At Splashtop, we aim to be transparent about how your personal information is collected, used, and/or shared. The purpose of this Policy is to inform you of the types of personal information we may collect from you and how that information will be used. Splashtop collects certain personal information through its Websites as well as its family of products and/or related services (each a “Service” or the “Services”). Except as expressly set forth in this Policy, Splashtop will not use your information in any other manner or for any other purpose.
If your data is governed by EU data protection law, the Controller responsible for the processing of your personal data is Splashtop B.V., having its registered office in (1019 GM) Amsterdam, the Netherlands, at Piet Heinkade 135.
If your data is governed by UK data protection law, the Controller is Splashtop, Inc. Our UK Representative is MyEDPO UK Limited, you can contact our UK representative at firstname.lastname@example.org
If you have any questions or wishes in connection with your personal data or with our privacy practices, you may contact us at email@example.com.
2. Scope of This Policy
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, or location data. The use of information collected through our Services shall be limited to the purpose of providing the Services for which the Subscriber has engaged.
Our Websites may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We are not responsible for the privacy practices of such other websites and we encourage you to review the privacy statements of any such other websites to understand their information practices.
In certain cases, we may process your personal information as a Processor or Service Provider on behalf of our client Subscribers. If you are an individual who interacts with a Subscriber while using our Services (such as a customer of one of our Subscribers who are, for example, a Managed Service Provider or an IT support technician) and would either like to amend your contact information or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.
4. What Information We Collect From You on our Websites
When visiting our Websites, you may be given the option to fill out a service registration, complete a survey or other form which could contain personally identifiable information, such as user identification name, an email address, and/or any other information that you voluntarily transmit with your communication to us.
In addition, whenever you visit a Splashtop web page, your browser may send certain information to our server, which we record. This information may include the URL of the referring web page, your browser, OS type, as well as the information set forth below:
We may use web beacons, tags and scripts on our Websites or in email we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies from our third-party service providers on an individual and aggregated basis. If you are located in the European Union or the UK, we will only use such technologies if you have consented to their use.
We may use Local Storage Objects (“LSOs”) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your Web browsing activity use LSOs such as HTML5 to collect and store information. For further information on how to manage Flash LSOs please visit https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy. Splashtop requires this information in order for the Website and Services to work as optimally as possible (for example, to display content correctly and to keep the Website and Services secure), the processing of these personal data is therefore necessary for the purposes of the legitimate interests pursued by Splashtop and are stored for 1 year.
We also use mobile analytics software to allow us to better understand the functionality of our mobile application on your device. This software may record information such as how often you use the mobile application, the events that occur within the mobile application, aggregated usage, performance data, and where the mobile application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application. The processing of personal data is necessary for the purposes of the legitimate interests pursued by Splashtop, in order to improve services and will not be retained for longer than 2 years.
5. What Information We Collect From You if you apply for a job with us
If you apply for a position at Splashtop, you will provide your personal data such as your first and last name, full address, email address, phone number and your CV and other attachments to your application. Splashtop uses this information to review your application and respond to your application. The processing of these personal data is necessary to enter into a contract to which you are a party and for the purposes of the legitimate interests pursued by Splashtop, namely recruitment. Splashtop retains your personal data for 4 weeks after rejection or, with your consent, for a period of 2 years.
6. Information We Collect from Subscribers through our Services 帐户和注册信息。
如果你注册了一个免费试用账户，你不需要输入你的信用卡信息，除非你决定继续付费订阅我们的服务。 一个第三方中介机构被用来管理信用卡处理。 除了代表我们进行信用卡处理外，该中介机构不允许为任何目的储存、保留或使用您的账单信息。
We refer to any information described above as “Account Information” for the purposes of this Policy. The processing of your Account Information in this context is necessary for the performance of a contract to which you are a party in connection with the use of our Service. You cannot register for an Account and make use of our services without providing us with these personal details. Except for Financial Records such as your name, billing and shipping address, invoice records, and/or agreements between you and Splashtop (“Financial Records”), your Account Information is stored for as long as you have an Account and will be deleted by contacting firstname.lastname@example.org. Splashtop has a legal obligation to retain Financial Records for a period of 7 years from the date of the invoice transaction.
We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, contests, promotions, sweepstakes, programs (including reseller, referral, beta, and early access program applications), requesting customer support, or otherwise communicating with us. The processing of personal information is necessary for the purposes of the legitimate interests pursued by Splashtop, in order to interact with you. Your personal data is stored for a period of one month after responding to your message, resolving your issue or the end of the survey, contest, promotion, sweepstake or program.
If you have signed up for Splashtop’s newsletters, we will send you information on the development of our Services. If, at any moment, you do not wish to receive emails of Splashtop anymore, you can unsubscribe by using the opt-out option that is provided in every email that we send you. You may also unsubscribe by sending an email to email@example.com. To subscribe, you have to provide us with your email address. We process this personal information on the basis of your consent, which you may withdraw at any point through unsubscribing. We retain your e-mail address and the data that show that you have signed up for the newsletter for as long as you are subscribed to the newsletter and no longer than 1 year after you unsubscribe.
We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of the Splashtop team participates. The processing of your personal data is therefore necessary for the performance of a contract to which you are a party. You cannot register for an event without providing us with these personal details. Your personal information is deleted in accordance with Newsletters section of this policy.
When you download, or install, and use our Services, we collect following information: (a) Device information including device names, the type of device you use, its IP address and MAC address, and operating system version and (b) Session information including session start time, end time, speed of access to Splashtop servers in different regions, our desktop software or mobile application crash dumps, or error logs. Splashtop requires this information in order for the Services to work as optimally as possible (for example, to display content correctly and to keep the Services secure), the processing of these personal data is therefore necessary to perform our contract with you and can be transferred to customer or deleted by contacting firstname.lastname@example.org.
7. Information We Collect from Other Sources
The Websites may include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them. If your personal information is governed by EU or UK data protection laws, Splashtop will only allow such data processing if you have consented to cookies (see section 4 above).
我们也可能从第三方获得其他信息，包括个人信息。 例如，我们可以从与我们的服务整合的第三方RMM（远程监控和管理）服务中获取设备信息。 我们从第三方RMM服务中获得的任何信息都是按照该服务确定的授权程序进行的。 你应该检查你在这些第三方服务上的隐私设置，以了解和改变通过这些服务发送给我们的信息。
8. How we use your personal Information
We use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at email@example.com or following the unsubscribe instructions included in our marketing communications; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.
9. Legal Basis for Processing:
We collect your personal information only where one or more of the following apply: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). 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.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. If you wish to withdraw your consent or if you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at firstname.lastname@example.org.
10. Sharing of Information Collected
我们与我们的第三方服务提供商共享信息，包括个人信息，我们使用这些服务提供商为我们的网站提供托管和维护、应用开发、备份、存储、支付处理、电子邮件通知服务、分析和其他服务。 这些第三方服务供应商可能会访问或处理您的个人信息，以便为我们提供这些服务。 我们不允许我们的第三方服务供应商将我们与他们共享的个人信息用于他们的营销目的或用于与他们向我们提供的服务有关的任何其他目的。
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, available at https://www.splashtop.com/terms/splashtop, or as otherwise required by law.
From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at email@example.com.
我们可能与Splashtop团队的任何成员分享信息，包括个人信息。 此外，我们可能与我们公司家族中的母公司、子公司或附属实体分享您的个人身份信息和/或汇总信息。 我们可能会在Splashtop参与的合并、整合或其他公司重组时，将您的个人可识别信息和/或汇总信息转让给继承实体，或转让给Splashtop所有或几乎所有与网站或服务有关的资产的购买者。
11. How Long We Retain Your Personal Information
We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal 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 completed automatically after a period of 2 years.
12. Your Privacy Rights
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at firstname.lastname@example.org. Subscribers to our Services may update or change their Account Information by editing their profile or organization record or by contacting email@example.com for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email firstname.lastname@example.org. Requests to access, change, or remove your information will be handled within thirty (30) days.
任何个人如果想要访问，或者想要纠正、修改不准确的信息，或者删除我们代表签约人储存或处理的个人信息，应该直接向签约人（数据控制者）提出询问。 在收到我们的用户之一要求我们删除数据的请求后，我们将在三十（30）天内对他们的请求作出回应。 我们将在向用户提供服务所需的时间内，保留我们代表用户存储和处理的个人信息。 我们将在必要时保留和使用这些个人信息，以履行我们的法律义务，解决争端，并执行我们的协议。
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at email@example.com.
Additional Rights for EEA and UK:
Right of Access: You have the right to obtain information about what personal information process about you.
Right to rectification: You have the right to request the rectification of inaccurate personal information concerning you.
Right to withdraw consent: Where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. In such case, we will stop processing your data immediately.
If you would like to exercise such rights, please contact us at firstname.lastname@example.org . We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request. These rights may not be exercisable where they conflict with the rights of Splashtop, Splashtop staff and clients, or others, including but not limited to certain proprietary rights, rights to fair proceedings, confidentiality rights, conflicting privacy rights.
We will respond to your request without undue delay and under usual circumstances within 1 month of receipt of your request; however, our response time may be extended by 2 additional months where necessary, taking into account the complexity of the matter and the volume of pending requests. If an extension to our typical response time is necessary, we will notify you within 1 month of receipt of your initial request, together with the reason(s) for the delay.
If we determine that no action will be taken regarding your request, we will inform you without delay and at the latest within 1 month of receipt of your request along with the reason(s) for our refusal to take action. In such case, you will have the right to lodge a complaint with the appropriate supervisory authority and to seek a judicial remedy.
The California Consumer Privacy Act (“the CCPA”) took effect January 1st, 2020. We are committed to protecting your privacy and complying with the CCPA. If you are a California consumer, the CCPA provides you with specific rights regarding your Personal Information:
Identifiers, such as name, email addresses, Internet Protocol address, account name, or other similar contact information identifiers
Categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including name telephone number, postal address, payment information and, for employment candidates, education and employment history
Internet and other similar network activity, such as browsing history on our web sites or information regarding interaction with our web sites, emails or products, inferences - including information about your interests, preferences and favorite brands and products
Customer records, billing address, credit or debit card information,
Professional or employment-related information from consumers and employment candidates including job title and business contact information
Your Rights: Under the CCPA, California consumers have the following rights: Right to request access to the specific pieces of personal information we have collected about them within the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, the categories of personal information we have disclosed about you in the preceding 12 months; Right to request rectification of and deletion of your personal information (subject to certain exceptions);
Right to object to processing;
Right to data portability;
You may opt out of the selling of your personal information and behavioral profiling including automated decision making.
If you choose to exercise your rights under the CCPA, Splashtop will not discriminate against you and you will continue to receive the same access to and pricing for the Services as any person who has chosen not to exercise their rights under the CCPA.
13. International Transfer Of Information Collected
Splashtop is a U.S.-based, global company. To facilitate our global operations, as well as to provide you with the Services you subscribed, we may transfer and access such personal information from around the world, including from other countries in which Splashtop has operations for the purposes described in this Policy. We may also transfer your personal information to our third party processors, who may be located in a different country to you. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. Splashtop has signed Data Processing Agreement (“DPA”) with our third party processors as contractual safeguard to ensure equivalent obligations as those required from Splashtop are satisfied. Some of our service providers are located outside the European Economic Area (EEA), including the United States, Taiwan and China. To comply with EU data protection laws around international data transfer, service providers outside the EEA are only allowed to process your personal data in accordance with a contract entered into between Splashtop and the service provider, incorporating the European Commission’s Standard Contractual Clauses, which ensure that adequate data protection arrangements are in place (Article 46.1(c) GDPR), or if another safeguard for international transfer detailed in GDPR Chapter V applies. For more information on where and how the relevant document may be accessed or obtained, please contact us.
14. Children’s Privacy
We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. The Websites are not intended for children under the age of 13. We do not target its services or the Websites to children under 13. We do not knowingly collect personally identifiable information from children under the age of 13. If you become aware that we are processing the personal information of children under the age of 13, please contact us and we will delete such data as soon as possible.
15. Links to Third Party Sites
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We employ procedural and technological measures, consistent with industry practices to protect your personally identifiable information. Such measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. We use firewalls, password protection, encryption, secure socket layer and take other physical security measures and place internal restrictions on whom within Splashtop may access your data to help prevent unauthorized access to your personally identifiable information. You may find additional details about our technical and organizational measures here: https://www.splashtop.com/security/practices/technical-and-organizational-measures.
By mail: 10050 North Wolfe Road, Suite SW2-S260, Cupertino, CA 95014
通过电话 ：+1 408-861-1088
This Policy was last updated: October 2, 2023
This policy may be translated into different languages. In case of any conflicts or inconsistencies between the English version or any translation hereof, the English version shall prevail and govern.