Through this Policy, VisualCamp regards personal data of the users as important and inform them of the purpose and method of VisualCamp’s using the personal data provided by the users and the measures taken by VisualCamp for protection of those personal data.
The Policy will be effective on the 15th day of November, 2019 and, in case of modification thereof, VisualCamp will make public notice of it through posting it on the bulletin board of its website or individual notice through sending e-mails or mobile alarm.
1. Data to be collected and method of collection
(1) Personal data items to be collected
Personal data items to be collected by VisualCamp are as follows:
• Data provided by the users
– Name, email address, phone number, ID, national information, payment information, purchase activity, delivery, contact detail for transaction
– For minors, data of legal representatives (name, birth date, CI and DI of legal representatives)
• Data collected while the users use Services
– Equipment identifier, operation system, hardware version, equipment se-up and telephone number
– Log data, use time, internet protocol address, cookie and web beacon
– Data generated when you interact with our Services including from third parties.
(2) Method of collection
VisualCamp collects the data of users in a way of the followings:
– Webpage, written form, telephone calling, e-mailing
– Provided by partner companies
– By approving turning on the camera to use our applications
2. Use of collected data
VisualCamp uses the collected data of users for the following purposes:
(1) Use our Services
• Provide software with hardware, content, apps and other needs
• Performance of contract and service fee settlement regarding provision of services demanded by the users
• To detect and deter unauthorized or fraudulent use of or abuse of the Services
• Making notice of functional update of Services or policy
(2) Improve our Services
• To give feedback for issues from Services
• Improve services when it integrated with third parties’ hardware, content, apps and other needs
(3) Other purpose
• Use of data with prior consent of users. For example, to provide Services and place advertisements based on statistical characteristics.
• To comply with applicable laws or legal obligation
VisualCamp agrees that it will consent from the users, if VisualCamp desires to use the data other than those expressly stated in this Policy
3. Sharing collected data
Except for the following cases, VisualCamp will not share personal data with third parties:
(1) When VisaulCamp shares the data with its affiliates, partners and service providers;
• Bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of VisualCamp
(2) When the users consent the sharing in advance;
• When the user selects to be provided by the information of Services of certain companies by sharing his or her personal data with those companies
• Other cases where the user gives prior consent for sharing his or her personal data
(3) When the sharing is required by the laws
• If required to be disclosed by the laws and regulations
• If required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations
• Share non-identified data to make statistics on users’ service usage
4. Data retention and deletion
Your personal data will no longer remain with us when you deleted your account.
However, transaction record may remain for legal or accounting purpose.
5. Cookies, Beacons and Similar Technologies
VisualCamp may collect collective and impersonal data through ‘cookies’ or ‘web beacons.
Cookies are very small test files to be sent to the browser of the users by the server used for operation of the websites of VisualCamp and will be stored in hard-disks of the users’ computer
Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email.
These functions are used for evaluating, improving services and setting-up users’ experiences so that much improved services can be provided by VisualCamp to the users.
The items of cookies to be collected by VisualCamp and the purpose of such collection are as follows:
(1) Strictly necessary cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
(2) Performance cookies
These cookies collect data how the users use the website of VisualCamp such as the data of the pages which are visited by the users most. This data helps VisualCamp to optimize its website so that the users can search that website more comfortably. This cookie does not collect any data of the users. Any and all the data collected by this cookie will be processed collectively and the anonymity will be guaranteed.
(Examples of performance cookies)
• Web analysis: provide statistical data on the ways of using website
• Advertisement response fee: check the effect of advertisement of VisualCamp
• Tracing affiliated companies; one of visitors of VisualCamp provides anonymously feedback to the affiliated companies
• Management of error: measure an error which may occur so as to give a help for improving website
• Design testing: test other design of the website of VisualCamp
(3) Targeting cookies or advertising cookies
This cookie is connected with the services provided by a 3rd party such as the buttons of ‘good’ and ‘share’. The 3rd party provides these services by recognizing that the users visit the website of VisualCamp.
(Examples of targeting cookies or advertising cookies)
• Carry out PR to the users as targets in other websites by connecting through social networks and these networks use the data of users’ visit
• Provide the data of users’ visit to ad agencies so that they can suggest an ad which may attract the interest of the users
The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be save: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by VisualCamp.
6. User’s right to access and option
The users or their legal representatives, as main agents of the information, may exercise the following options regarding the collection, use and sharing of personal data by VisualCamp:
• Exercise right to access to personal data;
• make corrections or deletion;
• make temporary suspension of treatment of personal data; or
• request the withdrawal of their consent provided before
If, in order to exercise the above options, you, as an user, use the menu of ‘amendment of member information of webpage or contact VisualCamp by using representative telephone or sending a document or e-mails, or using telephone to the responsible department (or person in charge of management of personal information), VisualCamp will take measures without delay: Provided that VisualCamp may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
VisualCamp regards the security of personal data of uses as very important. VisualCamp constructs the following security measures to protect the users’ personal data from any unauthorized access, release, use or modification.
• Encryption of personal data
– Transmit users’ personal data by using encrypted communication zone
– Store important data such as passwords after encrypting it
• Countermeasures against hacking
• Establish and execute internal management plan
• Install and operate access control system
• Take measures to prevent forging of alteration of access record
8. Protection of personal data of children
In principle, VisualCamp does not collect any data from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. Services of VisualCamp are the ones to be provided to ordinary people, in principle. The website or application of VisualCamp has function to do age limit so that children cannot use it and VisualCamp does not intentionally collect any personal data from children through that function.
However, if VisualCamp collects any personal data from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the Services for unavoidable reason, VisualCamp will go through the additional procedure of the followings for protecting that personal data of children:
• obtain consent from the parents or guardian of children so as to collect personal data of children or directly send the data of Services of VisualCamp
• give the parents or guardian of children a notice of VisualCamp’s policy of privacy protection for children including the items, purpose and sharing of personal data collected
• grant to legal representatives of children a right to access to personal data of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before
• limit the amount of personal data exceeding those necessary for participation in online activities
9. Modification of Privacy Protection Policy
VisualCamp has the right to amend or modify this Policy from time to time and, in such case, VisualCamp will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.
10. Data transmission
Considering it engages in global businesses, VisualCamp may provide the users’ personal data to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal data is transmitted, retained or processed, VisualCamp takes reasonable measures for protecting that personal data.
(for US region customer) In addition, when the personal data obtained from the European Union is used or disclosed, VisualCamp may have to comply with safe harbor principle as required by the Commerce Department of USA, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures.
11. 3rd Party’s sites and services
Services of VisualCamp may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of VisualCamp.
12. How to comply with GDPR
(1) Lawful processing of personal data under GDPR
Processing personal data by VisualCamp shall be lawful only if and to the extent that at least one of the following applies:
• A user has given consent to the processing of his or her personal data
• Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:
– Member management, identification, etc.
– Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
• Processing is necessary for compliance with a legal obligation to which VisualCamp is subject
– Compliance with relevant law, regulations, legal proceedings, requests by the government
• Processing is necessary in order to protect the vital interests of users, or other natural persons
– Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that ay harm users or other natural persons.
• Processing is necessary for the performance of a task carried out in the public interest of in the exercise official authority vested in VisualCamp
• Processing is necessary for the purposes of the legitimate interests pursued by VisualCamp by a third party (except where such interests are overridden by the interests of fundamental rights and freedoms of the data subject which require proection of personal data, in particular where the data subject is a child)
(2) Users’ right when applying GDPR
The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal data by VisualCamp:
• The right to access to personal data;
The users or their legal representatives may access the data and check the records of the collection, use and sharing of the data under the applicable law.
– The users or their legal representatives may requrest to correct inaccurate or incomplete data
• The right to erasure;
– The users their legal representatives may request the deletion of the data after the achievement of their purpose and the withdrawal of their consent.
• The right to restriction of processing;
– The users or their legal representatives may make temporary suspension of treatment of personal data in case of the disputes over the accuracy of data and the legality of data treatment, or if necessary to retain the data.
• The right to data portability
– The users or their legal representatives may request to provide or transfer the information
• The right to object
– The users or their legal representatives may suspend the treatment of personal data if the data is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.
• The right to automated individual decision-making, including profiling
– The users or their legal representatives may request to cease the automated treatment of personal data, including profiling, which has critical impact or cause legal effect on them.
If, in order to exercise the above rights, you, as an user, use the menu of ‘amendment of member information of webpage or contact VisualCamp by sending a document or e-mails, or using telephone to VisualCamp (person in charge of management of personal information or a deputy), VisualCamp will take measures without delay: Provided that VisualCamp may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
13. Responsible department of VisualCamp
VisualCamp designates the following person in charge of personal data in order to protect personal data of customers and deal with complaints from customers:
CPO: Yun Chan Suk
Tel: +82 70-7945-7799
The latest update date: 12th November, 2019
Thank you for integrating VisualCamp’s eye tracking technology to your application.
VisualCamp’s SeeSo, AI based SDK requires approval of using camera. It is automatically asked to users. However, we STRONGLY recommend receiving consent from users, before activating SeeSo Software from your application. SeeSo Software generates gaze data includes gaze coordinate(x,y), fixation, and eye blink. Gaze data is text and numerical data which can’t identify the user. Because software processes the image to data on device in real-time, face image is NOT stored any server of VisualCamp.
Though we give restriction on what third party application or other service providers can do with the data, VisualCamp is not responsible for data you collected. You should create your own privacy policies. If you want to review SeeSo, click here.
For more information, please contact via e-mail (firstname.lastname@example.org).
Thank you for selecting VisualCamp’s eye tracking technology.
When you use any types of devices integrated with VisualCamp’s TrueGaze Software, you MUST receive consent from users or subjects. TrueGaze Software generates gaze data includes pupil movement, fixation rate, and eye glint. The format of gaze data is x, y coordination and numeric characters. Eye Image is only used for gaze data generating process from the device. It is limited to store and use by itself as a data.
For more information, please contact via e-mail (email@example.com).