Shenzhen Leiyun Optoelectronics Technology Co., Ltd. Privacy Policy
SHENZHEN LEIYUN Technology Co., Ltd. Mobile Privacy Policy
Last updated:November 24, 2021
SHENZHEN LEIYUN Technology Co., Ltd. and subsidiaries (“we”, “us”, “our”, “SHENZHEN LEIYUN Technology Co., Ltd.”) are committed to protecting the privacy of our users (“User”, “you” or “your”). This privacy policy (“Privacy Policy”) describes:
(i) our policies and procedures regarding Personal Data (as defined below) that we collect, use, share or other process as a result of your personal use of the following services, products, and corresponding mobile applications (collectively, the “Products”): AiLivin app.
(ii) the practices that we apply to your Personal Data; and
(iii) your rights and choices regarding your Personal Data.
PLEASE READ: WE MAY USE CERTAIN ANALYTICS OR TRACKING TECHNOLOGIES TO ENABLE THE CORE FUNCTIONALITIES OF OUR PRODUCTS, GATHER YOUR USE OF OUR PRODUCTS TO IMPROVE SUCH PRODUCTS’ FUNCTIONALITIES, AND DISPLAY PERSONALIZED CONTENT, ADs OR NOTIFICATIONS TO IMPROVE YOUR USER EXPERIENCE. BY CONTINUING TO USE OUR PRODUCTS WITHOUT CHANGING YOUR SETTINGS, YOU CONSENT TO OUR USE OF THESE TECHNOLOGIES ON YOUR DEVICE IN ACCORDANCE WITH THIS PRIVACY POLICY.
HOW TO OPT-OUT: You can opt-out by adjusting the current Product settings that allow us to use your Personal Data for Product Improvement or personalization of user interface with our Product. You can change your preferences by going to the “Me” Tab &rt; under the “Setting” icon (i.e., ) &rt; “Privacy Setting”. In the [Privacy Settings] section of the App, please move the toggle switch under “Device Analysis” and/or “Personalization” to opt-out.
In addition to this Privacy Policy, your use of the Products is governed by our Terms of Use (in which the AiLivin app is referred as “App”). If you do not agree with any provision of this Privacy Policy and the Terms of Use, you should not use our Products or services. Capitalized terms used but not defined in this Privacy Policy can be found in our Terms of Use.
If you have any questions, commentaries, suggestions or complaints, please contact us through the following contact methods:
Definition
In this Policy, “Personal Data” means information relating to our Users(i) who can be identified or are identifiable directly from that information only, or (ii) who can be indirectly identified from that information in combination of other information we have access.
The term “Smart Devices” refers to those computing devices produced or manufactured by hardware manufacturers, with robot interface and the ability to transfer data that connect wirelessly to a network, including smart home appliances, smart garment devices, smart air cleaning devices, etc.
What Personal Data do we collect?
For purposes described in the “Purposes and Legal Basis for processing Personal Data” section of this Privacy Policy, we will collect the following Personal Data:
1.Information We Collect from You
Account and Profile Data: In order to access certain features of the Platform,you will register for an account with us. During registration, we ask for the following data relating to your account, including your contact information, which includes your email address, contact number, username, and login credentials. During your interaction with our Products, we may further collect the following data relating to your profile and preference of use, including the nickname, avatar, country code, language preference or time zone information in your account so that you can access or use certain features of the Products.
Communications and Feedback: When you use the feedback and suggestion functions in our Products to report a problem with the Products or provide feedback, we will collect your email address, mobile contact number, and feedback content that you provide in order to address your concerns or questions. At the same time, if you receive email communications from us, we use certain tools to capture data related to if/when you open our message or click on any links or banners it contains.
(together, “Identity Data”).
By providing your Personal Data via the Products, you authorize us to initiate electronic communications by telephone to numbers (including to cellular phones) that are provided through the Products or as part of the registration, and text messages (SMS or MMS) to cellular phone numbers that are provided through the Products to provide transaction updates or other purposes related to the Products and our other services. We will not send marketing and/or promotional text messages to you that are unrelated to the services provided through the Products. You consent to such communications, which may occur by use of an automatic telephone dialing system. Standard data and message rates may apply for SMS and MMS alerts, whether you send or receive such messages, and you agree to be responsible for all such charges. Do not submit your information if you do not consent to being contacted by telephone, text, or email.
2.Information We Collect Automatically
2.1 Device information: When you interact with our Products via a computer or mobile device, including, without limitation, a desktop computer, laptop, mobile phone, tablet, or other electronic device (each, a “Device”), we will automatically collect device information (“Device Information”), which includes your device's MAC address, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log Documents, mobile network information. When you use Smart Devices to interact with our Products, we may collect additional Device Information about the type of device you use, unique device identifier (e.g., IMEI number), Bluetooth information, online status, activation time, firmware version and upgrade information, among others.
2.2 Usage data: During your interaction with our Products and services, we will automatically collect usage data related to visits, clicks, downloads, sending/receiving messages and other usage of our Products and services (“Usage Data”). Please refer to “Improve Our Services and Maintain Security “ and “Personalization” sections below for more instructions on how to disable the collection of Usage Data.
2.3 Anonymous Data: We may also collect, use, and share aggregated data that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third-party (together, “Anonymous Data”). The use and disclosure of Anonymous Data will not be subject to the terms of this Privacy Notice. We may create Anonymous data derived from your Personal Data and other individuals whose data we collect. Anonymous Data might include analytics information and information collected by us using software that monitors how you and other users interact with our Products. If we combine this type of Anonymous Data with other information to identify a specific natural person, or combine it with personal information, during the combined use period, this type of non-personal information will be treated as Personal Data, which will be subject to this Privacy Policy.
2.4. Location information: We may collect and use your location information (“Location Information”) so that you can access specific features of our Products. And when you use such specific features of our Products, we may collect real-time geographic location information about you based on your consent. When you enable geofencing on the app and consent to the collection of Location Information, the App will generate information about your location and share it with the Google map service. Due to strict data protection measures and subject to the “Third Party Websites and Services” section below, please refer to the Google Data Protection Policy for more instructions on protecting your personal data: https://privacy.google.com/businesses/gdprservices/. You can turn off this function by adjusting the location service settings in your mobile device at any time to stop the collection of your Location Information.
Purposes and Legal Basis for processing Personal Data
To the extent permitted by applicable law, we may use and process Personal Data described above to:
·Provide You Products: We process your Identity Data, Device Information, Usage Data, and/or Location Information to provide you with our Products and services that you have requested or purchased, including without limitation to set-up and maintain Your account, provide customer service, fulfil purchases through the Products. The legal basis for this processing is consent, or where applicable, our legitimate interests in the proper administration of our Products, and/or the performance of our contract with you according to our Terms of Use.,
·Improve Our Services and Maintain Security: We process your Device Information, Usage Data, and/or Location 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 process is to consent, or where applicable, our legitimate interests in the proper administration of our Products, and/or performance of our contract with you according to our Terms of Use. To disable the use of your Personal Data for improving our Services, you can change your preferences by going to the “Me” Tab &rt; under the “Setting” icon (i.e., ) &rt; “Privacy Setting”. In the [Privacy Settings] section of the App, please move the toggle switch under “Device Analysis” to turn it off.
·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 send you notifications related to the services you have bought, such as alert services (“Notification”). You can check the [App Notification] section in the App under the “Me” Tab and then select the “Setting” icon (i.e., ) to manage these communications. When you decide not to authorize the Notifications function, you may go to the “Me” Tab &rt; under the “Setting” icon (i.e., ) &rt; “App Notification”, and then move the toggle switch under “Enable Notification” to turn it off. Once you opt-out, we will no longer process your information for such intention. The legal basis for this processing is consent, or where applicable, our legitimate interests in the proper administration of our Products, and/or the performance of our contract with you according to our Terms of Use.
·Marketing Communication: We may process your Personal Data to provide marketing and advertising materials to you relating to the Products. If we do so, each email marketing communication we send you will contain instructions permitting you to opt-out of receiving future communications. If you do not want to receive marketing communications via push notification, you may disable this function when you enter the App, or by changing your preferences by going to the “Me” Tab &rt; under the “Setting” icon (i.e., ) &rt; “App Notification”. In the [App Notification] section of the App, please move the toggle switch under “Enable Notification” to turn it off. The legal basis for this processing is your consent, or where applicable, our legitimate interests in the proper administration of our Products.
·Personalization: We may process your Personal Data to personalize product design and to provide you with services customized for you, such as recommending and displaying information regarding Products suited to you, emailing or otherwise inviting you to engage in studies relating to your use of the Products. If you do not allow us to process your Personal Data for personalization, you may disable this function when you enter the App, or by changing your preferences by going to the “Me” Tab &rt; under the “Setting” icon (i.e., ) &rt; “Privacy Setting”. In the [Privacy Settings] section of the App, please move the toggle switch under “Personalization” to turn it off. The legal basis for this processing is your consent, or where applicable, our legitimate interests in the proper administration of our Products.
·Legal Compliance: We may process your Personal Data to the extent it is 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, including Terms of Use; (e) to protect our operations, business and systems in connection with establishing or exercising our legal rights or claims; (f) to exercise our rights, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud that undermine the 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 in connection defending against a legal claim. The legal basis for this processing is our legal obligations to comply with our obligations under applicable laws, or where applicableourlegitimate interest in the proper administration of our Products.
·Data Aggregation: We will use your Personal Data to create Anonymous Data, and use, retain, or disclose such Anonymous Data. The legal basis for this processing is our legitimate interest in the proper administration and improvement of our Products.
·Other Processing Activities. We may process any of the Personal Data identified in this Policy when necessary for:
-Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our Legitimate Interest in the proper protection of our business; and
-Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Privacy Policy for which your Personal Data was provided to us.
Who do we Share Personal Data with?
At SHENZHEN LEIYUN Technology Co., Ltd, we only share Personal Data in ways that we provide below. We may share your Personal Data with the following recipients:
·To our third-party service providers who need the Personal Data perform certain support or operational services to us or to provide their services to you on our behalf, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, surveys, and other features offered on our Products, among others.
·To third parties upon your consent in connection with the specific purpose of facilitating their provisions of Smart Devices, and/or networks and systems to you through which you access and use our Products and services.
·To an affiliate or other third party in the event of any reorganization, merger, divestiture (i.e., sale of all or portion of our business), restructuring, joint venture, assignment, transfer or other disposition of all or any section of our business, assets, or stock (including without limitation in connection with any bankruptcy or similar proceedings).
·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, including Terms of Use; (e) to protect our operations, business and systems in connection with establishing or exercising our legal rights or claims; (f) to exercise our rights, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud that undermine the 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 in connection defending against a legal claim.
·To our corporate subsidiaries or affiliates under the same control and ownership, and their respective officers, directors, employees, accountants, attorneys, or agents who need the Personal Data to help us provide our Products or process Personal Data on our behalf.
·To our Professional Advisors. We may share your information with our and our affiliates’ insurers and other professional advisors, including attorneys and accountants (“Professional Advisors”), that need access to your Personal Data to provide operational or other support services on our behalf.
·Except for the parties described above, to other third parties only with your consent for specific purposes requested by you, including Map positioning (for which we will share with third-party services provider, Google Maps, Your Device Information, including IP address and MAC address).
International Transfer of Information Collected
In order to facilitate our operations, we may transfer, store and process your personal data in countries other than where you live. These arrangements may involve your Personal Data being located in various countries around the world, e.g., United States, where privacy laws differ from EU, China, or United Kingdom. We only make these arrangements or transfers where we have implemented appropriate levels of contractual, technical and organizational safeguards to ensure an adequate level of data protection where your Personal Data is transferred to countries outside the EEA or your country of residence, including the current version of Standard Contractual Clauses approved by the European Commission or other data processing contract approved by the applicable government agencies. By using the Products or submitting Personal Data through your use of our Products or other services, you fully understand and unambiguously consent to such international transfer, processing, storage of, and hosting of such information to those countries and other jurisdictions, for which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to laws in those jurisdictions. Your information will also be disclosed to third parties as described in the “Who do We Share Personal Data With” section above.
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Your Rights Relating to Your Personal Data
We respect your rights to control your Personal Data. You may practice any of the following rights by sending your requests to the address noted in the “Contact Us” section below.
You may exercise your rights over your Personal Data at no charge, unless otherwise allowed by the applicable privacy laws. In most cases, we will reply within the earlier of 15 business days or 30 calendar days. Occasionally, it may take longer if your request is particularly complex, or you have made a number or requests. In this case, we will notify you and keep you posted. If you decide to send us a request via email, please indicate what information you want to change, whether you want to delete your personal data from our database, or any restrictions you want us to be subject to when using your personal data. Please note that for security reasons, we may ask you to verify your identity before further process your request
If you are a resident of European Union or European Economic Area (EEA), You may exercise the following rights under the General Data Protection Regulation (GDPR):
·Right to Access to the Personal Data that we process about you: You have the right to receive confirmation as to whether or not personal data concerning you is being processed and, where that is the case, access to the personal data;
·Right to correct inaccurate or incomplete Personal Data about you: Our goal is to keep your personal information accurate, current and complete. Please contact us if you believe your information is not accurate of it is changes;
·Right to Delete your Personal Data: In some cases, you have a legal right to request that we erase your personal data;
·Right to Restrict the process of your Personal Data: - You have the right to request that we restrict the processing of your personal data, under certain conditions;
·Right to object to Processing - You have the right to object to our processing of your Personal Data under certain conditions;
·Right to transfer of Personal Data to you or a third party (“Right to Portability”): You have the right to request that we transfer the Personal Data that we have collected to another organization, or directly to you, under certain conditions; and
·Opt-out or object to our use of Personal Data about you under certain conditions.
·Withdrawal of consent: We will practice your privacy right to withdraw consent through the following approaches:
1) If we obtain your consent through your Device’s system settings, you may withdraw your consent by changing your Device’s 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 marketing communication. Once we receive your instruction, we will promptly take corrective action. There may be certain communications that are required for legal or security purposes, including changes to various legal agreements, that you may not be able to limit.
3) Unlink the Smart Device through the app, and the information related to the Smart Device will not be assembled.
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 Data based on your consent before the withdrawal.
Accuracy and Updating Your Information. Our goal is to keep your Personal Data accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Privacy Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, deficient, or incomplete personal data that you provide to us.
California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining Products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at “Contact Us” section.
Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. SHENZHEN LEIYUN Technology Co., Ltd provides various security measures to effectively ensure data security of user and device. As for device access, SHENZHEN LEIYUN Technology Co., Ltd uses proprietary algorithms to provide for data isolation, access authentication, access control, and implement security measures to protect your Personal Data we collect from unauthorized access, improper use or disclosure, deletion, modification and unlawful destruction or accidental loss. However, the safety and security of your Personal Data also depends upon you. Where you use a password for access to our Products, you are responsible for keeping your password confidential. Do not share your password with anyone. Please refer to our Terms of Use for additional information regarding your obligations to secure your user account located at AiLivin app.
Despite these measures, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from our Products. If you feel that the security of any account you might have with us has been threatened, you could immediately notify us of the problem by emailing: support@nvccloud.com. How Long Do We Store your Personal Data?
We process your Personal Data for so long as it is reasonably necessary for the purposes set forth in this Privacy Policy, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements, unless there is a specific legal requirement for us to keep the data for a longer retention period.
After the retention period ends, we will delete your Personal Data. When we are unable to do so for technical reasons, we will implement appropriate measures to securely store your Personal Data and isolate it to prevent any further such use of your Personal Data. To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.
Third-Party Websites and Services
This Privacy Policy only applies to our Products and does not address or apply to, and we are not responsible for, the privacy, information or other practices of any third parties, including, without limitation any other third-party application or website to which our Product may contain a link. These third parties may at times gather information from or about you and have their own privacy policies. We do not control and are not responsible for the privacy practices of these third parties. If you click on an embedded third-party link, you will be redirected away from the Product to the external third-party website. You can check the URL to confirm that you have left the Product.
We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content or media provided by any third parties or their websites; (2) control third parties’ independent collection or use of your information; or (3) endorse any third-party information, products, services, or websites that may be reached through embedded links on the Product. Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.
Children’s Online Privacy Protection Act
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Product and services are not directed to children aged 13 or younger, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Product or provide any information to or on the Product. If you are under 13, please do not use or provide any information on the Product (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us via the “Contact Us” details provided at the end of this Privacy Policy.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business and data governance 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. The App may contain links to external sites or services which are not governed by this Privacy Policy. We cannot take responsibility for the privacy practices of any third-party sites to which we link. 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:
SHENZHEN LEIYUN Technology Co., Ltd
Postal Mailing Address: 1406, Block A, Building 11, SHENZHEN Bay Science and Technology Ecological Park, Nanshan District, SHENZHEN