Privacy Policy of Using CR Smart Home App
Effective Date: 28 April 2022
Updated: 28 April2022
CR Smart Homeand
subsidiaries (“we”, “us”, “our”, “CR Smart Home”) are committed to
protecting your privacy. This Privacy Policy (“Policy”) describes our practices
in connection with information privacy on Personal Data we process through your
individual use of the following services, products, and related mobile
applications (collectively, the “Products”):
·CR Smart Home Mobile
Application
Before you use our Products,
please carefully read through this Policy and understand our purposes and
practices of collection, processing of your Personal Data, including how we
use, store, share and transfer Personal Data. 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 Personal Data, or if you start to use our Products and
does not expressly object to the contents of this Policy, we will consider that
you fully understand and agree with this Policy. If you have any question r
regarding this Policy, please do not hesitate to contact us via:
Confirm：crsmarthome1719@gmail.com
For other branded mobile
applications powered by CR Smart Home, our Clients control all the
Personal Data collected through our Products. We collect the information under
the direction of our Clients and the processing of such information shall be
limited to the purpose of providing the service for which our Clients has
engaged us. If you are a customer of one of our Clients and would no longer
like to be contacted by one of our Clients that use our 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 be used to identify an individual or reflect the
activity of an individual, either from that information alone, or from that
information and other information we have access to about that individual.
Personal Sensitive Data includes
personal biometric information, communication records and contents, health
information, transaction information, and precise location information. When we
collect Personal Sensitive Data from you, we will generate an explicit notification
for your consent before we collection personal sensitive data about you.
Smart Devices refers to those
computing devices produced or manufactured by hardware manufacturers, with
human-machine interface and the ability to transmit data that connect
wirelessly to a network, including: smart home appliances, smart wearable
devices, smart air cleaning devices, etc.
Apps refers to those mobile
applications developed byCR Smart
Homethat provide end users remote control to Smart Devices and
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 ask you to provide necessary Personal Data that is required to
provide those services. If you do not provide your Personal Data, we may not be
able to provide you with our products or services.
1.Information You Voluntarily
Provide Us
·Registered Account Data:
When you register an account with us, we may collect your name and contact
details, such as your email address, phone number, user name, and login
credentials. During your interaction with our Products, we may further collect
your nickname, profile picture, country code, language preference or time zone
information into your account.
If you authorize login to the Products with a third party account,
we will obtain from such third party your account information (such as
portrait, nickname, region, gender, etc.) which may be bound with your CR
Smart Home account for quick login. We will ensure compliance with
applicable data protection laws and regulations, as well as agreements,
policies or documentations agreed with such third party regarding sharing
personal information, in processing your Personal Data.
However, if the Services you request or purchase are based on
your account, please go to the registration/login page for guidance.
Information based on additional
functions:
Confirm: the system permissions
that allow in the your App
In order to offer you with more
convenient and higher-quality Services with optimized user experiences, we may
collect and use certain information 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 Services of the App and connected Smart Devices, but
certain features based on these additional functions may not be available.
These additional functions may include:
1)Additional functions based on location information:
When you enable the
location-based functions through permission settings on your mobile device, we
will collect and process your location information 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 controlling your Smart Devices, or b) non-precise
geo-location when you use certain Smart Devices 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 Maps services. Please note that Google has corresponding
data protection measures, which you may refer to Google’s Data Processing and
Security Terms for more details.
You may disable the collection
and 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 scan
the code by turning on the camera permission to pair with a Smart Device, take
video, etc. Please be aware that even if you have agreed to enable the camera
permission, we will only 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 - Switch on/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 your photos/pictures/videos after turning on the photo album permission,
so as to realize functions such as changing the avatar, reporting device usage
problems by providing photo proofs, etc.. When you use the photos and other
functions, we will not recognize this information; but when you report a device
usage problem, 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 - Switch on/off Photo Album".
4)Additional services related to microphone-based service:
You can use the microphone to
send voice information after turning on the microphone permission, such as
shooting videos, waking up the voice assistant, etc. For these functions, we
will collect your voice information to recognize your command. Please be aware
that even if you have agreed to enable the microphone permission, we will only
obtain voice information through the microphone when you voluntarily activate
the microphone in the App.
You may opt-out the using of
microphone permission: "My - Setting -
Privacy Right Setting - Switch on/off Microphone".
5)Additional services based on storage permission(Android):
The purpose is to ensure the
stable operation of the App by utilizing the storage permission. After you give
or indicate the permission to read/write your mobile device’s storage, we will
access pictures, files, crash log information and other necessary information
from your mobile device’s storage to provide you with functions, such as
information publications, or record the crash log information locally.
You may opt-out the using of
storage permission: "My - Setting - Privacy
Right Setting - Switch on/off Storage".
6)Additional services based on Notification permission:
The reason why we ask you for the
permission is to send you notifications about using the Smart Devices or
Services, especially if you have purchased security services and you require an
alert or message so that you can capture the real-time status.
You may opt-out the using of App
notifications: "My - Message Center -
Setting - Switch on/off Notifications".
7) Additional services based on Alert Window permission：
You may choose to bind a camera
in the App and require the App to 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 - Switch on/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 and configuring Smart Devices. In
these functions, we will communicate with Smart Devices via Bluetooth. Please
be aware that even if you have agreed to enable the Bluetooth permission, we
will only use Bluetooth for communication in these scenarios: display device
status on the home page and Smart Device panel; perform device control on the
home page and Smart Device panel; 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 on HomeKit permission (iOS):
You can enable related functions
after enabling HomeKit permissions, including discovering Smart Devices,
enabling Smart Device network configuration, controlling Smart Devices, and
checking device status. Among these functions, we will process data with the
"Home“ App that comes with the iOS system through HomeKit. Please be aware
that even if you have agreed to enable the HomeKit permission, we will only use
it in these scenarios: on the home page, to discover HomeKit devices, HomeKit
device network configuration; in "Settings - HomeKit" for discovering
HomeKit devices, HomeKit device network configuration.
You may opt-out the using of
HomeKit permission via "My - Settings -
Privacy Settings-Turn off/on HomeKit permission".
10）Additional services
based on HealthKit (iOS):
You can proactively enable
related functions after enabling HealthKit permission, including statistics on
weight, height, running, and swimming. In these functions, we will exchange
data with the health-related functionalities that comes with the iOS system
through HealthKit. Please be aware that even if you have agreed to enable
HealthKit permission, we will only use them in these scenarios: when you use
the health-related Smart Device, such as body fat scales, bracelets, watch and
consent to use the HealthKit, the data reported 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/on HealthKit permission".
Please note that if you turn on
any permission, you authorize us to collect and use relevant personal
information to provide you with corresponding Services. Once you turn off any
permission, we will take it as canceling the authorization, and we will no
longer continue to collect Personal Data based on the corresponding
permissions, and the related functions may be terminated. However, your
decision to turn off the permission will not affect the previous collection and
use of information based on your authorization.
2.Information We Collect
Automatically
·Mobile Device Information:
When you interact with our Services, in order to provide and maintain the
normal operation of our Services, to improve and optimize our Services, and to
protect your account security as well, we automatically collect mobile device
information, such as mobile device model number, IP address, wireless
connection information, the type and version of the operating system, application
version number, push notification identifier, log files, and mobile network
information. Meanwhile, we will collect your software version number. In order
to ensure the security of the operating environment or to provide services, we
will collect information about the installed mobile applications and other
software you use.
·Usage Data: During your
interaction with our websites and Services, we automatically 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 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 solve them in timely
manner.
Please note that we cannot identify a specific individual by using
device information or log information alone. However, if these types of
non-personal information, combined with other information, may be used to
identify a specific individual, such information will be treated as Personal
Data. Unless we have obtained your consent or unless otherwise provided by data
protection laws and regulations, we will aggregate or desensitize such
information..
3.Smart Devices Related
Information:
·Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may
collect basic information about your Smart Devices such as device name, device
ID, online status, activation time, firmware version, and upgrade information.
·Information collected during the process of connecting to a
Smart Device: Based on the type of Smart
Device you need to connect, the basic information collected includes: Wi-Fi
information, device MAC address, etc.
·Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect
with our Products or Services, we may collect different information reported by
your Smart Devices. For example, Please
enter information about the smart device report.
·Confirm: If the product involves sensitive personal information, such
as health products, please be sure to explain it in the privacy policy. For
example: smart scales or fitness trackers may report your height, weight, body
fat content (BFM) , Body mass index (BMI) and skeletal muscle content (SMM); Confirm: Whether integrated third-party
health analysis functions, such as Apple Health, Google Health, etc., if so,
please refer to the following description; if not, you can delete then:
Please note that when you actively agree to enter the App name
and the application is connected to the Apple Health(or some other Health related platform, name it?), we will share
your measurement data with Apple Health (including only your BMI, height,
weight and body fat% data). The purpose of sharing data is only to measure and
analyze health-related indicators related to you, and it will never be
disclosed to other third parties. You can close at any time by managing the
HealthKit settings page.
·Confirm: If the product involves sensitive personal information, such
as camera products, especially with facial recognition equipment, please be
sure to make relevant explanations in the privacy policy. For example, smart
cameras may collect images or videos taken by them.
Purposes and legal basis for
processing Personal Data
The purpose for which we may
process information about you are as follows:
·Provide You with Our Services: We
process your account data, mobile device information, usage data, location
information, and Smart Device related information to provide you with the
Services that you have requested. The legal basis for this processing is to
perform our contract with you according to user
agreement or some other terms of user? Confirm.
·Improve Our Services: We
process your mobile device information, usage data, location information and
Smart Device related information to ensure the functions and safety of the
Services, to develop and improve the Services, to analyze the efficiency of our
operations and to prevent and trace fraudulent or inappropriate usage. The
legal basis for this processing is to perform our contract with you according
to our user agreement or some other terms of
user? Confirm.
·Non-marketing Communication: We
process your Personal Data to send you important information regarding the
Services, changes to our terms, conditions, and policies and/or other
administrative information. At the same time, we will also send you
notifications related to the services you have purchased, such as alert
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 decide
not to enable the Notifications function, we will no longer process your
information for such purpose. The legal basis for this processing is to perform
our contract with you according to our user
agreement or some other terms of user? Confirm.
·Data Analysis: In
order to analyze the usage of the products we provide and improve your user
experience, we will analyze the data you provide us, a) we need to check your
problems when you encounter any malfunctions during the usage of the product,
under such circumstance, you may not able to opt-out because it is highly
relate to your functionalities and quality of using our product and service,
and b) analyze data about how you interface with the product or under
particular scenarios so that you can better enjoy the convenience brought by
our Services, under such circumstance, if you do not agree 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 your selection. The legal basis for such processing is based on your
consent.
·Marketing Communication and Personalization: We may process your account data, usage data, device information
to personalize product design and to provide you with services tailored for
you, such as recommending and displaying information and advertisements
regarding products suited to you, and to 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, you may opt out when 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 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 a legal
obligation, process or request;
·enforce our User
Agreement and other agreements, policies, and standards, including
investigation of any potential violation 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 processing your personal data, we will inform such change to you via 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 CR Smart Home, we only
share Personal Data in ways that we tell you about. We may share your Personal
Data with the following recipients: Confirm
the following details
·To our third-party
service providers who perform certain business-related functions for us, such
as website hosting, data analysis, payment and credit card processing,
infrastructure provision, IT services, customer support service, e-mail
delivery services, and other similar services to enable them to provide
services to us.
·To our customers and
other business partners who provide you, directly or indirectly, with your
Smart Devices, and/or networks and systems through which you access and use our
websites and Services.
·To subsidiaries or
affiliates within our corporate family for purpose of regular business
activities based on our instructions and in compliance with applicable law,
this Policy and other appropriate confidentiality and security measures.
·To an affiliate or other
third party 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 a prominent notice on our website of any change in ownership, and
choices you may have regarding your Personal Data.
·As we believe in good
faith that access to, or use, preservation, or disclosure of the information is
reasonably necessary or appropriate to:
(a)Comply with applicable law, regulation, legal process, or
lawful governmental request;
(b)Enforce our User Agreement and other agreements, policies,
and standards, including investigation of any potential violation thereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property or safety of us, our users, a
third 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 only disclose your Personal Data to other third parties
with your consent.
International Transfer of
Information Collected
CR Smart Homewill comply with
applicable data localization requirements in corresponding jurisdictions with
respect to storage of data. To facilitate our operation, we may transfer, store
and process your Personal Data in jurisdictions other than where you live. Laws
in these countries may differ from the laws applicable to your country of
residence. When we do so, we will ensure that an adequate level of protection
is provided for the information by using one or more of the following
approaches:
·Agreement on the basis
of approved EU standard contractual 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.
·Confirm: Please add if there is any international transfer mechanism you
are relying on, for instance Privacy Shield.
If you would like further detail
on the safeguards we have 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 Personal Data. You may exercise any of the following rights:
Confirm: please provide at least 2 approaches for individual user
executing their privacy rights, for instance, via the privacy office email
address; ***@***.com, or via the route of Feedback imbedded in the App:
Me&rt;Personal Center&rt;Account and Security&rt;, etc. You do not have to pay a fee and
we will aim to respond you within 30 days. If you decide to email us, in your
request, please make clear what information you would like to have changed,
whether you would like to have your Personal Data deleted from our database or
otherwise let us know 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 further action on your request, for security purposes.
You may:
·Request access to the
Personal Data that we process about you: "My-Setting-Privacy
Settings-Personal Data Export";
·Request that we correct
inaccurate or incomplete Personal Data about you: 1) Modify your account number
(email address or phone number): "My-Setting-Account
and Security-Change your Account"; 2) Modify the nickname and/or
time zone: "My-Personal Information";
·Request deletion of Personal
Data about you: "My-Setting-Account and
Security-Delete Account", when you confirm the deletion of your
account, your Personal Data will be deleted accordingly.
·Request restrictions,
temporarily or 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 Confirm: the emailbox?;
·Request transfer of
Personal Data to you or a third party 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 send over the email request to Confirm: the emailbox?;
·Opt-out or object to our
use of Personal Data about you where our use is based on your consent or our
legitimate interests.
Withdrawal of
consent Confirm the following details:
We will exercise your privacy right to withdraw consent through the following
approaches:
1)For privacy permissions
acquired through device system settings, your consent can be withdrawn by
changing device permissions, including
Confirm: location, camera, photo album (picture library/video library),
microphone, Bluetooth settings, notification settings and 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 related to the Smart Device will not be collected;
6)By using product with the
"Try Now" mode, and not enable certain
location setting for particular smart scene, we will not collect any
Personal Data about you;
7)If you previously agreed to
associate 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 or
authorization, we may not be able to continue to provide you with certain
products or services correspondingly. However, your withdrawal of your consent
or authorization will not affect the processing of personal information based
on 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” (Deactivate Account）
Security Measures
We use commercially reasonable
physical, administrative, and technical safeguards to preserve the integrity
and security of your Personal Data. CR Smart Home provides various
security strategies to effectively ensure data security of user and device. As
for device access, CR Smart Home proprietary algorithms are
employed to ensure data isolation, access authentication, applying for
authorization. As for data communication, communication using security
algorithms and transmission encryption protocols and commercial
level information encryption transmission based on dynamic keys are
supported. As for data processing, strict data filtering and validation and
complete data audit are applied. As for data storage, all confidential information
of users will be safely encrypted for storage. If you have reason to believe
that your interaction with us is no longer secure (for example, if you feel
that the security of any account you might have with us has been compromised),
you could immediately notify us of the problem by emailing Please enter your
privacy email address.
Data Retention
We process your Personal Data for
the minimum period necessary for the purposes set out in this Policy, unless
there is a specific legal requirement for us to keep the data for a longer
retention period. We determine the appropriate retention period based on the
amount, nature, and sensitivity of your Personal Data, and after the retention
period ends, we will destruct your Personal Data.
·For as long as you
require us to fulfill the products and services you request from us as defined
in the Confirm user agreement or some other
terms of use?;
·Personal Data will no
longer be retained when you request to remove your Personal Data, we will
accordingly complete the task.
When we are unable to do so for
technical reasons, we will ensure that appropriate measures are put in place to
prevent any further such use of your Personal Data.
Children’s Privacy
Protecting the privacy of young
children is especially important to 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 of residence), and we request that these
individuals do not provide any Personal Data to us. We do not knowingly collect
Personal Data from any child unless we first obtain permission from that
child’s parent or legal guardian. If we become aware that we have collected
Personal Data from any child without permission from that child’s parent or
legal guardian, we will take steps to remove that information..
Changes to this Privacy Policy
We may update this Privacy Policy
to reflect changes to our information practices. If we make any material
changes we will notify you by email (send to the e-mail address specified in
your account) or by means of a notice in the mobile applications prior to the
change becoming effective. We encourage you to periodically review this page
for the latest information on our privacy practices.
Contact Us
If you have any questions about
our practices or this Privacy Policy, please contact us as follows:
CR Group Co., Ltd
Postal Mailing Address: 190 st
51 Beong Keng Knag1, Beoung Keng Kang, Phnom Penh, Cambodia
Email: Crgroup1719@gmail.com