Privacy Policy
Effective Date: April 30, 2024
Updated: April 30, 2024
MDX Electronics and subsidiaries 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”):
CASA CONECTADA Mobile Application
Before you use our Products, please carefully read through this
Policy and understand our purposes and practices of collection and 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:
email:
info@mdxelectronics.com
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 devices, etc.
Apps refers to those mobile applications developed by MDX
Electronicsthat 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 the 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, username, 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.
However,
if the Services you request or purchase are based on your account, please go to
the registration/login page for guidance.
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 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.
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.
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.
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.
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.
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.
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.
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.
Who do we Share Personal Data with?
At MDX Electronics, 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 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 our 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
MDX Electronics 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:
Please provide at least 2 approaches for individual user
executing their privacy rights, for instance, via the privacy office email
address; info@mdxelectronics.com or via
the route of Feedback imbedded in the App: CASA CONECTADA. 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); 2) Modify the nickname and/or time zone:
·Request deletion of Personal Data about you: 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, send over the email request to info@mdxelectronics.com. ·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 an email request to info@mdxelectronics.com.; ·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. MDX Electronics provides various security strategies to
effectively ensure data security of user and device. As for device access, MDX
Electronics 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 info@mdxelectronics.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 fulfill the products
and services you request from us as defined in the User Agreement.
·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:
MDX ELECTRONICS, LLC
6750 N Andrews Ave., Suite 200, Fort Lauderdale, Florida 33309
info@mdxelectronics.com