Privacy Policy
The guidance on prepare the Privacy Policy
(for reference only and please remove the guidance when launch your App):
1.
Please fill out the
information about corporate customer information;
2.
Please confirm contents
in highlighted to revise the policy;
3.
Please administer your
Privacy Policy from time to time according to the regulatory requirement.
Please enter the company name Mobile Privacy Policy
Effective Date: Please enter the date when this Privacy Policy
becomes effective
Updated: Please enter the date when this Privacy Policy is updated
Please
enter the company name and subsidiaries (“we”,
“us”, “our”, “Please enter the company name”) 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 T u y a 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.
·Please enter the App name 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:
Confirm2：please enter the contact information of corporate
customer privacy office or other responsible party who deal with privacy
matters.
Confirm3: Whether the customer will OEM/customize the App to
your customers. If yes, please refer to the following description; if not,
please delete then.
For other
branded mobile applications powered by Please
enter the company name, 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 Please
enter the company name that 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.
Confirm4: Determine whether the account registration/login is integrated
with a third-party account system, such as WeChat or Facebook. If yes, please refer
to the following description; if not, please delete then.
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 Please enter the company name account for quick login. We will ensure compliance with
applicable data protection laws and regulations, as well as agreements,
policies or documentations agreed with such third party regarding sharing
personal information, in processing your Personal Data.
- 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 connectioninformation,
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. For example, Please enter information
about the smart device report.
·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 T u y a 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 Please enter the company name, 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
Please
enter the company name will 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; ***@***.com,
or via the route of Feedback imbedded in the App: Me&rt;Personal
Center&rt;Account and Security&rt;, etc.
You do not have to pay a
fee and we will aim to respond you within 30 days. If you decide to email us,
in your request, please make clear what information you would like to have
changed, whether you would like to have your Personal Data deleted from our
database or otherwise let us know what limitations you would like to put on our
use of your Personal Data. Please note that we may ask you to verify your
identity before taking further action on your request, for security purposes.
You
may:
·Request access to the Personal Data
that we process about you;
·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.
Confirm7: if the App enables the account
deletion/termination, please fill out the route in the App to delete/terminate
the account.
Security
We
use commercially reasonable physical, administrative, and technical safeguards
to preserve the integrity and security of your Personal Data. Please enter the company name provides various
security strategies to effectively ensure data security of user and device. As
for device access, Please enter the company name
proprietary algorithms are employed to ensure data isolation, access
authentication, applying for authorization. As for data communication,
communication using security algorithms and transmission encryption protocols
and commercial level information encryption
transmission based on dynamic keys are supported. As for data processing,
strict data filtering and validation and complete data audit are applied. As
for data storage, all confidential information of users will be safely
encrypted for storage. If you have reason to believe that your interaction with
us is no longer secure (for example, if you feel that the security of any
account you might have with us has been compromised), you could immediately
notify us of the problem by emailing Please
enter your privacy email address.
Data
Retention
We
process your Personal Data for the minimum period necessary for the purposes
set out in this 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:
Please enter the full company
name
Postal Mailing Address: Please enter your company address
Email: Please enter your company email
address