MES Smart Mobile Privacy Policy
MES Smart Mobile Privacy Policy
Effective Date: March 5,
2022
Updated: March 5, 2022
MES Smart and subsidiaries (“we”, “us”, “our”, “MES Smart”)
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
MES Smart 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.
·MES Smart 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:
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 MES Smart, 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 by MES Smart 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
·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 MES Smart 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 Please enter the
product name.
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, Please enter information about
the smart device report.
·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. Please enter the App name.
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 MES Smartsending 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 MES Smart, 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
MES Smart 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; ***@***.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. MES Smart provides
various security strategies to effectively ensure data security of user and
device. As for device access, MES Smart 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 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:
MES Smart
Email