VivTech Mobile Privacy Policy
Effective Date: 06/15/2021
Updated: 06/15/2021
VivTech, LLC and
subsidiaries (“we”, “us”, “our”, “VivTech”) 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”):
·VivTech
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:
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 VivTech 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.
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 VivTech
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.
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.
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.
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 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 VivTech
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
VivTech, 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
VivTech 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:
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 withdrawalSecurity
We use commercially
reasonable physical, administrative, and technical safeguards to preserve the
integrity and security of your Personal Data. VivTech provides various security
strategies to effectively ensure data security of user and device. As for
device access, VivTech’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 Info@VivTechProducts.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:
VivTech, LLC
Postal Mailing Address: Wheeling, IL
Email: Info@VivTechProducts.com