This Privacy Policy (hereinafter referred to as “This Policy”) aims to clarify the manner, scope, and authority of the operators of the uCloudy Disk Software (hereinafter referred to as “uCloudy” or “This Software”) (hereinafter referred to as “Us”) to collect, use, store, share, transfer, and protect the personal information of users (hereinafter referred to as “You”), while informing you of the rights you have to share your personal information and the manner in which you exercise them.
This Policy applies to all cloud storage and related services provided by uCloudy using any device (including but not limited to smartphones, tablets, personal computers, etc.). Please carefully read and fully understand the full content of this Policy before using this Software and related services. Once you use or continue to use this Software, it is considered that you have agreed to our processing of your personal information in accordance with the terms of this Policy. If you do not agree to any terms of this Policy, please do not use this Software and related services.
1. Definition and scope
1.1 Core Definitions
1.1.1 Personal Information: Means various information recorded electronically or in other ways that can identify a specific natural person individually or in combination with other information, including but not limited to names, email addresses, mobile phone numbers, device information, usage records, etc.
1.1.2 Sensitive Personal Information: Means personal information that, if leaked, illegally provided, or misused, may endanger the safety of person and property, damage personal reputation, physical and mental health, or lead to discriminatory treatment, including but not limited to biometric information, financial account information, precise location information, etc.
1.1.3 Anonymized Information: Means information that, after processing, cannot be identified as a specific natural person and cannot be recovered. Such information no longer belongs to personal information, and we may freely use, process, and disclose it.
1.2 Applicability Scope
1.2.1 This Policy applies to all core services provided by uCloudy, including but not limited to cloud storage, file uploads and downloads, file management, link sharing, multi-device synchronization, and more.
1.2.2 This Policy does not apply to third-party services provided through uCloudy. The privacy policies of third-party services are determined by their own discretion and we assume no responsibility.
2. Collection and Use of Personal Information
2.1 Collecting Principles
2.1.1 Legitimacy Principles: We collect your personal information only on the condition that we have your consent, fulfill contractual obligations, or comply with legal and regulatory requirements.
2.1.2 Necessity Principle: We collect only the personal information necessary to provide the uCloudy Service, and do not collect information that is not related to the Service.
2.1.3 Transparency Principle: We clearly inform you of the purpose, scope and manner of the collection of personal information, and will not expand the scope of the collection without your consent.
2.2 Scope of Collection and Purpose of Use
2.2.1 Account Registration and Login Related Information: To complete account creation and login, we may collect your email address, mobile phone number, and password (encrypted storage) for authentication, account security maintenance, and service delivery.
2.2.2 Device Information: To ensure service compatibility, security and to optimize the user experience, we may collect information such as the device model, operating system version, device unique identifier, IP address and network connection status for your use of uCloudy for purposes of device adaptation, anomalous login detection and service troubleshooting.
2.2.3 File Related Information: The files you upload to uCloudy (including documents, images, videos, etc.) are used only to provide storage, preview, transfer, and sharing services. We will not view, analyze, or use the file contents without your express permission or legal requirement.
2.2.4 Usage Behavior Information: We may collect records of your use of uCloudy, including file upload/download times, sharing records, folder creation and management records, etc., for the purpose of optimizing service functionality, improving operational convenience and personalizing recommendations.
2.3 Special handling of sensitive personal information
2.3.1 In connection with the collection and use of sensitive personal information, we will separately inform you of the purpose and scope of the collection and obtain your separate consent.
2.3.2 We will adopt stricter security measures for sensitive personal information to prevent information disclosure, abuse or tampering.
3. Storage of Personal Information
3.1 Storage locations
3.1.1 We store your personal information on servers that comply with international data protection standards. The storage locations will be optimized based on your region and service needs, distributed across global compliant data centers, and strictly comply with local data storage laws and regulations.
3.1.2 Without your explicit consent, we will not transfer your personal information to storage in countries or regions that do not have data protection certifications.
3.2 Storage Period
3.2.1 We will store your personal information for the “minimum necessary period,” that is, for the minimum time necessary to achieve the purposes of the service, and after the period is exceeded, it will be automatically deleted or anonymized.
3.2.2 If you sign out of your uCloudy account, we will promptly delete all your personal information upon completion of the account sign-out, except as otherwise stipulated by law and regulations.
3.3 Storage Security
3.3.1 We use industry-leading security technologies, including but not limited to data encryption (transmission encryption uses the TLS protocol, rest data uses AES-256 encryption), access control, firewall protection, intrusion detection, and more to ensure the security of your personal information.
3.3.2 We have established a well-established security management system that limits the access to personal information by internal personnel, only authorized personnel can access it when performing their work duties, and requires adherence to strict confidentiality obligations.
4. Sharing and Transfer of Personal Information
4.1 Sharing Principles
4.1.1 We will not unlawfully share your personal information with any third party unless we obtain your explicit consent, comply with legal and regulatory requirements, or are required to fulfill contractual obligations.
4.1.2 If we do need to share personal information with a third party, we will sign strict confidentiality agreements with the third party, require the third party to process your personal information in accordance with this Policy and relevant laws and regulations, and monitor the third party‘s information processing behavior.
4.2 Sharing scope
4.2.1 Service partners third parties: In order to provide better services (such as payments, cloud storage infrastructure support, etc.), we may share necessary personal information with our partners third parties, but only provide the minimum amount of information required to perform the services, and the third parties may not use the information for other purposes.
4.2.2 Legal Requirements for Sharing: If we receive a legitimate request from judicial authorities or regulatory bodies, we will provide them with the necessary personal information, subject to compliance with laws and regulations.
4.3 Transfer of Personal Information
4.3.1 If we undergo changes such as mergers, splits, acquisitions, asset transfers, etc., your personal information will be transferred as part of the assets to the subject subject under the change, we will notify you in advance, and the subject subject under the change will continue to fulfill the information protection obligations stipulated in this Policy.
4.3.2 We will not transfer your personal information to any unrelated third parties without your consent.
5. Protection of Personal Information
5.1 Technology Protection Measures
5.1.1 We continue to invest in technology research and development, adopting various methods such as encryption technology, identity authentication, security auditing, etc., to prevent personal information from being leaked, tampered with, or lost.
5.1.2 We regularly conduct security checks and upgrades of servers and systems to promptly fix security vulnerabilities to ensure the security of the service environment.
5.2 Managing Protection Measures
5.2.1 We establish a strict information security management system, clarify the information protection responsibilities of personnel in various positions, and conduct regular information security training and audits for employees.
5.2.2 We have developed an emergency plan for data security incidents. If security incidents such as personal information disclosure or tampering occur, remedial measures will be taken promptly and you and relevant regulatory bodies will be notified as required by law and regulations.
5.3 Your protection obligations
5.3.1 You should properly store your uCloudy account information (such as account number, password) to avoid disclosure to others, and should promptly notify us if you discover an unusual login to your account or information leakage.
5.3.2 When you use the uCloudy service, you must comply with relevant laws and regulations and service terms. You must not upload or store illegal information, or you will bear the resulting information security risk on your own.
6. User Rights
6.1 Access Rights
6.1.1 You have the right to access your personal information and usage records stored in uCloudy, which can be accessed through the “Personal Center” or related functional modules within the uCloudy software.
6.2 Rights to Modify
6.2.1 You have the right to modify your account information (such as email address, mobile phone number, password, etc.), which you can do autonomously through the relevant functions in the software, and we will update your information promptly.
6.3 Right to Delete
6.3.1 You have the right to delete your uploaded files, usage records and account information, and once deleted, the related information cannot be recovered (except as otherwise prescribed by law and regulations).
6.3.2 If you believe that the personal information we collect exceeds the necessary scope, or there is irregular processing behavior, you can request us to delete the relevant information.
6.4 Revocation of the Right to Consent
6.4.1 You have the right to withdraw your consent to the collection, use, and sharing of your personal information, which you can complete through the in-software settings or by contacting us.
6.4.2 Upon withdrawal of consent, we will no longer collect, use or share your personal information, but this does not affect the information processing previously completed based on your consent.
6.5 Complaints and Right to Complaint
6.5.1 If you believe that our processing of personal information violates your legitimate interests, you can lodge a complaint with us through the contact details set out in this Policy, and we will promptly process the complaint upon receipt and provide feedback on the results.
7. Privacy Policy Updates and Notifications
7.1 Policy Updates
7.1.1 We will periodically update this Privacy Policy in accordance with updates to laws and regulations, and to optimize the functionality of our services.
7.1.2 After updating this Policy, we will notify you of the updated content through a pop-up window, notification, etc. within the uCloudy software. If you continue to use the uCloudy services, it will be considered that you agree to the updated Policy.
7.2 Notification Method
7.2.1 We will send you notifications related to the protection of personal information through your registered email address, mobile text message, or notification in uCloudy software.
8. Contact and Dispute Resolution
8.1 Contact information
8.1.1 If you have any questions, suggestions or complaints regarding this Privacy Policy, please contact us at the following email address: bisenov@manordsteel.com, and we will respond to your complaint within 3 business days.
8.2 Dispute Resolution
8.2.1 Disputes arising from or related to this Privacy Policy may be resolved by negotiation with us; if negotiation fails, any party has the right to file a lawsuit in the courts with jurisdiction where the service provider resides.
8.2.2 The interpretation and enforcement of this Privacy Policy applies to the global general laws and regulations related to data protection, and if there are stricter local requirements, local laws and regulations take precedence.