Heyaxa Mobile Privacy Policy
Effective Date: Nov 11,2021
Updated: Nov 11,2021
Heyaxa INC and
subsidiaries (“we”, “us”, “our”, “Heyaxa 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”): Confirm1: 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. If 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 Heyaxa 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.
·Heyaxa Mobile
ApplicationBefore 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 willconsider that you fully understand and agree with this Policy. If you have any question regarding this Policy, please do not hesitate to contact us via:
Confirm2：please enter the contact information of
corporate customer privacy office or other responsible party who deal with
privacy matters.
Confirm3: Whether the
customer will OEM/customize the App to your customers. If yes, please refer to
the following description; if not, please delete then.For other branded mobile applications powered by Heyaxa 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 byHeyaxa INCthat 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
·Account 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.
Confirm4: 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.
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 Heyaxa 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.
·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 real-time precise or 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 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.
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.
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.
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.
5)Additional services
based on storage permissions:
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.
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
·Device 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
information.
·Usage 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.
·Log Information:
When you use our app, the system and exception log may be uploaded.Please 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.
·Location 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 Weather station.
Based 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:
·Basic 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.
·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, Fat scale.
·Confirm 5.1: If the
product involves sensitive personal information, such as health products,
please be sure to explain it in the privacy policy. For example: smart scales
or fitness trackers may report your height, weight, body fat content (BFM) ,
Body mass index (BMI) and skeletal muscle content (SMM);
Confirm5.2 (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:
Please 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. Heyaxa. The application is
authorized to connect with Apple Health.
·Confirm 5.3: If the
product involves sensitive personal information, such as camera products,
especially with facial recognition equipment, please be sure to make relevant
explanations in the privacy policy. For example, smart cameras may collect
images or videos taken by them.
Purposes and legal basis
for processing Personal Data
The purpose for which we
may process information about you are as follows:
·Provide 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 you
according to our Terms of Use.,
·Improve 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
you according to our Terms of Use.
·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 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
Use.
·Marketing
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 Heyaxa 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..
·Personalization:
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.
·Legal 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.
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 Heyaxa 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
Sites and Services.
·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,
incompatible new uses of your Personal Data, and choices you may have regarding
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, 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.
·To subsidiaries or
affiliates within our corporate family, to carry out regular business
activities.
Except for the third
parties described above, to third parties only with your consent.
International Transfer of
Information Collected
Heyaxa 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:
lAgreement 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:
Confirm6: please provide
at least 2 approaches for individual user executing their privacy rights, for
instance, via the privacy office email address; support@Heyaxa.com, or via the route of Feedback imbedded in the App: Me&rt;Personal
Center&rt;Account and Security&rt;, etc.
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;
·Request that we correct
inaccurate or incomplete Personal Data about you;
·Request deletion of
Personal Data about you;
·Request restrictions,
temporarily or permanently, on our processing of some or all Personal Data about
you;
·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; and
·Opt-out or object to our
use of Personal Data about you where our use is based on your consent or our
legitimate interests.
•Withdrawal of consent:
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,
notifications and other related functions;
2) 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;
3) Unbind the Smart
Device through the app, and the information related to the Smart Device will
not be collected;
4) By using product with
the visitor mode, we will not collect any personal data about you;
When 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.
Confirm7: if the App
enables the account deletion/termination, please fill out the route in the App
to delete/terminate the account.
Security
We use commercially
reasonable physical, administrative, and technical safeguards to preserve the
integrity and security of your Personal Data. Heyaxa INC provides
various security strategies to effectively ensure data security of user and
device. As for device access, Heyaxa 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 support@Heyaxa.com.
Data Retention
We process your Personal
Data for the minimum period necessary for the purposes set out in this Privacy
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. 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 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.
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:
Heyaxa INC
Postal Mailing Address:
2662 E Del Amo Blvd Carson CALIFORNIA 90221
Email: Support@Heyaxa.com