PRIVACY POLICY
Effective Date: 1 July 2024
Updated: 1 July 2024
Plasma Science Pte Ltd and subsidiaries (“we”, “us”,“our”, “Plasma Science Pte Ltd”) are committed to protecting your privacy. ThisPrivacy Policy (“Policy”) describes our practices in connection withinformation privacy on Personal Data we process through your individual use ofthe following services, products, and related mobile applications(collectively, the “Products”):
Trident Air Mobile Application
Before you use our Products, please carefully readthrough this Policy and understand our purposes and practices of collection,processing of your Personal Data, including how we use, store, share andtransfer Personal Data. In the Policy you will also find ways to execute yourrights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register withyour Personal Data, or if you start to use our Products and does not expresslyobject to the contents of this Policy, we will consider that you fullyunderstand and agree with this Policy. If you have any question r regardingthis Policy, please do not hesitate to contact us via email:
Attn: Privacy Policy Team; Email sales@tridentair.com
For other branded mobile applications powered by PlasmaScience Pte Ltd, our Clients control all the Personal Data collected throughour Products. We collect the information under the direction of our Clients andthe processing of such information shall be limited to the purpose of providingthe service for which our Clients has engaged us. If you are a customer of oneof our Clients and would no longer like to be contacted by one of our Clientsthat use our service, please contact the Client that you interact withdirectly.
Definition
In this Policy, Personal Data means informationgenerated, collected, recorded and/or stored, electronically or otherwise, thatcan be used to identify an individual or reflect the activity of an individual,either from that information alone, or from that information and otherinformation we have access to about that individual.
Personal Sensitive Data includes personal biometricinformation, communication records and contents, health information,transaction information, and precise location information. When we collectPersonal Sensitive Data from you, we will generate an explicit notification foryour consent before we collect personal sensitive data about you.
Smart Devices refers to those computing devicesproduced or manufactured by hardware manufacturers, with human-machineinterface and the ability to transmit data that connect wirelessly to anetwork, including: smart home appliances, smart wearable devices, smart aircleaning devices, etc.
Apps refers to those mobile applications developed byPlasma Science Pte Ltd that provide end users remote control to Smart Devicesand with the ability to connect to the supplier IoT Platform.
What Personal Data do we collect
In order to provide our services to you, we will askyou to provide the necessary Personal Data that is required to provide thoseservices. If you do not provide your Personal Data, we may not be able toprovide you with our products or services.
1. Information You Voluntarily Provide Us
· Registered Account Data: When you register anaccount with 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 Plasma Science Pte Ltd accountfor quick login. We will ensure compliance with applicable data protection lawsand regulations, as well as agreements, policies or documentations agreed withsuch third party regarding sharing personal information, in processing yourPersonal Data.
However, ifthe Services you request or purchase are based on your account, please go tothe registration/login page for guidance.
· Feedback: When using feedbackand suggestion features in our Products, we will collect your email address,mobile phone number and your feedback content to address your problems andsolve device failures on a timely basis.
Information based on additional functions:
In order to offer you with more convenient andhigher-quality Services with optimized user experiences, we may collect and usecertain information if you consent to use additional functions in the App.Please note, if you do not provide such information, you may continue to usebasic Services of the App and connected Smart Devices, but certain featuresbased on these additional functions may not be available. These additionalfunctions may include:
1) Additional functions based on location information:
When you enable the location-based functions throughpermission settings on your mobile device, we will collect and process yourlocation information to enable these functions, such as pairing with your SmartDevices. Also, we may collect information about your: a) real-time and preciselocation, for instance when you choose to use the automation scenarios forcontrolling your Smart Devices, or b) non-precise geo-location when you usecertain Smart Devices or the Services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fencefeature, your location information will be generated and shared with GoogleMaps services. Please note that Google has corresponding data protectionmeasures, which you may refer to Google’s Data Processing and Security Termsfor more details.
You may disable the collection and use of yourlocation information by changing your mobile device settings ("My -Setting - Privacy Right Setting - Switch on/off Location Information"),upon which we will cease to collect and use your location information.
2) Additional services based on camera:
You may use the camera to scan the code by turning onthe camera permission to pair with a Smart Device, take video, etc. Please beaware that even if you have agreed to enable the camera permission, we willonly obtain information when you actively use the camera for scanning codes,video recording, etc.
You may opt-out the using of camera permission: "My - Setting - Privacy Right Setting - Switchon/off Camera".
3) Additional services for accessing and uploading pictures/videos based on photo albums(picture library/video library):
You can use this function to upload yourphotos/pictures/videos after turning on the photo album permission, so as torealize functions such as changing the avatar, reporting device usage problemsby providing photo proofs, etc.. When you use the photos and other functions,we will not recognize this information; but when you report a device usageproblem, we may use the photos/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) Additional services related to microphone-based service:
You can use the microphone to send voice informationafter turning on the microphone permission, such as shooting videos, waking upthe voice 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) Additional services based on storage permission(Android):
The purpose is to ensure the stable operation of theApp by utilizing the storage permission. After you give or indicate thepermission to read/write your mobile device’s storage, we will access pictures,files, crash log information and other necessary information from your mobiledevice’s storage to provide you with functions, such as informationpublications, or record the crash log information locally.
You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switchon/off Storage".
6) Additional services based on Notification permission:
The reason why we ask you for the permission is tosend you notifications about using the Smart Devices or Services, especially ifyou have purchased security services and you require an alert or message sothat you can capture 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 andrequire the App to display the real-time image of the camera in a separatewindow.
You may opt-out the using of alert windowinformation: "My - Setting - PrivacyRight Setting - Switch on/off Alert Window".
8) Additional services based on Bluetooth permission:
You can enable Bluetooth functions after turning onthe permission, including controlling the Smart Devices, acquiring status of,discovering and configuring Smart Devices. In these functions, we willcommunicate with Smart Devices via Bluetooth. Please be aware that even if youhave agreed to enable the Bluetooth permission, we will only use Bluetooth forcommunication in these scenarios: display device status on the home page andSmart Device panel; perform device control on the home page and Smart Devicepanel; discovering Smart Devices on the home page and the add device page,Smart Device distribution network.
You may opt-out the using of Bluetooth via "My - Settings - Privacy Setting -Disable/Enable Bluetooth permission".
9）Additional services based onHomeKit permission (iOS):
You can enable related functions after enablingHomeKit permissions, including discovering Smart Devices, enabling Smart Devicenetwork configuration, controlling Smart Devices, and checking device status.Among these functions, we will process data with the "Home” App that comeswith the iOS system through HomeKit. Please be aware that even if you haveagreed to enable the HomeKit permission, we will only use it in thesescenarios: on the home page, to discover HomeKit devices, HomeKit devicenetwork configuration; in "Settings - HomeKit" for discoveringHomeKit devices, HomeKit device network configuration.
You may opt-out the using of HomeKit permission via "My - Settings - Privacy Settings-Turn off/onHomeKit permission".
10）Additional services based onHealthKit (iOS):
You can proactively enable related functions afterenabling HealthKit permission, including statistics on weight, height, running,and swimming. 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 - Turnoff/on HealthKit permission".
Please note that if you turn on any permission, youauthorize us to collect and use relevant personal information to provide youwith corresponding Services. Once you turn off any permission, we will take itas canceling the authorization, and we will no longer continue to collectPersonal Data based on the corresponding permissions, and the related functionsmay be terminated. However, your decision to turn off the permission will notaffect the previous collection and use of information based on your authorization.
2. Information We Collect Automatically
· MobileDevice Information: When you interact with our Services, in orderto provide 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.
· Usage Data: Duringyour interaction with our websites and Services, we automatically collect usagedata relating to visits, clicks, downloads, messages sent/received, and otherusage 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 individual by using deviceinformation or log information alone. However, if these types of non-personalinformation, combined with other information, may be used to identify aspecific individual, such information will be treated as Personal Data. Unlesswe have obtained your consent or unless otherwise provided by data protectionlaws and regulations, we will aggregate or desensitize such information.
3. Smart Devices Related Information:
· BasicInformation of Smart Devices: When you connect your Smart Devices with theServices, we may collect basic information about your Smart Devices such asdevice name, device ID, online status, activation time, firmware version, andupgrade information.
· Informationcollected during the process of connecting to a Smart Device: Based onthe type of Smart Device you need to connect, the basic information collectedincludes: Wi-Fi information, device MAC address, etc.
· InformationReported by Smart Devices: Depending on the different Smart Devices youelect to connect with our Products or Services, we may collect differentinformation reported by your Smart Devices.
Purposes And Legal Basis For Processing Personal Data
The purpose for which we may process informationabout you are as follows:
· Provide Youwith 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.
· Improve OurServices: 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 user agreement.
· Non-marketingCommunication: We process your Personal Data to send you important informationregarding the Services, changes to our terms, conditions, and policies and/orother administrative information. At the same time, we will also send younotifications related to the services you have purchased, such as alertservices. You can check the “App Notification” in the App ("Me &rt;Message Center &rt; Setting &rt; Notification Setting”) to manage thesecommunications. When you decide not to enable the Notifications function, wewill no longer process your information for such purpose. The legal basis forthis processing is to perform our contract with you according to our user agreement.
· 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 the conveniencebrought by our Services, under such circumstance, if you do not agree to dataanalysis of your data, you can enter the privacy settings of App (“My &rt;Settings &rt; Privacy Settings &rt; Data Analysis”) to opt-out yourselection. The legal basis for such processing is based on your consent.
· MarketingCommunication and Personalization: We may process youraccount data, usage data, device information to personalize product design andto provide you with services tailored for you, such as recommending anddisplaying information and advertisements regarding products suited to you, andto invite you to participate in surveys relating to your use of the Services.If you do not allow us to process your Personal Data for personalization, youmay opt out when you enter the App, or by changing your preferences in “PrivacySettings”(“Me&rt; Settings &rt; Privacy Settings &rt; Personalization”) in theApp. The legal basis for this processing is your consent.
· LegalCompliance. We disclose information if we are legally required to do so, orif we have a good faith belief that such use is reasonably necessary to:
· comply with a legal obligation, process orrequest;
· enforce our User Agreement and otheragreements, policies, and standards, including investigation of any potentialviolation thereof;
· protect the rights, property or safety of us,our users, a third party or the public as required or permitted by law; or
· detect, prevent or otherwise address security,fraud or technical issues.
If there is any change in the purposes for processingyour personal data, we will inform such change to you via email and/or aprominent notice on our website of such changes of purposes, and choices youmay have regarding your Personal Data.
Who do we Share Personal Data with?
At Plasma Science, we only share Personal Data inways that we tell you about. We may share your Personal Data with the followingrecipients:
· To our customers and other business partnerswho provide you, directly or indirectly, with your Smart Devices, and/ornetworks and systems through which you access and use our websites andServices.
· To subsidiaries or affiliates within ourcorporate family for purpose of regular business activities based on ourinstructions and in compliance with applicable law, this Policy and otherappropriate confidentiality and security measures.
· To an affiliate or other third party in theevent of any reorganization, merger, sale, joint venture, assignment, transferor other disposition of all or any portion of our business, assets or stock(including without limitation in connection with any bankruptcy or similarproceedings). In such an event, you will be notified via email and/or aprominent notice on our website of any change in ownership, and choices you mayhave regarding your Personal Data.
· As we believe in good faith that access to, oruse, 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) Protectour operation and business systems;
(d) Protectthe rights, property or safety of us, our users, athird party or the public as required or permitted by law; or
(e)Perform risk management, screening and checks for unlawful, fraudulent,deceptive or malicious activities.
Except for the third parties mentioned above, we onlydisclose your Personal Data to other third parties with your consent.
International Transfer of Information Collected
Plasma Science willcomply with applicable data localization requirements in correspondingjurisdictions with respect to storage of data. To facilitate our operation, wemay transfer, store and process your Personal Data in jurisdictions other thanwhere you live. Laws in these countries may differ from the laws applicable toyour country of residence. When we do so, we will ensure that an adequate levelof protection is provided for the information by using one or more of thefollowing 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 wehave in place, 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 PersonalData. You may exercise any of the following rights:
Confirm: pleaseprovide at least 2 approaches for individual user executing their privacyrights, for instance, via the privacy office email address support@tridentair.com,or via the route of Feedback imbedded in the App: Me&rt;PersonalCenter&rt;Account and Security&rt;, etc.
You do not have to pay a fee and we will aim torespond you within 30 days. If you decide to email us, in your request, pleasemake clear what information you would like to have changed, whether you wouldlike to have your Personal Data deleted from our database or otherwise let usknow what limitations you would like to put on our use of your Personal Data.Please note that we may ask you to verify your identity before taking furtheraction on your request, for security purposes.
You may:
· Request access to the PersonalData that we process about you: "My-Setting-Privacy Settings-Personal DataExport";
· Request that we correctinaccurate or incomplete Personal Data about you: 1) Modify your account number(email address or phone number): "My-Setting-Accountand Security-Change your Account"; 2) Modify the nickname and/ortime zone: "My-Personal Information";
· Request deletion of Personal Dataabout you: "My-Setting-Account andSecurity-Delete Account", when you confirm the deletion of youraccount, your Personal Data will be deleted accordingly.
· Request restrictions, temporarilyor permanently, on our processing of some or all Personal Data about you:Please send over your request through "My-FAQ& Feedback", or send over the email request to support@tridentair.com;
· Request transfer of Personal Datato you or a third party where we process the data based on yourconsent or a contract with you, and where our processing is automated: Pleasesend over your request through "My-FAQ & Feedback", or send over theemail request support@tridentair.com;
· Opt-out or object to our use of Personal Dataabout you where our use is based on your consent or our legitimate interests.
Withdrawal of consent Confirm thefollowing details: We will exercise your privacy right to withdrawconsent through the following approaches:
1)For privacy permissions acquired through devicesystem settings, your consent can be withdrawn by changing device permissions,including Confirm: location, camera, photoalbum (picture library/video library), microphone, Bluetooth settings,notification settings and other related functions;
2)You may opt-out the non-marketing communicationthrough “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 theinformation related to the Smart Device will not be collected;
6)By using product with the "TryNow" mode, and not enable certain location setting forparticular smart scene, we will not collect any Personal Data about you;
7)If you previously agreed to associate App accountwith a third-party service, such as a health platform, please unbind it on thethird-party platform.
When you withdraw your consent or authorization, wemay not be able 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 Deletionof the 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, and technical safeguards to preserve the integrity and securityof your Personal Data. Plasma Science provides various security strategiesto effectively ensure data security of user and device. As for device access, PlasmaScience proprietary algorithms are employed to ensure data isolation, accessauthentication, and applying for authorization. As for data communication,communication using security algorithms and transmission encryption protocolsand commercial level information encryption transmission based on dynamickeys are supported. As for data processing, strict data filtering andvalidation and complete data audit are applied. As for data storage, allconfidential information of users will be safely encrypted for storage. If youhave reason to believe that your interaction with us is no longer secure (forexample, if you feel that the security of any account you might have with ushas been compromised), you could immediately notify us of the problem byemailing support@tridentair.com .
Data Retention
We process your Personal Data for the minimum periodnecessary for the purposes set out in this Policy, unless there is a specificlegal requirement for us to keep the data for a longer retention period. Wedetermine the appropriate retention period based on the amount, nature, andsensitivity of your Personal Data, and after the retention period ends, we willdestruct your Personal Data.
· For as long as you require us to fulfill theproducts and services you request from us.
· Personal Data will no longer be retained whenyou request to remove your Personal Data, we will accordingly complete thetask.
When we are unable to do so for technical reasons, wewill ensure that appropriate measures are put in place to prevent any furthersuch use of your Personal Data.
Children’s Privacy
Protecting the privacy of young children isespecially important to us. The Services are not directed to individuals underthe age of thirteen (13) (or such other age provided by applicable law in yourcountry/region of residence), and we request that these individuals do notprovide any Personal Data to us. We do not knowingly collect Personal Data fromany child unless we first obtain permission from that child’s parent or legalguardian. If we become aware that we have collected Personal Data from any childwithout permission from that child’s parent or legal guardian, we will takesteps to remove that information.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changesto our information practices. If we make any material changes, we will notifyyou by email (send to the e-mail address specified in your account) or by meansof a notice in the mobile applications prior to the change becoming effective.We encourage you to periodically review this page for the latest information onour privacy practices.
Contact Us
If you have any questions about our practices or thisPrivacy Policy, please contact us as follows:
PLASMA SCIENCE PTE LTD
Postal Mailing Address: 7 Yishun Industrial Street1 #03-49 Singapore 768162
Email: sales@tridentair.com