LAUNCH APPLICATION PRIVACY NOTICE
This Privacy Notice (“Privacy Notice”) outlines how Launch Tech Co., Ltd and our affiliated companies (“LAUNCH”, “we”, “our” or “us”), use Personal Information (defined below) that we process in connection with your use of our LAUNCH mobile application (“APP”) and all software, services, extensions, subdomains, and application programming interfaces related thereto (collectively, our “Service”). We make our APP available to eligible users who have successfully completed the registration process required to use the APP (each a “User”) and other visitors of the publicly available portion of the APP (together with Users, “you”, or “your”). Please read this Privacy Notice carefully to better understand how we collect, use, and disclose Personal Information about you as you use our APP.
1. Introduction
We strive to respect privacy and we recognize the need for appropriate protection and management of any Personal Information that is shared with us in connection with your use of our Services. As used in this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable person. You may choose whether or not to provide or disclose Personal Information in connection with your use of our APP and Services. If you choose not to provide any Personal Information we request, you may still visit and use parts of our APP, but may be unable to access or use certain features, options, programs, products, and services offered on our APP.
2. Data Collections and Uses
The following data is collected by or on behalf of LAUNCH that may constitute Personal Information:
2.1 Data Collected When You Sign Up For Our Services
| Categories of Personal Information | Point of Collection and Purposes |
|---|---|
| Account Registration Data | To create a LAUNCH account you need to provide data including your email address and a password. We may process your username and password (whether alone or in combination with other data to detect fraud) to enable you to log into our APP, and we process information relating to access privileges granted to you to appropriately control your access to restricted content. We process this Personal Information only as necessary to provide you our Services, as well as to further our legitimate interests of protecting our Services and the content on our APP. |
2.2 Data Created During Use of Our Services
| Categories of Personal Information | Point of Collection and Purposes |
|---|---|
| User Profile Data | You have choices about the information on your profile. You may choose to edit your username and nickname, choosing an image to represent yourself. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including making connections with other users of our products. We do not require Users to include sensitive data (e.g., race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation or criminal record) in their User profile. |
| Location Data | We collect precise or approximate GPS location data from a user’s LAUNCH device if enabled by the user to do so. You may use the APP without enabling LAUNCH to collect location data from LAUNCH devices. However, this may affect some functionality available in the APP . |
| Log Files on Our APP | We may maintain certain log files relating to the access and use of our APP. The information inside the log files may include internet protocol (“IP”) addresses, network request information, standard system logs, crash information and other anonymous identifier technologies (collectively, “Log Data”). Log Data may be used to monitor and analyze use of the APP, resolve technical issues, perform technical administration, enhance functionality and user-friendliness, and better tailor our Services to your needs. |
| Your Device and Location | If you use our Services from a mobile device, that mobile device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location. |
| Data Collected From Cookies, Web Beacons and Other Similar Technologies | We use cookies, which are small pieces of data stored in text files, to make interactions with our APP easy, efficient, and meaningful. When you visit our APP, our servers may send a cookie to your computer or other device. Cookies collect and allow us to compile information about the usage of our APP and interaction with emails from us. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to an email, opening an account, or filling out a web form, you remain anonymous to us. If you identify yourself to us, then these cookies may also collect Personal Information and may allow us to track your usage of our APP, determine your usage preferences, and improve and customize your experience when using our APP. We may use cookies that are session-based or persistent. Session cookies exist only during one session; that is, they are downloaded to your web browser when you visit our APP, but then disappear from your computer/device when you close your browser software or turn off your computer/device. Persistent cookies, on the other hand, are used for multiple visits to our APP and remain on your computer/device after you close your browser or turn off your computer/device. We may use web beacons, either alone or in conjunction with cookies, to compile information about your usage of our APP and interaction with communications from us. Web beacons, also known as pixels, are clear electronic images that can recognize certain types of information on your computer/device, such as cookies, when you view a particular site or email tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you open an email or click on a link in the email that directs you to our APP. We may also use web beacons to operate and improve our APP and email communications. Unlike cookies, however, web beacons are not stored on your computer/device, so even if you disable cookies on your web browser, web beacons may still load and be used as described above. |
2.3 Information Collected Automatically
Certain information on our APP is collected automatically by means of various software tools, as described below. We have a legitimate interest in using such information to assist in log-in, systems administration, and information security and abuse prevention purposes, as well as to track user trends, understand the usage of our APP, analyze the effectiveness of our APP, and improve our APP. Some or all of the automatically collected information may, alone or in combination with other information, constitute Personal Information under certain laws pertaining to data privacy. Some of our service providers may also use cookies or other methods to gather information regarding your use of our APP. These service providers may use these cookies or other tracking methods for their own purposes by evaluating information about your use of our APP in combination with any Personal Information about you that they may have. The use of this information, including any Personal Information they may have about you, by these service providers is subject to the privacy notices or privacy policies of such service providers, if any, rather than this Privacy Notice.
| Categories of Recipients | Reason(s) for Sharing |
|---|---|
| Our Affiliates | We will share your Personal Information with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Notice to help our Services be more relevant and useful to you and others. |
| Service Providers | We may transfer Personal Information to our service providers to perform tasks on our behalf and to assist us in providing our APP. For example, we may share your Personal Information with service providers who assist us in performing core functions (such as hosting, data storage, and security) related to the operation of our APP and/or by making certain interactive tools available to you as a user of our APP. We may also use service providers for technical and customer support, application development, data analysis (quantitative and qualitative), tracking and reporting functions, quality assurance, and other services. We may share Personal Information from or about you so that we can deliver our APP effectively. Service providers receive your Personal Information as necessary to perform their role, and we use commercially reasonable efforts to only engage with Providers that post a publicly available privacy notice or privacy policy. We may share your Personal Information with our auditors, lawyers or other professional advisors so they can support our business. These professional advisors are bound by obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. |
| Purchasers of Our Business | We may transfer or assign this Privacy Notice and any Personal Information to a related or third party entity as part of a merger, acquisition, sale, or other change of control of our business, assets, or equity, including in connection with any bankruptcy or similar proceedings. |
| Law Enforcement and Data Protection Authorities | We may disclose Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms of Use including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of LAUNCH, our users, or the public. |
3.Additional Purposes for Which We Use Your Personal Information
In addition to some of the specific uses of information we describe in this Privacy Notice, we may use information we receive to:
· help you efficiently access your information after you sign in;
· remember information so you will not have to re-enter it during your visit or the next time you visit the APP;
· provide and administer the services, information, content, and products you requested;
· to contact you in connection with our APP and services and in connection with certain other services (including new features, functionality, or services), notifications, programs or offerings that you may have registered for;
· develop analytics, perform business analyses, or perform similar tasks to improve the quality of our business, our APP and the content, products, and services we offer;
· diagnose or fix technology problems;
· automatically update the APP on your device;
· create aggregated, non-personal information, and/or de-identified information;
· comply with our legal obligations and protect our rights, our property, and the rights of third parties;
· ensure the technical functionality and security of our APP.
4. How We Share Your Personal Information
We do not sell, lease, rent or otherwise disclose the Personal Information collected from our APP to third parties unless otherwise stated in this Privacy Notice or unless you otherwise consent to us doing so. The following sets forth when and where we disclose Personal Information collected through our APP.
| Privacy Right | Description |
|---|---|
| Access to Your Personal Data | You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. This access information includes the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipient to whom the Personal Data have been or will be disclosed. You may have the right to obtain a copy of the Personal Data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs. |
| Rectification | You may have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. |
| Erasure | You may have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data. |
| Restriction of Processing | You may have the right to obtain from us restriction of processing your Personal Data. In such cases, the respective data will be marked and may only be processed by us for certain purposes. |
| Data Portability | You may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit those data to another entity without hindrance from us. |
| Object | You may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us, and we can be required to no longer process your Personal Data. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by us. However, such a right to object may in particular not exist if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded. |
5. Your Choices
5.1 Access, Amend, Erase, or Export Personal Information
You may be aware that a new European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls to help Users take advantage of those rights. “Personal Data” has the same meaning as defined in the GDPR. As available and except as limited under applicable law, the rights afforded to individuals are:
| Privacy Right | Description |
|---|---|
| Right to Know | You may have the right to request information on the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information. |
| Right to Delete | You may have a right to request us to delete Personal Information that we collected from you. |
If you would like to access, amend, erase, or export Personal Data about you collected through our APP, you may do so via the account management tools available on our APP. You may also submit a support request to techsupport-mower@cnlaunch.com and we will use commercially reasonable efforts to respond in a timely manner. Please note, however, that the only way to make some requested changes to your account may be by you through the APP following your successful login. You may close your account by contacting us at techsupport-mower@cnlaunch.com.
5.2 Control Data Collection From a Mobile Device
5.2.1 Device Settings. All major mobile device operating systems enable the users of mobile devices to control the types of data collected in and through mobile applications.
· iOS.
™ Apple instructions on how to control iOS device location settings can be found here.
™ Apple instructions on how to limit ad tracking on iOS devices can be found here.
™ For other privacy-related settings on iOS, please go to Settings from your mobile device’s home screen, and select “Privacy.”
· Android.
Android instructions on how to control device location settings can be found here.
Android instructions on how to limit ad tracking on Android devices can be found here.
5.2.2 Data Collected Via Bluetooth. All major mobile device operating systems enable the users of mobile devices to disable Bluetooth from functioning.
· iOS. You can disable Bluetooth by going to “Settings” from your device’s home screen; select “Bluetooth”; and turn Bluetooth off.
· Android. You can disable Bluetooth by going to the Settings app, then “Wireless and networks,” where you can disable Bluetooth.
6. Transfer of Personal Information Outside of Your Jurisdiction
To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies or Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by LAUNCH for this transfer of your personal information.
7. Retention of Personal Information
We reserve the right to retain any Personal Information as long as the Personal Information is needed to: (a) fulfill the purposes that are described in this Privacy Notice and (b) comply with applicable law.
8. Data Security
The security of Personal Information is important to us. We implement appropriate technical and organizational measures to help protect the security of your Personal Information. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, 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 Personal Information, we cannot guarantee the absolute security of Personal Information, our APP or our Services.
9. Children’s Privacy
We do not target children and do not knowingly collect any Personal Information directly from children under the age of 13. If we learn that we have collected any Personal Information of a child under the age of 13 years, we will take reasonable steps to delete the Personal Information. This may require us to delete the LAUNCH account for that child. If you believe that we might have any information from or about a child under 13, please email us at techsupport-mower@cnlaunch.com.
10. Changes to This Privacy Notice
Our Services may change and evolve over time. We may update this Privacy Notice from time to time in our discretion to reflect changes to our information practices. We will provide you with advance notice of a material change to this Privacy Notice prior to your access of any portion of the APP. We may (i) showing it to you again when you access the APP, or (ii) via inclusion in our next APP update that is submitted to the Apple and Google mobile application platforms, (iii) sending an email notifying you of the changes to the email address we have on file for you, or (iv) include a notice on our APP. We do not ordinarily provide notice of a non-material change to this Privacy Notice.
We encourage you to periodically review this page for the latest information on our privacy practices. The “Last Updated” legend at the top of this page will be updated with each change to this Privacy Notice. Your continued use of the APP and Services after this Privacy Notice has been updated (and after advance notice for a material change) indicates your agreement and acceptance of the updated version of the Privacy Notice. If the updated Privacy Notice is not acceptable to you, your sole recourse is to stop using and accessing the APP. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the APP.
11. Third Party Websites and APPs
Our APP may contain links to third-party websites and services that are not owned or controlled by LAUNCH (collectively, “Third Party Websites”). We do not endorse any such Third Party Websites or the information, materials, products or services contained on or accessible through such Third Party Websites. We have no control over, no obligation to monitor and are not responsible for the privacy practices or the content of any Third Party Websites, and you visit them at your own risk and understand that this Privacy Notice does not apply to your use of any such Third Party Website. Accordingly, you expressly relieve us from any and all liability arising from your use of any Third Party Website. We encourage you to read the terms and conditions and privacy policy or privacy notice of any Third Party Website that you visit.
12. How You Can Contact Us
Should you have any questions or complaints regarding this Privacy Notice, please contact our Data Protection Officer below:
Email:techsupport-mower@cnlaunch.com
Address: Launch Industrial Park, North of Wuhe Avenue, Banxuegang, Longgang, Shenzhen