PRIVACY POLICY

Welcome to the Privacy Policy of SVL Simulator (“SVL”). For purposes of this Privacy Policy, “We” or “Us” refers to SVL Simulator and “You” and “Your” refer to You, the individual accessing, browsing, or registering to use the Simulator Services or website (https://www.svlsimulator.com), or Your employer or other entity for whose benefit You act, as applicable (collectively “User”). This Privacy Policy sets forth SVL’s policy with respect to information collected, used, and disclosed about You. This page also informs You about the choices You have with respect to Your information. Simulator Services is not defined in our Privacy Policy and shall have the same meaning as ascribed in the Terms of Use. 
Your use of the Simulator Services is also subject to the Terms of Use https://www.svlsimulator.com/terms.


1.	What Personal Data We Collect About You

We collect Personal Data from visitors to the website and when You register for the Simulator Services Personal Data is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to You personally or Your household. SVL collects and stores the Personal Data that You have provided to Us voluntarily. We also collect Personal Data automatically via the website. If You provide Personal Data to our website You acknowledge and agree that such Personal Data may be transferred to the office and servers of SVL and its subsidiaries, direct and indirect parent, and affiliates located in the United States and the Republic of Korea. We collect the following Personal Data via the website including:
 - 	First and last name.
 -	Email address. 
 -	Company or Organization.
 -	Role in Company. 
 -	Location information.
 -	Demographics.
 -	Usage statistics that include but are not limited to customizations to maps, vehicles, environments, and other assets, time and duration of executing program, information about third party content brought in by You to the Simulator Services.
 -	Internet Protocol (IP) address – Your IP address is a number that lets computers attached to the Internet know where to send Your data – such as the webpages You view or SVL Simulator You run on Your computer.
 -	Cookies – “cookie” is a small text file that may be used to collect information about Your activity on the website. For example, when someone visits a page within the website, a cookie is placed on the user’s machine (if the user accepts cookies) or is read if the user has visited the website previously. Please see Section 5 below for additional information regarding our use of Cookies. 

We also collect information that does not identify you personally, such as aggregated data, demographic information, statistical information, age, location, gender or interests. If We combine this information with Personal Data, We will treat the resulting data as Personal Data.


2.	How We Use Personal Data We Collect About You

We use Your Personal Data that is collected on this website and through the Simulator Services primarily for the following purposes:
 -	To deliver our services;
 -	To ensure the website is relevant to Your needs;
 -	To ensure our website is functioning properly and prevent technical issues;
 -	To help Us create and publish content most relevant to You;
 -	To collect analytics information pertaining to use of the website, including traffic, usage, and download trends
 -	To notify You about a material change to this Privacy Policy or the Terms of Use Agreement, if necessary;
 -	To track and analyze aggregate usage and volume statistical information from our visitors and customers to gather analysis or valuable information so that We can improve our services and products;
 -	To monitor the usage of our website and Simulator Services;
 -	To provide You with news, offers, and general information about our Simulator Services and related products, with your consent where required;
 -	To contact You in response to inquiries;
 -	To maintain the accuracy of our records;
 -	As otherwise permitted by applicable law.
 -	To share data As Permitted by this Agreement


3.	How We Retain Your Personal Data

SVL keeps Your Personal Data for as long as appropriate to maintain Your account, fulfill Your requests, for legal compliance and enforcement purposes, to resolve disputes, and prevent fraud. Actual retention periods will depend on the product or service being used, Users control over the information they voluntarily provide, and the type and sensitivity of the Personal Data. 
When we delete electronic data files, we employ technical methods to destroy such files so that the data cannot be restored or reconstructed. For hard copies and paper documents, we destroy them through shredding.


4.	How We Share Your Data

SVL may share Your Personal Data with third parties outside SVL such as its affiliates (subsidiaries, indirect or direct parents, and corporate affiliates), and third-party analytics platforms in the course of providing You with services that have been requested by You, or so that We can ensure our services and products are meeting Your needs. SVL is responsible for the management of your Personal Data shared with affiliates and other third-parties described in this section. Where required by applicable law, you can obtain a list of third-parties processing your Personal Data by contacting us at contact@svlsimulator.com. See Section 8(A) below. For example: 
 - 	In some instances SVL may be required to transfer Your Personal Data to our parent company in the Republic of Korea to provide You with a service requested by You. 
 -	We may also share data such as cookies and log files with third-party analytics platforms for purposes described in “How We Use Personal Data Collected About You.” We may also send aggregate and anonymized data to these entities for the purposes described above. 
 - 	We may be required to share Your Personal Data where We are required to do so by law or subpoena or if We believe is necessary to (a) conform to the requirements of law or comply with legal process served on Us; (b) protect and defend our rights or property, including the rights and property of SVL; (c) and/or act in urgent circumstances to protect the personal safety of our end users.


5.	Cookies and Other Similar Technologies

We, and third-parties We allow, use cookies on our website. We may use session cookies or persistent cookies. Session cookies only last for the specific duration of Your visit and are deleted when You close Your browser. Persistent cookies remain on Your device’s hard drive until You delete them or they expire. Cookies may be used to track users across the web. Different cookies are used to perform different functions, which we explain below:
 - 	Essential. Some cookies are essential in order to enable You to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, We cannot enable appropriate content based on the type of device You are using.
 -	Browsing and Functionality. These cookies remember choices You make on our website. For example, when You return to our website, these cookies help remember Your preferences.
 -	Analytics. These cookies collect information about how You use our website, for instance which pages You go to most often, and if You get any error messages. 
 
You can set Your browser not to accept cookies. Additionally, You can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the web site of its manufacturer. Because cookies allow You to take advantage of some of our essential features, we recommend that You leave them turned on. However, if You opt out of cookies, some of our website features may not function as a result. 


6.	California Privacy Rights

This section supplements the terms of this Privacy Policy. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”). As of January 1, 2020 California residents have specific rights regarding their Personal Data. California residents are entitled to the following rights:

The right of access and data portability – You have the right to request that We disclose certain information to You about our collection and use of Your Personal Data over the past twelve (12) months. You also have the right to request information about our sale or disclosure for business purposes of Your Personal Data to third parties.

The right to request deletion of data – You have the right to request that We delete any Personal Data We have collected from You and retained, subject to certain exceptions. If You wish to exercise this right, please email your consumer request to contact@svlsimulator.com. We may request additional information from you to verify your request. Please note that this does not ensure complete removal of Your Personal Data if the information is necessary to provide You with the Simulator Services or required by law or subpoena.

Only You or a person registered with the California Secretary of State authorized to act on Your behalf may send a consumer request. You may also make a consumer request on behalf of Your minor child. You may only make two consumer request for access or data portability within a twelve (12) month period.  Please note that You are not required to create an account with Us to make a consumer request. The consumer request must:
 -	Provide sufficient information that allows SVL to reasonably identify You are the person whom We collected Personal Data or an authorized representative.
 -	Describe Your request with sufficient detail that allows Us to evaluate and respond to it. 

We endeavor to respond to a consumer request within forty-five (45) days of its receipt. If We require more time, up to ninety (90) days, We will inform You of the reasons and extension period in writing.

The right to opt-out of the sale of data. You have the right to request to opt-out of the sale of Your Personal Data to third-parties. You can exercise this right through the “Do Not Sell My Personal Information” link in the footer of our website, when such link becomes available on January 1, 2020.

The right to not be discriminated against. You have the right to not be discriminated against for exercising any of these rights granted to You under the CCPA.
California “Shine the Light Law” – California Civil Code Section § 1798.83 permits Users of our website that are California residents to request, once a year, certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make a request, please send an email to contact@svlsimulator.com with “Shine the Light” in the subject line. 


7.	Data Protection Rights Under GDPR

If You are visiting or registering for this website as a resident of the European Economic Area (EEA), You have certain data protection rights. You may contact Us about what Personal Data We collect about You and if You want to be removed from our systems. SVL would like to make sure You are fully aware of all of Your data protection rights. EEA users are entitled to the following:
The right to access – You have the right to request SVL for copies for Your Personal Data. 
The right to rectification – You have the right to request that SVL correct any Personal Data You believe is inaccurate. You also have the right to request SVL complete the Personal Data You believe is incomplete. 
The right to erasure – You have the right to request that SVL erase Your Personal Data, under certain conditions. 
The right to restrict processing – You have the right to request that SVL restrict the processing of Your Personal Data, for legitimate reasons. 
The right to data portability – You have the right to request that SVL transfer the Personal Data that We have collected to another organization, or directly to You, under certain conditions.
The right to lodge a complaint – You have the right to lodge a complaint with Your relevant data protection authority.
If You make a request, We have one month to response to You. If You wish to exercise one or more of these rights, please contact Us at contact@svlsimulator.com. 


8.	Data Processing

SVL will only process Personal Data of EEA residents in accordance with the User’s explicit consent unless processing is required by the European Union or Member state to which SVL may be subject, in which case SVL will inform the User of the legal requirement before processing the Personal Data. The term “Process” and “Processer” in this section shall have the same meaning as defined in the GDPR.

A.  Transferring Personal Data

User agrees that SVL may use Processors to Process Personal Data. A complete list is available upon request.


9.	International Data Transfers

We are based and store our data in the US. If You choose to provide us with Personal Data, please understand that Your Personal Data may be transferred to the US and that we may transfer that data to our affiliates and subsidiaries or to other third parties, across borders, and from Your country or jurisdiction to other countries or jurisdictions around the world. If You are visiting from the EU or other regions with laws governing data collection and use that may differ from US law, please note that You are transferring your Personal Data to the US and other jurisdictions which may not have the same data protection laws as the EU. We put in place appropriate operational, procedural and technical measures in order to ensure the protection of Your Personal Data. You acknowledge You understand that by providing your Personal Data: (i) Your Personal Data will be used for the uses identified above in accordance with this Privacy Policy; and (ii) Your Personal Data may be transferred to the US and other jurisdictions as indicated above, in accordance with applicable law.


10.	Your Choices

We would like to send You information about products and services that may interest You. If You have agreed to receive marketing, You may always opt out at a later time. If You no longer wish to be contacted for marketing purposes please contact Us at contact@svlsimulator.com or follow the “unsubscribe” link in the marketing communication. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until your unsubscribe is processed.
You may update Your account information and email-communication preferences at any time by contacting us at contact@svlsimulator.com. Please note that You may not opt out of SVL service related communications like account verification, changes and updates to the Simulator Services, technical and security notices. These communications will be primarily informational in nature, rather than promotional.


11.	Links to other sites

This Privacy Policy applies solely to Personal Data collected on the website and through the Simulator Services. The website may contain links to other web sites. We are not responsible for the privacy practices or the content of these other web sites. Any third party links do not imply that SVL endorsees or reviews third party websites. Please refer to the privacy policies on these other web sites to see how these third parties collect and handle your Personal Data.


12.	Children’s Privacy

SVL does not knowingly collect Personal Data from anyone under the age of 13 in the US or 16 in the EU. If You are under 13 in the US or under 16 in the EU please do not attempt to register on the website or send Us any Personal Data. 


13.	Changes to the Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. When We do, We will also revise the “last update” date at the top of this Privacy Policy. In the event We make material changes to the Privacy Policy, we will notify you via a prominent notice on the website and/or via email at the email address we have on file for you. 


14.	Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, We cannot ensure or warrant the security of any Personal Data You transmit to Us and You understand that any Personal Data that You transfer to LGEUS is done at Your own risk. Once We receive Your transmission, We make commercially reasonable efforts to ensure security on our systems. If We learn of a security systems breach We may attempt to notify You electronically so that You can take appropriate protective steps. By using this website or providing Personal Data to Us, You agree that We can communicate with You electronically regarding security, privacy and administrative issues relating to Your use of the website. We may post a notice on our website if a security breach occurs. We may also send an email to You at the email address You have provided to Us in these circumstances. Depending on where You live, You may have a legal right to receive notice of a security breach in writing.


15.	Assignment

In the event of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions and sales of all or substantially all of our assets, You grant us the right to assign the Personal Data collected via the website and Simulator Services.


16.	Contact Us

contact@svlsimulator.com
5150 Great America Parkway
Santa Clara, CA 95054