E&E Co. Ltd., DBA JLAHome Privacy Policy
E&E Co., Ltd DBA JLA Home Mobile Privacy Policy
Effective Date:October 1, 2021
Updated; October 1,
2021
E&E Co., Ltd DBA JLA Home and subsidiaries (“we”, “us”,
“our”, “E&E Co., Ltd DBA JLA Home”) 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”):
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 E&E Co., Ltd DBA JLA Home
services, such as searching and browsing any features on the Services. At this
moment, we will not collect Personal Data about your 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.
Secure Comfort 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 question regarding this Policy, please
do not hesitate to contact us via: jlacs@jlahome.com
or 1-866-456-8852
For other branded mobile applications powered by E&E
Co., Ltd DBA JLA Home , we control all the Personal Data collected through our
Products. We collect the information and the processing of such information
shall be limited to the purpose of providing the service.
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. We will generate an
explicit notification for your consent before we collect 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 connects wirelessly to a network, including:
smart home appliances, smart wearable devices, smart air cleaning devices, etc.
Apps refers to those mobile applications developed by
E&E Co., Ltd DBA JLA Home 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.
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.
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 E&E
Co., Ltd DBA JLA Home 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:
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.
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.
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.
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.
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.
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 connection information, 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 Electric Blankets.
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.
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,
contact information related to device registration or warrantee information, in
cases where warrantee service has not been provided.
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 E&E Co., Ltd DBA JLA Home 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 E&E Co., Ltd DBA JLA Home, 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
E&E Co., Ltd DBA JLA Home 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:
To Request deletion of all records held in relation to the
app.Please contact us at Phone
1-866-456-8852 or email jlacs@jlahome.com.
You do not have to pay a fee and we will aim to respond to 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;
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.
Security
We use commercially reasonable physical, administrative, and
technical safeguards to preserve the integrity and security of your Personal
Data. E&E Co., Ltd DBA JLA Home provides various security strategies to
effectively ensure data security of user and device. As for device access,
E&E Co., Ltd DBA JLA Home 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 jlacs@jlahome.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:
E&E Co., Ltd DBA JLA Home Postal Mailing Address: 45875
Northport Loop E, Fremont, CA 94538
Email: jlacs@jlahome.com