PRIVACY POLICY

  1. Introduction

This Privacy Policy (“Policy”) details Splashtop’s commitment to protecting the privacy of individuals who visit our Websites and who register to use the products and Service(s) (as defined below) which we market for subscription (“Subscriber”). For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.splashtop.com as well as the other websites that the Splashtop operates and that link to this Policy.

 

At Splashtop, we know that you care how information about you is collected, used, or shared. This Policy explains what information of yours may be collected by Splashtop through its family of products and/or related services (each a “Service” or the “Services”) and through the Websites, and how the information will be used. We will not use your information in any way except as described in this Policy.

 

  1. Who is Splashtop and how can you contact us?

The party 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 you have any questions or wishes in connection with your personal data, you may contact us at privacy@splashtop.com.

 

  1. 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 Service shall be limited to the purpose of providing the Services for which the Subscribers 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 encourage you to review the privacy statements of any such other websites to understand their information practices.

 

We have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. If you are an individual who interacts with a Subscriber while using our Services (such as a customer of one of our Subscribers, for example) 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.

 

  1. Privacy Policy Updates

Due to the Internet’s rapidly evolving nature, we may need to update this Policy from time to time. If so, we will post the updated Privacy Policy on our Websites located at https://www.splashtop.com/privacy. We may also send registered users of the Websites email notifications notifying such users of any changes to the Policy.

 

  1. Information We Collect From You on our Websites

You can generally visit our Websites without revealing any personally identifiable information about yourself. However, in certain instances, 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.

 

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:

 

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies to provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites. For detailed information about the use of cookies in the Websites, please read and review our Cookie Policy which can be found at https://www.splashtop.com/cookie-policy.

 

We partner with third parties to manage our advertising on other sites. Our third party partners may also use technologies such as cookies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. Splashtop will only do this if you have consented to cookies (Article 6.1(f) GDPR).

 

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 and Flash 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.

 

Email tracking:

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 the email is opened, we have access to certain information, such as the recipient’s email address; date and time in which the email was sent; confirmation that the recipient has opened the email after it has been received; timestamp of each email opening; browser and operating system used by the recipient who opened the email; number of clicks made on the respective hyperlink of them by the recipient; timestamp of each click on the link; browser and operating system used by the person who has clicked on the link. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by Splashtop (Article 6.1(f) GDPR), in order to analyze the reach and effectiveness of the mails send by Splashtop. The information is retained for two months.

 

Logs:

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. 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 (Article 6.1(f) GDPR) and are stored for 1 month.

 

Analytics:

We collect analytics information when you use the Websites to help us improve them. We may also share data about your actions on our Websites with third-party service providers of analytics services to help us analyze such data. 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 (Article 6.1(f) GDPR), in order to improve services and will not be retained for longer than six months.

 

Careers:

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 for the purposes of the legitimate interests pursued by Splashtop (Article 6.1(f) GDPR, namely recruitment. Splashtop retains your personal data for 4 weeks after rejection or, with your consent (Article 6(a) GDPR), for a period of 1 year.

 

  1. Information We Collect from Subscribers through our Services

Account and Registration Information:

We ask for and may collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with your Account.

 

If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.

 

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 (Article 6.1(b) GDPR). You cannot register for an Account and make use of our services without providing us with these personal details. Your Account Information is stored for as long as you have an Account and will be deleted within 6 months after you terminate your Account. Splashtop has a legal obligation to retain financial records for a period of 7 years.

 

Newsletters:

We wish to inform you on the developments of our Services, if you have signed up for Splashtop’s newsletters. 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 GDPR@splashtop.com. To subscribe you have to provide us with your email address. The processing thereof is necessary for the purposes of the legitimate interests pursued by Splashtop (Article 6.1(f) GDPR), namely direct marketing. 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 5 years after you unsubscribe.

 

Other Submissions:

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 data is necessary for the purposes of the legitimate interests pursued by Splashtop (Article 6.1(f) GDPR), 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.

 

Attendee Information:

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 (Article 6.1(b) GDPR). You cannot register for an event without providing us with these personal details. Your personal information is deleted within one month after the event.

 

Desktop software and Mobile Application:

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 for the purposes of the legitimate interests pursued by Splashtop (Article 6.1(f) GDPR) and are stored for one month.

 

  1. Information We Collect from Other Sources

Social Media Widgets:

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. Splashtop will only do this if you have consented to cookies (Article 6(a) GDPR). Please read the “Cookies” section above to find out more.

 

  1. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, email notification service, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

 

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

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.

 

Testimonials:

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 GDPR@splashtop.com.

 

Splashtop Sharing:

We may share information, including personal information, with any member of the Splashtop team. Moreover, we may share your personally identifiable information and/or aggregate information with a parent, subsidiary or affiliate entity in our corporate family. We may transfer your personally identifiable information and/or aggregate information to a successor entity upon a merger, consolidation or other corporate reorganization in which Splashtop participates or to a purchaser of all or substantially all of Splashtop’s assets to which the Websites or the Services relate.

 

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

 

  1. Your Privacy Rights

Under the GDPR, you have a number of rights with regard to your personal data and the processing thereof:

 

Right to access you have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and additional information about the processing of your personal data. Subscribers to our Services may update or change their Account Information by editing their profile or organization record or by contacting GDPR@splashtop.com for more detailed instructions.
Right to rectification you have the right to request the rectification of inaccurate personal data concerning you.
Right to be forgotten you have to right to ask us to erase your personal data (right to be forgotten) for example if the personal data are no longer necessary in relation to the purposes for which they were collected; you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; or the personal data have been unlawfully processed. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Right to restriction you have the right to obtain restriction of processing of your personal data, for example when you have contested the accuracy of your personal data.
Data portability you have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where the processing is based on your consent or on a contract.
Right to object you have the right to object to processing of personal data which is based on our legitimate interests. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims;

where personal data are processed for direct marketing purposes, you always have the right to object to processing of personal data for such marketing. In that case, we shall no longer process your personal data for such purposes.

Withdraw consent where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

 

Any request regarding this policy or our procedures may be sent to GDPR@splashtop.com. We will respond to your request without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

 

If we do not take action on your request, we will inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action. In that case, you also have the right to lodge a complaint with the supervisory authority and to seek a judicial remedy.

 

An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller).

 

Additional Rights for State of California:

 

Categories of Personal Information Collected: In the preceding 12 months, we have collected the categories of personal information listed below. Note that not all categories of information are collected from all people.

 

  • Identifiers, such as name, email addresses, Internet Protocol address, account name, or other similar identifiers
  • Categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including telephone number, postal address, payment information and, for employment candidates, education and employment history
  • Commercial information, including product usage data, records of products or services purchased or considered, or purchasing habits
  • 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
  • Geolocation data
  • Professional or employment-related information from employment candidates

 

Your Rights: Under the California Consumer Privacy Act of 2018 (“the CCPA”), California consumers have the right to request access to the specific pieces of personal information we have collected about them in 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. If you are a California consumer, you also have the right to request deletion of your personal information (subject to certain exceptions), to opt out of sales of personal information, and to receive equal service and price and not be discriminated against if you choose to exercise your rights under the CCPA. California consumers may make a rights request by sending a request via the email and postal mail contact options at the bottom of this privacy policy. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name and Splashtop account email address (which is required only if you already have an account with us).

 

Sale of Personal Information: We do not sell any of your personal data to third parties. If in the future we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

 

Further disclosures: For further disclosures regarding your personal information, as required by the CCPA, please refer to the remainder of this privacy policy. You can find information about the business and commercial purposes for which we collect your personal information, the sources from which we collect personal data, and information about the categories of third parties to whom we disclose your personal information to, as well as information regarding which categories of personal information are being disclosed.

 

  1. International Transfer Of Information Collected

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 (the United States, Taiwan and China). We may also transfer your personal information to our third party service providers (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. Some of our service providers are located outside the European Economic Area (EEA), in this case 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). For more information on where and how the relevant document may be accessed or obtained, please contact us.

 

  1. Security

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 may employ procedural and technological measures, consistent with industry practice, 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 may use firewalls, password protection, encryption, secure socket layer and take other physical security measures and place internal restrictions on who within Splashtop may access your data to help prevent unauthorized access to your personally identifiable information. If you have any questions about the security of your personal information, you can contact us at GDPR@splashtop.com.

 

  1. Complaints

It is possible that, despite our careful approach, you have a complaint about the way Splashtop processes your personal data and/or the way we deal with your rights. In that case, you may also submit a complaint to the national data protection authority. If you have any questions or complaints in connection with your personal data, you may also choose to contact us at GDPR@splashtop.com.

 

This Policy was last updated: January 7, 2021

This agreement 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.