Privacy Policy
Privacy Policy
Last Updated: August 10th, 2023
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects You.
- Data controller and representative
Through our websites (the “Websites”) and desktop applications and mobile applications (the “Applications” or “Products”), Franklin wireless from here on Franklin, and its affiliated solutions (collectively, “Franklin”, “Pintrac” “JEXtream”, “us,” or “we”) implement the processing of personal data listed below. Franklin is committed to protecting your privacy. We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information.
Please carefully read the following privacy policy which provides you, as the User of the Websites and/or Applications (the “User” or “You”), with the relevant information regarding the various processing of personal data implemented by Franklin.
- Data processing implemented by Franklin
2.1 Processing of personal data related to your visit to our website and the purchase and use of our products.
When the User visits our websites, purchases a Franklin product through the websites or the Application, or uses our products, Franklin implements the processing of personal data as follows:
2.1.1 Data we collect if you visit our websites.
- information about how you visit our websites (including the webpage that led you to a Franklin website, the search terms entered a search engine that led you to the Franklin website)
- Your operations and clicks on our websites.
- Date and time of the visit and the duration of use of the Websites.
2.1.2 Data we collect only if you submit it to us
- Email address
- Country
- Phone number
- Your account data
- Content for customer support communications.
2.1.3 Data we collect if you use our Products
We have different kinds of products and different products may collect different data. Generally, we may collect the data below if you use our products.
- We collect information about the products you use and how you use them, including but not limited to Launch data, Feature usage, Page clicks, Sign-in information.
- Your local device information, including but not limited to your device information, device hardware, operating system, other software on your system, Username, your Franklin ID, location, IP address, operating log information. Crash data and information about the files you are working with
- For our JEXtream product, we usually collect information on the device and application / firmware that has been installed on such device . The information may include device model, system version and language, User’s submitted information, installed applications, browser records, keywords (for early warning purposes), etc
For the JEXtream product, we request “android.permission.query_all_packages” permission on the device that installed JEXtream Parental and Kids app, with this permission we collect and store the installed applications of the device. We’ll delete these data anytime you want, just email us at cs@franklinwireless.com.
2.1.4 Purpose and legal basis of the processing
Franklin uses the information we collect about you for the following purposes:
Our processing of the collected personal data relies on the user’s consent or other circumstances the laws permit (such as for the performance of statutory duties or statutory obligations, or the conclusion or performance of a contract with the User, etc.).
- For Franklin to provide the user with the ordered products;
- for the performance of the contract to which the User is a party, under Article 6.1.b of the GDPR and the collected data is necessary for Franklin to identify and bill the User and to charge their bank card number;
- Provide customer service or support;
- To verify your identity and anti-piracy purposes;
- For Internal statistical and analytical purposes. Analyze your use of our websites visited, browsed, searched and products to better understand how they are being used so we can improve our services and the user experience and engage and retain users;
- For chargeback management purposes;
- To show you ads of Franklin products and services that we think may interest you.
2.1.5 Recipients of personal data
We treat your data with care and confidentiality and will only pass it on to third parties to the extent described below and not beyond. We do not share, sell, rent, or trade personal data with third parties for their promotional purposes.
– Service Providers: We may share your personal information with companies that help us run our business by processing personal information on our behalf for the purposes identified above. Such companies include payment processing companies that can help us process transactions, the parties providing our third-party cookies and tracking tools that may send tracking data or analysis reports to Franklin, email delivery service providers which can help us deliver emails to you, server companies we hire to provide service to you, chargeback management service providers, fraud monitoring and prevention providers, social media, and other marketing platforms and service providers.
In addition, Franklin may disclose the user’s data:
- Public Authorities: if Franklin is under a duty to disclose or share such personal data to comply with any legal obligation, or to protect the rights, property, or safety of its business, its customers, or others;
- Business Transactions: to successors in the title or replacement operators of all or part of Franklin’s respective businesses.
2.1.6 Transfer of personal data
The collected personal data may be transferred by Franklin to recipients who are located outside the UNITED STATES or Americas and such destinations may not have laws that protect the User’s data to the same extent as in the UNITED STATES or USA.
Franklin ensures that the user’s data processed by Franklin or by its suppliers and partners operating outside the UNITED STATES or within the Americas are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing, and any processing which is inconsistent with the purposes set out in this privacy policy.
Please find below the relevant transfer information:
- Franklin may transfer your payment information to payment processing companies within United States to process transactions
- Franklin may use third-party cookies and tracking tools (such as AdWords, Bing, Facebook, FireBase, and Google Analytics) to track information on how users use websites and products, such as website usage data and product usage data that may be sent to and stored on third-party servers located in United States. Such third-party cookies and tracking tools may send tracking data or analysis reports to Franklin for our above-mentioned purpose. Most third-party cookies and tracking tools process your data anonymously.
- Franklin may transfer your email address and other necessary information such as your name to email delivery service providers within United States to deliver emails to you
- Franklin may store personal data on Amazon servers leased within United States
- Franklin may transfer your relevant personal information to marketing platforms and service providers outside the United States to complete relevant services
- Franklin may transfer your relevant personal information to fraud monitoring and prevention providers outside the United States to complete relevant services.
2.1.7 Duration of the storage
Franklin will store the collected personal data for the duration necessary for the fulfillment of our contractual or legal obligations and permitted by applicable legislation. Beyond this duration, we will delete your data under applicable legislation. For Franklin to be able to demonstrate the existence of a right, a contract, or a legal obligation, the relevant personal data will be stored through intermediary archives for a duration that will not exceed what is strictly necessary regarding the purpose of the storage and under applicable legislation.
2.2 Processing of personal data related to comment areas
When the User decides to comment on a Franklin product through the websites or the Applications, Franklin implements the processing of personal data as follows:
2.2.1 Personal data we collect only if you submit it to us
Regarding this process, Franklin collects the following personal data:
- Email address
- Name or nickname
- profile photo
- Other potential personal information provided by the user through their comments (age, location, etc.)
- The content of your comment
2.2.2 Purpose and legal basis of the processing
This process is implemented by Franklin to improve its products and provide the consumers and potential consumers with better and transparent information about the Franklin products. Said comments and related personal data are provided by the user voluntarily so that the processing of the collected personal data relies on the user’s consent.
Franklin may use the comments (with your relevant information) you post for marketing purposes for others to better understand and use our products.
2.2.3 Recipients of personal data
We treat your data with care and confidentiality and will only pass it on to third parties to the extent described below and not beyond. We do not share, sell, rent, or trade personal data with third parties for any promotional purposes.
Service Providers: We may share your personal information with companies that help us to run our business by processing personal information on our behalf for the purposes identified above. These companies include email delivery service providers that can help us deliver emails to you, server companies we hire to provide services to you, social media, third-party online forums, and other marketing platforms and service providers.
2.2.4 Transfer of personal data
The collected personal data is transferred by Franklin to recipients who are located outside the United States and such destinations may not have laws that protect the user’s data to the same extent as in the United States.
Franklin ensures that the user’s data processed by Franklin or by its suppliers and partners operating outside the United States are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing, and any processing which is inconsistent with the purposes set out in this privacy policy.
Please find below the relevant transfer information:
- Franklin may transfer your email address and other necessary information such as your name to third-party email delivery service providers outside the United States to deliver emails to you
- Franklin may store your comments on the servers leased from server service providers
- Franklin may also transfer personal data related to your comments to social media, third-party online forums, other marketing platforms, and service providers outside the United States to complete relevant services.
2.2.5 Duration of the storage
Franklin will store the collected personal data for the duration necessary for the fulfillment of our contractual or legal obligations and permitted by applicable legislation. Beyond this duration, we will delete your data under applicable legislation.
2.3 Processing of personal data related to newsletters and advertising emails
Users may want to subscribe to Franklin’s newsletters to be provided with information and news regarding Franklin news and products. In this case, Franklin implements the processing of personal data as follows:
2.3.1 Personal data collected
Regarding this process, Franklin only collects your provided information such as the User’s email address, name or nickname, country, preferred product, and your operation to the promotional emails.
2.3.2 Purpose and legal basis of the processing
Franklin implements the processing of personal data to provide consumers and potential consumers with information and news regarding Franklin products.
The subscription to Franklin’s newsletters and the related provision of personal data is made voluntarily so that the processing of the collected personal data relies on the User’s consent.
2.3.3 Recipients of personal data
We treat your data with care and confidentiality and will only pass it on to third parties to the extent described below and not beyond. We do not share, sell, rent, or trade personal data with third parties for any promotional purposes.
- Service Providers: We may share your personal information with companies that help us run our business by processing personal information on our behalf for the purposes identified above. These companies include email delivery service providers that can help us deliver promotional emails to you, server companies we hire to provide service to you, and the parties providing our third-party cookies and tracking tools.
2.3.4 Transfer of personal data
The collected personal data is transferred by Franklin to recipients who are located outside the United States and such destinations may not have laws that protect the user’s data to the same extent as in the United States.
Franklin ensures that the user’s data processed by Franklin or by its suppliers and partners operating outside the United States are treated securely and are protected against unauthorized access, loss, destruction, unlawful processing, and any processing which is inconsistent with the purposes set out in this privacy policy.
Please find below the relevant transfer information:
- Franklin may transfer your email address and other necessary information such as your name to email delivery service providers outside the UNITED STATES to deliver newsletters and promotional emails to you;
- Franklin may store personal data on Amazon servers leased from server service provider Amazon;
- Franklin may use third-party cookies and track tools (such as Google Analytics) to track the information on the User’s operation to the advertising emails, such data will be sent to and stored in third-party servers outside the United States.
2.3.5 Duration of the storage
Franklin will store the collected personal data for the duration necessary for the fulfillment of our contractual or legal obligations and permitted by applicable legislation. Beyond this duration, we will delete the personal data according to applicable legislation.
2.4 Cookies and tracking tools
Franklin implements several industry-standard information-tracking tools to collect information about your use of our Websites and Applications. When the user consults the Websites and/or the Applications, Franklin implements cookies on the user’s device. The third-party tracking tools are listed as a blow, but it doesn’t necessarily mean each of our Websites or Products uses all the tracking tools listed below.
|
No. |
Name and link of third-party tracking tools |
Data collected by tracking tools |
Purpose of data collection |
Used on Website or product |
|
1 |
FireBase |
local device data |
better understand how the products work and crash and make improvements. |
product |
|
product usage data |
||||
|
2 |
Google Analytics |
Website usage data |
better understand how the Website and product work, and make improvements |
Website |
For additional information on cookies and tracking tools, please read Franklin’s cookies policy
- User’s Rights
To the extent required by the law of your jurisdiction, you may have the below rights. Before you exercise the below rights, you may consult your legal counsel if the laws of your jurisdiction stipulate the below rights. Residents in the UNITED STATES have the below rights.
|
Rights |
Content |
|
The right to be informed |
The User has the right to be provided with clear, transparent and easily understandable information about how Franklin collects and uses Personal Data and its rights. This is the reason why Franklin is providing the User with the information in this privacy policy. |
|
The right of access |
The User has the right to obtain access to its Personal Data (if Franklin is processing it), and other certain information (similar to that provided in this privacy policy). |
|
The right to rectification |
The User is entitled to have its Personal Data corrected if it’s inaccurate or incomplete. |
|
The right to erasure |
This ‘the right to be forgotten’ enables the User to request the deletion or removal of its Personal Data where there’s no compelling reason for Franklin to keep using it. This is not a general right to erasure; there are exceptions. |
|
The right to restrict processing |
Under certain circumstances, the User has the rights to ‘block’ or suppress further use of its Personal Data. |
|
The right to data portability |
The User has the rights to receive its Personal Data provided to Franklin in a structured, commonly used and machine readable format and has the right to transmit those data to another controller. |
|
The right to object to processing |
The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its Personal Data. |
|
The right to lodge a complaint |
The User has the right to lodge a complaint about the way Franklin handles or processes its Personal Data with its national supervisory authority (in France, the CNIL). |
|
The right to withdraw consent |
If the user has given its consent for a specific processing of its Personal Data implemented by Franklin, the User has the right to withdraw its consent at any time. In case the User does so, it does not mean that anything Franklin has done with the User’s Personal Data with its consent up to that point is unlawful). |
|
The right to define instructions |
The User has the right to define general or specific instructions regarding storage, deletion and use of its Personal Data after death. |
However, to register with Franklin, create a Franklin account, and use some Franklin websites, products, or services, the provision of some information such as the email address is mandatory!
If relevant information is not provided, then we will not be able to administer a Franklin account to you or provide you with the Websites, products or services requested. All other provision of your information is optional. Providing optional information will help us offer you a better experience, such as more personalized or tailored content or offerings.
- Collecting Information from Children
If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
- Revision of this Privacy Policy
Occasionally, we may change this privacy policy (or other documents related to privacy policy) to allow Franklin to use or share your data differently. If we do, the links to the policy on our Websites (which are generally found in the footer of the Websites) will indicate that the policy has been changed. For new Users, the change will become effective upon posting. For existing Users, if the change is significant, it will become effective 30 days after posting. We encourage you to periodically review the privacy policy for the latest information on our privacy practices.
- Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
- Apple
- Microsoft
If You decide to register through or otherwise grant us access to a Third-Party Service, We may collect Personal data that is already associated with Your Third-Party Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
- Google Analytics
We at Franklin use Google Analytics to collect data. We need this data to understand how you use our website so we can improve its design and functionality. We also need the data to get the most out of our marketing campaigns.
With your consent, Google Analytics will process and collect your personal data (cookies and IP address) to give us valuable information. Google Analytics will transfer your data to the United States and store it for 6 months. To learn more about Google’s data transfer policies, click here.
Standard contractual clauses are legal clauses written by the United Statesropean Commission. They are part of a contract between Google Ireland Ltd. and Google LLC, and Google LLC must follow them. Standard contractual clauses tell Google LLC what it can and cannot do with your data.
- Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
- Contact Franklin
If the User needs to contact Franklin for any reason (including to exercise any of its rights about data protection as set out above) please contact cs@franklinwireless.com
Franklin will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case Franklin may charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested), or refuse to act on the request.