Privacy Policy
Last updated: October 4, 2022
TDL SYSTEMS INC. recognizes and values the privacy of people ("you" or "User") who visit our website and/or use or access our apps (collectively the "TDL SYSTEMS INC. Services" or "our services").
This Privacy Policy applies to any and all of the TDL SYSTEMS INC. Services and describes why and how we collect, store, and use your personal data, and the choices and rights you have about the personal data you provide or we collect in connection with the TDL SYSTEMS INC. Services. By accessing our websites or otherwise using the TDL SYSTEMS INC. Services, you acknowledge that you have read, understood, and accepted the following terms..
1. WHAT DATA WE COLLECT AND PROCESS
Personal data means data that may be used to identify an individual, such as name, email address, and other data that you choose to submit.
(1) Data We Collect
i. Account Registration Information: Account information, namely, email address and password. We use this information to create the account for your use of our services as you requested, to analyze and manage our services for system administration, and to provide our services.
ii. User Generated Content: pictures, AR scans. Any content generated and provided by you is solely used to more accurately provide and improve our services. By submitting any content, you acknowledge that you have received the consent and approval of the creator and/or subject of your content.
iii. User Service Information. Any information that you provide in communications with our support team when you seek our technical and/or customer service support and/or exercise any of your legal rights as the data subject; in case of receiving your request for support, we use such information to provide relevant support as you request and further improve our services.
(2) Data We Collect Only for System Functions
i. Generated User ID. We generate and use this information to associate and content uploaded with your profile, and to allow you to connect to our servers on the legal basis of Service Provision.
ii. Bugs, Errors, and Other Data About Crashes and Diagnosis Thereof (if the occasional system crash occurs in our services). Device information (name, model, memory size, and graphics card model) and account information (User ID, stacktrace); we use such information to conduct identity verification for security purposes, to identify and address bugs, and to evaluate and improve the functionality of our services on the basis that it is in our legitimate interest to ensure the security of our services, and to improve our services.
2. WHY WE COLLECT AND PROCESS YOUR DATA
In order to provide services, perform the Terms of Service and/or any other agreements between you and TDL SYSTEMS INC, and/or perform the legal liabilities under the applicable laws, we collect and process your personal data to:
(1) allow you to access or restrict your access to our services;
(2) analyze and manage our services for system administration and user service.
(3) correct bugs or errors, improve our services and respond to customer desires and preferences
(4) develop new services or products that user(s) request and improve the user experience
3. WHO MAY ACCESS YOUR DATA
Your data is solely used by TDL SYSTEMS INC. and is not shared with any third parties except when requested by Competent Authorities as addressed below. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.
(1) Competent Authorities
We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose a certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.
4. DATA RETENTION
We will keep your data only for as long as your account is active or only for as needed to provide you the services requested unless deleted in accordance with your request or as otherwise required by law. You acknowledge and agree that your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support.
In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable law provides for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by applicable law.
5. COOKIES
Cookies are files with a small amount of data, which may include an anonymous unique identifier.
Cookies are sent to your browser from a web site and stored on your computer's hard drive.
Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
6. YOUR RIGHTS
If you request in writing, we will provide you a copy of your personal data in an electronic format after passing our verification process. You also have the right to correct or modify your data, have your data deleted, object how we use or share your data, restrict how we use or share your data, and make any other request as provided herein or regulated in the applicable regulations from authorities (including but not limited to the GDPR and the CCPA) through sending an email to the email address listed in article 9. Upon receiving your request via email, we will promptly conduct a verification process including but not limited to instructing you to provide information to confirm that you are the user from whom we have collected information.
(1) Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to access your personal data that we hold about you, i.e. the right to require free of charge, (i) information whether your personal data is collected, used, disclosed, or sold, (ii) categories of your personal data which has been collected, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting or selling your personal data (if any), (v) disclosure of sale of your personal data (if any): i.e. the categories of your personal data which has been disclosed or sold (if any) to third parties, the categories of third parties to whom your personal data was disclosed or sold (if any), statement regarding whether we have actual knowledge that we sell your personal data if you are under 16 years of age; and you have the right to require us to provide a duplicate of your personal data undergoing processing, subject to submitting a verifiable request in the form of email to the email listed in article 9. According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.
(2) Right to Rectify
If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up to date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay according to Article 16 of the GDPR and you can modify the information you provided via the privacy dashboard.
(3) Right to Request Deletion of Personal Information
You have the right to obtain deletion of your personal data or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email to the email address listed in article 9.
You acknowledge and agree that as a result of deleting your account certain services may no longer be accessible.
(4) Right to Object
When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR and/or of this Privacy Policy or any other applicable laws in your country of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence; in particular, if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.
(5) Right to Restrict Processing
You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.
(6) Right to Personal Data Portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in Article 20 of the GDPR or any other applicable laws in your country of residence.
(7) Right to Opt-Out of the Sale of Personal Information (if any)
You have the right to opt-out of the sale of your personal data (if any) and require us to make a statement regarding whether or not we sell your personal data and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.
(8) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer a financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal data. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.
(9) Right to Authorize an Agent to Make a Request on Your Behalf
You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and data security, we are entitled to denying such request.
Notwithstanding the foregoing, if the applicable laws in your country of residence provide otherwise, the corresponding laws shall govern.
7. SECURING YOUR DATA
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Please note that for security reasons, we store passwords in encrypted form.
8. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of October 4, 2022 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
9. CONTACT AND COMPLAINTS
If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using our services, please contact us as soon as possible by emailing us at info@oltfoot.com.