Tupa Company's Customer Commercial Privacy Statement

This statement was updated on November 18, 2019.

Tosee Pouyan e Arvand Company (collectively “Tupa”, “we” and “us”) respect your privacy. Therefore, we have produced a privacy notice (hereinafter referred to as “this notice”) that covers how we collect, use, disclose, protect, store and transfer your personal information.

Please take a few moments to read and understand this privacy notice and let us know if you have any questions.

Personal information means any electronic or other information that can be used together with other information to identify an identity or identify an individual. This notice explains how Tupa processes your information, but does not cover all processing cases, as you will be notified of them in a special processing activity. Accordingly, before using a particular product or service, it is recommended to read the privacy notice or additional notices published by Tupa for that product or service and understand how your information is processed.

This notice explains how Tupa processes your information, but does not cover all processing cases, as you will be notified of them in a special processing activity. Accordingly, before using a particular product or service, it is recommended to read the privacy notice or additional notices published by Tupa for that product or service and understand how your information is processed.

This notice is only for personal, home and industrial products of “Tupa”, including mobile phone applications, smart industrial devices, smart agricultural devices, industrial automation systems, agricultural automation systems, wearable devices, broadband devices, accessories, It applies to computer devices, mobile services, software, tools, websites and services that display or mention this notice.

This notice describes the following:

1. How “Tupa” collect and use your personal information

2. How “Tupa” uses cookies and similar technologies

3. How “Tupa” share your personal information

4. How “Tupa” protect your personal information

5. Links to Third Party Websites, Products and Services

6. International Transfers of Your Personal Information

7. International users

8. Updating this Notice

9. How to contact us

I. How Tupa collects and uses your personal information

A. Personal Information Collected by Tupa

Before using “Tupa” products and services, you may need to provide your personal information. You do not need to provide your personal information to Tupa, but in some cases, failure to provide certain personal information will prevent us from providing you with relevant products or services.

Tupa collects personal information for the purposes mentioned in this notice. Here are some examples of personal information we may collect:

1. Personal information you provide to Tupa

To use certain services and functions, you must register a “Tupa ID” (“Tupa” ID). When you register a Tupa ID or sign in with a Tupa ID to make an online purchase, download software, or purchase services, we ask you for relevant personal information such as your name, email address, mobile phone number, order information, Enter the delivery address and payment method.

Tupa may provide you with cloud services where you can back up and synchronize some of your files, images and data.

Some Tupa products allow you to share information with others or communicate with others. When you use Tupa products to share this information with your friends and family, you may need to create a Tupa ID where certain information, such as your nickname or avatar, is made public. Tupa may collect information about these people such as name, email address and mobile phone number.

“Tupa” will take necessary and appropriate actions to ensure that the security of this information is established. You must ensure that the persons whose information you provide consent to the provision of their information to Tupa.

In order to comply with legal requirements regarding real name verification in user accounts, preventing addiction to computer games or online payments, Tupa may ask you for a government-issued ID card or related ID card information for identification purposes to present yourself.

2. The information that Tupa collects when you use the service

Tupa collects information about your device and how you and your device exchange information with Tupa products and services. This type of information includes:

(1) Device and application information such as device name, device identification code (MEID, ESN, IMEI and SN), device activation time, hardware model, operating system version, application version, software identification code and device and application settings (such as region, language, time zone and font size).

(ii) mobile network information such as public mobile network provider identifier (PLMN) and Internet Protocol (IP) address;

(3) Login Information. When you use Tupa’s services or view content provided by Tupa, Tupa automatically collects and categorizes information, including access time, amount of access, IP address, and event information (such as errors, bugs, restarts and upgrades).

(4) Location information. Tupa collects, uses and processes your exact or relative location information when you access location-based services (such as when searching, using navigation software, or viewing the weather for a particular location). Location information can be obtained through WLAN, GPS and service provider network ID. We ask you to select the apps for which you want location services to be enabled. You can disable permission to access the location of certain services in the settings menu of your device and prevent the sharing of your location information.

(5) Information you store on Tupa’s servers. For example, the information you upload to the cloud is stored on Tupa’s servers for quick access and sharing between devices. We are unable to view your stored information on Tupa’s servers.

3. Information provided from third-party sources

To the extent permitted by law, Tupa collects information about you from public and commercial sources. Tupa may obtain certain information from third-party social networking services, such as when you use a social network account to log into Tupa’s website.

4. Collection and use of non-identifiable data

Non-identifiable data is data that cannot be used to identify individuals. Examples of non-identifiable data include website view statistics, app downloads, and product sales. Tupa collects statistical data to gain a proper understanding of how users use the services and products. By doing so, we can improve our services to better meet your needs.

We keep your personal information and non-identifiable data separately and use them independently. Tupa may, in its sole discretion, collect, use and disclose non-identifiable data for other purposes.

B. How Tupa uses your personal information

Tupa may use your personal information for the following purposes:

(1) Registration and activation of “Tupa” home and personal products that you have purchased.

(2) Registering a “Tupa” ID so that you can enjoy a wider range of mobile phone functions and services.

(iii) provide, activate or verify the products and services you have requested, or make changes and provide technical support and after-sales services for future products and services based on your needs;

(4) send you operating system or application update and installation notifications;

(5) Providing content and user experience tailored to each user.

(6) send you information about products and services that may be of interest to you, invite you to participate in Tupa’s promotional activities and market surveys, or send you marketing information; If you do not wish to receive this information, you can cancel it at any time.

(7) conducting internal audit, data analysis and research; Analyzing the efficiency of commercial operations and measuring market share and improving services and products of “Tupa”.

(8) Synchronize, share and store data that you have uploaded or downloaded, as well as data required for uploading and downloading operations.

(9) Enhancement of loss prevention and anti-fraud programs.

(10) Processes to comply with laws and regulations such as requests from authorities and taxes.

(11) other purposes in certain Services or with your consent;

II. How Tupa uses cookies and similar technologies

A. Cookie

A cookie is a text file stored on a web server or computer or mobile phone, the content of a cookie can only be retrieved and read by the server that created that cookie. Cookies are specific to the browser or mobile application you are using. The cookie text usually contains identifiers, the name of the website and some numbers and letters.

From time to time, Tupa stores cookies on your computer or mobile phone to improve your user experience, including:

(1) Technical cookies: Sign in and confirm. When you use a “tupa” identifier to log into a website, “session-based” cookies ensure that you experience these website functions as well as possible. .

(2) Customization Cookies: Save your preferences and settings. Websites can use cookies to store settings such as your computer or mobile phone’s language and font size settings, your shopping list items, or other browser preferences.

(3) Advertising cookies. Tupa uses cookies to collect information about your online activities and interests and to serve you relevant advertisements.

(4) Statistical cookies. With cookies, Tupa can collect information about your use of websites or other applications, whether for a single visit (using a session cookie) or multiple visits (using a persistent cookie).

(5) Social Media Cookies. Social media cookies are associated with services provided by third parties such as “like” and “share” buttons. The third party provides these services in exchange for recognizing that you have visited our websites.

You can choose to manage or delete these cookies. For more information, visit AboutCookies.org. You can delete all cookies stored on your computer, most internet browsers offer the option to block cookies. However, blocking cookies requires that you change your user settings each time you visit our website.

Learn how to manage cookie settings for your browser here:Internet Explorer, Google Chrome, Mozilla Firefox, Safari, Opera.

If you delete cookies, you will need to change your settings the next time you visit Tupa websites. Note that some “Tupa” services require the use of cookies. Disabling cookies may affect the use of some or all functions of these services.

B. Web Beacons and Pixel Tags

In addition to cookies, Tupa and some third parties may use web beacons and pixel tags on their websites. A web beacon is usually an electronic graphic image embedded in a website or email to identify cookies on your device when you browse the website or email. The pixel tag allows Tupa to know whether an email has been opened when it sends you an email.

Tupa and some third parties use these technologies for various purposes, such as analyzing service usage (including cookies) and providing you with more satisfying content and advertising. For example, when you receive an email from Tupa, it may contain a URL that directs you to a page on Tupa’s website.

If you click on that link, Tupa will track your visit and help us see your preferences for products and services and improve our products. If you do not want to be tracked in this way, you can unsubscribe from the “Tupa” email list at any time.

C. Other memories on the device

Tupa and some third parties may use on-device memory technologies, such as on-device shared items (also called “Flash cookies”) and HTML5 on-device memory, in certain services and products. These technologies, like cookies, store information on your device and can record some information about your activities and preferences.

However, these technologies may use different media than cookies. Because of this, you may not be able to control them using standard browser settings and tools. For more information on disabling or deleting information contained in Flash cookies, click here.

D. Do not intercept

Many browsers offer a “do not track” function that can send “do not track” requests to websites. Currently, Internet standards organizations have not specified policies on how websites should handle these requests. If you enable “Do Not Track” in your browser, all Tupa websites will respect your decision.

III. How Tupa Shares Your Personal Information

We do not provide your private information to other companies, organizations and individuals, except in the following circumstances:

(1) Sharing with Your Consent: After obtaining your consent, Tupa will share the information you have authorized with specified third parties or groups of third parties.

(2) Sharing according to laws and regulations: “Tupa” may provide your information in accordance with laws and regulations, to resolve legal disputes or when required by competent executive or judicial authorities and by law.

(3) Sharing with “Tupa” subsidiaries: Your information can be shared with “Tupa” subsidiaries only for explicit and legal purposes, and this sharing is only limited to the information required for these services. For example, we verify the international uniqueness of accounts before allowing them to register.

(4) Sharing with business partners: Some products and/or services are provided to you directly by our partners. Tupa may also share your information with them, they may use your information to provide products and/or services you request (such as products sold by third-party sellers through Tupa’s e-commerce platform, video content provided by other Companies use (Tupa) applications, make predictions about your interests and provide you with advertisements, promotional materials and other content.

(5) Sharing with Service Providers: Tupa may share your information with companies that provide services to us or on our behalf. Examples of these service providers include companies that provide hotline services, send email or provide technical support on behalf of Tupa. These service providers may use your information only to provide services to you on behalf of Tupa.

(6) “Tupa” will share your information when there is a reasonable requirement to share it, for example required by law or existing regulations, legal process or government.

In cases 3 to 6, Tupa will ensure the legality of this sharing and sign a non-disclosure agreement (NDA) and/or data processing clause with these companies, organizations and individuals to whom this personal information is provided, and obliges them to comply with this notice and take appropriate privacy and security measures when processing personal information.

IV. How Tupa protects your personal information

Tupa takes the security of your personal information very seriously and uses industry standard practices to protect your personal information and prevent unauthorized access, use, alteration, damage, loss or disclosure. For this purpose, “Tupa” uses these measures:

(1) We take reasonable and practicable steps to ensure that the personal information collected is kept to a minimum and is relevant to the purpose for which it is collected. We will not retain your personal information longer than is necessary for the purpose described in this notice and the privacy notice of specific services or products, unless an extension of the retention period is required by law.

(2) We use many technologies, such as cryptographic technologies, to ensure that your data remains confidential in transit. We use our trusted protection mechanisms to protect data and data storage servers from cyber attacks.

(3) We have implemented access control mechanisms to ensure that only authorized personnel have access to your personal information. In addition, we control the number of authorized personnel and employ hierarchical access management based on service requirements and personnel levels.

(4) We carefully select business partners and service providers and include personal information protection requirements in business contracts, audits and evaluations.

(5) We conduct security and privacy protection training courses, tests and public activities to increase individual employees’ awareness of data protection.

Tupa is committed to protecting your personal information. However, no security measure is perfect and no product, service, website, data transmission, computer system or network connection is completely secure.

To deal with possible risks such as disclosure, damage or loss of personal information, “Tupa” has developed several mechanisms and control measures, measures that define standards for rating weaknesses and security events and corresponding processing procedures. “Tupa” has formed a dedicated emergency response team to carry out security design, loss reduction, analysis, location and correction, as well as tracking operations in the relevant departments and based on the rules and regulations of actions when security events occur.

“Tupa” informs you of the events related to the personal information related to the security case and its possible effects, the actions that “Tupa” has taken or will take, suggestions related to active defense and risk reduction and corrective measures according to the legal and legal requirements. Gives. This notification can be done via email, message, push notification, etc. If it is difficult to notify the information on an individual basis, we will take appropriate and efficient actions to publish the security notice. In addition, we report the status of processing and control of personal information security cases as required by regulatory authorities.

V. Links to third-party websites, products and services

“Tupa” websites, applications, products and services may contain links to third party websites, products and services.

All links to “Tupa” websites, products and services are provided for the convenience of users only. You must determine your own interaction with these links. Before submitting personal information to third parties, please read and refer to the third party’s privacy policies.

VI. International transfers of your personal information

Our products and services are provided through resources and servers in different regions, we may need to transfer your personal information between several countries. Authorized employees of Tupa and third parties acting on our behalf may use, access or process personal information collected on your behalf and may do so in a region/country different from the region/country in which you reside. information you have entered into it, and therefore data protection laws may be less stringent. When we transfer personal information to other regions/countries, we will protect your personal information in accordance with this notice or as disclosed to you at the time the information was collected (for example, through a privacy notice or a supplemental notice for a specific product or service).

Tupa has implemented global privacy policies for the processing of personal information protected under data protection laws. “Tupa” transfers personal information according to the standards and conditions of existing data protection laws, including the standards and conditions related to security and processing, between the countries in which it operates.

With respect to the personal information of EU or Swiss users, we comply with existing legal requirements and provide adequate security for the transfer of personal information to countries outside the European Economic Area (“EEA”) or Switzerland. We use various legal mechanisms such as statutory contractual clauses to enforce the cross-border transfer of your personal information; Or we use security measures such as anonymizing information before transferring it abroad.

VII. International users

If the cloud services of “Tupa” customers are in one of the member countries of the European Economic Area (“EAA”) or Switzerland, Albania, Andorra, Bosnia, Faroe Islands, Gibraltar, Greenland, Macedonia, Moldova, Monaco, Montenegro, Sun Marino, Serbia, Vatican, Japan, South Korea, USA and Canada, TUPA Den will be the data controller.

VIII. Updating this statement

Tupa reserves the right to update this notice at any time.

If this notice is modified from time to time, “Tupa” will inform users of these changes through various networks, such as publishing the latest version on its official website at this address: http://users.tupa.ir.

“Major changes” in this notice include but are not limited to:

(1) Substantial changes in our service practices, for example the purposes of processing personal information, the types of personal information processed and the ways in which personal information is used.

(ii) material changes in our ownership structure and organizational structure, for example, ownership changes caused by a business restructuring, bankruptcy or acquisition;

(iii) changes in the basic terms of sharing, transferring or disclosing personal information;

(4) Substantial changes to your rights in relation to the processing of personal information and the ways in which you can exercise these rights.

(5) Change in the departments, officials and complaint networks of “Tupa” responsible for the security of personal information processing

(6) High risk identified in personal information security impact assessment reports

IX. How to contact us

We have designated a specific Personal Data Protection Department (or Data Protection Officer). If you have any questions, comments or suggestions, please let us know by visiting our contact page or by sending them to our offices around the world. To get the complete list of “Tupa” offices, please visit the international offices page.

Attention: Due to differences in language and laws, versions of the Tupa Consumer Business Privacy Notice may differ from this version in different countries. In the presence of these conflicts, the copies of this notice in each country are used and referred to as the main documents.

All rights are reserved for Tosee Pouyan e Arvand Company ©. 1400 – 2021