Privacy Policy

Effective Date: 2023-12-01

Updated: 2023-12-01

Power World Machinery Equipment Co., Ltd subsidiaries (“we”, “us”, “our”, “Power WorldMachinery Equipment Co., Ltd”) are committed to protecting your privacy.This Privacy 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”):

·Power world 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 with yourPersonal 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:

For other branded mobile applications powered by PowerWorld Machinery Equipment Co., Ltd, our Clients control all the PersonalData collected through our Products. We collect the information under thedirection 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 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 collection personal sensitive data about you.

Smart Devices refers to those computing devices producedor manufactured 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 PowerWorld Machinery Equipment Co., Ltd that provide end users remote control toSmart 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 youto 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 youwith our 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 you authorize login to the Products with a third partyaccount, we will obtain from such third party your account information (such asportrait, nickname, region, gender, etc.) which may be bound with your PowerWorld Machinery Equipment Co., Ltd account for quick login. We willensure compliance with applicable data protection laws and regulations, as wellas agreements, policies or documentations agreed with such third partyregarding sharing personal information, in processing your Personal Data.

·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 of enteringthe App, operating system of your mobile phone, and the purposes you haveauthorized 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 arebased on your account, please go to the registration/login page for guidance.

·Feedback: When using feedback and suggestionfeatures in our Products, we will collect your email address, mobile phonenumber and your feedback content to address your problems and solve devicefailures on a timely basis.

Information based on additional functions:

Confirm: the system permissions that allow in the yourApp

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 your locationinformation by changing your mobile device settings ("My - Setting -Privacy Right Setting - Switch on/off Location Information"), upon whichwe 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 thecamera permission to pair with a Smart Device, take video, etc. Please be awarethat even if you have agreed to enable the camera permission, we will onlyobtain information 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 - Switch on/off Camera".

3)Additional services for accessing and uploadingpictures/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 - Switch on/off Photo Album".

4)Additional services related to microphone-basedservice:

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 - Switch on/off Microphone".

5)Additional services based on storagepermission(Android):

The purpose is to ensure the stable operation of the Appby utilizing the storage permission. After you give or indicate the permissionto read/write your mobile device’s storage, we will access pictures, files,crash log 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 - Switch on/off Storage".

6)Additional services based on Notification permission:

The reason why we ask you for the permission is to sendyou notifications about using the Smart Devices or Services, especially if youhave purchased security services and you require an alert or message so thatyou 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 requirethe 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 thepermission, 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）Additionalservices 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/on HomeKit permission".

10）Additionalservices based on HealthKit (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 - Turn off/on HealthKitpermission".

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

·Mobile Device Information: When you interact withour Services, in order to provide and maintain the normal operation of ourServices, to improve and optimize our Services, and to protect your accountsecurity as well, we automatically collect mobile device information, such as mobiledevice model number, IP address, wireless connection information, the type andversion of the operating system, application version number, pushnotification identifier, log files, and mobile network information. Meanwhile,we will collect your software version number. In order to ensure the securityof the operating environment or to provide services, we will collectinformation about the installed mobile applications and other software you use.

·Usage Data: During your interaction with ourwebsites and Services, we automatically collect usage data relating to visits,clicks, downloads, messages sent/received, and other usage of our websites andServices.

·Log Information: When you use the App, in orderto improve your user experience, the system and exception log may be uploaded,including your IP address, language preference setting, operating systemversion, date or time of access, so that we can facilitate and accuratelyidentify problems and help you solve them in timely manner.

Please note thatwe cannot identify a specific individual by using device information or loginformation 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 yourconsent 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 youconnect your Smart Devices with the Services, we may collect basic informationabout your Smart Devices such as device name, device ID, online status,activation time, firmware version, and upgrade information.

·Information collected during the process ofconnecting to a Smart Device: Based on the type of Smart Device you need toconnect, the basic information collected includes: Wi-Fi information, deviceMAC address, etc.

·Information Reported by Smart Devices: Dependingon the different Smart Devices you elect to connect with our Products orServices, we may collect different information reported by your Smart Devices.For example, Please enter information about the smart device report.

Purposes and legal basis for processing Personal Data

The purpose for which we may process information aboutyou are as follows:

·Provide You with Our Services: We process youraccount data, mobile device information, usage data, location information, andSmart Device related information to provide you with the Services that you haverequested. The legal basis for this processing is to perform our contract withyou according to user agreement or some other terms of user? Confirm.

·Improve Our Services: We process your mobiledevice information, usage data, location information and Smart Device relatedinformation to ensure the functions and safety of the Services, to develop andimprove the Services, to analyze the efficiency of our operations and to preventand trace fraudulent or inappropriate usage. The legal basis for thisprocessing is to perform our contract with you according to our user agreementor some other terms of user? Confirm.

·Non-marketing Communication: We process yourPersonal Data to send you important information regarding the Services, changesto our terms, conditions, and policies and/or other administrative information.At the same time, we will also send you notifications related to the services youhave purchased, such as alert services. You can check the “App Notification” inthe App ("Me &rt; Message Center &rt; Setting &rt;Notification Setting”) to manage these communications. When you decide not toenable the Notifications function, we will no longer process your informationfor such purpose. The legal basis for this processing is to perform ourcontract with you according to our user agreement or some other terms of user?Confirm.

·Data Analysis: In order to analyze the usage ofthe products we provide and improve your user experience, we will analyze thedata you provide us, a) we need to check your problems when you encounter anymalfunctions during the usage of the product, under such circumstance, you maynot able to opt-out because it is highly relate to your functionalities andquality of using our product and service, and b) analyze data about how youinterface with the product or under particular scenarios so that you can betterenjoy the convenience brought by our Services, under such circumstance, if youdo not agree to data analysis of your data, you can enter the privacy settingsof App (“My &rt; Settings &rt; Privacy Settings &rt; DataAnalysis”) to opt-out your selection. The legal basis for such processing isbased on your consent.

·Marketing Communication and Personalization: Wemay process your account data, usage data, device information to personalizeproduct design and to provide you with services tailored for you, such asrecommending and displaying information and advertisements regarding productssuited to you, and to invite you to participate in surveys relating to your useof the Services. If you do not allow us to process your Personal Data forpersonalization, you may opt out when you enter the App, or by changing yourpreferences in “Privacy Settings” (“Me&rt; Settings &rt; PrivacySettings &rt; Personalization”) in the App. The legal basis for thisprocessing is your consent.

·Legal Compliance. We disclose information if weare legally required to do so, or if we have a good faith belief that such useis 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, our users,a third party or the public as required or permitted by law; or

·detect, prevent or otherwise address security, fraud ortechnical 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 Power World Machinery Equipment Co., Ltd, weonly share Personal Data in ways that we tell you about. We may share yourPersonal Data with the following recipients:

·To our third-party service providers who perform certainbusiness-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 servicesto enable them to provide services to us.

·To our customers and other business partners who provideyou, directly or indirectly, with your Smart Devices, and/or networks andsystems 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 of anyreorganization, 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)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 violationthereof;

(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 parties mentioned above, we onlydisclose your Personal Data to other third parties with your consent.

International Transfer of Information Collected

Power World Machinery Equipment Co., Ltdwill 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 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:

You do not have to pay a fee and we will aim to respondyou within 30 days. If you decide to email us, in your request, please makeclear what information you would like to have changed, whether you would liketo have your Personal Data deleted from our database or otherwise let us knowwhat limitations you would like to put on our use of your Personal Data. Pleasenote that we may ask you to verify your identity before taking further actionon your 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 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 confirmthe deletion of your account, your Personal Data will be deleted accordingly.

·Request restrictions, temporarily or permanently, on ourprocessing of some or all Personal Data about you: Please send over yourrequest through "My-FAQ & Feedback", or send over the emailrequest to Confirm: the emailbox?;

·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 send over the email request to Confirm:the emailbox?;

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

Withdrawal of consent Confirm the following details: Wewill exercise your privacy right to withdraw consent through the followingapproaches:

1)For privacy permissions acquired through device systemsettings, your consent can be withdrawn by changing device permissions,including Confirm: location, camera, photo album (picture library/videolibrary), microphone, Bluetooth settings, notification settings and otherrelated functions;

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

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 account witha third-party service, such as a health platform, please unbind it on thethird-party platform.

When you withdraw your consent or authorization, we maynot 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 Deletion of the Account: You can findthe 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 yourPersonal Data. Power World Machinery Equipment Co., Ltd providesvarious security strategies to effectively ensure data security of user anddevice. As for device access, Power World Machinery Equipment Co., Ltd 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 Pleaseenter your privacy email address.

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 the productsand services you request from us as defined in the Confirm user agreement orsome other terms of use?;

·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, 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 is especiallyimportant to us. The Services are not directed to individuals under the age ofthirteen (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 changes toour information practices. If we make any material changes we will notify youby email (send to the e-mail address specified in your account) or by means ofa notice in the mobile applications prior to the change becoming effective. Weencourage 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:

Power World Machinery Equipment Co., Ltd

Email: ida@powerworld-e.com