China Beijing 7invensun Technology Co., Ltd. Privacy Policy

The 7invensun Privacy Policy was updated on the 14th of February 2020.

We, Beijing 7invensun Technology Co., Ltd. (hereinafter referred to as "7invensun "or "we"), understand that eye tracking products and services (hereinafter referred to as "Services") require personal data, which is interconnected to user privacy and requires a prudent approach to protection. Therefore, we are obligated to recognize, respect and protect all user privacy.

The Company's Privacy Policy (hereinafter referred to as "Policy") is intended to describe the way in which 7invensun and its subsidiaries collect, use, disclose, and protect information. The Company will amend the Policy sporadically to update incomplete or outdated information, or information that requires modification. Major Policy changes will be published on the Company's official website, and new policies will take effect immediately following the release.

In addition to this Privacy Policy, we provide data and privacy information imbedded in our products connected with our Icon that ask to use your personal information.

1. What Personal Data we collect

Personal data and other information you (and others) give us as follows.

- We may collect information about you when you use our Services, including the following: When you register to use our Services, we may require you to provide us with your name, postal address, email address and phone number.

- When you buy something from us, we will collect information about the transaction. This can include your payment information, purchase activity and delivery and contact details.

- When you communicate with 7invensun, you may provide us with information such as your email address.

- If you seek customer support for one of our Services, then it's sometimes necessary for us to access your personal information to be able to help you with your problem，for example if we need to remotely control your device to troubleshoot. In those cases, we will either delete the data once the support matter has been resolved (as in the remote control case), or store the data according to applicable laws or regularity requirements.

Your Personal data and other information will not be collected when you use our services. We only collect the machine code of the eye tracking devices. The personal profile created by you in your devices will not be transmitted to 7invensun.

Third parties may also collect information about you through the Services, or receive information collected about you through the Services, as described below.

- We may share your personal data within the 7invensun and its subsidiaries in order to develop and improve our products and Services. Such information, however, is anonymized to the best extent possible.

- Some of our Services offers the opportunity to use a social media account as an access method to the Service. If you choose to do so, that social media platform will receive information that you chose that access method at one of 7invensun’s Services, and we will receive some types of information from the social media site. How that social media platform processes your information falls outside the scope of this Privacy policy.

2. How we use your personal data

We use the information we collect to provide you with our Services. For example, we use this information to:

-Provide you with hardware, solution, content, games, software and other services;

-Provide technical support and assistance;

-Conduct customer satisfactory surveys;

-Notify you about updates to our Services and products; and

We also use the information that we collect to understand, develop and improve our Services. For example, we use the information to:

-Seek and analyze input and feedback about our Services;

-Identify and address technical issues on our Services;

-Conduct and learn from research about the ways in which people use our Services; and

-Improve services offered by others, such as third parties that offer games, apps and other content connected to our Services.

We use the information that we collect to send you promotional messages and content and otherwise market to you on and offer our Services. We also use this information to measure how users respond to our marketing efforts. If you would like to opt out of receiving marketing emails, then you can always do so by follow the instructions implemented in every such promotional message.

We use the personal data that we collect to help promote safety and security on and off our Services and Products, such as by investigating suspicious activity or breaches of our terms or policies and protecting our or others’ rights or property.

3. How do we protect data?

Data Storage - Once data is received, we will take all reasonable steps to ensure your data is secure to prevent unauthorized access to it. All information you provide is stored on secure databases, our IT systems are password protected and all payment transactions are encrypted.

Security and passwords - When you create an account with us you are assigned a Customer ID number. Your account will require an email and password so that you can access your details online. The password is automatically generated by the booking system and we recommend you keep this password safe for future bookings.

Please do not share your password with anyone. Unfortunately, the passing of data via the internet is not completely secure therefore any transmission is at your own risk. Please keep these details safe and not written down anywhere. If you change your personal details or if you suspect that someone else has used your password, please notify us as soon as possible.

4. Reasons we share personal data

To provide and support our Services, information that we have about you is shared in certain circumstances. The following can see information about you when you and others use our Services.

- Developers, support and other online content providers on our services.

- You can interact with Third-party content, games, apps and other experiences through our Services. We may share information about you with these partners so they can provide you with the experiences that you've requested, such as:

- Information in your 7invensun profile and about how you use our Services. For example, we may provide a third-party games provider with your user ID or similar, so that the games provider may deliver a game to you that you’ve purchased bundled with one of our products.

- Any other information that you choose to share with the third party through your use of the Services.

- Sharing within related companies. Depending on which services you use, we share information with 7invensun’s subsidiaries.

- Other service providers. We share the information that we collect with vendors, service providers, researchers and other partners, who work at our direction to support the Services (such as hosting our Services, fulfilling orders, facilitating payments, analyzing the way people use our Services, processing credit card payments, providing customer service or sending electronic communications for us).

Other parties in connection with certain business transactions. In the event that the ownership of 7invensun (or any portion of our assets) changes as a result of a merger, acquisition or in the event of a bankruptcy, information from or about you or your device may be transferred to another company.

- Law enforcement or legal requests. We share information with law enforcement or in response to legal requests .

5. How the 7invensun companies work together

7invensun shares infrastructure, systems, and technology with its affiliates company to provide an innovative, andsafe experience across all Services that you use.

6. Third parties that provide content, marketing or functionality on our services

Some of the content, marketing and functionality on our Services may be provided by third parties that are not affiliated with us. For example, we work with companies that help us provide content within the Service that you purchased.

7. Data retention and deletion

We store data that identifies you until it is no longer necessary to provide our Services, for example when you delete an account with us. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain purchase information for accounting and tax purposes even after you have deleted your account.

When you delete an account with us, we delete or anonymize the data you provided us with and the data we collected during your use of the Services. Neither you nor us will be able to restore such deleted or anonymized data.

8. Changes to this policy

If we make changes to this Privacy Policy, we will provide notice of such changes as appropriate and may update the "Last Updated" date at the top of this Privacy Policy.

The Data Security Officer for 7invensun can be contacted at dso@7invensun.com.

9. What is our legal basis for processing data?

Our lawful bases for processing data are as follows:

-If processing is necessary to fulfill our contract with you, i.e. what we are obliged to provide under the agreement between you and us. Our obligations to you vary depending on the Service you are using. For example, we may need to store your name and address to keep track of our warranty obligations to you.

-With your consent. For example, when you have given your consent for 7invensun to use your eye images and other personal data to develop our algorithms and thus our products. It should be noted that you may withdraw your consentat any time, but a withdrawal of a consent shall, and cannot, affect the lawfulness of processing that has already been carried out based on that consent before its withdrawal.

-As necessary to comply with our legal obligations. For example, we must store some purchase information to comply with tax and accounting regulations. The legal ground for this processing (storing) is therefore necessary for compliance with legal obligations.

-Occasionally to protect your vital interests or those of others. On rare occasions, we may process your data if doing so is necessary to protect your vital interests. For example, in situations where there is an immediate risk to your health, we may share information with your caregiver.

-As necessary for our (or others) legitimate interests. We have a legitimate interest in providing an innovative, personalized, safe and profitable service to our existing and future users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

10. How can you exercise the rights provided to you under the GDPR?

Under the General Data Protection Regulation, you are entitled to exercise the following rights:

Right of Access: Find out what kind of personal information is held about you and get a copy of this information.

Right of Rectification: Ask for your information to be updated or corrected.

Right to Data Portability: Receive a copy of the information which you have provided under contract so that you can provide that information to another organization.

Right to Restrict Use: Ask for your personal information to stop being used in certain cases, including if you believe that the personal information about you is incorrect or the use is unlawful.

Right to Object: Objecting to use of your information (where a party is processing it on legitimate interest basis) and to have your personal information deleted.

Right to Erasure: In certain circumstances, you may also have your personal information deleted.

Find out more about these rights, and how you can exercise them by either contacting 7invensun at dso@7invensun.com or obtain information from the appropriate supervisory authority.

11. Contacting us

If you have any questions about our Privacy Policy, please contact us by e-mail at dso@7invensun.com.

12. Severability

If any part of this Policy shall be held unenforceable for any reason, the remainder of this Policy shall continue in full force and effect. In case of any dispute arising from this privacy policy, you agree that you will submit the dispute to Beijing Arbitration Commission for arbitration in Beijing in accordance with the current effective arbitration rules of the Commission.

7invensun has the final right to interpret the privacy policy, including the rules formulated and supplemented based on the privacy policy.