1. Data Controller and Representative
2. Personal Data Processing Implemented by VirtuLook
“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Depending on how you interact with us, we process different kinds of data and in different ways. Some data is automatically processed if you visit our Sites or use our Products. Others data is only processed if you actively submit it to us (like using our web forms to get in touch with us or uploading content to our Sites).
2.1 Data we process if you visit our Sites:
When the User visits our Sites, VirtuLook implements a processing of Personal Data as follows:
2.1.1 Personal Data we collect if you visit our Sites
- Date and time of the visit and the duration of use of the Site;
- Information about how you visit our Sites (including the webpage that led you to a VirtuLook Site, the search terms entered into a search engine which led you to a VirtuLook Sites);
- Your operations and clicks to our Sites;
- Date and time of the visit and the duration of use of the Sites;
-Information about your device (type of device, browser type and version, as well as settings, installed plug-ins, operating system).
The aforementioned Personal Data is referred to as Website Usage Data.
2.1.2 Purposes of Processing
We process Website Usage Data to allow you to surf the Sites and to ensure its functionality. We also process Website Usage Data to perform analyses on the performance of the Sites, to continuously improve the Sites and correct errors, to ensure IT security and operation of our systems, as well as to prevent or uncover abuse. We further process this data in aggregated or pseudonymized form to analyze trends, administer the Sites, track users' movements around the Sites, and to gather demographic information about our user base as a whole or to improve marketing (including serving you personalized, interest-based ads) as well as the user experience on our Site and guaranteeing the safety of our IT systems.
2.2 Data we process only if you submit it to us:
2.2.1 Personal Data we collect if you submit to us through the data collection form in the purchase process or other processes:
- Account Data: On some of our Sites, you can register for an account with your e-mail address and a password you create. If you register one of our Sites or Products, you will automatically create an account you can use to manage
your licensed Products. Usually you need to provide your Name, Gender, Age, Image, Email address, Address, Country, Postal code, Phone number, Company name and industry you work for to create your account;
-Transaction Data: Billing information, such as your name, email address, billing address, your business affiliation (company or organization name). Type of Product you purchase, Amount you pay in your currency, Subscription ID, Subscription-related URLs (such as purchase confirmation page URL, subscription cancelation URL, invoice PDF URL);
-Content of customer support communications;
-Other Data you voluntarily provide to us.
2.2.2 Purposes of Processing
We use Account Data to help you to create an account and keep a record of your product license (that is, authenticating and periodically verifying your licensing rights in the product for anti-piracy purposes) and to enable the provision of maintenance or support services to you. We will also use this information to provide in-product messaging with information about products, features, or services offered by VirtuLook.
We will use Transaction Data to complete your order, for billing purposes, and for internal accounting and charge back management purpose.
We will use the comment data to improve its products and provide the consumers and potential consumers with a better and transparent information about the VirtuLook products. VirtuLook may use the comments (with your relevant information) you post for marketing purpose in order for others to better understand and use our products.
In order to provide the Products you purchased to you, or perform the contract between you and VirtuLook.
We do not collect or process the data about your payment instruments such as credit card numbers, banking account numbers or Pay Pal accounts. This information is collected, processed and stored by our qualified payment processors.
From time to time, we may contact our customers directly by mail, email, or telephone to inform you about upgrades, new products, promotions, or special offers that you told us you were interested in receiving (including our newsletters). The subscription to VirtuLook’s newsletters and the related provision of Personal Data is made on a voluntary basis so that the processing of the collected Personal Data relies on the User’s consent. If you want to cancel the aforementioned purpose, you can contact us or operate through your account or our forms on our Sites.
2.3 Data we process if you use our Products:
2.3.1 Personal Data we collect if you use our Products:
Generally, the data we collect are limited to:
- your product serial number;
- Product Usage Data. We collect information about the products which you use and how you use them, including but not limited to Launch data, Feature usage, Page clicks, Sign-in information;
- Product Installation Data. Your local device information, including but not limited to your device information, device hardware, operating system, other software on your system, Username, your VirtuLook ID, location, IP address, operating log information, the size and format of the files you are working with;
- Crash data and the information of the files you are working with. If the User meets with a crash problem, we will enquire if the User agrees to send the original document to VirtuLook. Only if the User agrees to send VirtuLook the original document, VirtuLook can have access to the original document.
2.3.2 Purposes of Processing
We process Product Usage Data and Product Installation Data so that we can facilitate, evaluate, and verify your use of our products and services. We will also use the Product Usage Data for our own internal statistical and analytical purposes, and to evaluate and enhance users' experience of the Products by identifying customer preferences and analyzing crash data. If you want to cancel the aforementioned purpose, you can contact us or operate through your account or our forms on our Sites.
In order to provide the Products you purchased to you, or perform the contract between you and VirtuLook.
In order to provide customer service or support.
In order to show you ads for VirtuLook products and services that we think may interest you. If you want to cancel the aforementioned purpose, you can contact us or operate through your account or our forms on our Sites.
3. Our Legal Basis for Processing
When processing your Personal Data, we usually rely on your consent. However, under some circumstances, we may process your Personal Data without getting your prior consent, such circumstances may include: (a) processing is necessary for the performance of a contract to which you(the data subject) are party or in order to take steps at the request of the data subject prior to entering into a contract; (b) processing is necessary for compliance with a legal obligation to which VirtuLook (the controller) is subject; (c) processing is necessary in order to protect the vital interests of the data subject or of another natural person; (d) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (e) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of Personal Data, in particular where the data subject is a child.
If we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time.
4. Recipients of Your Personal Data
We treat your Personal Data with care and confidentially and will only pass it on to third parties to the extent described below and not beyond. We do not share, sell, rent, or trade Personal Data with third parties for their
promotional purposes without your prior consent.
- Service Providers: We may share your Personal Data with companies that help us to run our business by processing Personal Data on behalf of us for the purposes identified above. Such companies include payment processing companies which can help us process transactions, the parties providing our third-party cookies and tracking tools which may send tracking data or analysis report and to VirtuLook，email delivery service providers which can help us deliver promotion emails to you, server companies we hire to provide service to you, charge back management service providers, fraud monitoring and prevention providers, social medias, third party online forums, and other marketing platforms and service providers.
In addition, VirtuLook may disclose the User’s Personal Data to:
- Public Authorities: if VirtuLook is under a duty to disclose or share such Personal Data in order to comply with any legal obligation, or in order to protect the rights, property or safety of its business, its customers or others; and
- Business Transactions: to successors in title or replacement operators of all or part of VirtuLook’s respective businesses.
5. Transfer of Personal Data Across National Borders
The main locations where we process your Personal Data include the US, EU, China, but we may also transfer Personal Data to other countries in the world where our Products are available. We carry out these transfers across national boarder in compliance with applicable laws – for example, by putting data transfer agreements(such as the Standard Contractual Clauses required by GDPR) in place to help protect your Personal Data.
Please find below the relevant information on transfer across national borders:
- VirtuLook may transfer your payment information to payment processing companies outside the EU to process transactions;
- VirtuLook may use third party cookies and tracking tools (such as AdWords, Bing, bugsplat, Criteo, Facebook, Google Analytics, LinkedIn, Quora) to track the information on how Users use the Sites and products, such Sites usage data and product usage data may be sent to and stored in third party servers located outside the EU. Such third-party cookies and tracking tools may send the tracking data or analysis report to VirtuLook for our above-mentioned purpose. Most of the third-party cookies and tracking tools process your Personal Data anonymously;
- VirtuLook may transfer your email address and other necessary information such as your name to email delivery service providers outside the EU to deliver promotion emails to you;
- VirtuLook may store the Personal Data on the servers leased from server service providers;
- VirtuLook may transfer your relevant Personal Data to marketing platforms and service providers outside the EU to complete relevant service;
- VirtuLook may transfer your relevant Personal Data to fraud monitoring and prevention providers outside the EU to complete relevant service.
6. Duration of the storage
VirtuLook will store the collected Personal Data for the duration necessary for the fulfilment of our contractual relationship or legal obligations and permitted by applicable legislation. Beyond this duration, we will delete the Personal Data according to applicable legislation. in order for VirtuLook to be able to demonstrate the existence of a right or a contract or a legal obligation, the relevant Personal Data will be stored through intermediary archives for a duration that will not exceed what is strictly necessary regarding the purpose of the storage and in accordance with the applicable legislation. Regarding banking information, said information will be deleted once the payment has been processed and has become effective. Withdrawal time period could additionally apply. The number and the expiration date of the credit card number (not the CVV security code) could be stored through intermediary archives for evidence purposes in case of a claim regarding the payment, for the duration provided by applicable legislation.
7. Cookies and tracking tools
VirtuLook implements a number of industry standard information-tracking tools to collect information about your use with our Sites and Products. When the User consults the Sites and/or the Products, VirtuLook implements cookies on the User’s device. The third-party tracking tools are listed as blow, but it doesn’t necessarily mean each of our Sites or Products use all the tracking tools listed below.
|Name and link of third-party tracking tools
|Data collected by tracking tools
|Purpose of data collection
|Used on Website or product
( https://policies.google.com/ )
( https://privacy.microsoft.com/ )
( https://www.criteo.com/privacy/ )
( https://www.facebook.com/privacy/explanation/ )
( https://www.linkedin.com/legal/privacy-policy )
( https://www.quora.com/about/privacy )
|Website usage data
|targeting and advertising purpose
( https://policies.google.cn/privacy )
Website usage data
product usage data
local device data
|better understand how the Website and product work, and make improvements
( https://docs.bugsplat.com/introduction/production/security-privacy-and-compliance/privacy-policy )
|better understand how the product crash, and make improvements
Sensors Data SDK
( https://www.sensorsdata.cn/compliance/privacy.html )
|product usage data
|better understand how the product work, and make improvements
For additional information on cookies and tracking tools, please read VirtuLook’s cookies policy
8. Third Party Services
Some of our products may use the Third-Party services. When Third-Party Services are enabled by a Customer or an Authorized User, VirtuLook may share Information with Third-Party Services. Third-Party Services are not owned or controlled by VirtuLook and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions。
9. User’s Rights
To the extent required by the law of your jurisdiction, you may have below rights. Before you exercise below rights, you may consult your legal counsel if the laws of your jurisdiction stipulate below rights. Residents in the EU have below rights according to GDPR.
|The right to be informed
|The right of access
|The right to rectification
|The User is entitled to have its Personal Data corrected if it’s inaccurate or incomplete.
|The right to erasure
|This ‘the right to be forgotten’ enables the User to request the deletion or removal of its Personal Data where there’s no compelling reason for VirtuLook to keep using it. This is not a general right to erasure; there are exceptions.
|The right to restrict processing
|Under certain circumstances, the User has the rights to ‘block’ or suppress further use of its Personal Data.
|The right to data portability
|The User has the rights to receive its Personal Data provided to VirtuLook in a structured, commonly used and machine readable format and has the right to transmit those data to another controller.
|The right to object to processing
|The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its Personal Data.
|The right to lodge a complaint
|The User has the right to lodge a complaint about the way VirtuLook handles or processes its Personal Data with its national supervisory authority (in France, the CNIL).
|The right to withdraw consent
|If the user has given its consent for a specific processing of its Personal Data implemented by VirtuLook, the User has the right to withdraw its consent at any time. In case the User does so, it does not mean that anything VirtuLook has done with the User’s Personal Data with its consent up to that point is unlawful).
|The right to define instructions
|The User has the right to define general or specific instructions regarding storage, deletion and use of its Personal Data after death.
If you want to exercise your rights aforementioned, you can contact us directly or operate through your account or our forms on our Sites, we will actively cooperate with you and provide assistance to you.
However, to register with VirtuLook, to create an VirtuLook account, and to use some VirtuLook Sites, Products, the provision of some information including but not limited to the email address is mandatory: if relevant information is not provided, then we will not be able to administer an VirtuLook account to you, or provide you with the Sites, products or services requested. Other provision of your information is optional. Providing optional information will help us offer you a better experience, such as more personalized or tailored content or offerings.
10. Collecting Information from Children
VirtuLook's Sites and products are not intended for use by children under the age of 16 and we do not intentionally collect any information from users under the age of 16. If you do not meet applicable age requirements, please do not use those Sites and products. If a parent or guardian becomes aware that their child has provided VirtuLook with Personal Data or that we have otherwise inadvertently collected this information, contact us at contact@VirtuLook, so that we may delete the information from our servers.
12. Contacting VirtuLook
If the User needs to contact VirtuLook for any reason (including to exercise any of its rights in relation to data protection as set out above) please contact contact@VirtuLook.
VirtuLook will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case VirtuLook may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.
13.1 Privacy when accessing to Google Drive
13.2 Google API Services User Data Policy
PDFelement use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.”
You can view the Google API Services User Data Policy here: https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes