Privacy Policy

Back Engineering Labs

At Back Engineering Labs, we believe strongly in fundamental privacy rights- and that those
fundamental rights should not differ depending on where you live in the world. That’s why
we treat any data that relates to an identified or identifiable individual or that is linked or
linkable to them by Back Engineering Labs as “personal data,” no matter where the
individual lives. As soon as you visited our website https://back.engineering or contact us,
we receive information about you. In this privacy statement we explain what we do with
that information. We always handle your information with care and store it securely. If you
have any questions or want to know what information we have on you, please contact us at
[email protected]. We may amend this privacy statement if necessary. We
recommend that you regularly review this privacy statement so that you are aware of these
changes. This privacy statement was last modified on May 15 th, 2023.

Content

1. When do apply this privacy statement? 2. Who uses your data? 3. Whose data do we use? 4. How do we get your data? 5. What data of you do we use? 6. What do we use your data for? 7. How long do we store your data? 8. Who do we share your data with? 9. Where do where store your data? 10. How safe is your data with us? 11. What are your rights? 12. What rules apply to this privacy statement? 13. Which cookies do we use? 14. What do we do with data of minors? 15. Do you have a question about this privacy policy? 16. Notice for California residents

1. When do you apply this privacy statement

This privacy statement applies to all personal data that we process and to all domains
related to us. This concerns the personal data of everyone who has ever had contact with us
or visited our website, such as visitors, customers and business contacts. Personal data is all
data that can be traced back to you as an individual, such as your name, screenshots if there
is an issue, IP address, or surfing behaviour.

2. Who uses your data?

The owners are responsible for the website https://back.engineering and therefore the
responsible organization for the use of your personal data as described in this privacy
statement.

3. Whose data do we use?

We process the personal data of everyone who has had contact with us or visited our
website. These include visitors, private customers, business customers and contact persons
of our partners.

4. How do we get your data?

We receive the data directly from you as soon as you:

• visit our website
• fill in data on our website
• contact us by mail, telephone or other means

5. What data of you do we use?

At Back Engineering Labs, we believe that you can have great products and great privacy.
This means that we strive to collect only the personal data that we need. We use the
following data:

• Account information. Your Back Engineering Labs ID and related account details,
  including email address, devices registered, account status and age.

• Device information. Data from which your device could be identified, such as device
  serial number, or about your device, such as browser type.

• Contact information. Data such as name, email address, physical address, phone
  number, or other contact information.

• Payment information. Data about your billing address and method of payment, such
  as bank details, credit, debit, or other payment card information.

• Transaction information. Data about purchases of Back Engineering Labs products
  and services or transactional facilitated by Back Engineer Labs, including purchases
  on Back Engineer Labs platforms.

• Fraud prevention Information. Data used to help identify and prevent fraud,
  including a device trust score.

• Usage Data. Data about your activity on and use of our offerings, such as server
  launches within our services, including browsing history; search history; product
  interaction; crash data, performance and other diagnostic data; and other usage
  data.

• Location Information. Precise location only to support services such as where you
  are agree for region-specific services, and coarse location.

• Government ID Data. In certain jurisdictions, we may ask for a government-issued ID
  in limited circumstances, including when setting up a wireless account and activating
  your device, for the purpose of extending commercial credit, managing reservations,
  or as required by law.

• Other Information You provide to Us. Details such as the content of your
  communications with Back Engineer Labs including interactions with customer
  support and contract through social media channels.

You are not required to provide the personal data that we have requested. However, if you
choose not to do so, in many cases we will not be able to provide you with our products or
services or respond to requests you may have.

6. What do we use your data for?

We only use your personal data for the purpose for which we are allowed to use it:

• We use your data because we want to give you the best service as a customer.

7. How long do we store your data?

We keep your personal data for as long as we are required to do so by law and for as long as
necessary for the purpose for which we use your data. For example, as long as you are a
customer with us, we store your data according to the regulation RIN 3235-AI74 retention
period of seven years. After that, we only keep your data for statistical purposes and to
handle any complaints or legal matters. If you want to know more about how long we store
specific data about you, please contact us.

8. Who do we share your data with?

We only process your personal data ourselves. We don’t share your personal data with
others.

9. Where do where store your data?

The data that we collect from you may be transferred to, and stored at a server of Back
Engineering Labs, a destination outside of the European Economic Area (“EEA”) including for
the purposes of our hosting and data center provider. It may also be processed by staff
operating outside the EEA who work for us for one of our suppliers. Such staff maybe
engaged in, among other things, the processing of your payment details. By submitting your
personal data, you agree to this transfer, storing or processing. We will take all steps
reasonably necessary to ensure that your data is treated securely and in accordance with
this privacy policy. All information you provide to us is stored on your secure servers. Where
we have given you (or where you have chosen) a password which enables you to access
certain parts of our site, you are responsible for keeping this password confidential. We ask
you not to share a password with anyone. Unfortunately, the transmission of information
via the internet is not completely secure. Although we will do our best to protect your
personal data, we cannot guarantee the security of your data transmitted to our site; any
transmission is at your own risk. Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorized access. Your Rights We will
not share your personal data for marketing purposes. Our site may, from time to time,
contain links to and from the websites of our partner networks, advertisers and affiliates. If
you follow a link to any of these websites, please note that these websites have their own
privacy policies and that we do not accept any responsibility or liability for these policies.

Please check these policies before you submit any personal data to these websites. Access
to information GPDR Right of Access gives you the right to access information held about
you. Your right of access can be exercised in accordance with the Act. Any access request
may be subject to a fee of 10 dollars to meet our costs in providing you with details of the
information we hold about you. Changes to our privacy policy any changes we may make to
our privacy policy in the future will be posted on this page and, where appropriate, notified
to you by e-mail. Please check back frequently to see any updates or changes to our privacy
policy.

10. How safe is your data with us?

We have done a lot to protect your data as well as possible, both organisationally and
technical. We have secured our systems and various means of communication to ensure
that your data does not end up in the hands of others. Your data is therefore safe with us.
We also ensure that your data is only used by people who have received permission from
us. If you have any questions about the specific method of securing, please contact us on
[email protected].

11. What are your rights?

Because we use your data personal data, you have various rights. We have listed these
rights for you below.

Right to information
We must explain to you in an understandable and clear manner what we do with your data
and what control you have over it. that is why we explain in detail in this privacy statement
what data we collect from you and how handle your data.

Right to access
You may always ask us to view the data we hold about you.

Right to correction
You may ask us to have your data corrected if it is incorrect or incomplete.

Right to object
You may object to the processing of your data if you do not agree with the way we handle
your personal data. This right applies to the data we use for direct marketing. You can
indicate to us that you no longer wish to receive e-mails from us. This also applies to
personalized recommendations on our website.

Right to data portability
If you are a customer of ours or if you have given permission for the use of your data, you
may ask us to send you the digital data we have about you. This way you can transfer that
data to another organisation if you wish.

Right to restriction
You may ask to limit the use of your data. This means that in certain cases we may only
store your data but not use it.

Right to be forgotten
You may ask us to delete all data we have about you. We will then delete all data that can
be traced back to you. In some cases we cannot or may not yet delete your data. For
example, we have to keep some data for 7 years for the Internal Revenue Service.

Right to submit a complaint
You may submit a complaint about the way in which we handle your data. If you have a
complaint, we will be happy to resolve it for you. To do so, please contact
[email protected].

How do I submit a request or complaint?
You can submit your request or complaint to [email protected]. We process every
request or complaint within 30 days. If you submit multiple applications or complaints or if
you submit a complex request or complaint, this may take more time. In that case, we will
contact you within 60 days at the latest. We may ask you to identify yourself. In that case,
we will ask you to submit certain information to ensure that you are the correct person
whose personal data is.

12. What rules apply to this privacy statement?

Our privacy statement must meet several conditions. These conditions can be found in
particular in the U.S. privacy laws. In addition, the general rules that apply under California
state law and US federal law apply to our privacy statement.

13. Which cookies do we use?

You can indicate your what data we may use from you. If you have given us permission to
personalize your profile based on your surfing and search behaviour, we can set up our
website specifically for you so that its use becomes easier and more personal. We do these
using cookies. A cookie is small text file that is placed on your hardware when you visit our
website.
we use the following types of cookies on our website:

• functional cookies: like session and login cookies to collect session and login information.
• anonymised analytical cookies: to obtain information regarding the visits to our website,
  like numbers of visitors, popular pages and topics.
• tracking cookies: like advertising cookies that are intended to show relevant
  advertisements.

More specifically, we use the following cookies on our website:

• Personal tracking cookies: these allow us to learn that besides our website have also visited
  the relevant other website(s) from our network. The resulting profile is not linked to your
  name, address, e-mail address and the link, but only serves to match advertisements to your
  profile, so that they are as relevant as possible to you. We ask your permission for these
  cookies. These cookies are therefore not placed without your permission.
• Site improvements cookies: these allow us to test different versions of a webpage to see.

14. What do we do with data of minors?

We do not target minors with our website or as an organisation. This means that for users
under the age specified by law in their jurisdiction, for example under 13 in the U.S.- certain
Back Engineering Labs services will either block users under that age or will ask them to
obtain consent or authorization from a parent or guardian before they can use it, including
when creating an account to access Back Engineering Labs services. We will not knowingly
ask children under that age to provide more data than is required to provide for the
product. Once parental consent or authorization is granted, the child’s account is treated
much like any other account. Parents or guardians can change or revoke the consent choices
previously made.

15. Do you have a question about this privacy policy?

If you have a question about our privacy policy, please feel free to contact us on
[email protected]. We are happy to help.

16. Notice for California residents

If you reside in the state of California please see the notice below.

How to contact us

If there are any questions regarding this Privacy Policy or the information that we collect
about you, or if you feel that your privacy was not treated in accordance with this Privacy Policy, you may contact our Data Protection Officer at [email protected]

Privacy Notice for California Residents

This part of the Policy addresses the specific disclosure requirements under the California
Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer
Privacy Act Regulations by the Attorney General (collectively, “ CCPA “).

Categories of Personal Information We Process?

In the 12 preceding months, we have collected and disclosed the following categories of
Personal Information:
I apologize for the confusion. Here's the correct formatting of the information you provided:

Category of Personal Information Collected	Personal Information Collected	Categories of Service Providers to Whom Personal Information was Disclosed
Identifiers	Email address, device identifiers (UDID, IMEI, MAC, IP, identifiers issued by Client), image	Cloud Services, Fraud Prevention
Commercial Information	Feedback of Clients and/or End Users	Cloud Services
Internet or Other Electronic Network Activity Information	Usernames, directory names, server names, share names, file names and paths, configurations, logs related to Software and Client (e.g., event logs), browsing events and technical information transmitted by your device or your End Users' devices, including certain software and hardware information (e.g., the type of browser and operating system the device uses, language preference, access time and the domain name from which you or your End Users are linked to the Software.	Cloud Services

I hope this format accurately represents the information you provided. Let me know if there's anything else I can assist you with!

We do not sell (as this term is defined under the CCPA) any Personal Information.

We may share or transfer Personal Information to third parties as assets that are part of a
merger, acquisition, bankruptcy or other transaction in which the third party assumes
control of all or part of the Company. Such transfer will be handled according to the

requirement of the CCPA and shall not be regarded as a sale of Personal Information under
the CCPA.

Sources of Personal Information

In the 12 preceding months, we have collected the above-mentioned categories of Personal
Information from the following categories of sources:

• Clients or End Users directly.

Purposes for collection of Personal Information

Our purposes for collecting Personal Information can be found above, under the section
“How we use the information we collect”.

User Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This
section describes your CCPA rights and explains how to exercise those rights:

Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and
specific pieces of Personal Information that we have collected about you, the categories of
sources from which your Personal Information is collected, the business or commercial
purpose for collecting your Personal Information, the categories of Personal Information
that we disclosed for a business purpose, any categories of Personal Information about you
that we sold, the categories of third-parties with whom we have shared your Personal
Information, and the business purpose for sharing your Personal Information, if applicable.

Deletion Requests

You have the right to request that we delete any Personal Information collected from you
and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct
our service providers, subcontractors, and consultants to delete) your Personal Information,
unless an exception applies.

Exercising Your Rights

You can exercise your rights (such as deletion) by submitting a verifiable consumer request
to our email address: [email protected] (for any other query or request, please
reach out to [email protected] or by sending a mail to our physical address
specified in the HOW TO CONTACT US section.

Only you or a person authorized to act on your behalf may make a consumer request
related to your Personal Information.

The request must:

• Provide sufficient information to allow us to reasonably verify you are the person
  about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient details to allow us to properly understand,
  evaluate, and respond to it.
• We cannot respond to your request or provide you with Personal Information if we
  cannot verify your identity or authority to make the request and confirm the
  Personal Information relates to you. Making a verifiable consumer request does not
  require you to create an account with us. We will only use Personal Information
  provided in a verifiable consumer request to verify the requestor’s identity or
  authority to make the request. We will only use Personal Information provided in a
  verifiable consumer request to verify the requestor’s identity or authority to make
  the request.

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you
how we use it, please contact us at [email protected].

Response Timing and Format

Our goal is to respond to a verifiable consumer request within 30 days of its receipt. If we
require more time, we will inform you of the reason and extension period in writing within
the first 30 days period. We will deliver our written response, by mail or electronically, at
your option. Any disclosures we provide will cover only the 12-month period preceding the
request. If reasonably possible, we will provide your Personal Information in a format that is
readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it
is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants
a fee, we will tell you why we made that decision and provide you with a cost estimate
before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot
comply with your request.

Please note that these CCPA rights are not absolute and requests are subject to any
applicable legal requirements, including legal and ethical reporting or document retention
obligations.

Designating Agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the
  Secretary of State of California; and
• You sign a written declaration that you authorize the authorized agent to act on your
  behalf.

If you use an authorized agent to submit a request to exercise your right to know or your
right to request deletion, please mail a certified copy of your written declaration authorizing
the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code
sections 4000 to 4465, it may not be necessary to perform these steps and we will respond
to any request from such authorized agent in accordance with the CCPA.

Non-Discrimination

Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting
  discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a
  different level or quality of goods or services.