We, at Baseline Vision Ltd. (“we”, “us”, or “our”), put great efforts into making sure that we secure personal information and use it properly.
This privacy notice explains to end-users of our App, and players and non-players, whose image is captured or recorded bythe Cam (collectively: “you”), our privacy practices for processing personal information related to them when they use the App or Cam (“services”).
Below is a summary description of our services:
This notice also explains certain rights that you may have under applicable data protection and privacy laws (“privacy laws”) and how you may exercise them.
The term “personal information” refers to information that identifies an individual or relates to an identifiable individual or as otherwise defined under applicable data protection and privacy laws. The terms “sensitive information”, “processing”, and “data controller” mean as defined under applicable data protection and privacy laws.
The summary below will give you a quickand clear view of our practices. The first 8 headings in the summary also serveas the Notice at Collection, where applicable privacy laws require us toprovide such notice.
Please take the time to read our full notice. If you do not agree to the notice, please do not access or otherwise use our services.
This notice applies when we process personal information related to you when you use our services, or contact us in relation to the same. The App will be connected to the Cam following your installation of the application on your mobile device. As a result, the Cam will be collecting videos, photos, and voice recordings of the tennis sessions and games.
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Personal Information You Provide
- When you create an account in the App, we will collect your email address, full name, date of birth, residence country, playing hand (left/right).
- When you update your account in the App, we will collect your height, weight, gender, backhand (one hand/two hands).
- When you initiate a tennis session or game in the App, we collect your opponent’s name (as provided by you).
- When you provide us with feedback via the App, we will collect your response and feedback to the App.
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Personal Information We Collect
When you use the App to train in tennis sessions or play tennis games, and by utilizing the Cam, we will collect:
- Videos, photos,and voice recordings of the tennis sessions and games;
- Data related to your performance in tennis sessions and games, for example: number of strokes, calories burnt, etc.;
- Data related to your tennis sessions and games, for example: activity date and time, game type (singles, doubles), etc.;
- Inferred location data and address
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Your responsibilities:
o It’s your responsibility to inform and provide this notice to the tennis players you are playing with in the tennis sessions and games;
o It’s your responsibility to inform and provide this notice to non-players, such as spectators and audience, whose image may be possibly captured or recorded by the Cam.
When you use the App, we will collect usage data, user experience data, data concerning bugs and App analytics. Accordingly, in the preceding 12 months, we have collected the following categories of personal information:
- Identifiers and Personal information categories listed in the applicable US Privacy Laws,such as the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
- Commercial information, including services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and app installations;
- Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the services;
- We obtain the categories of personal information related to you listed in this notice directly and indirectly from you and your activity on the services.
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The services are not intended to collect sensitive information or special categories of personal data (within the meaning of applicable data protection and privacy laws).
However, such sensitive information may be included in the videos,photos, and voice recordings captured or recorded by the Cam, including the availability of such sensitive information in the App and optional download to the mobile device, as part of your use of the services.
Such sensitive information may include, for example:
o Biometric data, such as your and others’ facial image and voice recordings;
o Health data, such as injuries, physical disability, and medical treatment.
Additionally, we may also be able to infer additional information, including sensitive information, related to you from the recordings collected by the Cam.
Furthermore, the categories of personal information and sensitive information detailed in this notice may include any type of individual, including underage children and persons with disability, based on the specific individuals or end-users to which our customer making useof the Cam makes its own services available to.
Please see the sections titled “Your choices and rights” and “Exercising your choices and rights” for additional information on how you can request that we limit the use of sensitive information related to you by such third parties.
We do not collect or process sensitive information for the purpose of inferring characteristics about you and we do not sell sensitive information orshare sensitive information for cross-context behavioral advertising.
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We use personal information related to you for the following purposes:
- to provide you and other end-users with the services;
- to enable specific features of the services;
- to provide you with notifications related to your use of the services;
- where the provision of feedback is available, to provide you with feedback;
- to provide you with technical support related to our services;
- to maintain the services and to make them better for you and other end-users using it; and,
- to continue developing the services.
- We obey the law and expect you to do the same. If necessary, we will use personal information related to you to enforce our terms, policies, and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the services, and to take any action in any legal dispute and proceeding.
We commit to only process personal information related to you for the purposes described in this notice.
If you are located in the European Economic Area (EEA) and EU data protection laws apply to the processing of personal information related to you by us, then our processing of personal information related to you asa data controller is based on the following lawful grounds:
- We process your account and payment details to perform the contract with you;
- We will process personal information to comply with a legal obligation and to protect your and others’ vital interests;
- We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
· Communications with you, including direct marketing where you are our customer or a user of our customer, or where you contact us through our services or otherwise.
· Cyber security.
· Support, customer relations, service operations.
· Enhancements and improvements to yours and other users’ experience with the website and services.
· Fraud detection and misuse of the websites and services.
- All processing of Personal Information which are not based on the lawful grounds indicated above, are based on your consent.
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We do not sell, rent or lease personal information related to you.
We will disclose or share personal information related to you only subject to the terms of this notice, or subject to your prior consent.
To supports the purposes of using personal information under this notice,we will share personal information with certain members of our staff, external consultants, service providers, business partners, and certain other third parties, including:
- Certain members of our staff, as well as external consultants, with the express provision that their use of personal information related to you will comply with this notice;
- Operations service providers that, for example, host and back up content, provide analytics related to the use of the services, authenticate and secure log-ins,log activities, manage our production and development activities, operate oursystems, networks and databases, and enable cyber security and fraud detection and prevention;
- Payment service providers – we will share your payment transaction details to process and verify your payments;
- Communications and marketing service providers, for example, we may use service providers to manage our email messages transmission, engage local resellers to provide our services to you in a local language, or for enriching user data in order to improve your user experience;
- Law enforcement, courts and other agencies, authorities, and other relevant entities. We will comply with court orders, search warrants, regulatory orders, subpoenas, and provide information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will also report uploaded content and shared Personal Information, if we have a good-faith belief that the content, or the sharing of the content isillegal, abusive or violates third party rights;
- Other entities as part of a merger, acquisition, or any other corporate structural change.
Any such third party will commit to protect your privacy as required under applicable law and this notice.
The privacy practices of the above service providers are subject totheir own privacy policies and they may further use personal information as detailed in their privacy policies.
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We retain personal information for as long as necessary to fulfill the purposes of using such information under this policy and as permitted by law.
We will keep aggregated non-identifiable information without limitation, and to the extent reasonable We will delete or de-identify potentially identifiable information, when we no longer need to process the information in an identifiable form.
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IF YOU ARE UNDER THE AGE OF 13, YOU ARENOT ALLOWED TO USE OUR SERVICES WITHOUT THE CONSENT OF YOUR PARENT OR LEGALGUARDIAN!
If we need to rely on consent as a legal basis for processing personal information related to you and your country requires consent from a parent or legal guardian, we require your parent's consent before we collect and use that information. We encourage parents and legal guardians to monitor their children’s App usage and instruct their children to only provide information on the App under their monitoring and permission.
We do not knowingly collect personal information from minors under the age of 16 through our services, without their parent’s or legal guardian’s consent.
We do not sell or share personal information (within the meaning of privacy laws) related to children under the age of 16.
If you have reason to believe that a child under the age of 16 has provided us with personal information without the consent of their parent or legal guardian, please contact us with sufficient detail to enable us to delete that information.
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- Withdrawal of consent. At any time, contact us if you want to withdraw your consent to the processing of personal information related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
- Access. You have the right to confirm whether we are processing personal information about you and to access such information, including to request to know:
· what personal information we have collected about you;
· the categories of personal information;
· the categories of sources from which the personal information is collected;
· the business or commercial purpose for collecting, selling, or sharing such information;
· the categories of third parties to whom we disclose personal information; and,
· the specific pieces of personal information we have collected about you.
- Correction. You have the right to request that we correct inaccurate personal information that we maintain about you.
- Deletion. You have the right to request that we delete personal information related to you that we have collected from you,subject to certain exceptions under US Privacy Laws or GDPR, if applicable. Accordingly, note that when we delete personal information related to you that we have collected from or about you, it will be deleted from our active databases, but we will keep a reasonable number of copies in our archives. We will continue to retain the personal information related to you for legitimate business purposes as set forth above.
- To be informed. If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal information related to you, in accordance with this notice, will act accordingly.
- Object to the processing. You may object to the processing of personal information related to youfor direct marketing purposes. Additional information about this right is further detailed below under “Opt-out rights” and under the section titled “Exercising your choices and rights”.
- Portability. When exercising you right of access detailed above, you also have the right to obtain the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance. Note that you may only exercise this right no more than two times per calendar year. Also note that when responding to your request, we will omit any information that would disclose our trade secrets, as permitted by US Privacy Laws. You may also have the right to obtain a representative summary of personal information that you previously provided to us.
- Opt-out rights.You have the right to opt-out of the sale or sharing of personal information related to you by us, or otherwise the use of such information for targeted advertising or profiling for the purpose of making decisions that produce legalor similarly significant effects concerning you. As detailed above, we allow our service providers to collect personal information related to you. Undersome US Privacy Laws, such activity may constitute sharing or selling (within the meaning of US Privacy Laws) of personal information related to you. Accordingly, you have the right to request to opt-out of such third parties’ collection of personal information as further detailed below under the section titled “Exercising your choices and rights”.
- Limit the use of sensitive information. You have the right to request that we limit the use or disclosure of sensitive information related to you only to the purposes permitted under applicable US Privacy Laws. We do not actively collect sensitive information (within the meaning of US Privacy Laws) and do not infercharacteristics from sensitive information. However, as indicated above, our services may collect geolocation data, which constitutes sensitive information. Accordingly, you may contact us at support@baselinevision.com to request that we limit the use of sensitive information related to you to only the specific purposes permissible under US Privacy Laws.
- Non-discrimination. You have the right not to receive discriminatory treatment by us for exercising your privacy rights detailed in this notice (within the meaning of US Privacy Laws).
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We will give you choices about the ways we use and share personal information related to you,and we will respect the choices you make.
We collect and receive personal information related to you that we need for the purposes described in this notice. You can stop using the services at any time, thereafter we will stop collecting personal information related to you. However, we will store and continue to use certain personal information related to you as detailed above.
At any time, you can exercise your following opt-out options:
o object to the disclosure of personal information related to you to a third party, other than to third parties who act as our agents to perform tasks on our behalf and under our instructions;
o object to the use of personal information related to you for a purpose that is materially different from the purposes for which we originally collected such information, pursuant to this notice, or you subsequently authorized such use. You can exercise your choice by contacting us at: support@baselinevision.com.
You may also control what personal information related to you we collect from your device by changing the permissions settings on your mobile device’s privacy settings.
At any time, you can stop using the App and services. Termination of your App account is subject to your deletion of the account used by you to access the App and services.
Please note that you must delete your App account, and that uninstalling the App will not delete your account and credentials. It’s your sole responsibility to delete your App account as part of your requests for termination.
Note also that we may retain personal information related to you after you have terminated your use of the services, as detailed under the section titled “Data Retention”.
You may request to exercise the rights detailed under the section titled “Your choices and rights” by submitting your request to us by sending an email message to: support@baselinevision.com.
Only you or a person authorized to act on your behalf may make a request related to personal information related to you. A request for access can be made by you only twice within a 12-month period.
Your request must provide sufficient information to allow us toreasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.
We will do our best to respond to your request within 30 days of its receipt. If we require more time (up to additional 30 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive,or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.
We will not require that you create an account in order to exercise your rights under this notice and we will not increase the cost, or decrease the availability, of the services based solely on the fact that you have chosen to exercise one of your rights underthe CPRA or other US Privacy Laws.
After receiving our reply, you can appeal against our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it. We will also provide you with a link(to the extent available) where you can submit a complaint with the relevant Attorney General.
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We store and process information, including personal information, either directly or by using third parties such as data hosting service providers, including, without limitation, in Ireland, the State of Israel, andthe United States of America. The laws of the territories where your data willbe stored and processed can differ from the laws of the jurisdiction in which you live.
If you are a resident in a jurisdiction where transfer of personal information related to you to another jurisdiction requires your consent, then you provide us with your express and unambiguous consent to such transfer.
We make sure that our third-party service providers, provide us withadequate confidentiality and security commitments and we will take all steps reasonably necessary to ensure that personal information related to you is treated securely and in accordance with this notice.
If you are located in the EEA, note that we will transfer personal information related to you to other jurisdictions, which are not deemed to provide anadequate level of data protection. In such case, we will use appropriate safeguards, in particular, by way of entering into the European Union (EU)Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such personal information.
You can obtain a copy of the suitable safeguards that we use when transferring personal information as described above or receive further information about data transfer by contacting us at: support@baselinevision.com.
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We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy because there is no reasonable way to extract data from the aggregated information that we or other scan associate specifically with you.
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We are committed to ensuring the security of personal information. We and our hosting services implement systems, applications, and procedures to secure personal information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry standard security.
However, please understand that no security system is impenetrable, and although we make efforts to protect your privacy, we cannot guarantee that the services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
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We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this notice, to update this notice when we believe that we need to, and to verify that we display this notice properly and in an accessible manner. If you have any concerns about the way we process personal information related to you, you are welcome to contact our privacy team at: support@baselinevision.com, or write to us.
We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.
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From time to time, we will update this notice. If the updates have minor if any consequences, they will take effect 14days after we post a notice on the services. Substantial changes will be effective 30 days after we initially posted the notice.
Until the new notice takes effect, if it materially reduces the protection of your privacy under the then-existing notice you can choose not to accept it and terminate your use of the services. Continuing to use the services after the new notice takes effect means that you agree to the new notice. Note that if we need to adapt this notice to legal requirements, the new notice will become effective immediately or as requiredby law.
We can modify, enhance, or improve our application and services, and can accordingly offer additional tools and features. Such additional tools and features may be governed by additional ordifferent privacy practices, terms, and conditions, as provided by us, where applicable.
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If you have questions or comments about this notice, please contact us at: support@baselinevision.com. Note that we can only process requests received with sufficient information to enable us to process your request. If we need to request additional information in order to complete your request, we will do so.