Privacy Policy
Effective Date: 2021-10-18
Updated: 2021-10-18
InverFlowand
subsidiaries (“we”, “us”, “our”, “InverFlow”) 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”):
InverFlow Mobile
Application
In this Policy, Personal Data means information that
can be used to identify an individual, either from that information
alone, or from that information and other information we have access to about
that individual.
“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 byInverFlowthat
provide end users remote control to Smart Devices and with the ability to
connect to the supplier- InverFlow IoT
Platform.
For other branded mobile applications powered byInverFlow,
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.
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.
·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.
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 application
and exception log may be uploaded.
·Location Information: We may
collect information about your real-time precise or non-precise geo-location
when you use our specific Products or Services, such as pool pump.
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: smart scales or fitness trackers may report your height,
weight, body fat mass
(BFM) , Body mass index (BMI) and skeletal muscle mass (SMM);
smart cameras may report
images or videos captured 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. Because this information
may be important, you may not opt-out of receiving such communications. 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 our
Products and 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. The legal basis for this processing is your consent. Additionally,
if you consent to participate in our lottery, contest or other promotions, we
may use your personal data to manage such activities.
·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 our products.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.
Who do we
Share Personal Data with?
At InverFlow, 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 information,
and choices you may have regarding your personal information.
·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.
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:
Via
the “ Profile”-Personal Center” in our products（ for Product
version v1.0.0and later)
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.
Information Security Safeguards
We use commercially reasonable physical,
administrative, and technical safeguards to preserve the integrity and security
of your personal
information.
Inverflow provides
various security strategies to effectively ensure data security of user and
device. As for device access, Inverflow 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 must
immediately notify us of the problem by emailing inverflow.service@hotmail.com. Information Retention Period
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.
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.
Legal
application and jurisdiction
This
policy is formulated in accordance with the laws of the People’s Republic of
China and shall be governed by the laws ofthe People’s Republic of China.
If you have any questions about our practices or this
Privacy Policy, please contact us as follows:
Inverflow
Postal Mailing Address: 5TH FLOOR,
C6 BUILDING, NANLONG INDUSTRIAL ZONE, PANYU, GUANGZHOU,P.R. CHINA 511450