Privacy Policy of Zhejiang Liou Information Technology Co., Ltd.
Effective Date: February 24, 2023
Updated: February 24, 2023
Zhejiang Liou Information Technology Co., Ltd. and
subsidiaries (“we”, “us”, “our”, “Zhejiang Liou Information Technology Co.,
Ltd.”) 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”):
Smart Water 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:
Contact email:leopr@leopump.com
For other branded mobile applications powered by Zhejiang
Liou Information Technology Co., Ltd., 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 byZhejiang Liou Information Technology Co., Ltd. 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
·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.
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 Zhejiang Liou Information
Technology Co., Ltd. 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.
·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.
However,
if the Services you request or purchase are based on your account, please go to
the registration/login page for guidance.
·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.
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.
·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.
·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.
·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?
At Zhejiang
Liou Information Technology Co., Ltd., 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
Zhejiang
Liou Information Technology Co., Ltd. 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:
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 tothe email box;
·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 tothe email box;
·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. Zhejiang Liou
Information Technology Co., Ltd. provides various security strategies to
effectively ensure data security of user and device. As for device access, Zhejiang
Liou Information Technology Co., Ltd. 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 to leopr@leopump.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 theService
Agreement of Zhejiang Liou Information Technology Co., Ltd.;
·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:
Zhejiang
Liou Information Technology Co., Ltd.
Postal
Mailing Address: Room 102, Building 4, No.505, Da Street, No.23, Baiyang
Sub-District, Qiantang District Hangzhou, Zhejiang
Email: leopr@leopump.com