Privacy Policy
Effective
Date: March 31 ,2023
Updated: March
31 ,2023
This APP
respects and protects the privacy of all users who use the service. To provide
you with more accurate and personalized service, the APP will be in accordance
with the provisions of this Privacy Policy to use and disclose your personal
information. But the APP will deal with this information with a high degree of
diligence and prudence.
Before
you start using our Services, 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 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:
Email:-
falcon.smartmanager@gmail.com.
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.
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
·Registered
Account 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.
·Non-registered
Account: If you do not want to provide your account data when you start to use
any of the Services, you may use the App without logging in or creating an account,
namely the “Try Now” mode, and you may still use certain Services, such as
searching and browsing any features on the App by creating a guest ID. When you
are using the "Try Now" mode, we will not collect Personal Data
related to your account. Collection and use of the Personal Data collected here
will be limited to: the time of entering the App, operating system of your
mobile phone, and the purposes you have authorized in using the additional
functions of the App and/or the Smart Devices. For instance, if you enable the
location setting in the "Try Now" mode, the location data will be
uploaded for supporting the function. Once you exit from the "Try
Now" mode, we will remove your data instantly and permanently.
·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: a) real-time and precise location, for instance when
you choose to use the automation scenarios for controlling your Smart Devices,
or b) 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’s
Data Processing and Security Terms for more details.
You may
disable the collection and use of your location information by changing your
mobile device settings ("My - Setting - Privacy Right Setting - Switch
on/off Location Information"), 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.
You may
opt-out the using of camera permission: "My - Setting - Privacy Right
Setting - Switch on/off Camera".
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.
You may
opt-out the using of photo album permission: "My - Setting - Privacy Right
Setting - Switch on/off Photo Album".
4)Additional
services related to microphone-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.
You may
opt-out the using of microphone permission: "My - Setting - Privacy Right
Setting - Switch on/off Microphone".
5)Additional
services based on storage permission(Android):
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.
You may
opt-out the using of storage permission: "My - Setting - Privacy Right
Setting - Switch on/off Storage".
6)Additional
services based on Notification permission:
The
reason why we ask you for the permission is to send you notifications about
using the Smart Devices or Services, especially if you have purchased security
services and you require an alert or message so that you can capture the
real-time status.
You may
opt-out the using of App notifications: "My - Message Center - Setting -
Switch on/off Notifications".
7)
Additional services based on Alert Window permission:
You may
choose to bind a camera in the App and require the App to display the real-time
image of the camera in a separate window.
You may
opt-out the using of alert window information: "My - Setting - Privacy
Right Setting - Switch on/off Alert Window".
8)
Additional services based on Bluetooth permission:
You can
enable Bluetooth functions after turning on the permission, including
controlling the Smart 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 Bluetooth
permission, we will only use Bluetooth for communication in these scenarios:
display device status on the home page and Smart Device panel; perform device
control on the home page and Smart Device panel; discovering Smart Devices on
the home page and the add device page, Smart Device distribution network.
You may
opt-out the using of Bluetooth via "My - Settings - Privacy Setting -
Disable/Enable Bluetooth permission".
9)Additional services based on HomeKit permission
(iOS):
You can
enable related functions after enabling HomeKit permissions, including
discovering Smart Devices, enabling Smart Device network configuration,
controlling Smart Devices, and checking device status. Among these functions,
we will process data 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 HomeKit devices, HomeKit device network configuration; in
"Settings - HomeKit" for discovering HomeKit devices, HomeKit device
network configuration.
You may
opt-out the using of HomeKit permission via "My - Settings - Privacy
Settings-Turn off/on HomeKit permission".
10)Additional services based on HealthKit (iOS):
You can
proactively enable related functions after enabling HealthKit permission,
including statistics on weight, height, running, and swimming. In these
functions, we will exchange data with the health-related functionalities that
comes with the iOS system through HealthKit. Please be aware that even if you
have agreed to enable HealthKit permission, we will only use them in these
scenarios: when you use the health-related Smart Device, such as body fat
scales, bracelets, watch and consent to use the HealthKit, the data reported by
the Smart Device will be transferred to HealthKit.
You may
opt-out the using of HealthKit permission via "My - Settings - Privacy
Settings - Turn off/on HealthKit permission".
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
·Mobile
Device Information: When you interact with our Services, in order to
provide and maintain the normal operation of our Services, to improve and
optimize our Services, and to protect your account security as well, we
automatically collect mobile device information, such as mobile device model
number, IP address, wireless connection information, the type and version of
the operating system, application version number, push notification
identifier, log files, and mobile network information. Meanwhile, we will
collect your software version number. In order to ensure the security of the operating
environment or to provide services, we will collect information about the
installed mobile applications and other software you use.
·Usage
Data: During your interaction with our websites and Services, we
automatically collect usage data relating to visits, clicks, downloads,
messages sent/received, and other usage of our websites and Services.
·Log
Information: When you use the App, in order to improve your user
experience, the system and exception log may be uploaded, including your IP
address, language preference setting, operating system version, date or time of
access, so that we can facilitate and accurately identify problems and help you
solve them in timely manner.
Please
note that
we 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 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 aggregate or desensitize such information..
3.Smart
Devices Related Information:
·Basic
Information of Smart Devices: When you connect your Smart Devices with the
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
collected during the process of connecting to a Smart Device: Based on the
type of Smart Device you need to connect, the basic information collected
includes: Wi-Fi information, device MAC address, etc.
·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.
When you
voluntarily use a smart camera (IPC service) and connect to the App platform:
When you
connect a doorbell camera, a door lock, or a smart surveillance camera through
Falcon Smart service to monitor the security of your residence, during the
process, the device may capture the images if it recognizes someone or an
object is moving around, and then provide you a playback of related
surveillance content. At this time, we will automatically encrypt the captured
image and save it locally on the device. When you actively choose and
successfully purchase cloud storage service, the smart camera will upload the
pictures or video files you have taken to the cloud for further storage so that
you can review them on the App. We will keep your information based on the
cloud storage service you purchase. When you choose to delete the picture in
advance in the Falcon Smart App, you can delete it in the message center and if
you need to delete a video on the App, the cloud will respond to delete
immediately the video files you stored in the cloud service.
Purposes
and legal basis for processing Personal Data
The
purpose for which 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 related information to provide you with
the Services that you have requested. The legal basis for this processing is to
perform our contract with you according to User Agreement
Improve
Our Services: We
process your mobile device information, usage data, location information and
Smart Device related information to ensure the functions and safety of the
Services, to develop and improve the 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 User Agreement
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 ("Me -&rt; Message Center -&rt; Setting -&rt;
Notification Setting”) 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 user agreement or some other terms of user?
Confirm.
Data
Analysis: In order
to analyze the usage of the products we provide and improve your user
experience, we will analyze the data you provide us, a) we need to check your
problems when you encounter any malfunctions during the usage of the product,
under such circumstance, you may not able to opt-out because it is highly
relate to your functionalities and quality of using our product and service,
and b) analyze data about how you interface with the product or under particular
scenarios so that you can better enjoy the convenience brought by our Services,
under such circumstance, if you do not agree to data analysis of your data, you
can enter the privacy settings of App (“My -&rt; Settings -&rt; Privacy
Settings -&rt; Data Analysis”) to opt-out your selection. The legal basis for
such processing is based on your consent.
Marketing
Communication and Personalization: We may process your account 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”
(“Me-&rt; Settings -&rt; Privacy Settings -&rt; Personalization”) in the App.
The legal basis for this processing is your consent.
·Legal
Compliance. We disclose information if we are legally required to do so, or
if we have a good faith belief that such use is reasonably necessary to:
·comply
with a legal obligation, process or request;
·enforce
our User Agreement and other agreements, policies, and standards, including
investigation of any potential violation thereof;
·protect
the rights, property or safety of us, our users, a third party or the public as
required or permitted by law; or
·detect,
prevent or otherwise address security, fraud or technical issues.
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?
We only
share Personal Data in ways that we tell you about. Without your consent, we
will not disclose your Personal Data to third-party companies, organizations,
or individuals except in the following cases:
·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 websites and Services.
·To
subsidiaries or affiliates within our corporate family for purpose of regular
business activities based on our instructions and in compliance with applicable
law, this Policy and other appropriate confidentiality and security measures.
·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, and choices you may have regarding your Personal Data.
·As we
believe in good faith that access to, or use, preservation, or disclosure of
the information is reasonably necessary or appropriate to:
(a)Comply
with applicable law, regulation, legal process, or lawful governmental request;
(b)Enforce
User Agreement and other agreements, policies, and standards, including
investigation of any potential violation thereof;
(c)
Protect our operation and business systems;
(d)Protect
the rights, property or safety of us, our users, a third party or the public as
required or permitted by law; or
(e)Perform
risk management, screening and checks for unlawful, fraudulent, deceptive or
malicious activities.
Except
for the third parties mentioned above, we only disclose your Personal Data to
other third parties with your consent.
International
Transfer of Information Collected
Wewill 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:
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:
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: "My-Setting-Privacy
Settings-Personal Data Export";
·Request
that we correct inaccurate or incomplete Personal Data about you: 1) Modify
your account number (email address or phone number): "My-Setting-Account
and Security-Change your Account"; 2) Modify the nickname and/or time
zone: "My-Personal Information";
·Request
deletion of Personal Data about you: "My-Setting-Account and
Security-Delete Account", when you confirm the deletion of your account,
your Personal Data will be deleted accordingly.
·Request
restrictions, temporarily or permanently, on our processing of some or all
Personal Data about you: Please send over your request 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 where we process the data
based on your consent or a contract with you, and where our processing is
automated: Please send over your request through "My-FAQ &
Feedback", or send over the email request to Confirm: the emailbox?;
·Opt-out
or object to our use of Personal Data about you where our use is based on your
consent or our legitimate interests.
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,
notification settings and other related functions;
2)You may
opt-out the non-marketing communication through “Me -&rt; Message Center -&rt;
Notification Settings” to manage your selection;
3)You may
opt-out the data analysis features through “Me -&rt; Settings -&rt; Privacy
Settings”;
4)You may
opt-out the Personalization feature through “Me -&rt; Settings -&rt; Privacy
Settings -&rt; Personalization”;
5)Unbind
the Smart Device through the App, and the information related to the Smart
Device will not be collected;
6)By
using product with the "Try Now" mode, and not enable certain
location setting for particular smart scene, we will not collect any
Personal Data about you;
7)If you
previously agreed to associate App account with a third-party service, such as
a health platform, please unbind it on the third-party platform.
When you
withdraw your consent or authorization, we may not be able to continue to
provide you with certain 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.
About Deletion
of the Account: You can find the Delete function through “Me -&rt; Settings
-&rt; Account and Security -&rt; Delete Account” (Deactivate Account)
Security
Measures
We use
commercially reasonable physical, administrative, and technical safeguards to
preserve the integrity and security of your Personal Data. Weprovides
various security strategies to effectively ensure data security of user and
device. As for device access, We 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 falcon.smartmanager@gmail.com
Data
Retention
We
process your Personal Data for the minimum period necessary for the purposes
set out in this 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.
·For as
long as you require us to fulfil the products and services you request from us
as defined in the Confirm user agreement or some other terms of use?;
·Personal
Data will no longer be retained when you request to remove your Personal Data,
we will accordingly complete the task.
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 any child unless we first obtain
permission from that child’s parent or legal guardian. If we become aware that
we have collected Personal Data from any child 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:
Email: falcon.smartmanager@gmail.com