Ningbo Homemate Products CO., LTD. Privacy Policy

Effective Date:
2018.4

Updated: 2022.5

Ningbo Homemate Products CO., LTD. and subsidiaries (“we”,
“us”, “our”, “Ningbo Homemate
Products 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”):

·LINKPLUS
LIFE 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:

[email-masked]

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 Ningbo Homemate
Products 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.

·
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:

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 > Message Center > Setting >
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 > Settings > Privacy Settings > 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>
Settings > Privacy Settings > 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 Ningbo Homemate Products CO., LTD., 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

Ningbo Homemate Products CO., LTD. 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.

·
Confirm: Please add if there is any international transfer
mechanism you are relying on, for instance Privacy Shield.

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:

Confirm: please
provide at least 2 approaches for individual user executing their privacy
rights, for instance, via the privacy office email address; [email-masked], 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:
"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 > Message Center
> Notification Settings” to manage your selection;

3)You may
opt-out the data analysis features through “Me > Settings > Privacy
Settings”;

4)You may
opt-out the Personalization feature through “Me > Settings >
Privacy Settings > 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 > Settings > Account and Security
> 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. Ningbo Homemate Products CO., LTD. provides various
security strategies to effectively ensure data security of user and device. As
for device access, Ningbo Homemate Products CO.,
LTD. 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 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:

Ningbo Homemate Products CO., LTD.

Postal Mailing
Address: Floor 18th, Homemate Plaza,No.
1066  Sanwu
road, Zhenhai,Ningbo,China

Email: [email-masked]