UDIRC Privacy Policy

Last Updated: March 5, 2022

Thank you for your interest in UDIRC Technology Co., Ltd. and its affiliated companies (“UDI”, “we”, or “us”) and in the various hardware, firmware, software, websites, applications, and services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (each, a “Product” or “Service” and, collectively, the “UDI Products and Services”).
This Policy describes:

• The information that we gather from you,

• How we use and share this information,

• The rights and choices you have regarding this information,

• The steps we take to protect this information,

• The information gathered by third-party services,

• How we transfer your information,

• How we may change this Policy, and

• How you may contact us.

By using UDI Products and Services, you consent to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Terms of Use for the UDI Products and Services you use.

We may collect information about you directly from you, from third parties, and automatically through your use of the UDI Products and Services. Some information we collect from you are referred to as “personal information” or “personal data” in this Policy. Personal information or personal data is data that can identify you, or data that we can relate to you, such as your name, email address, credit card number, and shipping address.

• Account information. When you create a UDI account, you may provide us with information that includes your user ID, email address (or phone number, based on the country located), password or other information for account verification. You might choose to provide us with additional information — like gender, birthday, professional information and other information on your profile page.

• Contact information. When you place an order with UDI, or contact us for customer service, you may provide us with your contact information including your name, alias, email address, shipping address, billing address and phone number(s). Certain jurisdictions require provision of contact information when activating unmanned aerial system (UAS) products, opening online accounts, or under other similar circumstances as required by law. UDI only collects and stores UAS-regulatory related information to the extent required by applicable law.

• Payment information. When you place an order with UDI or engage in financial transactions by using UDI Products and Services, you may provide us with your payment information such as your bank account, credit card number, or debit card number.

• Photos and Videos. UDI does not automatically collect your photo or video without your consent and affirmative actions. When you choose to upload your photos, videos or other content using UDI Products and Services, including text content relating thereto, we may collect and store such content, including EXIF data relating to the photo or video. If such content contains information about others, you should obtain any required or appropriate consent from such persons and inform them about this Policy prior to uploading such content to UDI.

• Communications. When you contact us, we may collect information about your communications with us, including your contact information, and the time, topic, and content of your communications.

• Location information. When you activate UDI hardware products, use the map function of our apps, synchronize your flight record, obtain UAS safety/regulatory notifications, share your content on Skypixel, or search for nearby flying spots, you may provide us with geolocation information. In order to provide your location, you may be required to enable certain features of your device (such as GPS, Wi-Fi, and Bluetooth) to identify your location through a variety of means, including GPS location, IP address, cell tower location, or detection by physical on-location Wi-Fi or Bluetooth sensors. If your location is collected through Wi-Fi or Bluetooth sensors of your mobile device or other non-UDI Products, please be aware that such sensors, and the associated data services, may be provided by a third party, which may access such information for the purpose of providing such data services to UDI. You may provide your geolocation information to third-party map service providers to receive location-based services on UDI Products. When you unlock the geofencing features embedded in UDI Products and Services, you may provide us with the area code of your unlocked areas (“Authorization Zones”).

• Device-Related and Flight-Related Information. When you activate UDI products, request for after-sales service, unlock the geofencing features or upgrade the firmware, you may provide us with information about your UDI device, including model and serial number. Our after-sales team may ask for your flight data to provide the service you requested.

• Technical Information. When you visit our webpage or use our mobile applications, you may provide us with technical information about the device running the browser or the application. Such information includes your IP address or device address, web browser and/or device type, the web pages or sites that you visit just before or just after you use a Product or Service, hardware version, and operating system. We also may use these technologies to collect information regarding your interaction with UDI email messages, such as whether you opened, clicked on, or forwarded a message.

• When you apply for a position at UDI, you may provide us with your educational information, such as your academic degree and graduated school, and employment-related information, such as your former employers and working achievements. We may also collect such information from third party recruiters or websites.

• Cookies. We use cookies and other similar technologies (e.g. pixels etc.) on UDI websites and online services. Cookies are used to collect information, including personal data, from you. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. To learn more about cookies please see our Cookie Policy.

We use information we collect through UDI Products and Services in a variety of ways in providing the UDI Products and Services and operating our business. The use of information that we collect includes the following:

• To operate and provide features of the UDI Products and Services, to verify and manage UDI user accounts, to provide services and information that you request, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time by UDI. We will process your personal data in accordance with this Policy and any of your preferences, which are expressed via UDI Products and Services, including Flyingsee, UDIGPS and the UDIRC-X App.

• To maintain and enhance UDI Products and Services, to analyze the information you provide to us, to personalize the content you receive and provide you with tailored content that will be of interest to you.

• To understand and analyze the usage trends and preferences, to improve the UDI Products and Services, and to develop new products, services, features, and functionality.

• To contact you for administrative and informational purposes, including for customer service. We may send direct marketing such as communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. If you are an individual or consumer we will only send you direct marketing with your consent or as permitted by applicable law. You may send unsubscribe requests or withdraw your consent at any time. Please visit the section Your Rights and Choices Regarding Collected Information to find out more.

• To detect, prevent, and respond to fraud, abuse, security risks, and technical issues that could harm our users, us, or the public.

• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

• We will aggregate personal data we collect, such as the number and frequency of your visits to our sites and apps, to produce metrics and statistical information. We use aggregate data to help us understand how the site is being used and to improve its usability. We also use it to enhance the quality and availability of products and services we offer.

• To comply with applicable laws, such as laws related to the use of unmanned aerial system (UAS) products or opening online accounts.

If you are located in the European Economic Area, we will only use your information when we have a valid legal ground, including when:

• You have consented to the use of your information, for example to send you marketing communications.

• We need to use your information to enter into or perform a contract with you, for example to deliver UDI products, to provide map services, or provide you with the customer support and other after-sales services.

• We need to use your information to comply with a legal obligation, for example to comply with a court order, subpoena, or warrant.

• We or a third party have a legitimate interest in using your information. In particular, we have a legitimate interest in using your information to understand and improve our UDI Products and Services, and to monitor for and prevent fraud. We only rely on our own or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.

We will not disclose your information that we collect through UDI Products and Services to third parties except as described in this Policy or as we disclose to you at the time the information is collected. We may disclose information to third parties in the following circumstances:

• We may share your information with our parent company, affiliates and subsidiaries globally when permitted by law, and necessary to provide you with UDI Products and Services.

• Any information that you voluntarily choose to make publicly available by uploading it to a publicly accessible site or venue using UDI Products and Services (including sharing information on UDI’s online community forum, the “UDI Forum”), or that you otherwise elect to make public, will be available to anyone who has access to that content, including other users.

• We work with third party service providers to provide payment facilitation, parcel transportation, application development, traffic monitoring or analysis, electronic messaging, and other services for us. We require these service providers to use or disclose the information they process on our behalf, only as necessary to perform services on our behalf or comply with legal requirements.

• According to local laws and regulations, such as Remote Identification or other aviation regulations and requirements, your device-related information, product location, and remote controller (ground control station) location may be transmitted to and received by individuals, companies, or organizations determined by aviation regulations to be appropriate receivers of such information. Please refer to your local authorities for more information regarding what types of your information are subject to these requirements. Your UDI aircraft device information available from dealers.

• We may preserve and disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or enforceable request.

• We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activities, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the UDI Products and Services and any facilities or equipment used to make the UDI Products and Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

• Information about our users, including information you provided and any information collected through UDI Products and Services, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

• We may make certain aggregated, de-identified, or non-identifying information about users of UDI Products and Services available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iv) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality of UDI Products and Services.

• You may update, correct, or delete certain UDI account information and preferences by accessing your account preferences page, available through certain UDI Products and Services, including the udirc.com and various mobile applications. If you receive commercial email or text messages from us, you may unsubscribe at any time by following the instructions contained within the email or text message. You may also opt out from receiving commercial email or text messages from us or object to be profiled by sending your request to us by email at support@udirc.com.

• If you are located in the European Economic Area, you may also have the right to request access to additional information, including the right to request access to and receive certain information we maintain about you; to update or correct inaccuracies in the information we maintain about you; to receive a copy of the information which you provided for its transmission to another company; to object to the processing on grounds relating to your particular situation; and to have the information blocked, deleted, or erased, as appropriate. When we process personal data on the basis of your consent, you can also withdraw your consent. If you withdraw your consent, we will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdrew your consent.

• Note, however, that if you exercise your right to object or your rights of blocking, deletion or to be “forgotten” or if you decline to share certain information with us, or if you withdraw your consent to our processing of information about you, we may not be able to provide to you some, or any, of the features and functionality of UDI Products and Services.

• Likewise, if you close your UDI account, you will not be able to sign in to UDI Products or Services or access any of your information. However, you can open a new account at any time. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit, as authorized under applicable law, for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information will be subject to those third parties’ policies.

• If you wish to exercise any rights you have under applicable data protection law, including the right to access, amend or delete any information we hold about you, you may contact us at support@udirc.com.

• UDI Products and Services may contain features or links to websites and services provided by third parties. Any information you choose to provide on third-party sites or services, or any information otherwise collected by such third-party sites or services is collected directly by the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through UDI Products and Services.

• We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through UDI Products and Services. If you opt in to use such third-party services, please be sure to check the Privacy Policies of these sites as well as their “Terms of Use” before engaging in any business or uploading any information.

Except for certain products that are marked as “14+” or “for customers over the age of 14”, UDI Products and Services are not directed to children under the age of 16. We do not knowingly collect information from children under the age of 16 without obtaining parental consent.

We use certain physical, organizational, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards.

Your information collected by UDI may be transferred to and accessed by UDI entities and business partners globally to provide UDI Products and Services to you. If you choose to use UDI Products and Services from the European Economic Area (EEA), then UDI GmbH in Germany is the data controller, and we may transfer your personal data outside of EEA for storage and processing. You should be aware that the local laws in non-EEA countries may provide less protection than the laws applicable in the EEA. We nonetheless provide the same level of protection as specified in this Policy, regardless of the location of processing. For international transfer of data collected in the EEA, we require data recipients to enter into the standard contractual clauses approved by the European Commission. You may obtain a copy of the standard contractual clauses by contacting us at support@udirc.com.

We retain your information to provide service to you, or as required by applicable laws or regulations. We aim to retain your information only for the period necessary to fulfil our obligations under this Policy, unless otherwise required or permitted by law. We will carefully assess the need to collect data, the type of data collected, relevant legal framework, and the statute of limitations when determining the retention period.

Please contact us with any questions or comments about this Policy or our data practices by email at support@udirc.com or in writing to UDIRC Technology Co., Ltd. Guangfeng Industrial Area, Dengfeng Road, Chenghai District, Shantou City, Guangdong Province, China, 515800. You may contact us to have your information blocked, deleted or erased, or to opt out from profiling where your prior usage of UDI Products and Services is processed to provide you with customized or personalized products, services or advertisements, or to obtain copies of certain of your information in a portable format.

Please contact us with any questions or comments about this Policy or our data practices by email at support@udirc.com or in writing to UDIRC Technology Co., Ltd. Guangfeng Industrial Area, Dengfeng Road, Chenghai District, Shantou City, Guangdong Province, China, 515800. You may contact us to have your information blocked, deleted or erased, or to opt out from profiling where your prior usage of UDI Products and Services is processed to provide you with customized or personalized products, services or advertisements, or to obtain copies of certain of your information in a portable format. If you think that any of your rights have been infringed by us, you may also lodge a complaint with us or with a data protection regulator, including in your country of residence, place of work or where an incident took place. You can find out more information about your rights by contacting your local data protection regulator or the Bavaria State Office for Data Protection Supervision, or by searching their website at https://www.lda.bayern.de/en/index.html. If you have any queries or wish to exercise any of your rights under this Policy, please contact us as set out above.

Last Updated or Reviewed: March 5, 2022

This California Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to the Personal Information of certain California residents, who are Consumers receiving products or services for which we are a Business, as those terms are defined under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”), and is effective upon the date that the CCPA enters into operation.

Briefly, and as more fully defined in the CCPA, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Household; however, certain categories of information may be excluded, including, for example, de-identified or aggregate information, information lawfully made available from government records, medical information, data subject to HIPAA, data maintained by healthcare providers in the same manner as data subject to HIPAA, clinical trial data, consumer credit reporting agency data or data subject to the Fair Credit Reporting Act, data subject to the Gramm-Leach-Bliley Act, data subject to the Driver’s Privacy Protection Act, and data relating to vehicle ownership or warranty information.

Any capitalized terms herein are intended to have the same meaning as in the CCPA.

If you are a Consumer, California law may permit you to request information regarding the:

• Categories of Personal Information (as defined by applicable California law) collected, sold or disclosed by us;

• Purposes for which categories of Personal Information collected by us are used;

• Sources of information from which we collect Personal Information; and

• Specific pieces of Personal Information we have collected about you.

In addition, if you are a Consumer you may:

• Opt-out of the sale or disclosure of your Personal Information, in some circumstances;

• Opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding the Services;

• Opt-in to certain financial incentive programs we may offer related to the collection, sale, or deletion of your Personal Information; and

• Request deletion of your Personal Information by us and our service providers, in some circumstances.

Further, California law provides Consumers with the right not to receive discriminatory treatment by a business for the exercise of these rights regarding Personal Information.

We may collect the following categories of information about you directly or indirectly from you or our affiliates through your use of the UDI Products and Services:

• Identifiers, such as your name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our Website or from your Devices, or (3) directly from our affiliates. We use such information for our business purposes, including specifically:((1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.(3) Debugging to identify and repair errors that impair existing intended functionality.(4) Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

  (5) Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  (6) Undertaking internal research for technological development and demonstration.

  (7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Vendors and service providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Categories of Personal Information in Cal. Civ. Code Section 1798.80(e),
  such as your name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, or (2) directly from our affiliates. We use such information for our business purposes, including specifically:(1) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.(2) Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on behalf of the business or service provider.(3) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  (4) If you are applying for a position at UDI, we may use your information for the purposes of recruiting talents for us or our affiliates.

  We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Vendors and service providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Characteristics of Protected Classifications under California or Federal Law, such as gender. We collect such information (1) directly from you, e.g., forms you complete, or (2) directly from our affiliates. We use such information for Our business purposes, including specifically:(1) Showing your user profile with information you voluntarily provided to us by submitting online forms;(2) Recruiting talents for us or our affiliates.We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Vendors and service providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our Website or from your Devices, or (3) directly from our affiliates. We use such information for our business purposes, including specifically:(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, verifying quality of customer services, and auditing compliance with product specifications and other standards.(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.(3) Debugging to identify and repair errors that impair existing intended functionality.(4) Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, locating past service history.

  (5) Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  (6) Undertaking internal research for technological development and demonstration.

  (7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Vendors and service providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Internet or Other Electronic Network Activity Information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our Website or from your Devices, or (3) directly from our affiliates. We use such information for our business purposes, including specifically:(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.(3) Debugging to identify and repair errors that impair existing intended functionality.(4) Performing services on behalf of the business or service provider, including verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  (5) Undertaking internal research for technological development and demonstration.

  (6) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Vendors and service providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Geolocation Data, such as precise physical location and approximate location. We collect such information (1) directly from you, e.g., products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our Website or from your Devices. We use such information for our business purposes, including specifically:(1) Performing services on behalf of the business, including providing you with map services and UAS safety/regulatory notifications, finding your lost UDI Products, unlocking geofencing features in designated areas, and providing customer services.(2) Debugging to identify and repair errors that impair existing intended functionality.(3) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business, including retaining records relating to your geofencing unlock decisions.We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Vendors and service providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Sensory Information, such as audio, electronic, visual, thermal, or similar information. We collect such information directly from you, e.g., products and services you purchase. We use such information for our business purposes, including specifically, performing services on behalf of the business or service provider, including providing customer service.We may share such information with:
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.

• Professional or employment-related information, such as job application or resume information, past and current job history, and job performance information, unless exempt. We collect such information directly from you, e.g., forms you complete or products and services you purchase. We use such information for our business purposes, including specifically, recruiting talents for us or our affiliates.We may share such information with:
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.

• Inferences Drawn from Personal Information, such as consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We collect such information indirectly from you, e.g., from observing your actions on our Website or from your Devices. We use such information for our business purposes, including specifically:(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.(3) Debugging to identify and repair errors that impair existing intended functionality.(4) Undertaking internal research for technological development and demonstration.

  (5) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  We may share such information with:
  ▪️ Data analytics providers.
  ▪️ Affiliates.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.

Such information may be used for the purposes for which it was collected or as otherwise permitted or required by applicable law.

We have not sold in the preceding twelve months from the date of last review of this Privacy Policy, do not currently sell, and will not sell your personal information for twelve months from the date of the last review of this Privacy Policy.

You can make requests related to your California privacy rights at the attached link . You may also make those requests by email to support@udirc.com or in writing to UDIRC Technology Co., Ltd., Guangfeng Industrial Area, Dengfeng Road, Chenghai District, Shantou City, Guangdong Province, China, 515800. Please be aware that we do not accept or process requests through other means (e.g., via fax or social media).

We will review the information provided and may request additional information to ensure we are interacting with the correct individual. If you have an online account with us, you may be required to log-in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

By law, we are not required to collect personal information that we otherwise would not collect in the ordinary course of our business, retain personal information for longer than we would otherwise retain such information in the ordinary course of our business, or re-identify or otherwise link information that is not maintained in a manner that would be considered personal information. If we have not requested specific additional information from you to verify your request, please do not send such information.

We generally will aim to avoid requesting additional information from you for the purposes of verification. However, if we cannot reasonably verify your identity or more information is needed for security or fraud-prevention purposes, we may consider any of the following factors, alone or in combination, in requesting additional information:

• The type, sensitivity, and value of the personal information collected and maintained about the consumer, as applicable law requires a more stringent verification process for sensitive or valuable personal information;

• The risk of harm to the consumer posed by any unauthorized access or deletion;

• The likelihood that fraudulent or malicious actors would seek the personal information;

• Whether the personal information to be provided by the consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;

• The manner in which the business interacts with the consumer;

• Available technology for verification; and

• Other factors that may be reasonable in the circumstances, are consistent with industry practice, are recommended by California government officials, or which may be required by law or regulation following the effective date of this Privacy Policy.

If your request is regarding household information, the same verification steps above are required before we can provide you with aggregate household information. For us to process a request for access to or deletion of specific pieces of information regarding your household, all members of the household must make the request, and we must be able to verify each household member.

In some cases, we may not have sufficient information about you or your household to be able to verify your identity or sufficiently differentiate you from another consumer or household to the degree of certainty required by law, in which case, we will not be able to act upon your request. In such cases, it may be unlikely that we would be able to identify you or your household in the future without collecting significantly more information or seeking to re-identify de-identified information. At this time, we do not intend to take such steps in response to a request made pursuant to this Privacy Policy and applicable law does not require that we do so. If, in the future, we determine a reasonable method to identify you or your household absent such steps, we will provide an update to you through this Privacy Policy and in response to any such request at that time.

Information that you submit for the purpose of allowing us to verify your identity in furtherance of a consumer-related or household-related request pursuant to California law will only be used by us, and our service providers if any, for that purpose and no other. Except where we are required by law to maintain such information for record-keeping purposes, we will take steps to delete any new personal information collected for the purpose of verification as soon as practical after processing your request.

Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request, including, for example, where fulfilling your request may infringe upon the rights and freedoms of other consumers.

We reserve the right to charge a reasonable fee or take other appropriate action in response to requests from a consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.

You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a notarized statement. You must submit evidence of your designation of an authorized agent in writing to: UDIRC Technology Co., Ltd., Guangfeng Industrial Area, Dengfeng Road, Chenghai District, Shantou City, Guangdong Province, China, 515800. We may require verification of your authorized agent in addition to the information for verification above for consumers and households.

UDI does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

For questions regarding this California Privacy Notice, contact us by email at support@udirc.com, or in writing at UDIRC Technology Co., Ltd., Guangfeng Industrial Area, Dengfeng Road, Chenghai District, Shantou City, Guangdong Province, China, 515800.