Privacy Policy

Effective Date: Dec 12, 2024

Updated: Jan 6, 2025

Premium Levella subsidiaries (“we”, “us”, “our”, “PremiumLevella”) are committed to protecting your privacy. This Privacy Policy(“Policy”) describes our practices in connection with information privacy onPersonal Data we process through your individual use of the following services,products, and related mobile applications (collectively, the “Products”):

- Premium Levella Mobile Application

Before you use our Products, please carefully read through thisPolicy and understand our purposes and practices of collection, processing ofyour Personal Data, including how we use, store, share and transfer PersonalData. In the Policy you will also find ways to execute your rights of access,update, delete or protect your Personal Data.

When you accept this Policy when you register with your PersonalData, or if you start to use our Products and does not expressly object to thecontents of this Policy, we will consider that you fully understand and agreewith this Policy. If you have any question r regarding this Policy, please donot hesitate to contact us via email to contact@premiumlevella.com.

For other branded mobile applications powered by Premium Levella,our Clients control all the Personal Data collected through our Products. Wecollect the information under the direction of our Clients and the processingof such information shall be limited to the purpose of providing the servicefor which our Clients has engaged us. If you are a customer of one of ourClients and would no longer like to be contacted by one of our Clients that useour service, please contact the Client that you interact with directly.

Definition

In this Policy, Personal Data means information generated,collected, recorded and/or stored, electronically or otherwise, that can beused to identify an individual or reflect the activity of an individual, eitherfrom that information alone, or from that information and other information wehave access to about that individual.

Personal Sensitive Data includes personal biometric information,communication records and contents, health information, transactioninformation, and precise location information. When we collect PersonalSensitive Data from you, we will generate an explicit notification for yourconsent before we collection personal sensitive data about you.

Smart Devices refers to those computing devices produced ormanufactured by hardware manufacturers, with human-machine interface and theability to transmit data that connect wirelessly to a network, including: smarthome appliances, smart wearable devices, smart air cleaning devices, etc.

Apps refers to those mobile applications developed by PremiumLevella that provide end users remote control to Smart Devices and with theability to connect to the supplier IoT Platform.

What Personal Data do we collect

In order to provide our services to you, we will ask you toprovide necessary Personal Data that is required to provide those services. Ifyou do not provide your Personal Data, we may not be able to provide you withour products or services.

1.Information You Voluntarily Provide Us

· Registered Account Data: When you register an accountwith us, we may collect your name and contact details, such as your emailaddress, phone number, user name, and login credentials. During yourinteraction with our Products, we may further collect your nickname, profilepicture, country code, language preference or time zone information into youraccount.

If youauthorize login to the Products with a third-party account, we will obtain fromsuch third party your account information (such as portrait, nickname, region,gender, etc.) which may be bound with your Premium Levella account forquick login. We will ensure compliance with applicable data protection laws andregulations, as well as agreements, policies or documentations agreed with suchthird-party regarding sharing personal information, in processing your PersonalData.

· Non-registered Account: If you do not want to provideyour account data when you start to use any of the Services, you may use theApp without logging in or creating an account, namely the “Try Now” mode, andyou may still use certain Services, such as searching and browsing any featureson the App by creating a guest ID. When you are using the "Try Now"mode, we will not collect Personal Data related to your account. Collection anduse of the Personal Data collected here will be limited to: the time ofentering the App, operating system of your mobile phone, and the purposes youhave authorized in using the additional functions of the App and/or the SmartDevices. For instance, if you enable the location setting in the "TryNow" mode, the location data will be uploaded for supporting the function.Once you exit from the "Try Now" mode, we will remove your datainstantly and permanently.

However,if the Services you request or purchase are based on your account, please go tothe registration/login page for guidance.

· Feedback: When using feedback andsuggestion features in our Products, we will collect your email address, mobilephone number and your feedback content to address your problems and solvedevice failures on a timely basis.

Information based on additional functions:

In order to offer you with more convenient and higher-qualityServices with optimized user experiences, we may collect and use certaininformation if you consent to use additional functions in the App. Please note,if you do not provide such information, you may continue to use basic Servicesof the App and connected Smart Devices, but certain features based on theseadditional functions may not be available. These additional functions mayinclude:

1)Additionalfunctions based on location information:

When you enable the location-based functions through permissionsettings on your mobile device, we will collect and process your locationinformation to enable these functions, such as pairing with your Smart Devices.Also, we may collect information about your: a) real-time and precise location,for instance when you choose to use the automation scenarios for controllingyour Smart Devices, or b) non-precise geo-location when you use certain SmartDevices or the Services, such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature,your location information will be generated and shared with Google Mapsservices. Please note that Google has corresponding data protection measures,which you may refer to Google’s Data Processing and Security Terms for moredetails.

You may disable the collection and use of your locationinformation by changing your mobile device settings ("My - Setting - Privacy Right Setting - Switch on/off LocationInformation"), upon which we will cease to collect and use yourlocation information.

2)Additionalservices based on camera:

You may use the camera to scan the code by turning on the camerapermission to pair with a Smart Device, take video, etc. Please be aware thateven if you have agreed to enable the camera permission, we will only obtaininformation when you actively use the camera for scanning codes, videorecording, etc.

You may opt-out the using of camera permission: "My - Setting - Privacy Right Setting - Switchon/off Camera".

3)Additionalservices for accessing and uploading pictures/videos based on photo albums(picture library/video library):

You can use this function to upload your photos/pictures/videosafter turning on the photo album permission, so as to realize functions such aschanging the avatar, reporting device usage problems by providing photo proofs,etc.. When you use the photos and other functions, we will not recognize thisinformation; but when you report a device usage problem, we may use thephotos/pictures you upload to locate your problem.

You may opt-out the using of photo album permission: "My - Setting - Privacy Right Setting - Switchon/off Photo Album".

4)Additionalservices related to microphone-based service:

You can use the microphone to send voice information afterturning on the microphone permission, such as shooting videos, waking up thevoice assistant, etc. For these functions, we will collect your voiceinformation to recognize your command. Please be aware that even if you haveagreed to enable the microphone permission, we will only obtain voiceinformation through the microphone when you voluntarily activate the microphonein the App.

You may opt-out the using of microphone permission: "My - Setting - Privacy Right Setting - Switchon/off Microphone".

5)Additionalservices based on storage permission (Android):

The purpose is to ensure the stable operation of the App byutilizing the storage permission. After you give or indicate the permission toread/write your mobile device’s storage, we will access pictures, files, crashlog information and other necessary information from your mobile device’sstorage to provide you with functions, such as information publications, orrecord the crash log information locally.

You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switchon/off Storage".

6)Additionalservices based on Notification permission:

The reason why we ask you for the permission is to send younotifications about using the Smart Devices or Services, especially if you havepurchased security services and you require an alert or message so that you cancapture the real-time status.

You may opt-out the using of App notifications: "My - Message Center - Setting - Switch on/offNotifications".

7)Additional services based on Alert Window permission：

You may choose to bind a camera in the App and require the Appto display the real-time image of the camera in a separate window.

You may opt-out the using of alert window information: "My - Setting - Privacy Right Setting - Switchon/off Alert Window".

8)Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning on the permission,including controlling the Smart Devices, acquiring status of, discovering andconfiguring Smart Devices. In these functions, we will communicate with SmartDevices via Bluetooth. Please be aware that even if you have agreed to enablethe Bluetooth permission, we will only use Bluetooth for communication in thesescenarios: display device status on the home page and Smart Device panel;perform device control on the home page and Smart Device panel; discoveringSmart Devices on the home page and the add device page, Smart Devicedistribution network.

You may opt-out the using of Bluetooth via "My - Settings - Privacy Setting -Disable/Enable Bluetooth permission".

9）Additional services based on HomeKit permission (iOS):

You can enable related functions after enabling HomeKitpermissions, including discovering Smart Devices, enabling Smart Device networkconfiguration, controlling Smart Devices, and checking device status. Amongthese functions, we will process data with the "Home“ App that comes withthe iOS system through HomeKit. Please be aware that even if you have agreed toenable the HomeKit permission, we will only use it in these scenarios: on thehome page, to discover HomeKit devices, HomeKit device network configuration;in "Settings - HomeKit" for discovering HomeKit devices, HomeKitdevice network configuration.

You may opt-out the using of HomeKit permission via "My - Settings - Privacy Settings-Turn off/onHomeKit permission".

10）Additional services based on HealthKit (iOS):

You can proactively enable related functions after enablingHealthKit permission, including statistics on weight, height, running, andswimming. In these functions, we will exchange data with the health-relatedfunctionalities that comes with the iOS system through HealthKit. Please beaware that even if you have agreed to enable HealthKit permission, we will onlyuse them in these scenarios: when you use the health-related Smart Device, suchas body fat scales, bracelets, watch and consent to use the HealthKit, the datareported by the Smart Device will be transferred to HealthKit.

You may opt-out the using of HealthKit permission via "My - Settings - Privacy Settings - Turn off/onHealthKit permission".

Please note that if you turn on any permission, you authorize usto collect and use relevant personal information to provide you withcorresponding Services. Once you turn off any permission, we will take it ascanceling the authorization, and we will no longer continue to collect PersonalData based on the corresponding permissions, and the related functions may beterminated. However, your decision to turn off the permission will not affectthe previous collection and use of information based on your authorization.

2.Information We Collect Automatically

· MobileDevice Information: When you interact with our Services, in order toprovide and maintain the normal operation of our Services, to improve andoptimize our Services, and to protect your account security as well, weautomatically collect mobile device information, such as mobile device modelnumber, IP address, wireless connection information, the type and version ofthe operating system, application version number, push notificationidentifier, log files, and mobile network information. Meanwhile, we willcollect your software version number. In order to ensure the security of theoperating environment or to provide services, we will collect information aboutthe installed mobile applications and other software you use.

· UsageData: During your interaction with our websites and Services, weautomatically collect usage data relating to visits, clicks, downloads,messages sent/received, and other usage of our websites and Services.

· LogInformation: When you use the App, in order to improve your user experience,the system and exception log may be uploaded, including your IP address,language preference setting, operating system version, date or time of access,so that we can facilitate and accurately identify problems and help you solvethem in timely manner.

Please note that we cannot identify a specific individualby using device information or log information alone. However, if these typesof non-personal information, combined with other information, may be used toidentify a specific individual, such information will be treated as PersonalData. Unless we have obtained your consent or unless otherwise provided by dataprotection laws and regulations, we will aggregate or desensitize such information.

3.Smart Devices Related Information:

· BasicInformation of Smart Devices: When you connect your SmartDevices with the Services, we may collect basic information about your SmartDevices such as device name, device ID, online status, activation time,firmware version, and upgrade information.

· Informationcollected during the process of connecting to a Smart Device: Basedon the type of Smart Device you need to connect, the basic informationcollected includes: Wi-Fi information, device MAC address, etc.

· InformationReported by Smart Devices: Depending on the different Smart Devices you electto connect with our Products or Services, we may collect different informationreported by your Smart Devices.

Pleasenote that when you actively agree to Premium Levella and the application isconnected to the Apple Health, we will share your measurement data with AppleHealth (including only your BMI, height, weight and body fat% data). Thepurpose of sharing data is only to measure and analyze health-relatedindicators related to you, and it will never be disclosed to other thirdparties. You can close at any time by managing the HealthKit settings page.

Purposes and legal basis for processing Personal Data

The purpose for which we may process information about you areas follows:

· ProvideYou with Our Services: We process your account data, mobile deviceinformation, usage data, location information, and Smart Device relatedinformation to provide you with the Services that you have requested. The legalbasis for this processing is to perform our contract with you according to user agreement.

· ImproveOur Services: We process your mobile device information, usage data, locationinformation and Smart Device related information to ensure the functions andsafety of the Services, to develop and improve the Services, to analyze theefficiency of our operations and to prevent and trace fraudulent orinappropriate usage. The legal basis for this processing is to perform ourcontract with you according to our useragreement.

· Non-marketingCommunication: We process your Personal Data to send you importantinformation regarding the Services, changes to our terms, conditions, andpolicies and/or other administrative information. At the same time, we willalso send you notifications related to the services you have purchased, such asalert services. You can check the “App Notification” in the App ("Me &rt; Message Center &rt; Setting &rt;Notification Setting”) to manage these communications. When you decidenot to enable the Notifications function, we will no longer process yourinformation for such purpose. The legal basis for this processing is to performour contract with you according to our useragreement.

· DataAnalysis: In order to analyze the usage of the products we provide andimprove your user experience, we will analyze the data you provide us, a) weneed to check your problems when you encounter any malfunctions during theusage of the product, under such circumstance, you may not able to opt-outbecause it is highly relate to your functionalities and quality of using ourproduct and service, and b) analyze data about how you interface with theproduct or under particular scenarios so that you can better enjoy theconvenience brought by our Services, under such circumstance, if you do notagree to data analysis of your data, you can enter the privacy settings of App (“My &rt; Settings &rt; Privacy Settings &rt; DataAnalysis”) to opt-out your selection. The legal basis for suchprocessing is based on your consent.

· MarketingCommunication and Personalization: We may process your account data,usage data, device information to personalize product design and to provide youwith services tailored for you, such as recommending and displaying informationand advertisements regarding products suited to you, and to invite you toparticipate in surveys relating to your use of the Services. If you do notallow us to process your Personal Data for personalization, you may opt outwhen you enter the App, or by changing your preferences in “Privacy Settings” (“Me&rt; Settings &rt; Privacy Settings &rt;Personalization”) in the App. The legal basis for this processing isyour consent.

· LegalCompliance. We disclose information if we are legally required to do so,or if we have a good faith belief that such use is reasonably necessary to:

· comply with a legal obligation, process or request;

· enforce our User Agreement and other agreements,policies, and standards, including investigation of any potential violationthereof;

· protect the rights, property or safety of us, ourusers, a third party or the public as required or permitted by law; or

· detect, prevent or otherwise address security, fraudor technical issues.

If there is any change in the purposes for processing yourpersonal data, we will inform such change to you via email and/or a prominent noticeon our website of such changes of purposes, and choices you may have regardingyour Personal Data.

Who do we Share Personal Data with?

At Premium Levella, we only share Personal Data in ways that wetell you about. We may share your Personal Data with the following recipients:

· To our third-party service providers who performcertain business-related functions for us, such as website hosting, dataanalysis, payment and credit card processing, infrastructure provision, ITservices, customer support service, e-mail delivery services, and other similarservices to enable them to provide services to us.

· To our customers and other business partners whoprovide you, directly or indirectly, with your Smart Devices, and/or networksand systems through which you access and use our websites and Services.

· To subsidiaries or affiliates within our corporatefamily for purpose of regular business activities based on our instructions andin compliance with applicable law, this Policy and other appropriateconfidentiality and security measures.

· To an affiliate or other third party in the event ofany reorganization, merger, sale, joint venture, assignment, transfer or otherdisposition of all or any portion of our business, assets or stock (includingwithout limitation in connection with any bankruptcy or similar proceedings).In such an event, you will be notified via email and/or a prominent notice onour website of any change in ownership, and choices you may have regarding yourPersonal Data.

· As we believe in good faith that access to, or use,preservation, or disclosure of the information is reasonably necessary orappropriate to:

(a)Complywith applicable law, regulation, legal process, or lawful governmental request;

(b)Enforceour User Agreement and other agreements, policies, and standards, includinginvestigation of any potential violation thereof;

(c)Protect our operation and business systems;

(d)Protectthe rights, property or safety of us, our users, a third party or the public asrequired or permitted by law; or

(e)Performrisk management, screening and checks for unlawful, fraudulent, deceptive ormalicious activities.

Except for the third parties mentioned above, we only discloseyour Personal Data to other third parties with your consent.

International Transfer of Information Collected

Premium Levella will comply with applicable data localizationrequirements in corresponding jurisdictions with respect to storage of data. Tofacilitate our operation, we may transfer, store and process your Personal Datain jurisdictions other than where you live. Laws in these countries may differfrom the laws applicable to your country of residence. When we do so, we willensure that an adequate level of protection is provided for the information byusing one or more of the following approaches:

· Agreement on the basis of approved EU standardcontractual clauses per GDPR Art. 46. For more information,see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

If you would like further detail on the safeguards we have inplace, you can contact us directly as described in this Privacy Policy.

Your Rights Relating to Your Personal Data

We respect your rights and control over your Personal Data.

You do not have to pay a fee and we will aim to respond youwithin 30 days. If you decide to email us, in your request, please make clearwhat information you would like to have changed, whether you would like to haveyour Personal Data deleted from our database or otherwise let us know whatlimitations you would like to put on our use of your Personal Data. Please notethat we may ask you to verify your identity before taking further action onyour request, for security purposes.

You may:

· Request access to the Personal Data that we processabout you: "My-Setting-Privacy Settings-Personal Data Export";

· Request that we correct inaccurate or incompletePersonal Data about you: 1) Modify your account number (email address or phonenumber): "My-Setting-Account andSecurity-Change your Account"; 2) Modify the nickname and/or timezone: "My-Personal Information";

· Request deletion of Personal Data about you: "My-Setting-Account and Security-DeleteAccount", when you confirm the deletion of your account, yourPersonal Data will be deleted accordingly.

· Request restrictions, temporarily or permanently, onour processing of some or all Personal Data about you: Please send over yourrequest through "My-FAQ &Feedback", or send over the email request to contact@premiumlevella.com

· Request transfer of Personal Data to you or a thirdparty where we process the data based on your consent or a contract with you,and where our processing is automated: Please send over your request through "My-FAQ & Feedback", or sendover the email request to contact@premiumlevella.com

· Opt-out or object to our use of Personal Data aboutyou where our use is based on your consent or our legitimate interests.

Withdrawal of consent Confirm the followingdetails: We will exercise your privacy right to withdraw consentthrough the following approaches:

1)For privacy permissions acquired through device systemsettings, your consent can be withdrawn by changing device permissions,including location, camera, photo album (picturelibrary/video library), microphone, Bluetooth settings, notification settingsand other related functions;

2)You may opt-out the non-marketing communication through “Me &rt; Message Center &rt; Notification Settings”to manage your selection;

3)You may opt-out the data analysis features through “Me &rt; Settings &rt; Privacy Settings”;

4)You may opt-out the Personalization feature through “Me &rt; Settings &rt; Privacy Settings &rt;Personalization”;

5)Unbind the Smart Device through the App, and the information relatedto the Smart Device will not be collected;

6)By using product with the "Try Now" mode, andnot enable certain location setting for particular smart scene, wewill not collect any Personal Data about you;

7)If you previously agreed to associate App account with athird-party service, such as a health platform, please unbind it on thethird-party platform.

When you withdraw your consent or authorization, we may not beable to continue to provide you with certain products or servicescorrespondingly. However, your withdrawal of your consent or authorization willnot affect the processing of personal information based on your consent beforethe withdrawal.

About Deletion ofthe Account: You can find the Delete function through “Me &rt; Settings &rt; Account and Security &rt;Delete Account” (Deactivate Account）

Security Measures

We use commercially reasonable physical, administrative, andtechnical safeguards to preserve the integrity and security of your PersonalData. Premium Levella provides various security strategies to effectivelyensure data security of user and device. As for device access, Premium Levella proprietaryalgorithms are employed to ensure data isolation, access authentication,applying for authorization. As for data communication, communication usingsecurity algorithms and transmission encryption protocols and commerciallevel information encryption transmission based on dynamic keys aresupported. As for data processing, strict data filtering and validation andcomplete data audit are applied. As for data storage, all confidentialinformation of users will be safely encrypted for storage. If you have reasonto believe that your interaction with us is no longer secure (for example, ifyou feel that the security of any account you might have with us has beencompromised), you could immediately notify us of the problem by emailing contact@premiumlevella.com.

Data Retention

We process your Personal Data for the minimum period necessaryfor the purposes set out in this Policy, unless there is a specific legalrequirement for us to keep the data for a longer retention period. We determinethe appropriate retention period based on the amount, nature, and sensitivityof your Personal Data, and after the retention period ends, we will destructyour Personal Data.

· Personal Data will no longer be retained when yourequest to remove your Personal Data, we will accordingly complete the task.

When we are unable to do so for technical reasons, we willensure that appropriate measures are put in place to prevent any further suchuse of your Personal Data.

Children’s Privacy

Protecting the privacy of young children is especially importantto us. The Services are not directed to individuals under the age of thirteen(13) (or such other age provided by applicable law in your country/region ofresidence), and we request that these individuals do not provide any PersonalData to us. We do not knowingly collect Personal Data from any child unless wefirst obtain permission from that child’s parent or legal guardian. If webecome aware that we have collected Personal Data from any child withoutpermission from that child’s parent or legal guardian, we will take steps toremove that information.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to ourinformation practices. If we make any material changes, we will notify you byemail (send to the e-mail address specified in your account) or by means of anotice in the mobile applications prior to the change becoming effective. Weencourage you to periodically review this page for the latest information on ourprivacy practices.

Contact Us

If you have any questions about our practices or this PrivacyPolicy, please contact us as follows:

Premium Levella

Postal Mailing Address: 8150 NW 76TH Ave. Medley Florida,33166-7544. United States (US)

Email: contact@premiumlevella.com