companies Act 2006), including Ultrahaptics North America Inc.
- Selected third parties including:
- business partners, suppliers, sub-contractors, collaboration partners, auditors, legal and tax advisors, service providers and third party vendors for the performance of any contract we enter into with you, or that you may enter into with them. This includes disclosure to our distributors so that orders for hardware can be fulfilled; and
- analytics and search engine providers that assist us in the improvement and optimisation of our site and our software (including, in relation to Sensation Editor, Nalpeiron, its partners, subsidiaries and affiliates).
- We will disclose your personal information to third parties in the following circumstances:
- if we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets only if necessary for the sale or purchase;
- if a third party acquires Ultrahaptics or substantially all of its assets, in which case personal data held by Ultrahaptics (including that about its customers), will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if required by any court or tribunal of competent jurisdiction, or in order to enforce or apply our licence terms.
For more information about this section please contact us at the address or email listed at the end of this Policy.
6. WHERE WE STORE YOUR PERSONAL DATA
The information that we collect from or about you may be transferred to, stored and processed at a destination outside the European Economic Area (“EEA“), including in the event of transfers to Ultrahaptics North America Inc. and our office in South Korea. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, distributors or service providers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. In particular, if you place an order for hardware in the USA or Japan, or to be distributed in the USA or Japan, the information we hold about you will be transferred to, stored and processed at a destination in the USA or Japan, in connection with the fulfilment of your order. In relation to the service provided by Nalpeiron, the information collected (see above) will be transmitted to servers used by Nalpeiron for storage and further processing by us, Nalpeiron or Nalpeiron’s partners, subsidiaries or affiliates. This may involve transfers to, and storage and processing at, a destination outside the EEA, including (but not limited to) the USA.
The transfers, storage or processing described in this section are necessary: (a) for the performance of a contract between us and the relevant third party, where such contract has been concluded in your interest, or (b) between you and us, or in relation to pre-contractual steps relating to that contract. Where you have consented to use of your personal information for marketing purposes, we will transfer that information to our email marketing service provider, who is based in the USA and is certified under the Privacy Shield framework (for more information about the Privacy Shield framework, please see here). We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, such as the Developers Area, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take all steps reasonably necessary to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your data. You can also exercise the right and can withdraw your consent at any time by contacting us at FAO Data Protection, Ultrahaptics Limited, The West Wing, One Glass Wharf, Bristol, England, BS2 0EL or email@example.com. Alternatively, if you receive our marketing emails you can unsubscribe from further marketing emails from us by selecting the “unsubscribe” link at the bottom of our emails to you. Please note that it can take 24 hours for us to receive notice of this so you may continue to receive marketing emails in the interim period. If you have asked us to stop using your personal data for marketing purposes, your name and any relevant contact details will be added to and kept on a “suppression list” to make sure that we do not send you marketing communications via the relevant channels in the future.
You also have the right, in some circumstances, to do the following:
- request that we erase information we hold about you;
- receive a copy of any personal information provided to us by you and require us to provide this information to a third party;
- restrict the use of your personal data by us; and
- object to the use of your personal data by us, including where that information is used for direct marketing purposes (as discussed above).
8. ACCESS TO INFORMATION
You have the right to request a copy of information held about you. If you would like a copy of some or all of your personal information, please either write to us at: FAO Data Protection, Ultrahaptics Limited, The West Wing, One Glass Wharf, Bristol, England, BS2 0EL or email us at: firstname.lastname@example.org . Any access request will be free of charge in general (although there are certain circumstances where we can charge a reasonable fee).
We want to make sure that your personal information is accurate and up to date. You may ask us to correct personal information that is inaccurate.
9. OTHER SITES AND THIRD PARTIES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and third party vendors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In relation to the service provided by Nalpeiron (see above), a copy of Nalpeiron’s privacy notice is located at www.nalpeiron.com/privacy.
10. YOUR RIGHT TO COMPLAIN
Should you have a complaint regarding our use of your personal data then please contact us in the first instance so that we have the opportunity to deal with your concerns.
However at all times you have the right to make a complaint to the relevant supervisory authority. The UK supervisory authority is the Information Commissioner’s Office (ICO), whose contact details can be found at: https://ico.org.uk/global/contact-us/.
11. CHANGES TO OUR POLICY