PRIVACY POLICY

Last Updated: 8/31/2023

Thank you for using PhotoSphere!

This Privacy Policy describes how we collect, use, and handle your personal information when you use PhotoSphere.

PhotoSphere may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by us. This Privacy Policy does not apply to how third parties collect, use, disclose or retain information. We encourage you to review the privacy policies of these third-party websites or services. We may modify this Privacy Policy at any time, provided certain provisions of this Privacy Policy prove to be incomplete or outdated and further provided that these changes are reasonable for you, taking into account your interests. We will post the most current version on the page of My-Software Setting-About RAWERKS. If a revision meaningfully reduces your rights, we will notify you prior to the update’s effective date via an in-app notification.

By using PhotoSphere and Products or other acting permitted by the applicable laws, you are deemed to have read, acknowledged, and accepted all the provisions stated here in this Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e.g. General Data Protection Regulation in Europe Union), we will specifically seek prior express consent to the particular processing (e. g. providing marketing materials to you) of personal information. Furthermore, we are committed to protecting the privacy, confidentiality, and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

In this Privacy Policy, “Personal Information” shall have the same meaning as “personal data” and shall means the information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual.

1. What Information We Collect and Why We Collect the Information

We collect the following information to provide, improve, and protect our App Services:

Account information. When you register for PhotoSphere Account, we will collect your mobile phone number and verification code, which will be used to verify your user identity and ensure that we are providing services for you. You can choose to fill in the nickname, profile picture and other supplementary information according to your own requirements to use our other services (the specific service content and corresponding information will be informed to you through the system prompt). If you log in through the authorization of a third party, we will obtain your public information (profile picture, nickname, etc.) registered on the third-party platform and bind it with your PhotoSphere Account. For the personal information that we need but the third party cannot provide, we will still require you to provide.

Device information. When you activate your NAS Product, we will collect the WIFI information connected to your mobile terminal device so that NAS Product can connect to the network for activation. When you bind or unbind a NAS Product, to bind or unbind your NAS Product to your PhotoSphere Account, we will collect the serial number and verification code of the product you bind.

Your content. When you share content (including audio, video, photo album and other files), we will collect your device serial number, PhotoSphere Account, storage path and sharing time to generate corresponding sharing links for you. With respect to the content you share, we only provide corresponding data transmission services, do not collect or use the content you share, and will not make any modifications or edits to the aforementioned content. It should be reminded that the sharing function may make your corresponding personal information public within the scope specified by you. You must carefully decide whether to use it and be responsible for the relevant consequences. When you use the baby album function, we will collect the baby nickname and date of birth you entered, which will be used to classify your uploaded baby videos and photos.

Usage information. We collect information related to how you use RaWerks services and manage your Product, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We use this information to improve our RaWerks services, develop new services and features, and protect our users. For example, to improve RaWerks services, we collect information about how you interact with RaWerks services to understand what features are most useful to you and improve them. To protect our users, we analyze things like IP addresses, device type, login history, and password changes to detect and respond to abusive behavior. We may also record adjustments you make to your Products through RaWerks services and we store this information along with data collected directly by your Product.

Device information. We also collect information from and about the devices you use to access RaWerks services to ensure the stability of PHOTOSPHERE and the security of the service. This includes things like the browser type, device information (device name, Android ID, and the UUID, IMEI, MAC, system version, language, and time zone of your device), type of network, the Operator you use and ICCID and traffic usage of the SIM card.

2. How We Use Your Information

We process your information (1) to provide RaWerks services described in Terms of Services; (2) in furtherance of our legitimate interests in operating RaWerks services and business; and (3) with your consent. In some cases, we may process your information to comply with applicable law, legal process, or regulation; protect any person from death or serious bodily injury; or to carry out a task in the public interest.

Examples of RaWerks processing your information to provide you with RaWerks services include:

1. Troubleshooting issues you may encounter with RaWerks Services and Products. If you contact us with questions or concerns about RaWerks Services or Products, we may use your personal information to verify your identity and respond.

When there are reasonable doubts regarding your identity, you might be asked to provide further information, e.g., a copy of a document, which helps us to verify your identity. It can be any document such as a photo of your Product, or your purchase invoice. Should you provide any other documents, personal details such as your name and your address should be clear in order to be able to identify you, while any other data such as a photo or any personal characteristics, may be blacked out. Our use of the information on your identification document is strictly limited: the information will only be used to verify your identity and will not be stored for longer than needed for this purpose.

Examples of RaWerks processing your information in furtherance of our legitimate interests in operating PhotoSphere and business include:

1. Understanding how you use our Services and improving them.
2. Investigating and preventing security issues and abuse of RaWerks services or RaWerks users.
3. Analyzing issues you may encounter with RaWerks Services and Products and improving them. For example, we may analyze the connection speed between your Product and your Account to troubleshoot the issue and improve them.
4. Managing our everyday business needs, such as auditing, administration of our RaWerks services, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service.
5. Whom We Share Information with

We do not sell any personal information to third parties and we never will.

We may share your personal information with third parties as discussed below:

Others working for and with RaWerks. RaWerks uses certain trusted third parties (for example, push services and IT services) to help us administer our Products and RaWerks Services effectively, provide a better user experience, and increase the quality of our Products and RaWerks Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions. For a list of trusted third parties that we use to process your personal information, please contact us.

New Owner. If RaWerks and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such circumstance, we will notify you by sending an email to the email address associated with your account or via an in-app notification of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.

Law and Order; the Public Interest. We access, preserve and share your information with regulators, law enforcement or others:

1. In response to a legal request (e.g. a search warrant, court order or subpoena) if we have a good-faith belief that the law requires us to do so;
2. When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorized use of RaWerks Services and Products, breaches of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or RaWerks services), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse, and other harmful activity on and off RaWerks services.
3. Securing and Retention Your Information

Security. We have implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We conduct periodic reviews and assessments of the effectiveness of our security controls. We also continue to work on features to keep your information safe.

Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, RaWerks cannot guarantee that your information is under absolute security with the existing security technology. If you have any further questions about the security of our PhotoSphere, please contact us.

Retention. Generally, we store your information on RaWerks’s servers which is established upon third-party servers until you delete or edit it, or for as long as your account is in existence or we need it to provide you the services, unless a longer retention period is required or permitted by applicable laws.

5. Your Rights

Keeping your personal information current helps ensure that we provide you with the most relevant offers. You can access, update, or delete your personal information by logging into your PhotoSphere Account and going to your account setting page.

You can limit the information you provide to PhotoSphere as well as the communications you receive from PhotoSphere through your Account preferences. Notwithstanding, we may still e-mail you non-commercial e-mails related to your Account and your transactions on PhotoSphere services.

If you close your account, we will initiate deletion of this information immediately. But please note: (a) there might be some latency in deleting this information from our servers and back-up copies; and (b) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

You may manage how your mobile device and browser share certain device data with us by adjusting the privacy and security settings on your device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

If you are located in the European Economic Area (EEA), subject to limitations in applicable law, you have certain rights in respect to your personal information, such as a right of access, rectification, restriction, opposition, and portability. In order to exercise your rights, please contact us. You also have the right to withdraw your consent at all times, free of charge. You can do this by opting out by rejecting the use of cookies through your browser settings. However, your withdrawal may affect your continued use of PhotoSphere. If you have concerns about how we handle your personal information, you have the right to lodge a complaint with the data protection authority in your country/region of residence.

6. Children’s Privacy

We do not intend that any portion of PhotoSphere will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction and such use is prohibited. PhotoSphere is designed and intended for adults. By using PhotoSphere, you represent that you are at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction in order to create an account. If we obtain actual knowledge that an account is associated with a registered user who is under the age of 18 years old, or equivalent minimum age in the relevant jurisdiction, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us, please contact us. A parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof.

7. Global Operations

Currently, we use third-party services for our data center and your personal information will be stored in the data center, regardless of where you use our services. The laws, regulations, and standards in which your information is stored or processed may be different from those of your own country. You have understood that the risks under applicable data protection laws are different. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

8. California Consumer Privacy Act Notice

California residents have additional privacy rights under the California Consumer Privacy Act, which are described in the California Consumer Privacy Act Notice.

9. Contact Us

Your personal information is controlled by (RaWerks, Inc). If you have questions or concerns about PhotoSphere, RaWerks, or privacy, please do not hesitate to contact our Data Protection Officer at info@getphotosphere.com. Please provide: (i) your name (or nickname), your country/region of residence and your preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links or pages.

If they can’t answer your question, you have the right to contact your local data protection supervisory authority.

RaWerks, Inc.
773 E LAKEMONT DR
DRAPER UT 84020
UNITED STATES