IoThings Company Limited Mobile Privacy Policy
Effective Date: 8 December 2023
Updated: 8 December 2023
IoThings Co.,Ltdand subsidiaries (“we”, “us”,“our”, “IoThings Co.,Ltd”) 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”):
IoThings 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:
IoThings Co.,Ltd,
No. 499 Kamphaengphet Rd Chatuchak Bangkok 10900
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 by IoThings Co.,Ltd 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 IoThings Co.,Ltd 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.
Information based on additional
functions:
Confirm: the system
permissions that allow in the your App
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.
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 user 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.
·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
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” (“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 Please enter
the company name, 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
Please enter the
company namewill 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
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 info@iothings.co.th
·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.
Withdrawal
of consent Confirm the following details: 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. Please enter the company name provides
various security strategies to effectively ensure data security of user and
device. As for device access, Please enter the company name 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 Please
enter your privacy email address.
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 Confirm user 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:
IoThings Company Limited
Postal Mailing
Address: 499 Kamphaengphet 6 Rd. Ladyao Chatuchak Bangkok 10900
Email: info@iothings.co.th