Privacy Policy
Effective Date:15/June/2024
Updated: 15/June/2024
Foshan LeqinTrading Co., Ltd. and subsidiaries (“we”, “us”, “our”, “Foshan LeqinTrading Co., Ltd.”) are committed to protecting your privacy. This PrivacyPolicy (“Policy”) describes our practices in connection with informationprivacy on Personal Data we process through your individual use of thefollowing services, products, and related mobile applications (collectively,the “Products”):
VANSEA HOME Mobile Application
Before you useour Products, please carefully read through this Policy and understand ourpurposes and practices of collection, processing of your Personal Data,including how we use, store, share and transfer Personal Data. In the Policyyou will also find ways to execute your rights of access, update, delete orprotect your Personal Data.
When you acceptthis Policy when you register with your Personal Data, or if you start to useour Products and does not expressly object to the contents of this Policy, wewill consider that you fully understand and agree with this Policy. If you haveany question r regarding this Policy, please do not hesitate to contact us via:
please enterthe contact information of corporate customer privacy office or otherresponsible party who deal with privacy matters.
For otherbranded mobile applications powered by Foshan Leqin Trading Co., Ltd.,our Clients control all the Personal Data collected through our Products. Wecollect the information under the direction of our Clients and the processingof such information shall be limited to the purpose of providing the servicefor which our Clients has engaged us. If you are a customer of one of our Clientsand would no longer like to be contacted by one of our Clients that use ourservice, 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 orreflect the activity of an individual, either from that information alone, orfrom that information and other information we have access to about thatindividual.
PersonalSensitive Data includes personal biometric information, communication recordsand contents, health information, transaction information, and precise locationinformation. When we collect Personal Sensitive Data from you, we will generatean explicit notification for your consent before we collection personalsensitive data about you.
Smart Devicesrefers to those computing devices produced or manufactured by hardwaremanufacturers, with human-machine interface and the ability to transmit datathat connect wirelessly to a network, including: smart home appliances, smartwearable devices, smart air cleaning devices, etc.
Apps refers tothose mobile applications developed by Foshan Leqin Trading Co., Ltd. that provide end usersremote control to Smart Devices and with the ability to connect to the supplierIoT Platform.
What Personal Data do we collect
In order toprovide our services to you, we will ask you to provide necessary Personal Datathat is required to provide those services. If you do not provide your PersonalData, we may not be able to provide you with our products or services.
1.Information YouVoluntarily 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, phonenumber, user name, and login credentials. During your interaction with ourProducts, we may further collect your nickname, profile picture, country code,language preference or time zone information into your account.
If you authorize login to theProducts with a third party account, we will obtain from such third party youraccount information (such as portrait, nickname, region, gender, etc.) whichmay be bound with your Foshan Leqin Trading Co., Ltd. account forquick login. We will ensure compliance with applicable data protection laws andregulations, as well as agreements, policies or documentations agreed with suchthird party regarding sharing personal information, in processing your PersonalData.
However, if the Services yourequest or purchase are based on your account, please go to theregistration/login page for guidance.
Information basedon additional functions:
In order tooffer you with more convenient and higher-quality Services with optimized userexperiences, we may collect and use certain information if you consent to useadditional functions in the App. Please note, if you do not provide suchinformation, you may continue to use basic Services of the App and connectedSmart Devices, but certain features based on these additional functions may notbe available. These additional functions may include:
1)Additional functions based on location information:
When you enablethe location-based functions through permission settings on your mobile device,we will collect and process your location information to enable thesefunctions, such as pairing with your Smart Devices. Also, we may collectinformation about your: a) real-time and precise location, for instance whenyou choose to use the automation scenarios for controlling your Smart Devices,or b) non-precise geo-location when you use certain Smart Devices or theServices, such as robot cleaner and weather service.
Based on yourconsent, when you enable the geo-fence feature, your location information willbe generated and shared with Google Maps services. Please note that Google hascorresponding data protection measures, which you may refer to Google’s DataProcessing and Security Terms for more details.
You may disablethe collection and use of your location information by changing your mobiledevice settings ("My - Setting - PrivacyRight Setting - Switch on/off Location Information"), upon which wewill cease to collect and use your location information.
2)Additional services based on camera:
You may use thecamera to scan the code by turning on the camera permission to pair with aSmart Device, take video, etc. Please be aware that even if you have agreed toenable the camera permission, we will only obtain information when you activelyuse the camera for scanning codes, video recording, etc.
You may opt-outthe 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 usethis function to upload your photos/pictures/videos after turning on the photoalbum permission, so as to realize functions such as changing the avatar,reporting device usage problems by providing photo proofs, etc.. When you usethe photos and other functions, we will not recognize this information; butwhen you report a device usage problem, we may use the photos/pictures youupload to locate your problem.
You may opt-outthe 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 themicrophone to send voice information after turning on the microphonepermission, such as shooting videos, waking up the voice assistant, etc. Forthese functions, we will collect your voice information to recognize yourcommand. Please be aware that even if you have agreed to enable the microphonepermission, we will only obtain voice information through the microphone whenyou voluntarily activate the microphone in the App.
You may opt-outthe using of microphone permission: "My -Setting - Privacy Right Setting - Switch on/off Microphone".
5)Additional services based on storagepermission(Android):
The purpose isto 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’sstorage, we will access pictures, files, crash log information and othernecessary information from your mobile device’s storage to provide you withfunctions, such as information publications, or record the crash loginformation locally.
You may opt-outthe using of storage permission: "My -Setting - Privacy Right Setting - Switch on/off Storage".
6)Additional services based on Notificationpermission:
The reason whywe ask you for the permission is to send you notifications about using theSmart Devices or Services, especially if you have purchased security servicesand you require an alert or message so that you can capture the real-timestatus.
You may opt-outthe using of App notifications: "My -Message Center - Setting - Switch on/off Notifications".
7) Additional services based on Alert Windowpermission：
You may chooseto bind a camera in the App and require the App to display the real-time imageof the camera in a separate window.
You may opt-outthe using of alert window information: "My- Setting - Privacy Right Setting - Switch on/off Alert Window".
8) Additional services based on Bluetooth permission:
You can enableBluetooth functions after turning on the permission, including controlling theSmart 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 Bluetoothpermission, we will only use Bluetooth for communication in these scenarios:display device status on the home page and Smart Device panel; perform devicecontrol on the home page and Smart Device panel; discovering Smart Devices onthe home page and the add device page, Smart Device distribution network.
You may opt-outthe using of Bluetooth via "My - Settings- Privacy Setting - Disable/Enable Bluetooth permission".
9）Additional services based onHomeKit permission (iOS):
You can enablerelated functions after enabling HomeKit permissions, including discoveringSmart Devices, enabling Smart Device network configuration, controlling SmartDevices, and checking device status. Among these functions, we will processdata 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 HomeKitdevices, HomeKit device network configuration; in "Settings -HomeKit" for discovering HomeKit devices, HomeKit device networkconfiguration.
You may opt-outthe using of HomeKit permission via "My -Settings - Privacy Settings-Turn off/on HomeKit permission".
10）Additional services based onHealthKit (iOS):
You canproactively enable related functions after enabling HealthKit permission,including statistics on weight, height, running, and swimming. In thesefunctions, we will exchange data with the health-related functionalities thatcomes with the iOS system through HealthKit. Please be aware that even if youhave agreed to enable HealthKit permission, we will only use them in thesescenarios: when you use the health-related Smart Device, such as body fatscales, bracelets, watch and consent to use the HealthKit, the data reported bythe Smart Device will be transferred to HealthKit.
You may opt-outthe using of HealthKit permission via "My- Settings - Privacy Settings - Turn off/on HealthKit permission".
Please notethat if you turn on any permission, you authorize us to collect and userelevant personal information to provide you with corresponding Services. Onceyou turn off any permission, we will take it as canceling the authorization,and we will no longer continue to collect Personal Data based on thecorresponding permissions, and the related functions may be terminated.However, your decision to turn off the permission will not affect the previouscollection and use of information based on your authorization.
2.Information WeCollect Automatically
· Mobile Device Information: When you interact with ourServices, 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 asmobile device model number, IP address, wireless connection information, thetype and version 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 withour websites and Services, we automatically collect usage data relating tovisits, clicks, downloads, messages sent/received, and other usage of ourwebsites and Services.
· 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 that we cannot identify aspecific individual by using device information or log information alone.However, if these types of non-personal information, combined with otherinformation, may be used to identify a specific individual, such informationwill be treated as Personal Data. Unless we have obtained your consent orunless otherwise provided by data protection laws and regulations, we willaggregate or desensitize such information..
3.Smart DevicesRelated Information:
· Basic Information of SmartDevices: 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 theprocess of connecting 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 SmartDevices: Depending onthe different Smart Devices you elect to connect with our Products or Services,we may collect different information reported by your Smart Devices. Forexample, Please enter information aboutthe smart device report.
· Confirm: If the product involves sensitive personalinformation, such as health products, please be sure to explain it in theprivacy policy. For example: smart scales or fitness trackers may report yourheight, weight, body fat content (BFM) , Body mass index (BMI) and skeletalmuscle content (SMM); Confirm: Whetherintegrated third-party health analysis functions, such as Apple Health, GoogleHealth, etc., if so, please refer to the following description; if not, you candelete then:
Please note that when you activelyagree to enter the App name and the application is connected to the AppleHealth(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 ofsharing data is only to measure and analyze health-related indicators relatedto you, and it will never be disclosed to other third parties. You can close atany time by managing the HealthKit settings page.
Purposes and legalbasis for processing Personal Data
The purpose forwhich 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 relatedinformation to provide you with the Services that you have requested. The legalbasis for this processing is to perform our contract with you according to user agreement or some other terms of user
· Improve Our Services: We process your mobile deviceinformation, 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 toprevent and trace fraudulent or inappropriate usage. The legal basis for thisprocessing is to perform our contract with you according to our user agreement or some other terms of user
· Non-marketing Communication: We process your Personal Data tosend you important information regarding the Services, changes to our terms,conditions, and policies and/or other administrative information. At the sametime, we will also send you notifications related to the services you havepurchased, such as alert services. You can check the “App Notification” in theApp ("Me &rt; Message Center &rt; Setting&rt; Notification Setting”) to manage these communications. When youdecide not to enable the Notifications function, we will no longer process yourinformation for such purpose. The legal basis for this processing is to performour contract with you according to our useragreement or some other terms of user
· 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; PrivacySettings &rt; Data Analysis”) to opt-out your selection. The legal basisfor such processing is based on your consent.
· Marketing Communication andPersonalization: We may process your account data, usage data, device informationto personalize product design and to provide you with services tailored foryou, such as recommending and displaying information and advertisementsregarding products suited to you, and to invite you to participate in surveysrelating to your use of the Services. If you do not allow us to process yourPersonal Data for personalization, you may opt out when you enter the App, orby changing your preferences in “Privacy Settings”(“Me&rt; Settings &rt; Privacy Settings &rt; Personalization”) in theApp. The legal basis for this processing 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, andstandards, including investigation of any potential violation thereof;
· protect the rights, property or safety of us, our users, a thirdparty or the public as required or permitted by law; or
· detect, prevent or otherwise address security, fraud ortechnical issues.
If there is anychange in the purposes for processing your personal data, we will inform suchchange to you via email and/or a prominent notice on our website of suchchanges of purposes, and choices you may have regarding your Personal Data.
Who do we SharePersonal Data with?
At FoshanLeqin Trading Co., Ltd., we only share Personal Data in ways that we tellyou about. We may share your Personal 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 provide you,directly or indirectly, with your Smart Devices, and/or networks and systemsthrough which you access and use our websites and Services.
· To subsidiaries or affiliates within our corporate family forpurpose of regular business activities based on our instructions and incompliance 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 andother agreements, policies, and standards, including investigation of anypotential violation thereof;
(c) Protect our operation andbusiness systems;
(d)Protect the rights, propertyor safety of us, our users, a third party or the public as required orpermitted by law; or
(e)Perform risk management,screening and checks for unlawful, fraudulent, deceptive or maliciousactivities.
Except for thethird parties mentioned above, we only disclose your Personal Data to otherthird parties with your consent.
InternationalTransfer of Information Collected
Foshan LeqinTrading Co., Ltd. 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 on the basis of approved EU standard contractualclauses 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 wouldlike further detail on the safeguards we have in place, you can contact usdirectly as described in this Privacy Policy.
Your RightsRelating to Your Personal Data
We respect yourrights and control over your Personal Data. You may exercise any of thefollowing rights:
You do not haveto pay a fee and we will aim to respond you within 30 days. If you decide toemail us, in your request, please make clear what information you would like tohave changed, whether you would like to have your Personal Data deleted fromour database or otherwise let us know what limitations you would like to put onour use of your Personal Data. Please note that we may ask you to verify youridentity 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 Dataabout you: 1) Modify your account number (email address or phone number): "My-Setting-Account and Security-Change yourAccount"; 2) Modify the nickname and/or time zone:"My-Personal Information";
· Request deletion of Personal Data about you: "My-Setting-Account and Security-DeleteAccount", when you confirm the deletion of your account, yourPersonal 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 email request to Confirm: the emailbox?;
· Request transfer of Personal Data to you or a third party wherewe process the data based on your consent or a contract with you, and where ourprocessing is automated: Please send over your request through "My-FAQ & Feedback"
· Opt-out or object to our use of Personal Data about you whereour use is based on your consent or our legitimate interests.
Withdrawalof consent Confirm the following details: We will exercise your privacy right to withdrawconsent through the following approaches:
1)For privacypermissions acquired through device system settings, your consent can be withdrawnby changing device permissions, includingConfirm: location, camera, photo album (picture library/video library),microphone, Bluetooth settings, notification settings and other relatedfunctions;
2)You mayopt-out the non-marketing communication through “Me&rt; Message Center &rt; Notification Settings” to manage your selection;
3)You mayopt-out the data analysis features through “Me&rt; Settings &rt; Privacy Settings”;
4)You mayopt-out the Personalization feature through “Me&rt; Settings &rt; Privacy Settings &rt; Personalization”;
5)Unbind theSmart Device through the App, and the information related to the Smart Devicewill not be collected;
6)By usingproduct with the "Try Now" mode, and not enable certainlocation setting for particular smart scene, we will not collect anyPersonal Data about you;
7)If youpreviously agreed to associate App account with a third-party service, such asa health platform, please unbind it on the third-party platform.
When youwithdraw your consent or authorization, we may not be able to continue toprovide you with certain products or services correspondingly. However, yourwithdrawal of your consent or authorization will not affect the processing ofpersonal information based on your consent before the 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 usecommercially reasonable physical, administrative, and technical safeguards topreserve the integrity and security of your Personal Data. Foshan LeqinTrading Co., Ltd. provides various security strategies to effectivelyensure data security of user and device. As for device access, Foshan LeqinTrading Co., Ltd. proprietary algorithms are employed to ensure dataisolation, access authentication, applying for authorization. As for datacommunication, communication using security algorithms and transmissionencryption protocols and commercial level information encryptiontransmission based on dynamic keys are supported. As for data processing,strict data filtering and validation and complete data audit are applied. Asfor data storage, all confidential information of users will be safelyencrypted for storage. If you have reason to believe that your interaction withus is no longer secure (for example, if you feel that the security of anyaccount you might have with us has been compromised), you could immediatelynotify us of the problem by emailing Please enter your privacy emailaddress.
Data Retention
We process yourPersonal Data for the minimum period necessary for the purposes set out in thisPolicy, unless there is a specific legal requirement for us to keep the datafor a longer retention period. We determine the appropriate retention periodbased on the amount, nature, and sensitivity of your Personal Data, and afterthe retention period ends, we will destruct your Personal Data.
· For as long as you require us to fulfill the products andservices you request from us as defined in the Confirmuser agreement or some other terms of use
· Personal Data will no longer be retained when you request toremove your Personal Data, we will accordingly complete the task.
When we areunable to do so for technical reasons, we will ensure that appropriate measuresare put in place to prevent any further such use of your Personal Data.
Children’sPrivacy
Protecting theprivacy of young children is especially important to us. The Services are notdirected to individuals under the age of thirteen (13) (or such other ageprovided by applicable law in your country/region of residence), and we requestthat these individuals do not provide any Personal Data to us. We do notknowingly collect Personal Data from any child unless we first obtainpermission from that child’s parent or legal guardian. If we become aware thatwe have collected Personal Data from any child without permission from thatchild’s parent or legal guardian, we will take steps to remove thatinformation..
Changes to thisPrivacy Policy
We may updatethis Privacy Policy to reflect changes to our information practices. If we makeany material changes we will notify you by email (send to the e-mail address specifiedin your account) or by means of a notice in the mobile applications prior tothe change becoming effective. We encourage you to periodically review thispage for the latest information on our privacy practices.
Contact Us
If you have anyquestions about our practices or this Privacy Policy, please contact us asfollows:
Foshan LeqinTrading Co., Ltd.
Email: prettycare-help@outlook.com