Privacy Policy
Effective
Date: 8 Jun 2022
Updated:
8 Jun 2022
Myjja (Singapore) Pte. Ltd. and subsidiaries (“we”, “us”, “our”, “Myjja”)
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”):
Myjja 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 do 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 questions regarding this Policy, please do not hesitate to
contact us via:
Email:
enquiry@myjja.com.sg
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 but not limited to smart home
appliances, smart wearable devices, smart air cleaning devices, etc.
Apps
refers to those mobile applications developed by Myjja 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.
·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:
Additional functions based on location
information:When
you enable the location-based functions through permission settings on your
mobile device, we will collect and process your location information to enable
these functions, such as pairing with your Smart Devices. Also, we may collect
information about your: a) real-time and precise location, for instance when
you choose to use the automation scenarios for controlling your Smart Devices,
or b) non-precise geo-location when you use certain Smart Devices or the
Services, such as robot cleaner and weather service.
Based
on your consent, when you enable the geo-fence feature, your location
information will be generated and shared with Google Maps services. Please note
that Google has corresponding data protection measures, which you may refer to
Google’s Data Processing and Security Terms for more details.
You
may disable the collection and use of your location information by changing
your mobile device settings upon which we will cease to collect and use your
location information.
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 in your settings under (“me” &rt;
“settings” &rt; “Privacy Settings” &rt; “Camera”)
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 in your settings under (“me”
&rt; “settings” &rt; “Privacy Settings” &rt; “Access storage permissions”)
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 in your settings under (“me”
&rt; “settings” &rt; “Privacy Settings” &rt; “Microphone”)
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 in your settings.
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 in your settings.
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 in your settings.
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 your settings.
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 your settings.
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 your settings.
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 but is not limited to 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.
Please note that when you actively agree
to enter the Myjja app and the application is connected to the Apple Health or
equivalent, we will share your measurement data with Apple Health (including
only your BMI, height, weight and body fat% data) or equivalent. 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
user service agreement.
·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 user service agreement.
·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 user
service agreement.
·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” 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 Myjja,
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
Myjja 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:
(b)via the route
of Feedback imbedded in the App
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: 1) Modify your
account number (email address or phone number) 2) Modify the nickname and/or
time zone: "My-Personal Information";
·Request
deletion of Personal Data about you: when you confirm the deletion of your
account, your Personal Data will be deleted accordingly.
·Request
restrictions, temporarily or permanently, on our processing of some or all
Personal Data about you: Please send over your request through "My-FAQ
& Feedback" or send over the email request to enquiry@myjja.com.sg. ·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 enquiry@myjja.com.sg. ·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,
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 if available, 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. Myjja provides
various security strategies to effectively ensure data security of user and
device. As for device access, Myjja’s 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 enquiry@myjja.com.sg. Data Retention
We process
your Personal Data for the minimum period necessary for the purposes set out in
this Policy, unless there is a specific legal requirement for us to keep the
data for a longer retention period. We determine the appropriate retention
period based on the amount, nature, and sensitivity of your Personal Data, and
after the retention period ends, we will destruct your Personal Data.
·For as long
as you require us to fulfill the products and services you request from us as
defined in the user service agreement.
·Personal Data
will no longer be retained when you request to remove your Personal Data, we
will accordingly complete the task.
When we are
unable to do so for technical reasons, we will ensure that appropriate measures
are put in place to prevent any further such use of your Personal Data.
Children’s Privacy
Protecting
the privacy of young children is especially important to us. The Services are
not directed to individuals under the age of thirteen (13) (or such other age
provided by applicable law in your country/region of residence), and we request
that these individuals do not provide any Personal Data to us. We do not
knowingly collect Personal Data from any child unless we first obtain
permission from that child’s parent or legal guardian. If we become aware that
we have collected Personal Data from any child without permission from that
child’s parent or legal guardian, we will take steps to remove that
information.
Changes to this Privacy Policy
We may update
this Privacy Policy to reflect changes to our information practices. If we make
any material changes, we will notify you by email (send to the e-mail address
specified in your account) or by means of a notice in the mobile applications
prior to the change becoming effective. We encourage you to periodically review
this page for the latest information on our privacy practices.
Contact Us
If you have
any questions about our practices or this Privacy Policy, please contact us as
follows:
Myjja
(Singapore) Pte. Ltd.
Postal
Mailing Address: 60 Paya Lebar Road #06-36 409051