Homeplus Digital Broadband Co., Ltd. Mobile Privacy Policy
Effective Date: 2022/5/1
Updated: 2022/4/22
Homeplus Digital Broadband Co., Ltdand subsidiaries (“we”, “us”, “our”, “Homeplus Digital Broadband Co., Ltd ”)
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”):
Confirm1: If the App has integrated the ‘Try Now’ or other features
representing non-login (visitor mode), if yes, please refer to the following
description and if no, please delete then.
If you do not want to provide your profile data when you start to
use any of the Services, you may use the App without login or creating an
account, and you may still use certain services, such as searching and
browsing any features on the Services. At this moment, we will not collect
Personal Data about account or profile, and the collected data will be limited
to those you have authorized to be collected for purpose of using the
additional functions of the App and/or the Smart Devices, as well as
corresponding usage information. However, if the Services you request or
purchase are based on your account, please go to the registration/login page for
guidance.
·Home+
SmartHome
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:
For other
branded mobile applications powered by Homeplus
Digital Broadband Co., Ltd , 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 by Homeplus
Digital Broadband Co., Ltdthat
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
·Account or Profile 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
Homeplus Digital Broadband Co., Ltdaccount 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.
- Feedback: When using
feedback and suggestion features in our Products, we will collect your
email address, mobile phone number and your feedback content to address
your problems and solve device failures on a timely basis.
·Information based on additional
functions: 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 real-time precise or 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 Data
Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/.
You may reject such use of your location information by managing the permission
settings in the Services, 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.
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.
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.
5)Additional services based on storage
permissions:
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.
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
·Device Information: When you interact
with our Product, we automatically collect device information, such as the MAC
address of your devices, IP address, wireless connection information, operating
system type and version, application version number, push notification
identifier, log files, and mobile network information.
·Usage Data: During your interaction
with our Sites and Services, we automatically collect usage data relating to
visits, clicks, downloads, messages sent/received, and other usage of our Sites
and Services.
·Log Information: When you use our app,
the system and exception log may be uploaded.
Please note that one 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 non-personal 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 anonymize
and desensitize such non-personal information.
·Location Information: When you enable
location-based functions through permission settings on your mobile device, we
will collect and process your location information to enable certain functions,
such as pairing with your Smart Devices. Also, we may collect information about
your real-time precise or non-precise geo-location when you use our specific
Products or Services, such as Please enter the product name.
Based on your consent, when you enable the
geo-fence feature on the Products, your location information will be generated
and shared with Google Map services. Please note that Google has corresponding
data protection measures, which you may refer to Google Data Protection Terms
for more details: https://privacy.google.com/businesses/gdprservices/. You may
reject such use of your location information by managing the permission
settings in the Products, upon which we will cease to collect and use your
location information.
3.Smart
Devices Related Information:
·Basic Information of Smart Devices:
When you connect your Smart Devices with our Products or 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 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.
·Confirm 5.1: 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);
Confirm5.2 (depending on the 5.1): 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 app, 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. Please enter the App name. The application is
authorized to connect with Apple Health.
·Confirm 5.3: 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 Services: We process your account and profile data, device
information, usage data, location information, and Smart Device related
information to provide you with our Products and Services that you have
requested or purchased. The legal basis for this processing is to perform
our contract with you according
to our Terms of Use.,
- Improve
Our Services: We process your device information, usage data, location
information and Smart Device related information to ensure the functions
and safety of our Products, to develop and improve our Products and
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 Terms of Use.
- 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 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 Terms of Use.
- Marketing
Communication: We may process your Personal Data to provide marketing and
promotional materials to you on the Services. If we do so, each
communication we send you will contain instructions permitting you to
opt-out of receiving future communications of that nature. If you do not
agree to sending you marketing communications, you may opt out when
you enter the App, or by changing your preferences in [Privacy Settings]
of the App. The legal basis for this processing is your consent..
- Personalization:
We may process your account and profile 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] in the App. The legal basis for this processing is your consent.
- Legal
Compliance: We may process your Personal Data as we believe to be
necessary or appropriate: (a) to comply with applicable laws and
regulations; (b) to comply with legal process; (c) to respond to requests
from public and government authorities (d) to enforce our terms and
conditions; (e) to protect our operations, business and systems; (f) to
protect our rights, privacy, safety or property, and/or that of other
users, including you; and (g) to allow us to pursue available remedies or
limit the damages that we may sustain.
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 Homeplus Digital Broadband Co., Ltd ,
we only share Personal Data in ways that we tell you about. We may share your
Personal Data with the following recipients:
- 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 Sites and Services.
- 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, incompatible new uses of your
Personal Data, and choices you may have regarding your Personal Data.
- As
we believe to be necessary or appropriate: (a) to comply with applicable
laws and regulations; (b) to comply with legal process; (c) to respond to
requests from public and government authorities, including public and
government authorities outside your country of residence; (d) to enforce
our terms and conditions; (e) to protect our operations, business and
systems; (f) to protect our rights, privacy, safety or property, and/or
that of other users, including you; and (g) to allow us to pursue
available remedies or limit the damages that we may sustain.
- To
subsidiaries or affiliates within our corporate family, to carry out
regular business activities.
Except for the
third parties described above, to third parties only with your consent.
International Transfer of Information Collected
Homeplus Digital Broadband Co., Ltdwill 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.
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:
Confirm6:
please provide at least 2 approaches for individual user executing their
privacy rights, for instance, via the privacy office email address; tigerhsiao@homeplus.net.tw 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;
·Request that we correct inaccurate or
incomplete Personal Data about you;
·Request deletion of Personal Data about
you;
·Request restrictions, temporarily or
permanently, on our processing of some or all Personal Data about you;
·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; and
·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: 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 location, camera, photo
album (picture library/video library), microphone, Bluetooth settings,
notifications and other related functions;
2) In the marketing
communications that you agree to, the information we send to you contains
instructions that allow you to withdraw your consent in accordance with the
“unsubscribe” method described in the information;
3) Unbind the
Smart Device through the app, and the information related to the Smart Device
will not be collected;
4) By using
product with the visitor mode, we will not collect any personal data about you;
When you
withdraw your consent or authorization, we may not be able to continue to
provide you with the 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.
Security
We
use commercially reasonable physical, administrative, and technical safeguards
to preserve the integrity and security of your Personal Data. Homeplus Digital
Broadband Co., Ltd. provides various
security strategies to effectively ensure data security of user and device. As
for device access, Homeplus Digital Broadband Co., Ltd. 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 Homeplus Digital Broadband Co., Ltd.
Data Retention
We
process your Personal Data for the minimum period necessary for the purposes
set out in this Privacy 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. 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 anyone under the age of thirteen (13)
unless we first obtain permission from that child’s parent or legal guardian.
If we become aware that we have collected Personal Data from anyone under the
age of thirteen (13) 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:
Homeplus Digital Broadband Co., Ltd.
Postal Mailing Address: 3F., No. 399, Ruiguang Rd., Neihu Dist., Taipei
City , Taiwan (R.O.C.)
Email: tigerhsiao@homeplus.net.tw