Privacy Policy

Privacy Policy (Cloud-Based Services)

Personal information provided to us via your usage of this Software is protected by applicable laws. The personal information you assented to provide is used by the data controller, Clear Touch Interactive (hereinafter referred to as "Clear Touch" ), domiciled in 1100 Thousand Oaks Blvd, Greenville, SC 29607, for the sake of providing quality screen sharing services. In this regard, we develop this Privacy Policy to explain how we collect, use, disclose, transfer and store your Personal Data when you use our Software. Before using our products (or services) and submitting your Personal Data, please read the Privacy Policy carefully to understand our approach to customer privacy.

This Policy will help you understand the followings:

1. 1. 1. How We Collect and Use Your Personal Data
      2. How We Store Your Personal Data
      3. How We Disclose Your Personal Data
      4. How We Protect Your Personal Data
      5. Your Rights
      6. How We Process Children’s Personal Data
      7. Global Transfer of Your Personal Data

 

I. How We Collect and Use Your Personal Data

When you use this Software, we will collect the following personal information for purpose of providing you with quality screen sharing services: Additionally the information is further defined below in the "User Experience Plan" section. 

• • • Operational information: We will collect the operational information generated in the course of using the Software, including the frequency of using each function and click order, in order to analyze user habits, and then to optimize the product functionality, so as to provide you with more comfortable services.
    • Device information: In order to distinguish among different users, we will collect your device recognition code for anti-fraud and anti-cheating purposes.
    • Location information: In order to access and display the name of your current connected Wi-Fi, and help you determine whether your device is connected to the same Wi-Fi with the IFP, we will collect your accurate location information.

When you use the Software, in order to realize the screen sharing function and provide you with better service, we will request some of your device’s permissions. You can set it up or turn it off in your device settings to adjust our access to your device. Denying requests to relevant access may render some functions of the Software unusable.

1. 1. • Camera permission: when you choose to scan the QR code in this Software to realize the screen sharing function, we will request your camera usage permission.
      • Location permission: in order to access and display the name of your current connected Wi-Fi, we will request permission to your location information.
      • Check WLAN connection: in order to access and have knowledge of your network connection status when you use the Software, and to provide a smooth service, we will check your WLAN connection.
      • Read or write to the external storage card: we may read or write to the external storage card to share or drop content in the external storage card, or to store files or screenshots shared by other devices.
      • Detect other running apps: In order to detect whether cloud-based services are running normally, we will detect your currently running apps.
      • App usage data statistics: in order to analyze your preferences and provide you with a better user experience, we will acquire your app usage data statistics permissions when you use the Software.

Providing personal information and authorization to use shall be completely voluntary and we will not process your personal information in any manner or share it with any third party without your consent, or in the absence of any other legal basis.

 

II. How We Store Your Personal Data

We use the cloud to store your Personal data. The retention period for Personal Data is the minimum time necessary to achieve the collection purposes, except the law requires a longer period. We will delete or anonymize Personal Data beyond the above retention period.

 

III. How We Disclose Your Personal Data

1. 1. • We may share some of your Personal Data with Affiliated Companies and authorized partners who cooperate with us in providing products and services. We will not share your Personal Data with Third parties for their own marketing or commercial purposes.
      • Affiliated Companies: Your Personal Data may be shared with Clear Touch’s Affiliated Companies. We only share necessary Personal Data subject to the purposes stated in this Privacy Policy. If the Affiliated Companies wish to change the purpose of processing, they will ask for your authorization and consent again.
      • Authorized partners: to realize the purposes stated in this Policy, some of our services will be provided by our authorized partners. We may share some Personal Data with our partners to provide better customer service and user experience. For example, we use a third-party cloud storage service provider to store your information. Third-party service providers are also used to provide you with customer service including on-site service. 
      • Where a merger, acquisition or bankruptcy liquidation takes place, if transfer of Personal Data is involved, we will request the new company or organization which obtains your Personal Data to be subject to this Privacy Policy, otherwise we will ask such company or organization to acquire your authorization and consent again. 

We will only share your Personal Data for lawful, legitimate, necessary, specific and clear purposes, and only Personal Data necessary for service provision will be shared. Our partners are not allowed to use the shared Personal Data for any other purposes.

We will only publicly disclose your Personal Data if it is mandatorily required by laws, in compliance with subpoena, legal proceedings, legal actions or compulsory request by the supervisory department of government agencies. If we sincerely believe that disclosure is necessary to protect our rights, ensure your or others’ safety, investigate fraud or respond to the government, we may publicly disclose your Personal Data.

IV. How We Protect Your Personal Data

• • We have taken reasonably feasible and technical measures to protect collected service-related data. However, please be careful, even if we undertake reasonable measures to protect your data, there is no website, internet transmission, computer system or wireless connection that is definitely safe. 
  • We have taken safeguarding measures in accordance with industry standards to protect the Personal Data you provided and prevent data from unauthorized access, public disclose, use, modification, damage or loss. We take all reasonably practical measures to protect your Personal Data.  In particular:
  • We encrypt a lot of information. For instance, we do not store your password but only store the Hash value after your password’s double layer SHA as a proof of security authentication. The HASH algorithm of SHA is irreversible. Therefore, no one can find your password according to the Hash value. We periodically review practices regarding information collection, storage and possessing (including physical security measures), to prevent various systems from unauthorized access.
  • We use computer systems that have limited access and merely allow Clear Touch employees who need to know Personal Data in order to help us process it or authorized staff from service companies to access Personal Data. These people are required to comply with strict contractual confidentiality obligations. Failure to comply with the obligations will lead to legal liabilities or termination of contract with Clear Touch.
  • The security of your information is extremely important to us. Therefore, we endeavor to ensure the security of your Personal Data and implement measures such as security encryption during storage and transmission to prevent your information from unauthorized access, use, or disclosure. At the same time, no one can access the specific content of some encrypted data except the users themselves.
  • In case of a Personal Data security incident, in accordance with the requirements of laws and regulations, we will promptly inform you the basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc. We will inform you in a timely manner by email, mail, telephone, push notification, etc., regarding the relevant situations of the incident. When it is difficult to notify each Personal Data subject individually, we will issue a notice reasonably and effectively. In the meantime, we will take the initiative to report on the handling of Personal Data security incidents in accordance with the regulatory department’s requirements.

 

V. Your Rights 

We respect your rights to Personal Data. Below is a list of your legal rights and the way we protect them.  Please note, in case of safety, we may ask to verify your identity before processing your request. 

• • Right to Know: We publish this Privacy Policy to inform you of how we handle your Personal Data. We are committed to the transparency of the use of your information.
  • Access Right: If you are to exercise your access right, you can send an email to it@getcleartouch.com to visit data including your product series number, model, stored conference information, etc. 

• • Right of Rectification: If you find there is a mistake with your Personal Data we process, you are entitled to ask us to make rectifications. You can ask us to correct your Personal Data by sending an email to it@getcleartouch.com. When confirmed, we will rectify accordingly.

• • Right to Delete: If we do not have legal reasons to continue the possession and processing of your information, you can request us to delete your Personal Data by sending an email to it@getcleartouch.com.

• • Right to Restrict Processing: You are entitled to request Clear Touch to restrict processing of your Personal Data. This means we can store your Personal Data but cannot process it. We only retain data needed for future response. You can send an email to it@getcleartouch.com to achieve your right to restrict processing. 

• • Right of Data Portability: Within scope permitted laws and regulations, you are entitled to obtain your Personal Data in a structured, commonly used, and machine-readable format. For instance, if you decide to change the service provider, this right enables you to reliably and safely move, copy or easily transfer your Personal Data between IT systems without affecting its use. After your formal authorization, you can exercise your right of data portability by sending an email to the following address: it@getcleartouch.com

• • Right of Refusal: Even if the processing of your data is based on our legitimate interest, exercise of public right, direct marketing (including data aggregation) and statistics, you have the right to refuse our process to your Personal Data by sending an email to the following address: it@getcleartouch.com.

• • Right to Withdraw Consent: If you agree to our processing of your Personal Data but later change your mind, you can withdraw your consent at any time and we must stop processing. You can withdraw consent by sending email to the following address: it@getcleartouch.com.

• • Right to Refuse Automated Decision: You have rights not to be bound by automatic decisions, including user profiling. If these decisions will significantly affect your legitimate rights, you can send an email to it@getcleartouch.com to refuse automated decisions. We will respond to your request and take appropriate measures when necessary. 

• • Right to Complaint: You are entitled to file a complaint with the data protection authority of your country about our processing of your Personal Data. 

We will respond and reply to you as soon as possible. Generally, we will reply to you within one month upon receipt of your request (If necessary, we may extend it by an additional two months as permitted by law. We will inform you the reason for the extension within the aforementioned 30-day period, such as the request is too complicated or too much in volume). If you are not satisfied with the response you received, you can refer the complaint to the relevant regulatory authority in your jurisdiction. 

VI. How We Process Children’s Personal Data

1. • Our Software and services are mainly adult-oriented. A child should not create his/her own user account. We treat anyone under 16 years old (or equivalent minimum age in relevant jurisdiction) as a child. 
   • When we find that a child’s Personal Data is collected, we will endeavor to delete relevant data as soon as possible. 

 

VII. How Your Personal Data Transferred Globally

• • As a company headquartered in the United States and based on global operations, we will provide products or services through resources and servers all over the world, which means after obtaining your authorization and consent, your Personal Data may be transferred to or accessed from the overseas jurisdictions of the countries where you use the products or services. The types of data that may need to be transmitted across the border include the data listed in the section "How We Collect and Use Your Personal Data ".

• • In order to analyze the performance of the products and services and improve functionality, the Personal Data collected and generated during the global use of products may be transmitted to China and stored in a third-party cloud server in China. We will take corresponding protective measures according to the requirements of applicable laws to ensure data security.

• • If Personal Data collected and generated in the European Economic Area is transferred to countries outside the European Economic Area, we will ensure that proper protective measures are taken to comply with General Data Protection Regulation (“GDPR”). For example:

• • Has signed the Standard Clauses Contract approved by the European Commission according to Article 47 of GDPR.

• • Collage Server Location Information: Any version greater than v3.2 - San Francisco, US and Singapore 

• • Command Server Location Information: San Francisco, US and Germany

• • OTA panel firmware update server: San Francisco, US

For lack of appropriate protection measures, we will request your express consent on cross-border data transfer and take safety measures to encrypt or de-identify to ensure your Personal Data safety.

For more information on protection measures on Personal Data in the scenario of cross border data transfer, please contact us via email: it@getcleartouch.com.

 

VIII. Security Certificates

• Bytello Share and Bytello DMS are white-label software that have obtained the ISO 27701 certification (certificates available upon request). Collage and Command are Clear Touch-branded versions of Bytello Share and Bytello DMS respectively and both software share the same compliant software code and policies.
• NUITEQ, our Interactive Education Software company has obtained the ISO 27001 certification. A press release of this information can be found here: https://www.nuiteq.com/company/blog/nuiteqs-information-security-management-system-is-certified-to-iso-27001

 

If you have any concerns or doubt over our Privacy Policy or our practices, please contact us via the following channels:

Address: 1100 Thousand Oaks Blvd, Greenville, SC 29607

E-mail: it@getcleartouch.com