Privacy Policy
Effective Date: 01 Nov 2024
Updated: 01 Nov 2024
Western International LLCand subsidiaries (“we”, “us”, “our”, “Western International
LLC”) 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”):
·GEESMART 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: 18742 WIG,
NIP, Dubai.
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 byWestern
International LLCthat 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.
·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 or some other terms of user? Confirm.
·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
agreement or some other terms of user? Confirm.
·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 or some other terms of user? Confirm.
·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 Western International LLC,
we only share Personal Data in ways that we tell you about. We may share your
Personal Data with the following recipients: Confirm
the following details
·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
Western International LLCwill 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 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 Confirm: the
emailbox?;
·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
Confirm: 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. Western International LLC provides
various security strategies to effectively ensure data security of user and
device. As for device access, Western International LLC 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 noufal.vk@westernint.com . 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 or some
other terms of use?;
·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:
Western International LLC
Postal Mailing Address: Corp
Office, NIP, Jebel Ali, Dubai, 18742
Email: Noufal.vk@westernint.com