HORIZON START LIMITED Privacy Policy
The current version of the Privacy Policy is effective December 19, 2023. The Privacy Policy provides information about how HORIZON START LIMITED manages the personal information you disclose to HORIZON START LIMITED when you use HORIZON START LIMITED products and services.
Read our privacy measures and contact HORIZON START LIMITED if you have any questions.
Introduction
This Privacy Policy describes how HORIZON START LIMITED and its affiliates (hereinafter referred to as UNIEL, UnielSmart, Company or we) collect, use, disclose, process and safeguard the information you provide to HORIZON START LIMITED through the UnielSmart applications/services when you use our products and services. If HORIZON START LIMITED asks you to provide any information in order to verify your identity when using UnielSmart products and services, we will use that information in strict accordance with this Privacy Policy and/or our Terms and Conditions for Users.
This Privacy Policy has been written with your needs in mind. It is important that you fully understand how HORIZON START LIMITED collects and uses personal data, and that you have full confidence in your ability to control all personal data that you provide to HORIZON START LIMITED.
In this Privacy Policy, "personal data" means information that can be used to directly or indirectly identify a specific individual, including in combination with other information about that individual available to UnielSmart. Such personal data may include, but is not limited to, information you provide or transmit to HORIZON START LIMITED as well as information about the device(s).
By using HORIZON START LIMITED products and services or performing other activities permitted by applicable law, you acknowledge that you have read and agreed to all provisions of this Privacy Policy, including as modified by HORIZON START LIMITED from time to time. In order to comply with applicable laws, including local data protection legislation (e.g. the General Data Protection Regulation in the European Union), HORIZON START LIMITED specifically requests prior express consent for certain processing (e.g. automated individual decision-making) of special categories of personal data. In addition, HORIZON START LIMITED is committed to protecting the privacy and security of your personal data by complying with applicable laws, and we are equally committed to ensuring that all employees and partners of the Company comply with these obligations.
If you have any questions about the data processing practices described in this Privacy Policy, please email privacy@uniel.ru.
What information is collected and how HORIZON START LIMITED uses it
Types of information to be collected
In order to successfully provide services to you, HORIZON START LIMITED requests the personal data required for this purpose. Otherwise, HORIZON START LIMITED will not be able to provide services and features to you.
HORIZON START LIMITED collects only that information which is necessary for the legitimate purposes expressly stated, and not for further processing in ways incompatible with such purposes. HORIZON START LIMITED may collect the following information (not necessarily personal data):
·Information you provide to HORIZON START LIMITED or transmit to HORIZON START LIMITED (including your contact information): Personal information you provide to HORIZON START LIMITED, such as your name, cell phone number, email address, UnielSmart account information (security-related information, name, date of birth, gender), or data that you may synchronize with the device you use to access the UnielSmart Services, information used to create an account on the UnielSmart services or related to account setup, devices you add, and information you send.
·Information related to the handheld device terminal or SIM card: HORIZON START LIMITED may collect information related to the operation of the UnielSmart handheld device terminal. Examples: IMEI number, IMSI number, operating system version, device manufacturing information, model name, and network operator. HORIZON START LIMITED may also collect information about the device linked to your account. Examples: MAC address, DID, network status of the device (IP address and network signal strength), and firmware version.
·Specified information about you: HORIZON START LIMITED may collect and use content such as data connected with your UnielSmart account.
·Location information (only for certain services/functions): various kinds of information about your location. For example, region, country code, city code, mobile network code, country code for calls to cell phones, cell ID, area name, longitude and latitude, time zone settings, language settings.
·Log information: information about your use of certain functions, applications, and websites. For example, cookies and other anonymous identifier technologies, IP address, network request information, temporary messaging logs and standard system logs, and fail information.
·Other information: Environment Characteristic Values (ECV) (i.e., the value generated from the UnielSmart account ID, phone device ID, connected Wi-Fi network ID, and location value).
·Account Data: Account related information such as password, secret questions in case of forgotten passwords and their answers, etc.
HORIZON START LIMITED may also collect other types of anonymous information not directly or indirectly associated with a specific user that is aggregated, anonymized or de-identified. For example, when you use a particular service, information about the device model and operating system version of your UnielSmart cell phone may be collected. Such information is collected to improve the quality of services provided.
How personal data is used
Personal data is collected to provide services and/or products and to comply with applicable laws. You hereby consent to the processing and disclosure of your personal data to our affiliated companies (in the communications, social media, technology and cloud services industries) and third party service providers (defined below) for the purposes set forth in this Privacy Policy.
HORIZON START LIMITED may use personal data for the following purposes:
·providing services, processing, maintaining, improving, enhancing, developing our products and/or services that HORIZON START LIMITED provides to you, and services provided through your UnielSmart device, portals, applications or services;
·sending you content about your device and services, as well as other popular topics (including news, firmware and program updates, customer support, related information and notices);
·Conducting marketing activities, such as providing marketing and promotional materials and updates. Details of marketing and promotional materials are contained in the Direct Marketing section below.
·Analyzing and developing statistical information regarding the use of our products and services to further optimize our products and services.
·Storing and maintaining your data for use in business transactions or to fulfill legal obligations.
·Providing services locally without communicating with our servers.
Below is additional information about how HORIZON START LIMITED uses your data (including personal data): setting up a UnielSmart account. Personal information collected when you create a UnielSmart account on our websites or through our mobile devices and applications is used to create your UnielSmart user profile and/or personal page.
·Providing location-dependent services. When you use UnielSmart applications and/or services and access devices, UnielSmart may use your location information to determine the time zone of your device. This ensures that the time and service area are correctly displayed on the device. It also allows you to optimize your work by providing services such as pre-activating the relevant device at the user-defined time. You can disable this feature at any time by opening the device settings or by stopping using the corresponding application/service.
·Device Access. HORIZON START LIMITED needs to authenticate devices that are managed through the app. For this reason, it is required to verify legal authentication of the device using the factory MAC address or DID. In addition, the device must be configured through the app to connect to the network. During setup, you are required to enter the Wi-Fi network name and password. This information will only be used to connect the device to the network. The specified Wi-Fi network name and password will be encrypted and stored locally on your device. They will not be sent to the server. Further, you can access your device and delete this data at any time. HORIZON START LIMITED also needs to analyze the IP address and network signal strength to determine the best method of network connectivity. This ensures the network stability of the device.
·Displaying the device status. This allows you to remotely view the device status at any time, regardless of whether it is on or off.
·Setting up automated tasks. Event details sent by your device can be used to create personalized, automatic tasks. (These event details come from the device you added. The specific information that can be set depends on the level of access the device has to confidential data. For each device you add, the terms of the Privacy Policy from the provider of that device are provided, to which you may agree).
·Push notifications. Account numbers and IMEI numbers will also be used for UnielSmart's push notification service, which sends notifications to the user. You can disable this feature at any time by changing the preferences in the Message Settings section.
·Confirmation of the user's identity. UnielSmart uses authentication systems to verify a user's identity so that attackers and other unauthorized persons cannot log into the account.
·Collecting feedback from users. Your feedback is very important as it helps HORIZON START LIMITED to improve UnielSmart applications and services. To keep track of your feedback, UnielSmart may use the personal information you provide to contact you and maintain records.
·Sending notifications. Occasionally, HORIZON START LIMITED may use your personal data to send important notifications, such as device fault status messages, personalized push notifications (these are subject to the availability of additional equipment) and alerts about changes to our terms, conditions and policies.
Direct marketing
HORIZON START LIMITED may use your name, phone number, email address, UnielSmart or UnielSmart account number and IMEI number to provide you with materials about products and services from DIGMA Group companies and our business partners that offer networking solutions, mobile applications, cloud products and services. HORIZON START LIMITED will use your personal data after obtaining your prior explicit consent by performing a clear confirmatory action or by indicating that there is no objection on your part in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of having your personal data used for direct marketing. If you no longer wish to receive emails of a particular nature, you may unsubscribe by following the unsubscribe link at the bottom of each email. HORIZON START LIMITED will not share your personal data with its business partners for their use of that data for direct marketing purposes.
Who does HORIZON START LIMITED share your information with?
HORIZON START LIMITED does not sell personal data to third parties.
HORIZON START LIMITED may disclose your personal information to third parties (as described below) in order to provide the products or services you have requested.
HORIZON START LIMITED may disclose information to the third party service providers and affiliates listed at the end of this section. In any situation described at the end of this section, you can be assured that HORIZON START LIMITED will only share personal data with your consent. Your consent given to HORIZON START LIMITED will also apply to sub-processors of your personal data. Please note that if in any of the situations described below, HORIZON START LIMITED shares your information with a third-party service provider, it shall specify in the contract that the third party is bound by actions and obligations to comply with applicable local data protection laws. HORIZON START LIMITED ensures within the contract that Third Party Service Providers comply with the privacy standards applicable to them in their national jurisdiction.
Providing information to our group and third-party service provider
In order to operate successfully and provide you with the full functionality of our products and services, HORIZON START LIMITED may disclose your personal information to other UNIEL affiliates (including through the use of social media, cloud services, and other communication technologies) or third-party service providers (our mail distribution centers, delivery service providers, telecommunications companies, data centers, data warehouses, customer service, advertising service providers, and agents representing HORIZON START LIMITED), i.e., affiliates of HORIZON START LIMITED and/or other third parties (collectively referred to as "third-party service providers"). Such third-party service providers may process your personal data on behalf of HORIZON START LIMITED or for the purposes set out above. If you use certain mobile applications on your devices, HORIZON START LIMITED may share your IP address with third parties to provide certain services at your request.
Providing information to others
HORIZON START LIMITED may disclose your personal information to others without your consent, if required by applicable law.
Information not requiring consent
·HORIZON START LIMITED may share anonymized information in aggregate form with third parties (such as advertisers on our website) for commercial purposes. HORIZON START LIMITED may report common trends in the use of our services, such as the number of customers in a particular group purchasing certain products or performing certain transactions.
·For the avoidance of misunderstanding: UNIEL may collect, use and disclose your personal data without your consent only where explicitly authorized by local data protection laws (e.g., to testify in court). HORIZON START LIMITED may also disclose your information without your consent if HORIZON START LIMITED has a reasonable belief that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraudulent activity, or comply with government requests.
Ensuring security
UnielSmart safety measures
HORIZON START LIMITED is committed to ensuring security of your personal data. To avoid unauthorized access, HORIZON START LIMITED undertakes to take all appropriate measures to protect your personal data.
For example, you can use a two-factor authentication system to access your UnielSmart account (where available). When you send information to our main server from your UnielSmart device or receive information over this channel, HORIZON START LIMITED ensures that it is encrypted using a number of protocols, including SSL.
All your personal data is stored on secure servers located at controlled facilities. HORIZON START LIMITED categorizes your data by importance and confidentiality and guarantees the highest level of protection for your personal data. HORIZON START LIMITED also ensures that employees and third party service providers who provide products and services to you by accessing this information are contractually bound by strict confidentiality obligations. To summarize: HORIZON START LIMITED regularly reviews its data collection, storage and processing policies, including physical security measures, to avoid unauthorized access and use.
HORIZON START LIMITED will take all appropriate measures to protect your personal information. However, it should be remembered that using the Internet is not entirely safe. For this reason, HORIZON START LIMITED cannot guarantee the security or integrity of any personal data transmitted from or to you over the Internet.
HORIZON START LIMITED will take appropriate measures in the event of a personal data breach by notifying the relevant supervisory authorities and, in some cases, the data subjects in accordance with applicable law, including local data protection laws.
What you can do
·You can help protect your personal information by not sharing your login, password, and account information with anyone other than those you authorize. When logging into UnielSmart applications/services using an account, regardless of the circumstances (and especially if you are using someone else's computer or a public Internet portal), you should always log out when your session ends.
·HORIZON START LIMITED is not liable for any security breach caused by third parties accessing your personal data if you have not properly protected the data. Notwithstanding the foregoing, you should notify Nippon Klick immediately if any Internet users access your account without authorization or other security breaches occur.
Your support will help HORIZON START LIMITED better protect your personal data.
Storage policy
HORIZON START LIMITED will retain information collected about you for as long as it is necessary for the purposes for which it was obtained or to comply with applicable legal requirements or authorizations. As soon as HORIZON START LIMITED has compelling reasons to believe that such storage of personal data no longer serves the purpose for which it was collected, HORIZON START LIMITED will cease to store such personal data or make it impossible to associate such data with specific individuals. If further processing is intended for archiving in the public interest, for scientific or historical research or statistics in accordance with applicable law, the data may continue to be stored by HORIZON START LIMITED, even if the further processing is incompatible with the original purposes.
Accessing other functions on your device
UnielSmart applications/services may need access to certain functions on your device, such as Wi-Fi network status. Applications/services need this information to work on your device and you need it to work with them. You may close the application/service on your device at any time or contact HORIZON START LIMITED at privacy@uniel.ru to withdraw your consent.
You are in control of your personal data
Control parameters
HORIZON START LIMITED knows that everyone has different privacy requirements. Therefore, below are some examples of how HORIZON START LIMITED gives you the ability to restrict the collection, use, disclosure and processing of your personal data, and you can manage your privacy settings.
·Enabling or disabling scheduled user interaction and location data access.
·Log in and out of your UnielSmart account:
·If you have previously authorized HORIZON START LIMITED to use your personal information for the purposes described above, you may change your mind at any time by writing to HORIZON START LIMITED or sending an email to privacy@uniel.ru.
Accessing, updating, correcting, erasing or restricting the processing of your personal data
·You have the right to request access to and correction of any of your personal data stored by HORIZON START LIMITED. Before HORIZON START LIMITED can process your request, HORIZON START LIMITED will ask you to confirm your identity. Upon receiving sufficient information, HORIZON START LIMITED will be able to process your request to access or correct personal data. HORIZON START LIMITED will respond to your request within the time limits set out in the applicable data protection laws.
·A copy of your personal data that is collected and processed by HORIZON START LIMITED will be provided to you free of charge upon request. HORIZON START LIMITED may charge a reasonable fee for additional requests for the same information based on actual administrative costs and in accordance with applicable law.
·If you wish to request access to your personal data held by HORIZON START LIMITED, or if you believe that your personal data is incorrect or incomplete, please notify HORIZON START LIMITED immediately at the e-mail address below. E-mail address: privacy@uniel.ru.
·If you are a user from the European Union and you are subject to the General Data Protection Regulation (GDPR), you may request that HORIZON START LIMITED erase your personal data. HORIZON START LIMITED will consider the grounds for your request for data erasure and take reasonable steps, in particular taking technical measures where such grounds are applicable under the GDPR.
·If you are a user from the European Union and are subject to the GDPR, you may request that HORIZON START LIMITED restrict the processing of your personal data. HORIZON START LIMITED will review the basis of your restriction request. Where grounds apply under the GDPR, HORIZON START LIMITED will only process your personal data in the circumstances applicable under the GDPR and will inform you until the processing restrictions are lifted.
·If you are a user from the European Union and are subject to the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, that results in legal consequences concerning you or similarly significantly affects you.
·If you are a European Union user and are subject to the GDPR, you have the right to receive your personal data in a structured and disseminated format and to transfer the information to another data controller.
Withdrawal of consent
·You may send an email to privacy@uniel.ru requesting that we withdraw your consent to the collection and/or disclosure of any of your personal data that HORIZON START LIMITED holds or controls. HORIZON START LIMITED undertakes to process your request within a reasonable time, after which HORIZON START LIMITED will comply and cease to collect, use and/or disclose your personal data.
·Please note that withdrawing your consent may result in some legal consequences. If your withdrawal of your consent restricts HORIZON START LIMITED from processing your personal data, it may mean that you will not be able to use UnielSmart products or services.
Transferring personal data outside your jurisdiction
To the extent that HORIZON START LIMITED will need to transfer personal data outside of your jurisdiction, whether to our affiliates (including through the use of social media, cloud services and other communication technologies) or to third-party service providers, HORIZON START LIMITED agrees to comply with applicable law at all times. In particular, to ensure that all such transactions comply with local data protection laws, HORIZON START LIMITED is committed to implementing appropriate security measures.
Uniel is a global company. Therefore, subject to applicable laws, HORIZON START LIMITED may transfer your personal data to any Uniel Group subsidiary worldwide, processing such information for the purposes described in this Privacy Policy. In addition, HORIZON START LIMITED may transfer your personal data to our third-party service providers, which may be located in a country outside the European Economic Area (EEA).
Whenever HORIZON START LIMITED transfers personal data from the EEA to a third party, which may or may not be a legal entity of HORIZON START LIMITED outside the EEA, HORIZON START LIMITED does so on the basis of the EU standard contractual clauses or we apply other protections set out in the GDPR.
UnielSmart may use foreign facilities under the management and control of HORIZON START LIMITED to process and back up your personal data. HORIZON START LIMITED currently operates data centers in multiple jurisdictions. Their data protection laws may differ from those in your jurisdiction. You understand that the risks associated with applicable data protection laws vary and that HORIZON START LIMITED may transfer to and store your personal data in one of its overseas centers, but this will not affect the obligation to protect your personal data in accordance with this Privacy Policy.
If you choose to use other third-party services available for this product or service (Amazon Alexa, Google Assistant, Yandex Alisa, etc.), third parties may be able to read your information. In addition, this data may be transferred to a third-party server outside of your jurisdiction, and you consent to such transfer.
Miscellaneous
Minors
·HORIZON START LIMITED believes that parents have a responsibility to monitor their children's use of UnielSmart products and services. However, our policy does not require HORIZON START LIMITED to obtain personal information of minors or to send promotional materials to such persons.
·UnielSmart does not seek to obtain personal information of minors. If parents or guardians have reason to believe that their child has provided personal data to UnielSmart without their prior consent, they should contact HORIZON START LIMITED to ensure that such personal data is deleted and that the minor's subscriptions to relevant HORIZON START LIMITED services are canceled.
Priority order
If you have accepted the applicable User Agreement and there is a discrepancy with this Privacy Policy, the User Agreement takes precedence.
Privacy Policy Updates
HORIZON START LIMITED periodically reviews its Privacy Policy and may update it in accordance with changes to our information processing policies. If we make material changes to this Privacy Policy, HORIZON START LIMITED will notify you by email (using the email address provided in your account), send you a notice on the UnielSmart app, or contact you via your mobile device. This will help you understand what information HORIZON START LIMITED collects and how HORIZON START LIMITED uses it. Such changes to this Privacy Policy will be effective as of the date specified in the notice or on the website. We encourage you to review this page regularly, as it may contain updates to our privacy practices. If you keep using products on the website, cell phone and/or other device-based services, this means that you accept the updated Privacy Policy. If HORIZON START LIMITED needs to collect other personal data about you or use or disclose your personal data for a new purpose, HORIZON START LIMITED will again ask you to provide consent.
Is it necessary to agree to all third party terms and conditions?
Our Privacy Policy does not apply to third-party products and services. UnielSmart products and services may include third-party products and services and links to third-party websites. If you use such products and services, third parties may also collect your personal data. For this reason, HORIZON START LIMITED strongly recommends that you carefully read the privacy policies of third parties, like ours. HORIZON START LIMITED is not responsible for how third parties use the personal data collected from you, and we cannot control how they use that data. Our Privacy Policy does not apply to other websites to which our services link.
If you use these additional services for certain products on the UnielSmart Portal, the terms of the third party and its Privacy Policy apply and you will be deemed to have agreed to the terms for each of these extensions.
Contact HORIZON START LIMITED
If you have any questions or feedback about this Privacy Policy or questions about the collection, use and disclosure of your personal information by HORIZON START LIMITED, please contact our Data Protection Officer at the address below referring to "Privacy Policy":
HORIZON START LIMITED
Unit 09, 7/F, Fabrico Factory Bldg, 78-84 Kwai Cheung Road, Kwai Chung. N.T., Hong Kong
Thank you for taking the time to read our Privacy Policy!