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Privacy Policy

Updated 18 October 2024.


Ultraleap Limited (our UK trading entity) and Ultraleap Inc (our US trading entity) and their affiliated entities (hereafter “Ultraleap”, “we”, “our”, “us”) are committed to protecting the privacy and security of your personal information.

If there is any conflict between the terms of this policy and any applicable data protection rules to which Ultraleap is subject, those rules shall apply.

INFORMATION WE COLLECT

Information you give us. 
This is information about you that you give us by filling in forms on our website, or by corresponding with us by phone, e-mail, through our chatbot, or in person.  It includes information you provide when you subscribe to our newsletter, sign up for our Evaluation Kit, order one of our development kits, sign up for our academic program, or register your interest in, sign up for or pre-order any of our other software or hardware, register to use our site, search our site, place an order for software or hardware, whether through us, or through a third party vendor, apply for a job (more details of which can be found at our Recruitment Privacy Statement here: https://www.ultraleap.com/recruitment-gdpr-notice/), and when you report a problem with our site (including by raising a support ticket).  The information you give us may include your name, job title, address, e-mail address, phone number, debit or credit card information, educational institute (in the case of signing up for our academic program).

Information we receive from other sources. 
This is information we receive about you if you use any of the other websites we operate, the other services we provide, or from sources not linked to us including information published publicly by you on platforms such as LinkedIn, and information you have provided to external recruiters and consented to them sharing with us. More details of privacy and recruitment can be found at the link provided above.

We may also collect non-identifiable infrared hand image data. 
This data helps us to improve our products and services, including to train and improve our tracking software. We do not associate this data to your device ID, any account you have with us, or any other personally identifiable information. Although this data does not constitute personal data, you can still choose to stop sharing this data with us in the software control panel.


Cookies. 
We use cookies and equivalent technologies in relation to both our website and products. See below to learn more about how we collect this non-personal data.

HOW WE USE THIS INFORMATION

We will use this information:

  • to enter into agreements with you, to carry out our obligations arising from any such contracts entered into between you and us, to provide you with the information, products and services that you request from us, and to engage with you in relation to the provision of your services to us under any such contracts;
  • to enable our third party vendors to carry out their obligations arising from any contracts entered into between you and them and to provide you with the information, products and services that you request from them (this includes the sharing of your information with our third party vendors to facilitate any purchase by you of our products);
  • to verify that any use of our software is authorised;
  • to notify you about changes to our service in relation to a contract that we have with you;
  • where required to do so, in order to comply with legal obligations which apply to us;
  • Because it is in our legitimate interests;
  • to improve our products and services.

With your permission we may also use this information for technical support and marketing purposes, including:

  • to contact you in respect of technical support requests made by you;
  • to contact you to offer sales support where you have asked us to do so;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to contact you with questionnaires about our goods or services so that we may carry out market research and analysis to improve those goods and services;
  • to provide you with information about other goods or services we feel may interest you.

HOW WE SHARE YOUR INFORMATION

We may share your information within our group, and with selected third parties including:

  • business partners, suppliers, sub-contractors, collaboration partners, auditors, legal and tax advisors, service providers (including to the third party who provides out website’s chatbot) and third party vendors (this includes disclosure to our distributors so that orders for hardware can be fulfilled);
  • analytics and search engine providers that assist us in the improvement and optimisation of our site and our software.

We may disclose your personal information to other third parties in the following circumstances:

  • if we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets only if necessary for the sale or purchase;
  • if a third party acquires Ultraleap or substantially all of its assets, in which case personal data held by Ultraleap (including that about its customers), will be one of the transferred assets;
  • in order to enforce or apply our licence terms; or
  • in situations where Ultraleap is obliged to disclose personal information in response to the mandatory and lawful requirements of public authorities to whose jurisdiction it is subject. For example, in connection with national security or law enforcement. 

TRANSFERRING YOUR DATA INTERNATIONALLY

Ultraleap participates in the EU – US Data Privacy Framework and the UK extension, and consequently we rely on the adequacy decisions made by the EU and the UK regarding the US to process personal data from Europe and the UK in our US business.

Otherwise, the information that we collect from or about you may in some circumstances be transferred to, stored, or processed at a destination outside of the UK or US, including in the event of transfers to other parts of our group not located in the UK or US. It may also be processed by third parties operating outside the UK or US who work for us, our suppliers, distributors, or service providers. This may include third parties engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

Where it is necessary to transfer your data internationally, we will ensure we have taken appropriate safeguards to ensure the safety of your information and our compliance with the relevant data privacy regimes. In some cases, Ultraleap may remain liable for onwards transfers.

YOUR RIGHTS

You may have certain rights in relation to information of yours that we hold. This can include:

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erase;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • rights in relation to automated decision making and profiling.

You also have the right to request a copy of the personal information we hold about you.


You can exercise these rights, including the right to make a data subject access request or to withdraw any consent granted by you to us to use any of your personal information for a particular purpose, by writing to us at the address or email address provided below.

THIRD PARTIES

Orders for hardware or payments for software may be dealt with by third-party vendors.  Where third party vendors deal with your order you will be subject to their privacy policies, website terms of use and/or terms and conditions that may apply when visiting and transacting through their website.  Ultraleap is not a party to your agreement with any third-party vendor and does not accept any responsibility or liability for such policies, terms, conditions or agreement or loss and / or damage caused by such policies, terms, conditions or agreement.

CONTACTING US & OTHER INFORMATION


Contact us.

Should you have a complaint regarding our use of your personal data then please contact us at the addresses laid out below in the first instance so that we have the opportunity to deal with your concerns.

You also have the right to make a complaint to the relevant supervisory authority. The UK supervisory authority is the Information Commissioner’s Office (ICO), whose contact details can be found at: https://ico.org.uk/global/contact-us/.

Any other questions, comments and requests regarding this Privacy Statement or the treatment of your personal data (including requests to exercise your rights regarding any correction, amendment or update to, or deletion of, your information) should be addressed to Data Protection at Ultraleap Limited, The West Wing, One Glass Wharf, Bristol, England, BS2 0EL or info@ultraleap.com.

Other information, relevant to the processing of information in the US by Ultraleap Inc.

Ultraleap complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce.  Ultraleap has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) regarding the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. data protection framework (‘DPF’) and the UK Extension to the EU-U.S. DPF, Ultraleap Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) with regard to unresolved complaints concerning the handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

The Federal Trade Commission has jurisdiction over Ultraleap Inc.’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

If you are an individual, you may, under certain conditions, have the right to invoke binding arbitration for complaints regarding Ultraleap Inc.’s DPF compliance not resolved by any of the other DPF further details of which can be found here: https://dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

COOKIES (& SIMILAR TECHNOLOGIES) STATEMENT

Automatic information gathering on our website

On each of your visits to our site, including when you access and use our Developer Area, we automatically collect technical information, such as the Internet protocol (IP) address used to connect your computer or other electronic device to the Internet, your login information, your browser type and version, time zone settings, browser plug-in types and versions, operating system and platform, and the type of electronic device used; and, information about your visit, including details of the pages you visit, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Cookies on our website

To achieve this, our site uses cookies (small files of letters and numbers placed on your computer or other electronic device when you access our site) to distinguish you from other users of our site, which helps us to provide you with a good experience when you browse our site and also enables us to improve our site.

The following types of cookies may be used by Ultraleap on its website:

  • Necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, or to put items of software in your shopping basket and use our check-out process). They do not store any identifiable personal data.
  • Analytical cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to perform specific functions, for example, facilitating third party features like imbedded video players.

Further information on the cookies used and their purpose on each web page you visit can be found by selecting ‘Customize’ on the cookie consent banner on our website, or by clicking on the cookie item in the bottom left of the website, should you have already closed the banner.

In most cases we need your consent in order to use cookies on our site. The exception is where the cookie is essential in order for the operation of the website. There is a banner on our home page which describes how we use cookies and which also provides a link to this Policy. You are asked to confirm your acceptance to the use of cookies by clicking “Accept All” within the banner on the home page, but should you not wish to do so alternative options to customise are available. You are also able to reject or disable cookies by modifying the settings of your browser.

Please note that not accepting cookies, or rejecting or disabling them within your browser, may negatively affect your experience on our site and your ability to use and view content.

You can remove cookies by deleting them from your browser history (cache) when you leave the site. There are also other tools that allow you to choose how cookies and similar technologies are used based on the browser and device you are using, for example, you may use your browser or device settings to clear or decline cookies, and to prevent your data from being used by Google Analytics, you can install Google’s opt out browser add-on.

Technologies similar to cookies in our products

We may also collect analytic information when you use Ultraleap hardware (or an Ultraleap-authorised embedded optical module) and its associated software, including performance data such as frequency and duration of use, tracking performance, environmental conditions, distances of tracked objects from the device, type and frequency of touchfree and non-touchfree interactions made, and other performance data. We may also collect technical error data such as the presence of smudges, calibration or synchronization errors or states or other software or hardware errors or states. These analytics can be opted out of in the settings function of our software. This information is tied to your hardware ID and may be associated to any account you have with us.

We also collect infrared hand image data (which does not constitute personal data) as described in our Privacy Policy, above.