This Privacy Policy
Effective Date: 20220701
Updated: 20220701
ZEALUX Inc.and
subsidiaries (“we”, “us”, “our”, “ZEALUX Inc.”) 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”):
·INVERBOOST 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:
www.zealux.com
For other branded mobile applications powered by ZEALUX
Inc., 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 byZEALUX
Inc.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 ZEALUX
Inc. 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.
Please note that when you actively agree to enter the App
name and the application is connected to the Apple Health, 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.
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 our
·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 our
·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
·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 ZEALUX Inc., 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
ZEALUX Inc.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 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. ZEALUX Inc. provides various security strategies to
effectively ensure data security of user and device. As for device access, ZEALUX
Inc. 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@zealux.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 our;
·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:
ZEALUX Inc.
Email: info@zealux.com