Last updated: May 12, 2024

Privacy Policy

Back Engineering Labs Inc.

At Back Engineering Labs Inc. 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 Inc., 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 contact@back.engineering. 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 April 27 ste, 2024.

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 and Delaware residents and other states
17. Your Rights in the EU**

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 Inc. 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 Inc. 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 Inc. products and services or transactional facilitated by Back Engineer Labs Inc., including purchases on Back Engineer Labs Inc. 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 Inc., 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 Inc. 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 contact@back.engineering.

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 contact@back.engineering.

How do I submit a request or complaint? You can submit your request or complaint to contact@back.engineering. 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 Inc. 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 Inc. 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 contact@back.engineering. We are happy to help.

16. Notice for California and Delaware residents and other states

If you reside in the state of California or the state of Delaware 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 contact@back.engineering.

Privacy Notice for California and Delaware 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 “) and the Delaware Personal Data Privacy Act (“ DPDPA” ).

Categories of Personal Information We Process?

In the 12 preceding months, we have collected and disclosed the following categories of Personal Information:

Category of Personal
Information Collected

Personal Information Collected

Categories of service
providers to whom Personal
Information was disclosed

A. Identifiers

Email address, device identifiers
(UDID, IMEI, MAC, IP, identifiers
issued by Client), image

Cloud Services

Fraud Prevention

B. Commercial
information

Feedback of Clients and/or End
Users

Cloud Services

C. 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

We do not sell (as this term is defined under the CCPA and DPDPA) 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 DPDPA and shall not be regarded as a sale of Personal Information under the CCPA and DPDPA.

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 and DPDPA

The CCPA and DPDPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA and DPDPA 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: contact@back.engineering (for any other query or request, please reach out to contact@back.engineering 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 contact@back.engineering.

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 and DPDPA 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 and DPDPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
• The authorized agent is a natural person or a business entity registered with the Secretary of State of Delaware; 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 and DPDPA.

Non-Discrimination

Unless permitted by the CCPA and DPDPA, 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.

17. Your Rights in the EU:

The General Data Protection Regulation is an EU regulation that provides individuals with certain rights in relation to their personal data which is either processed by an organization established in the E, or for individuals located in the EU, processed by an organization outside of the EU that offers goods/services to or monitors such individuals in the EU.

If this applies to you, you will have the following rights (subject to certain conditions) with

respect to your personal information:

The right to object to processing. You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by third party.

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights, which is why we are providing you with this information in this privacy notice.

The right of access. You have the right to obtain access to personal information about you that we process. You can do this by contacting us in the manner provided above in the HOW TO CONTACT US section.

The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in personal information that we hold by contacting us in the manner provided above in the HOW TO CONTACT US section.

The right to erasure. This enables you to request the deletion or removal of your personal information in certain circumstances, such as where there is no compelling reason for us to keep using it or its use is unlawful. This is not a general right to erasure and there are a number of exceptions e.g. where we need to use your personal information in defense of a legal claim.

The right to restrict processing. You have rights to suspend further use of your personal information, whereby we can still store your personal information but cannot use it further.

The right to data portability. You have rights in some circumstances to obtain and reuse your personal information for your own purposes across different services.

The right to withdraw consent. If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful).

The right to lodge a complaint. You have the right to lodge a complaint about the way we process your personal information with data protection regulator where you live, work, or where you believe your rights have been violated.