Privacy Policy
Effective Date: 01.09.2025
Updated: 01.07.2025
Axiom Smart and subsidiaries (“we”, “us”, “our”, “AxiomSmart”) 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”):
Axiom Smart Mobile Application
Before you use our Products,please carefully read through this Policy and understand our purposes andpractices of collection, processing of your Personal Data, including how weuse, store, share and transfer Personal Data. In the Policy you will also findways to execute your rights of access, update, delete or protect your PersonalData.
When you accept this Policy whenyou register with your Personal Data, or if you start to use our Products anddoes not expressly object to the contents of this Policy, we will consider thatyou fully understand and agree with this Policy. If you have any question rregarding this Policy, please do not hesitate to contact us via e-mail: legal@axiomsmart.ge
For other branded mobileapplications powered by Axiom Smart, our Clients control all thePersonal Data collected through our Products. We collect the information underthe direction of our Clients and the processing of such information shall belimited to the purpose of providing the service for which our Clients hasengaged us. If you are a customer of one of our Clients and would no longerlike to be contacted by one of our Clients that use our service, please contactthe Client that you interact with directly.
Definition
In this Policy, Personal Datameans information generated, collected, recorded and/or stored, electronicallyor otherwise, that can be used to identify an individual or reflect theactivity of an individual, either from that information alone, or from thatinformation and other information we have access to about that individual.
Personal Sensitive Data includespersonal biometric information, communication records and contents, healthinformation, transaction information, and precise location information. When wecollect Personal Sensitive Data from you, we will generate an explicitnotification for your consent before we collection personal sensitive dataabout you.
Smart Devices refers to thosecomputing devices produced or manufactured by hardware manufacturers, withhuman-machine interface and the ability to transmit data that connectwirelessly to a network, including: smart home appliances, smart wearabledevices, smart air cleaning devices, etc.
Apps refers to those mobileapplications developed by Axiom Smart that provide end users remotecontrol to Smart Devices and with the ability to connect to the supplier IoTPlatform.
What Personal Data do we collect
In order to provide our servicesto you, we will ask you to provide necessary Personal Data that is required toprovide those services. If you do not provide your Personal Data, we may not beable to provide you with our products or services.
1.Information You VoluntarilyProvide Us
· RegisteredAccount Data: When you register an account with us, we may collect your nameand contact details, such as your email address, phone number, user name, andlogin credentials. During your interaction with our Products, we may furthercollect your nickname, profile picture, country code, language preference ortime zone information into your account.
If you authorize login to the Products with a thirdparty account, we will obtain from such third party your account information(such as portrait, nickname, region, gender, etc.) which may be bound with yourAxiom Smart account for quick login. We will ensure compliance withapplicable data protection laws and regulations, as well as agreements,policies or documentations agreed with such third party regarding sharingpersonal information, in processing your Personal Data.
However, if the Services you request or purchase arebased on your account, please go to the registration/login page for guidance.
· Feedback: When using feedback and suggestion features in ourProducts, we will collect your email address, mobile phone number and yourfeedback content to address your problems and solve device failures on a timelybasis.
Information based on additionalfunctions:
In order to offer you with moreconvenient and higher-quality Services with optimized user experiences, we maycollect and use certain information if you consent to use additional functionsin the App. Please note, if you do not provide such information, you maycontinue to use basic Services of the App and connected Smart Devices, but certainfeatures based on these additional functions may not be available. Theseadditional functions may include:
1)Additional functions based on location information:
When you enable thelocation-based functions through permission settings on your mobile device, wewill collect and process your location information to enable these functions,such as pairing with your Smart Devices. Also, we may collect information aboutyour: a) real-time and precise location, for instance when you choose to usethe automation scenarios for controlling your Smart Devices, or b) non-precisegeo-location when you use certain Smart Devices or the Services, such as robotcleaner and weather service.
Based on your consent, when youenable the geo-fence feature, your location information will be generated andshared with Google Maps services. Please note that Google has correspondingdata protection measures, which you may refer to Google’s Data Processing andSecurity Terms for more details.
You may disable the collectionand use of your location 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 scanthe code by turning on the camera permission to pair with a Smart Device, takevideo, etc. Please be aware that even if you have agreed to enable the camerapermission, we will only obtain information when you actively use the camerafor scanning codes, video recording, etc.
You may opt-out the using ofcamera permission: "My - Setting - Privacy Right Setting - Switch on/offCamera".
3)Additional services for accessing and uploadingpictures/videos based on photo albums (picture library/video library):
You can use this function toupload your photos/pictures/videos after turning on the photo album permission,so as to realize functions such as changing the avatar, reporting device usageproblems by providing photo proofs, etc. When you use the photos and otherfunctions, we will not recognize this information; but when you report a deviceusage problem, we may use the photos/pictures you upload to locate yourproblem.
You may opt-out the using ofphoto album permission: "My - Setting - Privacy Right Setting - Switchon/off Photo Album".
4)Additional services related to microphone-basedservice:
You can use the microphone tosend voice information after turning on the microphone permission, such asshooting videos, waking up the voice assistant, etc. For these functions, wewill collect your voice information to recognize your command. Please be awarethat even if you have agreed to enable the microphone permission, we will onlyobtain voice information through the microphone when you voluntarily activatethe microphone in the App.
You may opt-out the using ofmicrophone permission: "My - Setting - Privacy Right Setting - Switchon/off Microphone".
5)Additional services based on storagepermission(Android):
The purpose is to ensure thestable operation of the App by utilizing the storage permission. After you giveor indicate the permission to read/write your mobile device’s storage, we willaccess pictures, files, crash log information and other necessary informationfrom your mobile device’s storage to provide you with functions, such asinformation publications, or record the crash log information locally.
You may opt-out the using ofstorage permission: "My - Setting - Privacy Right Setting - Switch on/offStorage".
6)Additional services based on Notificationpermission:
The reason why we ask you for thepermission is to send you notifications about using the Smart Devices orServices, especially if you have purchased security services and you require analert or message so that you can capture the real-time status.
You may opt-out the using of Appnotifications: "My - Message Center - Setting - Switch on/offNotifications".
7) Additional services based on Alert Windowpermission：
You may choose to bind a camerain the App and require the App to display the real-time image of the camera ina separate window.
You may opt-out the using ofalert window information: "My - Setting - Privacy Right Setting - Switchon/off Alert Window".
8) Additional services based on Bluetooth permission:
You can enable Bluetoothfunctions after turning on the permission, including controlling the SmartDevices, acquiring status of, discovering and configuring Smart Devices. Inthese functions, we will communicate with Smart Devices via Bluetooth. Pleasebe aware that even if you have agreed to enable the Bluetooth permission, wewill only use Bluetooth for communication in these scenarios: display devicestatus on the home page and Smart Device panel; perform device control on thehome page and Smart Device panel; discovering Smart Devices on the home pageand the add device page, Smart Device distribution network.
You may opt-out the using ofBluetooth via "My - Settings - Privacy Setting - Disable/Enable Bluetoothpermission".
9）Additionalservices based on Home Kit permission (iOS):
You can enable related functionsafter enabling Home Kit permissions, including discovering Smart Devices,enabling Smart Device network configuration, controlling Smart Devices, andchecking device status. Among these functions, we will process data with the"Home “App that comes with the iOS system through Home Kit. Please beaware that even if you have agreed to enable the Home Kit permission, we willonly use it in these scenarios: on the home page, to discover Home Kit devices,Home Kit device network configuration; in "Settings –Home Kit" for discovering Home Kit devices,Home Kit device network configuration.
You may opt-out the using of Home Kit permissionvia "My - Settings - Privacy Settings-Turn off/on Home Kit permission".
10）Additionalservices based on Health Kit (iOS):
You can proactively enablerelated functions after enabling Health Kit permission, includingstatistics on weight, height, running, and swimming. In these functions, wewill exchange data with the health-related functionalities that comes with theiOS system through Health Kit. Please be aware that even if you have agreed toenable Health Kit permission, we will only use them in thesescenarios: when you use the health-related Smart Device, such as body fat scales,bracelets, watch and consent to use the Health Kit, the data reported by theSmart Device will be transferred to Health Kit.
You may opt-out the using ofHealth Kit permission via "My - Settings - PrivacySettings - Turn off/on Health Kit permission".
Please note that if you turn onany permission, you authorize us to collect and use relevant personalinformation to provide you with corresponding Services. Once you turn off anypermission, we will take it as canceling the authorization, and we will no longercontinue to collect Personal Data based on the corresponding permissions, andthe related functions may be terminated. However, your decision to turn off thepermission will not affect the previous collection and use of information basedon your authorization.
2.Information We CollectAutomatically
· Mobile Device 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.
· Usage Data: 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.
· Log Information: When you use the App, in order to improve your userexperience, the system and exception log may be uploaded, including your IPaddress, language preference setting, operating system version, date or time ofaccess, so that we can facilitate and accurately identify problems and help yousolve them 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 RelatedInformation:
· Basic Information 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.
· Information collected during the process ofconnecting to a Smart Device: Based on the type of Smart Device you need to connect, thebasic information collected includes: Wi-Fi information, device MAC address, etc.
· Information Reported by Smart Devices: Depending on the different Smart Devices you selectto connect with our Products or Services, we may collect different informationreported by your Smart Devices. For example, please enter information about the smart device report.
Please note that when you actively agree to enter theApp name and the application is connected to the Apple Health or some other Healthrelated platform, we will share your measurement data with Apple Health(including only your BMI, height, weight and body fat% data) or other Health related platform. The purpose of sharing data is only to measure andanalyze health-related indicators related to you, and it will never bedisclosed to other third parties. You can close at any time by managing theHealth Kit settings page.
Purposes and legal basis forprocessing Personal Data
The purpose for which we mayprocess information about you are as follows:
· Provide You 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 our useragreement.
· Improve Our Services: We process your mobile device information, usagedata, location information and Smart Device related information to ensure thefunctions and safety of the Services, to develop and improve the Services, toanalyze the efficiency 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-marketing Communication: 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 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 useragreement.
· Data Analysis: 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; Data Analysis”) to opt-out yourselection. The legal basis for such processing is based on your consent.
· Marketing Communication and Personalization: We may process your account data, usage data, deviceinformation to personalize product design and to provide you with servicestailored for you, such as recommending and displaying information andadvertisements 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. Thelegal basis for this processing is your consent.
· Legal Compliance. 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 alegal obligation, process or request;
· enforce ourUser Agreement and other agreements, policies, and standards, includinginvestigation of any potential violation thereof;
· protect therights, property or safety of us, our users, a third party or the public as requiredor permitted by law; or
· detect, preventor otherwise address security, fraud or technical issues.
If there is any change in thepurposes for processing your personal data, we will inform such change to youvia email and/or a prominent notice on our website of such changes of purposes,and choices you may have regarding your Personal Data.
Who do we Share Personal Data with?
At Axiom Smart, we onlyshare Personal Data in ways that we tell you about. We may share your PersonalData with the following recipients:
· To ourthird-party service providers who perform certain business-related functionsfor us, such as website hosting, data analysis, payment and credit cardprocessing, infrastructure provision, IT services, customer support service,e-mail delivery services, and other similar services to enable them to provideservices to us.
· To ourcustomers and other business partners who provide you, directly or indirectly,with your Smart Devices, and/or networks and systems through which you accessand use our websites and Services.
· To subsidiariesor affiliates within our corporate family for purpose of regular businessactivities based on our instructions and in compliance with applicable law,this Policy and other appropriate confidentiality and security measures.
· To an affiliateor other third party in the event of any reorganization, merger, sale, jointventure, assignment, transfer or other disposition of all or any portion of ourbusiness, assets or stock (including without limitation in connection with anybankruptcy or similar proceedings). In such an event, you will be notified viaemail and/or a prominent notice on our website of any change in ownership, andchoices you may have regarding your Personal Data.
· As we believein good faith that access to, or use, preservation, or disclosure of theinformation is reasonably necessary or appropriate to:
(a)Comply with applicable law, regulation, legalprocess, or lawful governmental request;
(b)Enforce our User Agreement and other agreements,policies, and standards, including investigation of any potential violationthereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property or safety of us, ourusers, a third party or the public as required or permitted by law; or
(e)Perform risk management, screening and checks forunlawful, fraudulent, deceptive or malicious activities.
Except for the third partiesmentioned above, we only disclose your Personal Data to other third partieswith your consent.
International Transfer of InformationCollected
Axiom Smart will complywith applicable data localization requirements in corresponding jurisdictionswith respect to storage of data. To facilitate our operation, we may transfer,store and process your Personal Data in jurisdictions other than where youlive. Laws in these countries may differ from the laws applicable to yourcountry of residence. When we do so, we will ensure that an adequate level ofprotection is provided for the information by using one or more of thefollowing approaches:
· Agreement onthe basis of approved EU standard contractual clauses per GDPR Art. 46. Formore 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 detailon the safeguards we have in place, you can contact us directly as described inthis Privacy Policy.
Your Rights Relating to YourPersonal Data
We respect your rights andcontrol over your Personal Data. You may exercise any of the following rights:
Via email to: legal@axiomsmart.ge
Via the route of Feedback imbeddedin the App: through "My-FAQ & Feedback".
You do not have to pay a fee andwe will aim to respond you within 30 days. If you decide to email us, in yourrequest, please make clear what information you would like to have changed,whether you would like to have your Personal Data deleted from our database orotherwise let us know what limitations you would like to put on our use of yourPersonal Data. Please note that we may ask you to verify your identity beforetaking further action on your request, for security purposes.
You may:
· Request accessto the Personal Data that we process about you: "My-Setting-PrivacySettings-Personal Data Export";
· Request that wecorrect inaccurate or incomplete Personal Data about you: 1) Modify youraccount number (email address or phone number): "My-Setting-Account andSecurity-Change your Account"; 2) Modify the nickname and/or time zone:"My-Personal Information";
· Requestdeletion of Personal Data about you: "My-Setting-Account and Security-DeleteAccount", when you confirm the deletion of your account, your PersonalData will be deleted accordingly.
· Requestrestrictions, temporarily or permanently, on our processing of some or allPersonal Data about you: Please send over your request through "My-FAQ& Feedback", or send over the email request to legal@axiomsmart.ge
· Requesttransfer of Personal Data to you or a third party where we process the databased on your consent or a contract with you, and where our processing isautomated: Please send over your request through "My-FAQ &Feedback", or send over the email request to legal@axiomsmart.ge
· Opt-out orobject to our use of Personal Data about you where our use is based on yourconsent or our legitimate interests.
We will exercise your privacy right towithdraw consent through the following approaches:
1) For privacy permissionsacquired through device system settings, your consent can be withdrawn bychanging device permissions, including: location, camera, photo album (picturelibrary/video library), microphone, Bluetooth settings, notification settingsand other related functions;
2) You may opt-out thenon-marketing communication through “Me &rt; Message Center &rt; NotificationSettings” to manage your selection;
3) You may opt-out the dataanalysis features through “Me &rt; Settings &rt; Privacy Settings”;
4) You may opt-out thePersonalization feature through “Me &rt; Settings &rt; Privacy Settings &rt;Personalization”;
5) Unbind the Smart Devicethrough the App, and the information related to the Smart Device will not becollected;
6) By using product with the"Try Now" mode, and not enable certainlocation setting for particular smart scene, we will not collect anyPersonal Data about you;
7) If you previously agreed toassociate App account with a third-party service, such as a health platform,please unbind it on the third-party platform.
When you withdraw your consent orauthorization, we may not be able to continue to provide you with certainproducts or services correspondingly. However, your withdrawal of your consentor authorization will not affect the processing of personal information basedon your consent before the withdrawal.
About Deletion of the Account: You can find the Delete function through “Me&rt; Settings &rt; Account and Security &rt; Delete Account” (DeactivateAccount）
Security Measures
We use commercially reasonablephysical, administrative, and technical safeguards to preserve the integrityand security of your Personal Data. Axiom Smart provides varioussecurity strategies to effectively ensure data security of user and device. Asfor device access, Axiom Smart proprietary algorithms are employedto ensure data isolation, access authentication, applying for authorization. Asfor data communication, communication using security algorithms andtransmission encryption protocols and commercial level informationencryption transmission based on dynamic keys are supported. As for dataprocessing, strict data filtering and validation and complete data audit areapplied. As for data storage, all confidential information of users will besafely encrypted for storage. If you have reason to believe that yourinteraction with us is no longer secure (for example, if you feel that thesecurity of any account you might have with us has been compromised), you couldimmediately notify us of the problem by emailing to legal@axiomsmart.ge
Data Retention
We process your Personal Data forthe minimum period necessary for the purposes set out in this Policy, unlessthere is a specific legal requirement for us to keep the data for a longerretention period. We determine the appropriate retention period based on theamount, nature, and sensitivity of your Personal Data, and after the retentionperiod ends, we will destruct your Personal Data.
· For as long asyou require us to fulfill the products and services you request from us asdefined in our user agreement.
· Personal Datawill no longer be retained when you request to remove your Personal Data, wewill accordingly complete the task.
When we are unable to do so fortechnical reasons, we will ensure that appropriate measures are put in place toprevent any further such use of your Personal Data.
Children’s Privacy
Protecting the privacy of youngchildren is especially important to us. The Services are not directed to individualsunder the age of sixteen (16) and we request that these individuals do not provideany Personal Data to us. We do not knowingly collect Personal Data from anychild unless we first obtain permission from that child’s parent or legalguardian. If we become aware that we have collected Personal Data from anychild without permission from that child’s parent or legal guardian, we willtake steps to remove that information.
Changes to this Privacy Policy
We may update this Privacy Policyto reflect changes to our information practices. If we make any materialchanges, we will notify you by email (send to the e-mail address specified inyour account) or by means of a notice in the mobile applications prior to thechange becoming effective. We encourage you to periodically review this pagefor the latest information on our privacy practices.
Contact Us
If you have any questions aboutour practices or this Privacy Policy, please contact us as follows:
Axiom Smart LLC
Postal Mailing Address: Vazha-PshavelaAv. III Block, 15 Building, 155 App. Tbilisi, 0186, Georgia
Email: legal@axiomsmart.ge