Privacy Policy

PRIVACY POLICY 

Last Updated: November 19, 2021

1. INTRODUCTION

ULINK Technology, Inc. (“ULINK,” “us,” or “we”) respects the privacy of the visitors to the ULINK websites which include ULINKtech.com, ulinkda.com, https://qnap.ulinkda.com, ulinkreporter.com, and https://www.ulink-da.com (“websites” or “sites”) and users of ULINK software. This privacy policy (“privacy policy” or “policy”) is an agreement between ULINK and you, as the user of the ULINK websites or ULINK software (“you”). This agreement tells you when this policy is effective, what information we collect from you, how we might use it, how you can review or change the personal information you provided to us, how we may change this policy, and the steps we take to ensure that your personal information is protected.

2. AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF USE

All activities in which you may engage on the websites and software are voluntary. You are not required to provide any personal data to us unless you choose to access features on the sites which require the information. If you do not agree with the terms of this policy or other terms of use on the websites, then you should immediately exit the websites or software and discontinue using the sites or software. If you do not agree with the terms of our privacy policy posted at https://ulinktech.com/privacy-policy/, and our terms of use posted at https://ulinktech.com/legal/terms-of-use/, please do not provide us with personal data, and leave the websites. The terms of use of the sites are expressly incorporated herein by reference and made a part of this policy. By using the ULINK websites, you signify that you agree to the terms of this privacy policy as well as to our terms of use. 

3. EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY

This privacy policy is effective as of August 23, 2021, and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the websites. We reserve the right to change this privacy policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to the sites. You should check this policy periodically as its terms may change from time to time. Your continued use of the sites after we post any such modifications will constitute your acknowledgment of the modified policy and your agreement to abide and be bound by the modified policy. We will also revise the “last updated” date found at the beginning of this privacy policy and in this section when we post changes to it. 

4. POLICY APPLICABLE TO ONLINE ACTIVITIES ONLY 

The privacy policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond ULINK’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation. This privacy policy only applies to information collected through the sites and software. This privacy policy does not apply to any information we may collect from you in any place other than the websites and software. 

5. PERSONAL DATA WE MAY COLLECT 

We may ask you for certain information referred to on the sites and software as “personal data,” which includes information that is capable of being associated with, or could reasonably be linked, directly or indirectly, with your identity as an individual. Such information may include, items such as your name, address, date of birth, age, gender, e-mail address, telephone number, identification number, location data, online identifiers, device serial numbers, credit card, account data, employment information, Internet Protocol (IP) address, and account activity. You may be required to provide personal data to access or use certain parts of our websites and software, services, or features of the sites and software. If you do not provide the requested personal data, you may not be able to access or use the features of the sites and software where such information is requested. 

5.1. Click Stream Data. When you visit our website we may also collect “click stream data” (server address, domain name). This information can be combined with information you have provided to us by registering, for example, which will enable us to analyze and better customize your visits. We may use click stream data for traffic analysis of our website, to determine which features of our site are most or least effective or useful to you. 

5.2. Cookies. We may also use cookies to gather information about your visits to our website and enhance your experience. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used for such activities as remembering your user name and password, if you use such a feature on this site. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the website you visit and you may lose access to some of its features

6. HOW WE USE YOUR PERSONAL INFORMATION 

We will primarily use the personal data you provide for the following purposes:

A. To send you information or materials via e-mail about products, offers, and news we think might interest you. This information may relate to products, offers, and news of the ULINK or its licensees or selected commercial partners. 

B. To complete a purchase or provide you access to the websites, software, and our services. 

C. To verify your identity when you try to access the websites and software, and use our services. 

D. To customize, improve, and enhance our services and our marketing materials. 

E. To improve ULINK’s processes and algorithms and artificial intelligence. 

F. To enforce or defend improper use in violation of our policies and contracts with you.

G. To deter data breaches, illegal activities, and fraud. 

H. To comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interest or legitimate interests of others. 

I. To establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or legitimate interests of others.

7. GENERAL DATA WE MAY COLLECT

There may be other instances in which we collect information from you that is more general in nature that does not directly or indirectly identify you as an individual (“general data”). Such general data may be collected from you whenever you access the site, whether or not you provide us with any personal data. We use this data to help provide more useful information to our customers and to understand the use and access of our website, software, products, and services.

8. PROTECTION OF YOUR PERSONAL DATA AND GENERAL DATA 

8.1. Security Measures. In order to protect the personal data that we receive from you through our websites and software, we have implemented various security measures, including technical, administrative, and physical security measures to protect your information from unauthorized access, loss, and improper use. On a regular basis, we review our security procedures in order to consider appropriate new technology and methods and compliance with applicable privacy laws. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. 

8.2. Risk of Interception. Please keep in mind, however, that whenever you give out personal data online there is a risk that third parties may intercept and use that information. ULINK strives to protect your personal data and privacy, we cannot guarantee the security of any information you disclose online. By using the sites, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through the sites and that any personal data, general data, or other data or information received from you through the sites is provided to us at your own risk, which you expressly assume. 

9. THIRD PARTIES 

9.1. Sharing Data With Persons or Entities Who Manage The Websites. Depending on the services used through the ULINK websites and software, the personal data collected can be managed and controlled by ULINK or third parties. This enables the ULINK websites to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of the ULINK websites. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal information collected are stored.

9.2. Disclosing Data to Third Parties. We do not sell, trade, or otherwise transfer your personal data to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “service partners”). Our service partners may use your personal data to operate our sites, to deliver their services, and to provide our services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the websites or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us. We will encourage our service partners to adopt and post privacy policies. However, the use of your personal data by our service partners is governed by the privacy policies of those service partners and is not subject to our control. ULINK utilizes Amazon Web Services, Inc. (AWS) as a hosting and backend service for the websites. You can read more about how AWS uses your personal information and general information here: https://aws.amazon.com/privacy/. AWS participates in the EU-US and Swiss-US Privacy Shield frameworks. 

9.3. Security. ULINK will release your personal data without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose personal data upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this agreement to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this policy.

9.4. Links to Third Parties. For your convenience and to improve the usage of the websites we may insert links to third parties on the sites. This privacy policy does not apply to such third party websites. These links take you outside our service and off the ULINK’s site and are beyond our control. This includes links from partners that may use ULINK’s logos as part of a co-branding agreement. The sites those links can take you to have their own separate privacy policy and although we seek to protect the integrity of our sites, ULINK is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal data. 

10. DELETING OR MODIFYING PERSONAL INFORMATION

You may cancel your registration at any time, and you may opt out of receiving any e-mails from ULINK. Additionally, you can choose to have all your personal data deleted from our database. You may opt out, or delete or modify your personal data, by contacting us at support@ulinktech.com or writing to Attn: Privacy Compliance, 3120 De La Cruz Blvd., Suite 117, Santa Clara, CA 95054 with your request. We encourage you promptly to update your personal data when it changes. 

Special notes for DA Drive Analyzer users: If you purchased your license from ULINK, you may request a copy, delete, or modify your personal data by emailing ulink_pi@ulinktech.com with your request. If you purchased your license from a seller that is not Vendor, please contact them directly to request a copy, delete, or modify your personal data. Furthermore, ULINK may delete your personally identifiable information after your license has been rendered unusable by any means, including but not limited to: license expiry, license deactivation, or termination of the license by the license seller. 

11. RETENTION OF PERSONAL DATA 

ULINK may retain your personal data for a period of time consistent with the original purpose of collection. We will keep your personal data as long as reasonably necessary for your use of our services and for a reasonable period of time thereafter. We may also retain your personal data during the time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements. If none of the above grounds to keep your data apply, we will delete your personal data in a secure manner according to this policy. 

12. NO USE OF THIS SITE BY PERSONS UNDER 16 PERMITTED 

ULINK intends only persons who are 16 years or older to use the websites. Personal registration information submitted by a person under the age of 16 will not be accepted. Any general information provided by a person under the age of 16 and gathered during his or her visit may be used as indicated in this policy. ULINK is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 16. We will not be liable for any losses or damages incurred by the unauthorized disclosure or processing of personal information under the age of 16. 

13. YOUR RIGHTS TO YOUR PERSONAL INFORMATION 

Unless exempt under application privacy laws, you have the following rights with respect to your personal information:

13.1 Right to Access or Disclosure of Personal Data. You have the right to request a copy of your personal information collected by ULINK. 

13.2 Right to Rectification. You have the right to request modification of your personal information, including the correction or errors and the updating of personal information.

13.3 Right to Deletion/Erasure. You have the right to deletion or erasure of your personal information when it is no longer necessary for us to retain such information, except when we are obligated to comply with a legal obligation or to establish, exercise or defend legal claims.

13.4 Right to Restrict Data Processing. You have the right to withdraw your consent to the processing of your personal information at any time. 

13.5 Right to Data Portability. You can request that your personal information file be sent electronically to a third party when the processing is based on your consent or is necessary for the performance of a contract with you.

13.6 Right to Object. You have the right to request that we stop processing your personal information where you believe such information to be inaccurate or our processing is unlawful. Additionally, you can request that we stop processing your personal information if we no longer need to process such information for a particular purpose unless we are unable to delete the data due to legal or other obligation or your request we retain your personal information.

13.7 Right to Lodge a Complaint. You have the right to lodge a complaint regarding our processing of your personal information, with the competent authority where you reside or in which your personal information is processed. 

14. CALIFORNIA CONSUMER PRIVACY ACT

14.1 Categories of Personal Data. The California Consumer Privacy Act (“CCPA”) requires us to describe the information we collect in certain “categories.” The categories we collect include:  

A. Identifiers (such as your name, alias, address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers); 

B. Commercial information (such as data regarding transactions); 

C. Financial data (such as credit card or payment information);

D. Internet or other electronic network or device activity (such as information on interaction with a website, application, software, or advertisement, and browsing history); 

E. Geolocation data (such as IP-based or city, state, or zip level data); 

F. Inference data (such as user profile information from data in this section); 

G. Legally protected classifications (such as age and gender); and

H. Other information that identifies or can reasonably be associated with you (such as information you voluntarily provide as you use the sites or software, user-generated content or additional profile information).

14.2 Sources of Personal Data. We may collect personal data either directly from you or indirectly from you from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements. 

14.3 Business Purpose. Our collection of information is for the following business purposes:

A. To send you information or materials via e-mail about products, offers, and news we think might interest you. This information may relate to products, offers, and news of the ULINK or its licensees or selected commercial partners. 

B. To complete a purchase or provide you access to the websites, software, and our services.

C. To verify your identity when you try to access the websites and software, and use our services.

D. To customize, improve, and enhance our services and our marketing materials.

E. To improve ULINK’s processes and algorithms and artificial intelligence.

F. To enforce or defend improper use in violation of our policies and contracts with you.

G. To deter data breaches, illegal activities, and fraud.

H. To comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interest or legitimate interests of others. 

I. To establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or legitimate interests of others.

14.4 Sharing of Personal Data. We may share categories of personal data to accomplish the various business purposes above and as described throughout this privacy policy. 

14.5 CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests regarding your personal data. Specifically, the CCPA allows you to request us to: 

A. Right to Request Access to Your Personal Data and Data Portability Rights. You have the right to request access to your personal data that we have collected over the past 12 months. Upon verification of your request, we will disclose to you the categories of personal data we collected or have collected, our business or commercial purpose for collecting the personal data, the categories of third parties with whom we share the personal data, the specific pieces of personal data we collected about you (data portability request), and if such personal data has been sold or disclosed for a business purpose.

B. Right to Deletion of Personal Data. You have the right to request that we delete any of the personal data that we have collected from you subject to certain exceptions. If we are unable to comply with your request, we will provide you an explanation in our response.

We do not discriminate against users or customers on the basis of their exercising any of the rights afforded by the CCPA in accordance with California residents’ rights under the statute.

To protect your personal data, we will verify your identity using the data points you have previously provided to us. Please have this information available so that we can verify your request.

You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written authorization signed by you to make a request on your behalf, and your authorized agent also able to verify their identity with us. If you would like to designate an agent for purpose of making a request under the CCPA, you agent must register as such with the California Secretary of State and submit a copy of this registration along with your verified consumer request.

15. QUESTIONS OR COMMENTS 

If you have any questions, comments, or requests relating to our website or the privacy policy, send an e-mail to support@ulinktech.com or write to Attn: Privacy Compliance Officer, 3120 De La Cruz Blvd., Suite 117, Santa Clara, CA 95054.