Privacy Policy
Last updated: March 08, 2024
Effective date: March 8, 2024
Hangzhou Tuya Information Technology Co., Ltd. and its affiliates (hereinafter collectively referred to as "we" or "Tuya") are committed to protecting your personal privacy.
The Tuya Light Privacy Policy (hereinafter referred to as "this Policy") applies to the products and/or services provided by the Tuya platform, including the Tuya Light application (mobile client) (collectively referred to as "Services"). When you use our services, we will collect and process your relevant information, so please read this Policy carefully and make sure you understand our rules for collecting and processing your personal information (including how to collect, use, store, and share such information), as well as how to access, update, delete and protect this information for you.
When you agree to this Privacy Policy, or start or continue to use our products or services in an appropriate manner, and do not contact us to express contrary opinions in an appropriate manner, we will regard you as fully understanding and agreeing to this Policy. During the reading process, if you have any questions, comments, suggestions or complaints, especially if you believe that our personal information processing behavior has damaged your legal rights and interests, you can complain/suggest our services through appropriate regulatory channels, or contact us through the following contact information:
Customer Service: support@issmartlz.me
Privacy Office: support@issmartlz.me
If you are a minor under the age of 18, please read this agreement in the presence of your legal guardian or parent. At the same time, if you are a child under the age of 14, please be sure to read the "Tuya Light Children's Privacy Protection Statement" and ensure that you and your guardian or parent clearly understand the relevant information on children's privacy protection. This policy mainly explains to you:
1. What personal information do we collect
2. Definition of Purpose and Legal Basis for Processing Personal Information
3. With whom we share your personal information
4. Transfer of Collected Information
5. Rights related to personal information
6. Information security measures
7. Information Retention Period
8. Protection of Children’s Personal Information
9. Statement on Policy Changes
10. Contact Us
definition
In this policy,
Affiliated companies: companies directly or indirectly controlled by Tuya; or directly or indirectly controlling Tuya; or jointly controlling the same company as Tuya; or companies directly or indirectly controlled by the same company as Tuya, including but not limited to parent companies and subsidiaries; subsidiaries controlled by the same parent company as Tuya, etc.
Personal information : any information recorded electronically or otherwise that can be used alone or in combination with other information to identify an individual or reflect the activities of a specific individual.
Personal sensitive information : including personal biometric information, communication records and content, health information, transaction information, precise location information, etc. When we provide you with specific products or services that involve the collection of personal sensitive information, we will obtain your consent through prominent and clear notifications before collecting your personal sensitive information.
Smart device : refers to a non-standard computing device produced or manufactured by a hardware manufacturer, with a human-computer interface and capable of transmitting information via a wireless network, including smart home appliances, smart wearable devices, smart air purification equipment, etc.
Application : refers to the mobile application developed by Tuya (including Tuya mobile client) that can help end users remotely control smart devices and connect to the Tuya Internet of Things (IoT) platform.
1. What personal information do we collect?
In order to provide you with our services, we will ask you to provide the personal information necessary for such services. If you do not provide your personal information, we will not be able to provide you with the corresponding products or services.
1. Information you voluntarily provide to us
Registration account information : When you register an account with us, we collect your account name and contact information, including your email address, phone number, username , and login credentials . During your interaction with our products, we further collect nicknames, country codes, language preferences, or time zone information in your account.
When you choose to authorize the use of a third-party account to log in, we will obtain your shared account information (default system avatar, nickname, and region information) from the third party and bind it to your Tuya account for quick login. We will use your personal information in accordance with the agreement with the third party and the terms regarding sharing of personal information in the privacy policy published by the third party, subject to compliance with relevant laws and regulations.
However, if the services you use or purchase are based on your account information, please go to the registration/login page to register or log in.
User feedback : When you use our services and submit service-related feedback and suggestions to us, we will collect your email address, mobile phone number, feedback content (added pictures or videos), and submitted problem logs. This information will be used to help us handle your application problems and smart device-related failures in a timely manner.
At the same time, depending on different application products and services, Tuya will collect corresponding and necessary personal information in order to provide you with products and services.
Information collected based on the additional functions provided
In order to provide you with more convenient and better products and/or services and strive to improve your experience, we will collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of the basic services of the Tuya Light application, but you will not be able to obtain the user experience brought to you by these additional services. These additional services include:
Additional services based on location information :
When you enable the positioning function of your mobile device through system authorization and use location-based services, we will collect and use your location information so that you can use Tuya Smart App to pair with smart devices. And when you use our specific products or services (such as weather services), based on your consent , we will collect real-time precise or non-precise geolocation information about you. When you use the geo-fencing function and create a scene to generate a location change, we will apply for background location permission to locate the user's location to complete the user's pre-screening automation capabilities. You can turn off the positioning service in the system of your mobile device to stop us from collecting your location information. Reasons for obtaining positioning permissions in [Add Device] (Android system only): Enter the Add Device function, based on the function of searching for nearby devices, Bluetooth scanning is required. If you want to use the Bluetooth function in the application, you must declare two permissions. The first is the Bluetooth permission. You need this permission to perform any Bluetooth communication. The second permission that must be declared is the positioning permission. Because Bluetooth scanning can be used to collect user location information. Bluetooth needs to apply for positioning, otherwise it will affect the user's device addition.
Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Access Geolocation] permission
Additional services based on camera:
After turning on the camera/camera permission, you can use this function to scan the code to add the device you purchased and shoot video. Please be aware that even if you have agreed to turn on the camera/camera permission, we will only obtain information when you actively scan the code or use the camera/camera to shoot.
Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Access to Camera Permission]
Additional services for photo/video access and upload based on photo albums (photo/video libraries):
After enabling the photo album permission, you can use this function to upload your photos/pictures/videos to provide proof of reporting device usage issues. When you report device usage issues, we will locate your problem through the photos/pictures you uploaded.
Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Access to Photos]
Additional services related to microphone-based voice technology:
After enabling microphone permissions, you can use the microphone to implement voice functions, including shooting videos and waking up the voice assistant. In these functions, we will collect your voice information to identify your command needs. Please be aware that even if you have agreed to enable microphone permissions, we will only obtain voice information through the microphone when you actively click the microphone icon in the App or record a video.
Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Access to Microphone Permissions]
Additional services based on Bluetooth technology:
After turning on Bluetooth permissions, you can use Bluetooth functions, including device control, device status acquisition, device discovery, and device network configuration. In these functions, we will communicate with terminal devices via Bluetooth. Please be aware that even if you have agreed to turn on Bluetooth permissions, we will only use Bluetooth for communication in the following scenarios: display device status on the home page and device panel; control devices on the home page and device panel; discover devices and configure devices on the home page and add device page.
Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Bluetooth Permissions]
You understand and agree that the above additional services require you to enable access to your location information (geolocation) , camera, photo album, microphone (voice) in your device to enable the collection and use of information involved in these permissions. You can view the status of the above permissions item by item in your device settings and decide whether to enable or disable these permissions .
Please note that if you enable any permission, it means that you authorize us to collect and use relevant personal information to provide you with the corresponding services. If you disable any permission, it means that you cancel the authorization. We will no longer continue to collect and use relevant personal information based on the corresponding permission, and we will not be able to provide you with the services corresponding to the permission. However, your decision to disable the permission will not affect the collection and use of information based on your authorization.
2. Information We Collect Automatically
· Mobile device information : When you interact with our products, we will automatically collect mobile device information, including mobile device model, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files and mobile network information, to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience and protect the security of your account. At the same time, we will collect your software version number. To ensure the security of the operating environment or to provide services, we will collect information about the mobile applications and other software you use and the application installation list of the application (for the purpose of performance monitoring of the application).
Usage Information : During your interactions with our Website and Services, we automatically collect usage information related to visits, clicks, downloads, messages sent/received, and other uses of our Website and Services.
Log information : When you use our applications, in order to improve your user experience, system and exception logs will be uploaded for analysis, including your IP address, language you use, operating system version, date or time of access, so that we can accurately identify problems and help you solve problems in the process of using the service.
Please note that separate mobile device information and service log information cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be considered personal information during the combined use period. We will anonymize and de-identify such information unless you authorize us or otherwise required by laws and regulations.
3. Information about smart devices
When you use a smart device, in order to ensure its proper functioning, support your normal use, and improve and optimize the service experience of the device, we automatically collect certain information that is inherent to the device as well as information generated during your use of it.
• Basic Information of Smart Devices:
When you use a smart device that is connected to our products or services, we collect basic information about the device, including the device name, device ID, online status, activation time, firmware version, upgrade information, MAC address, Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, and Wi-Fi password), device MAC address, device ID, device IP address, Bluetooth MAC address, and information reported by the smart device.
II. Purpose and legal basis for processing personal information
We process your information for the following purposes:
Providing you with services: We process your account information, mobile device information, usage information, location information, and smart device-related information to provide the products and services you request. The legal basis for such processing is to perform our contract with you in accordance with our Tuya Light User Agreement . Improve our services: We process your mobile device information, usage information, location information, and smart device related information to ensure the functionality and security of our products, develop and improve our products and services, analyze our operational efficiency, and prevent and track fraud or improper use. The legal basis for such processing is to perform our contract with you in accordance with our User Agreement.
Non-marketing communications: We process your personal information to send you important information related to services, terms/conditions and policy changes and/or other management information. At the same time, we will also send you notifications related to the services you purchased, including alarm services. You can check the [Message Push] in the Tuya Light App ([My] - [Settings] - [APP Message Notification]) to manage whether you require to receive such message communications. When you choose to turn off push notifications, we will no longer continue to push such information to you.
The legal basis for this processing is the performance of our contract with you under our User Agreement.
Compliance: We only process your personal information when we are required to disclose it by law or when we deem it necessary or appropriate to:
Comply with applicable laws, regulations, legal process or requests from public and governmental authorities;
Enforce our Terms of Use and other agreements, policies or standards, including investigating any potential violations;
To protect our rights, privacy, safety or property and/or those of other users, including you; and to pursue available detection, prevention, remedy or limitation of damages that we may be required to provide or to address security, fraud or technical issues.
We also use your personal information in other ways for which we provide specific notice at the time of collection and obtain your consent as required by applicable law. If the purpose of processing your personal information changes, we will notify you of such changes by email and/or a prominent notice on our website and inform you of your choices regarding your personal information.
3. With whom do we share your personal information?
Tuya only shares your personal information in a way that you know about. We will share your personal information with the following participants:
Disclose your personal information to third-party service providers who provide certain business-related services to us, including website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support services, email delivery services, and other similar services to enable them to provide their services to us.
Disclose your personal information to our customers and other business partners who directly or indirectly provide you with the Smart Devices and/or the networks and systems you use to access and use our Websites and Services.
To affiliates or other third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including, without limitation, in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or our website of any change in ownership, incompatible new uses of your personal information, and choices you may have regarding your personal information.
Disclose your personal information to our subsidiaries or affiliates to carry out regular business activities.
We will share your personal information reasonably and legally in the following necessary or appropriate circumstances:
Comply with applicable laws, regulations, legal processes, policies and/or standards, or requests from relevant public and governmental authorities;
Enforce our Terms of Use and other agreements, policies and standards, including investigating any potential violations;
Protect our operations, business and systems;
protect our rights, privacy, safety or property and/or the rights, privacy, safety or property of other users including you; and
Risk management, detection and identification of illegal, fraudulent, deceptive or malicious activity.
In addition to the third parties mentioned above, we will disclose your personal information to other third parties only with your consent.
When you use services provided by a third party, we will share the corresponding information after ensuring that the third party has obtained your authorization and consent, and in other circumstances that comply with laws and regulations. You can learn how the third party will handle your personal information through the relevant information listed in this list. We will also strictly restrict the third party's access to personal information to protect the security of your personal information. Please click here to view details of third-party information sharing In addition, to ensure the stable operation of Tuya applications or to achieve related independent functions, we will embed third-party SDKs in the application. Please note that the third-party SDK may change the type of personal information it processes due to version upgrades, policy adjustments, etc. Please refer to its official instructions. Please click here to view details of third-party information sharing IV. Transfer of Collected Information
Tuya operates globally, so the personal information we collect in accordance with this policy may be transferred, stored and processed between different countries or regions. The laws and regulations applicable to the countries or regions where we operate may differ from those applicable in your country/region of residence, but we will strictly comply with the laws and regulations and requirements related to personal information protection (please click to view Tuya's global data center and storage). Therefore, within the framework of personal information protection, in order to facilitate our operations, we may transfer personal information to the countries or regions where we conduct business. Regardless of where your information is stored, our privacy and security practices are designed to provide global protection for your personal information. Including, the European Commission has determined that certain countries outside the European Economic Area (EEA), the United Kingdom or Switzerland have mechanisms to adequately protect personal information. When personal information of users in the European Economic Area, Switzerland or the United Kingdom is transferred to recipients located in countries outside the European Economic Area, Switzerland or the United Kingdom that have not been deemed to have an adequate level of data protection, we ensure that the information is transferred in accordance with the "EU Standard Contractual Clauses". You can click here to view the agreement reached under the "EU Standard Contractual Clauses" approved pursuant to Article 46 of the GDPR.
In particular, we store and process personal information collected and generated during our operations in mainland China in data centers in mainland China, except for cross-border transfers permitted under applicable laws.
If you would like to learn more about our security measures, you can contact us directly through this policy.
V. Rights Related to Personal Information
We respect your rights and will also handle your personal information. You can exercise any of the following rights:
Please send an email to support@issmartlz.me
You can exercise your personal rights without paying any fees. According to the relevant requirements of local data protection laws, if your account service is in mainland China, we will complete the verification and processing of your needs within 15 working days; if your account service scope is outside mainland China, we will respond to your needs within 30 days.
If you decide to send us a request via email, please specify what information you would like changed, whether you would like your personal information to be deleted from our database, or what limitations you would like us to have on our use of your personal information. Please note that for security reasons, we will ask you to verify your identity before we proceed with your request.
You can exercise your rights related to your personal information through the following channels:
·Request access to the personal information we process about you (i.e. obtain a copy of your personal information): [My] - [Settings] - [Privacy Policy Management] - [Personal Information Query and Export];
· Request us to correct inaccurate or incomplete personal information about you: 1) Modify your "Nickname": [My] - [Personal Information];
·Request to delete your personal information: [My] - [Personal Information] - [Account and Security] - [Deregister Account]. You can delete your personal information according to the prompts;
· Request temporary or permanent restriction on our processing of some or all of your personal information: Please delete your account through [My] - [Personal Information] - [Account and Security] in the application;
Request that we transfer your personal information to you or a third party when we process your information based on your consent or a contract with you, and when we process your information automatically: submit your request at support@issmartlz.me;
If you choose to object or refuse our use of your personal information when we use your personal information based on your consent or our legitimate interests, please refer to the following "Withdrawal of Consent":
Withdrawal of consent: We will safeguard your right to withdraw your consent in the following ways:
1) As mentioned above, you can change the device permissions obtained through the device system settings through [My] - [Settings] - [Privacy Settings] in the application to withdraw your consent, including location, camera/camera, album (photo gallery/video gallery), microphone, Bluetooth settings and other related functions;
2) For non-marketing communications that you agree to, you can turn off your choice through [My] - [Settings] - [APP Message Notification]
2) Unbind your smart device through the app, and your smart device usage information will not be collected;
3) If you have previously voluntarily agreed to associate your Tuya account with a third-party service, such as a third-party platform, please unbind it on the third-party platform.
When you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the part of your authorization that you have withdrawn. However, your withdrawal of consent or authorization does not affect the withdrawal of the personal information processing that was previously carried out based on your consent.
• About deleting/cancelling your account to delete your personal information : You can delete/cancel your account through the following path: [My] - [Personal Information] - [Account and Security] - [Cancel Account].
VI. Information Security Measures
We take commercially reasonable physical, management and technical safeguards to maintain the integrity and security of your personal information. Tuya provides a variety of security strategies to effectively ensure the information security of users and devices.
In terms of device access, we use Tuya's proprietary algorithms to ensure data isolation, access authentication and authorization application.
In terms of data communication, it supports the use of security algorithms and transmission encryption protocols as well as commercial-grade information encryption transmission based on dynamic keys.
In terms of data processing, strict data filtering and verification as well as a complete data review process are adopted.
In terms of data storage, all confidential information of users will be securely encrypted for storage.
In addition to the above-mentioned technical security guarantees, Tuya has also formulated a series of security guarantees at the institutional and management levels, including assigning specific positions and responsibilities, organizing security and privacy protection training courses, strengthening employees' awareness of data protection, controlling access rights and other measures to prevent data loss, illegal use, unauthorized access or leakage, tampering or damage.
If for any reason you believe that your interaction with us is no longer secure (for example, if you believe that the security of your Tuya account has been compromised), please notify us immediately by sending an email to support@issmartlz.me as described below.
If a security incident occurs that affects the security of your personal information, we will immediately notify you through the email address, phone number, message center push, etc. you have reserved, and inform you of suggestions for reducing or preventing related risks. If necessary, we will take appropriate remedial measures in a timely manner in accordance with the internal security incident emergency plan, and report to the relevant competent authorities in accordance with regulations.
We have obtained Enterprise Privacy Certification. For more information about EPC, please click here . VII. Information Retention Period
We will process your personal information for the shortest period necessary to achieve the purposes described in this policy or as required by laws and regulations, unless it is required to be retained for a longer period of time in accordance with specific legal requirements. We will determine the appropriate retention period based on the amount, nature and sensitivity of your personal information, and we will destroy your personal information after the retention period ends.
2) When you explicitly request to delete your personal information, we will set this as a task and will no longer retain your personal information.
When we confirm that the purpose of collecting and processing personal information has been fulfilled based on 1), or after we confirm your deletion or cancellation application based on 2), or after we terminate the operation of the corresponding products or services, we will stop retaining and delete your personal information. Generally, we will no longer retain your personal information once the prescribed information retention period is reached. If we are unable to destroy the information for technical reasons, resulting in the retention of personal information exceeding the storage period, we will take appropriate measures to prevent your personal information from being further used, including anonymization.
8. Protection of Children’s Personal Information
Tuya attaches great importance to the protection of children's personal information. If you are under 14 years old (or the prescribed age in your country/region), you must carefully read the "Tuya Light Children's Privacy Protection Statement" and obtain the written consent of your parents or legal guardians before using our services. Tuya protects children's personal information in accordance with the relevant laws and regulations of each region, country or region. Please note that if we find that we have collected children's personal information without the prior consent of verifiable parents or legal guardians, we will try to delete the relevant personal information as soon as possible. IX. Statement on Policy Changes
We will update this Policy at least once a year as our information practices change. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by posting a notice on this App prior to the change becoming effective. We encourage you to review this App periodically for the latest information on our privacy practices.
10. Contact Us
If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us through the methods provided below and specify "Privacy Policy". We have a professional privacy and security team to solve your problems when you request rights and inquire about issues related to personal information. If your question itself involves a more serious matter, we may ask you to provide more information to confirm the nature and impact of the matter. If you are not satisfied with the response you receive, you can transfer the complaint to the appropriate regulatory agency. When you consult us, we will provide information on relevant complaint channels that may be used based on your actual situation.
Contact information and address:
Hangzhou Tuya Information Technology Co., Ltd.
Mailing address: 3rd Floor, 7th-12th Floors, Building A, Huace Center, Wuchanggang Road, Xihu District, Hangzhou City, Zhejiang Province
Email: Privacy Office support@issmartlz.me