Date: From 15/10/2021
subsidiaries (“we”, “us”, “our”, “IP Khaytiov”) are committed to
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”):
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.
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 Kojima 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.
HOME Mobile Application
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.
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:
enter the contact information of corporate customer privacy office or other
responsible party who deal with privacy matters.
Whether the customer will OEM/customize the App to your customers. If yes,
please refer to the following description; if not, please delete then.
other branded mobile applications powered by IP Khaytiov, 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.
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.
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.
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.
refers to those mobile applications developed by IP Khaytiov 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
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
1.Information You Voluntarily Provide Us
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.
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.
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 IP Khaytiov 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
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.
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:
functions based on location information:
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
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.
services based on camera:
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.
services for accessing and uploading pictures/videos based on photo albums
(picture library/video library):
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.
services related to microphone-based service:
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.
services based on storage permissions:
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
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
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
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.
Information: When you use our app, the system and exception log may be
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: 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.
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:
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.
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.
5.1: If the product involves sensitive personal information, such as health
smart scales or fitness trackers may report your height, weight, body fat
content (BFM) , Body mass index (BMI) and skeletal muscle content (SMM);
(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:
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
5.3: If the product involves sensitive personal information, such as camera
products, especially with facial recognition equipment, please be sure to make
collect images or videos taken by them.
Purposes and legal basis for processing
purpose for which we may process information about you are as follows:
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
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
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
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 Kojima 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..
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.
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.
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
Who do we Share Personal Data with?
Khaytiov, we only share Personal Data in ways that we tell you about. We
may share your Personal Data with the following recipients:
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.
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.
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.
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.
subsidiaries or affiliates within our corporate family, to carry out regular
for the third parties described above, to third parties only with your consent.
International Transfer of Information
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
on the basis of approved EU standard contractual clauses per GDPR Art. 46. For
you would like further detail on the safeguards we have in place, you can
Your Rights Relating to Your Personal
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; firstname.lastname@example.org, or via the route of Feedback imbedded in the App:
Me&rt;Personal Center&rt;Account and Security&rt;, etc.
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
access to the Personal Data that we process about you;
that we correct inaccurate or incomplete Personal Data about you;
deletion of Personal Data about you;
restrictions, temporarily or permanently, on our processing of some or all
Personal Data about you;
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
or object to our use of Personal Data about you where our use is based on your
consent or our legitimate interests.
of consent: We will exercise your privacy right to withdraw consent through the
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;
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;
Unbind the Smart Device through the app, and the information related to the
Smart Device will not be collected;
By using product with the visitor mode, we will not collect any personal data
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.
if the App enables the account deletion/termination, please fill out the route
in the App to delete/terminate the account.
use commercially reasonable physical, administrative, and technical safeguards
to preserve the integrity and security of your Personal Data. IP Khaytiov provides
various security strategies to effectively ensure data security of user and
device. As for device access, IP Khaytiov 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.
process your Personal Data for the minimum period necessary for the purposes
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.
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.
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
contact us as follows: