AIRROBO Privacy Policy

Last Updated: June 9, 2022
Effective Date: June 9, 2022

Thank you for using the AIRROBO robot vacuum cleaner from AIRROBO! This AIRROBO Privacy Policy (hereinafter referred to as "this Policy") details how we collect, use and store your personal data when you use the robot vacuum cleaner, and your related rights. The main points are as follows:

  1. AIRROBO (hereinafter referred to as "we") in this Policy refers to Best Epoch Technology Co. LTD, the service provider of AIRROBO. Its registered address is 22F, Building C1, Nanshan iPark, No.1001 Xueyuan Avenue, Nanshan District, Shenzhen;
  2. The AIRROBO products in this Policy refer to the Airrobo APP and its corresponding smart robot vacuum cleaners;
  3. This Policy applies to users of AIRROBO smart robot vacuum cleaners sold on online platforms in the Asia Pacific, Europe, and the United States;
  4. When you log in for the first time, we ask for your consent to the privacy agreement before collecting some of your personal data or sensitive personal data. If you refuse, you will not be able to use the Airrobo APP and the app will be closed automatically;
  5. Without your consent or unless compelled by applicable laws, rules, and/or the appropriate authorities, we will not disclose your personal data to a third party;
  6. Outside of AIRROBO, we will not obtain your personal data from a third party without your consent or unless necessary to comply with applicable laws, regulations, or requested by authorized authorities;
  7. You can view, update, and delete your personal data through the methods described in these terms. You can also withdraw your consent, file complaints, and set up additional associated privacy control functions through these channels.

For more detailed information, please refer to the relevant chapters according to the following index

I. What Personal Data We Collect
II. Purpose and Legal Basis for Processing Personal Data
III. How We Use Cookies and Similar Technologies
IV. How We Share, Transfer, Disclose and Provide Your Personal Data
V. How We Transfer Your Personal Information around the World
VI. How We Protect Your Personal Data
VII. How We Protect Personal Data of Children
VIII. How We Ensure that You Exercise Your Personal Rights
IX. How to Update this Policy
X. How to Contact Us

 

I. What Personal Data We Collect

We may need to process your personal data in specific situations to guarantee the proper operation of our products and services. As required by the GDPR, we have implemented the necessary organizational and technical measures as the data controller to protect the security of personal data:

(I) Personal data you provide directly

  • Identifying information and personal profiles. When you register for an account, we may collect your contact information, such as your email address. You may provide your own nickname, profile photo, country code, language preference, or time zone information when you are using our products. Following your voluntary account cancellation, we will erase or anonymize your personal data in accordance with the law. In this case, you are generally free to choose the personal data you want to provide for us. However, your use of Airrobo features or services may be limited if you choose not to provide identifying information.;
  • Customer service communication data. When you use the feedback and suggestion functions in our products, we gather your email address, cell phone number, and feedback content so that we can promptly address your issues and equipment failures. You may upload your photos, videos, or other media after providing us with an access to the camera or local storage so that we can identify the problems based on the photos/pictures/videos you upload;


(II) Personal data we collect automatically

  • Geolocation information. After you provide us with an access to geographic location (under the Android operating system, the setting of the Google framework is configured to require that the location information be obtained before establishing a Bluetooth connection) and the Bluetooth, the App will collect your geographic location information and connect to the robot vacuum cleaner through Bluetooth scanning. When you use our specific products or services (such as weather services, and scheduled cleaning functions), with your consent, we will collect approximate location information from the cellular network to determine your time zone so that a cleaning task can be properly scheduled. You may disable location services in the operating system of your mobile device to stop our collection of your location information;
  • Network connection information. We collect your Wi-Fi information (SSID, Wi-Fi Mac address, Wi-Fi password), and SN information of your device for the App to configure the network for the robot vacuum cleaner. The mobile device sends Wi-Fi information to the robot vacuum cleaner through a Bluetooth connection, to connect the robot vacuum cleaner to the network. Such information is stored locally in the robot vacuum cleaner and will not be uploaded to the cloud. If you refuse to provide the above personal data, you will not be able to use the network connection function. However, you can use the manual mode in the APP to control the movement of the robot vacuum cleaner through the Bluetooth module;
  • Voice data. After you provide us with an access to your microphone, we will record your speech for voice control for robot vacuum cleaners that support Alexa or Google Home.;
  • Mobile terminal information. When you use our products, we automatically collect device information, such as device model, operating system, device hardware serial number (referring to a string programmed into the device by the device manufacturer as a unique device identifier), Android ID, login IP address, wireless connection information, operating system type and version, application version number, push notification identifiers, log files and mobile network information;
  • Mobile terminal usage data. When you visit our website or use our services, we automatically collect usage data related to visits, clicks, downloads, sending/receiving messages, and other use of our website and services;
  • Log information. When you use our application, system and exception logs will be uploaded, including your IP address, language used, version of operating system, date or time of access;


(III) Information about the robot vacuum cleaner

  • Basic information of the robot vacuum cleaner: We will collect basic information about the robot vacuum cleaner, such as device name, device ID, online status, time of activation, firmware version, and upgrade information;
  • Information reported by the robot vacuum cleaner: When you use our application, system and exception logs may be uploaded. When you provide us with an access to the local storage, we may read or write necessary information including pictures, files, and crash log information in the storage space of your device to provide you with information or record crash log information locally;

Please be aware that whenever you provide us with an access, you authorize us to collect and use relevant personal data to provide you with corresponding services. If you deny any access, it implies that you are canceling your authorization, and we will no longer be able to collect and use the associated personal data based on that access or offer you the associated services. However, your choice to deny access will have no impact on the information that has already been collected and used with your authorization.

 

II. Purpose and Legal Basis for Processing Personal Data

We process your information for the following purposes:

  • Providing services for you: We process your account and profile data, device information, usage data, location information, and smart device-related information to provide the products and services you request or purchase. The legal basis for such processing is based upon the fulfillment of our Contract with you in accordance with our Terms of Use;
  • Improving our services: We process your device information, usage data, location information, and smart device-related information to ensure the functionality and safety of our products, develop and improve our products and services, analyze the efficiency of our operations, and prevent and track fraud or misuse. The legal basis for such processing is based upon the fulfillment of our Contract with you in accordance with our Terms of Use;
  • Non-marketing communications: We process your personal data to send you important information on services, terms/conditions, policy changes, and/or other management matters. Given the importance of such information, you may not be able to opt-out of receiving such emails. The legal basis for such processing is based upon the fulfillment of our Contract with you in accordance with our Terms of Use;
  • Marketing communications: We may process your personal data to send you marketing and promotional materials related to our products and services. Each marketing and promotional email we send you includes instructions for you to opt-out of receiving such email. The legal basis for such processing is performed based on your Consent. In addition, if you agree to participate in our drawings, contests, or other promotions activities, we may use your personal data to run such activities;
  • Personalized services: We may process your account and profile data, usage data, and device information to design and provide you with personalized products and services (such as recommending and displaying product information and advertisements suitable for you) and invite you to participate in user surveys. The legal basis for such processing is based upon the performance based on your Consent;
  • Compliance: We process your personal data as we deem necessary or appropriate to (a) comply with applicable laws and regulations; (b) follow the legal process; (c) respond to requests from public bodies and government authorities; (d) exercise our terms and conditions; (e) protect our operations, business, and systems; (f) protect the rights, privacy, safety or property of us and/or other users, including you; and (g) seek available remedies or limit the damages we may be liable for.

 

III. How We Use Cookies and Similar Technologies

In order to make our services function properly and ensure that you have a smoother and eaiser experience, we will occasionally store small data files known as Cookies on your computer, mobile communication terminal, or robot vacuum cleaner device. Cookies are small data files that a website or mobile application stores on your computer, mobile communication terminal, or robot vacuum cleaner device. When you visit our website, Cookies enable us to remember your habits and preferences over a period of time (e.g. login name, interface language, setting preferences). We may use various technologies to collect and store data about your access to our website or mobile application. The information collected can help us identify you, spare you from having to repeatedly enter registration information, or help us determine the security status of your account. These data files, which your browser or associate applications may supply as Cookies, Clickstreams, Web, or other local storage (collectively, "Cookies"), eliminate the need for you to re-enter information or manage user preferences each time you access the App or pages you have browsed. You may clear the cache in the corresponding settings of your browser or APP. Please be aware that certain features of our services can only be provided by using cookies.

 

IV. How We Share, Transfer, Disclose and Provide Your Personal Data

Please be aware that this APP is developed by Tuya Smart (NYSE: TUYA). We may share or entrust Tuya Smart to process some of your personal data in relation to specific functionalities in order to give you comprehensive product features and positive user experiences. We access the software development kits (SDK) provided by Tuya Smart and its third parties to implement the relevant functions described in this Privacy Policy. These functions can provide us with data storage services, data processing, log analysis, etc.

(I) Sharing

  1. Service providers as data processors
  • Please be aware that we cannot, on our own, fulfill all functional services for the products we offer. We will use data processing services, such as the software development kits (SDK) offered by service providers, to execute the necessary functions outlined in this Privacy Policy in order to give you comprehensive product functions and positive user experiences. These functions can provide us with data storage services, data processing, log analysis, etc. The purpose of providing such information is to realize the core functions of our products and/or services, and we conduct strict security monitoring on the software development kits (SDK) used by service providers for obtaining information to protect data security;
  • Details about the types of personal information collected by our service providers and the purposes of collection are as follows:
  1. Tuya: from Tuya Smart Co., Ltd., providing data storage services, data processing, and log analysis;
  2. Tencent Mobile Analysis: from Shenzhen Tencent Computer System Co., Ltd., providing mobile analysis functions
  3. AutoNavi Android Navigation SDK: Android navigation SDK path planning, professional navigation, UI interface customization, navigation components, truck navigation, etc.;
  4. ReactNative: from Facebook, a cross-platform UI development and design platform;
  5. Xiaomi Push: from Xiaomi Technology Co., Ltd., providing push services for developers;
  6. VIVOPUSHSDK: from Guangdong TelCheer Network Technology Co., Ltd., for message push services provided by Vivo to developers;
  7. GooglePlacesSDK: from Google Inc., applicable for demonstrations of Google Places SDK for Android;
  8. Tencent Share SDK: from Shenzhen Tencent Computer System Co., Ltd., used for integration in APP and sharing content to WeChat and Moments.


      2. Sharing of other personal information

Your personal information may be shared with our affiliates, but we only do so when it is required and consistent with the purpose outlined in this Privacy Policy. Your consent should be obtained anew if our affiliates want to change the purpose they are processing your personal information. Other than the aforementioned service providers and the affiliates of AIRROBO, we will not disclose your personal information to companies, organizations, or individuals without your consent, unless it is required by relevant laws and regulations, or as requested by competent authorities.

(2) Transfer

We will not transfer your personal information to any company, organization, or individual, unless:

(1) we obtain your consent or authorization in advance;

(2) we must provide such information in accordance with laws and regulations, the requirements of legal procedures, and mandatory administrative or judicial requirements;

(3) we provide such information in accordance with the relevant agreements with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;

(4) in case of asset transfers, mergers, and other similar transactions. Please be aware that the part being sold can include your personal information. If there is a transfer of personal information, we expect the new company or organization to uphold this Privacy Policy going forward; otherwise, we expect the company or organization to request your consent again.

(3) Disclosure

We will not disclose your personal information to any company, organization, or individual except  your consent or as required by relevant laws and regulations.

 

V.  How We Transfer Your Personal Information around the World

We process and back up personal information through Tuya Smart (NYSE: TUYA). In general, Tuya strictly follows the general principles of "data localization requirement" and "synchronization on a need basis" to ensure that any personal information of users is stored on the local server to the greatest extent possible, and is not synced to other areas. We will abide by applicable regulations if we must transmit personal data to our affiliates or service providers outside your jurisdiction. We implement uniform security safeguards to ensure that all transfers comply with the requirements of locally applicable data protection laws.

If you are a resident of the European Economic Area, we share your personal data in compliance with the GDPR rules on the transfer of personal information. When transferring your personal information to organizations outside the European Economic Area, we shall follow the relevant rules. We only share your personal information with organizations in countries with "adequate protection", otherwise we will transfer such information with appropriate safeguards (such as standard contractual clauses). If the above-described appropriate safeguards are not available, we should transfer your personal information with your consent.

 

VI.  How We Protect Your Personal Data

When you provide us with your personal information, unless the law requires or permits longer storage periods, we only keep the information for as long as necessary to achieve the purposes of this Policy. We ensure the confidentiality and integrity of your personal information by using reasonable commercially available administrative, technical, and physical safeguards. For example, in terms of device access, we take safeguard measures for data security, access authentication, and authorization applications. In terms of data communication, we support the use of security algorithms and transmission encryption protocols, as well as business-level encrypted transmission of information based on dynamic keys. In terms of data processing, strict data filtering and validation and a complete data review process are adopted. In terms of data storage, all confidential information of users should be properly encrypted for storage.

We recommend that you pay full attention to the protection of personal information, especially the login ID, password, and other important personal information during your use of our products or services. We will also make every effort to keep your personal information secure. In the event of a personal information security incident, we will implement an emergency plan to limit the harm caused and promptly disclose the incident's results in line with the requirements of regulatory authorities and applicable laws and regulations. In accordance with the requirements of relevant laws and regulations, we shall also notify you of the basic situation of the security incident and the remedial measures taken or to be taken by App push notifications, emails/short messages, telephone, etc. if necessary. If it is difficult to send a notification one by one, we will issue alerts through announcements and other means.

 

VII. How We Protect Personal Data of Children

Our APP is not intended for minors, and in accordance with the Children's Online Privacy Protection Act (COPPA) and other laws and regulations, we do not knowingly collect children's personal information. If you are a parent or legal guardian and you think your child may have given us personal information, please contact us to delete it.

VIII. How We Ensure that You Exercise Your Personal Rights

We are committed to following data protection laws around the world, such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Under the applicable laws, you may exercise the following rights:

Right of access: You have the right to access and inquire about your personal information and its copies, subject to exceptions provided by laws and regulations;

Right of correction: You have the right to amend or correct any personal information you provided that you later discover to be incorrect or incomplete.;

Right to erasure: You have the right to request that we erase your personal information. We evaluate your erasure request and take corresponding steps including technical measures if your request meets the relevant provisions.

Right to portability: You may request that your personal information be transferred to other parties.

  1. Individual rights in the European Economic Area and the United Kingdom

If you are from the European Economic Area or the United Kingdom, we only process your personal information on the following lawful basis:

  • Your consent
  • Performing your Contract with us
  • Compliance with our legal obligations
  • Protecting your vital interests
  • For the public interest
  • For our legitimate interests, without prejudice to your fundamental rights and freedoms

You also have the option to file a complaint with regulators in certain circumstances. Additionally, we have designated a Data Protection Officer who is solely accountable for safeguarding your personal data.

For more information or to exercise your rights, please contact us.

  1. California privacy rights

Information access and right to erasure. After verifying the identity, any consumer in California has the right to request enterprises to disclose the following personal information they have collected in the past 12 months up to two times during a 12-month period:

(1) Categories of personal information collected from such consumer;

(2) Sources from which personal information was collected;

(3) Commercial activities and purposes of collecting or selling personal information;

(4) Third parties receiving personal information shared;

(5) Categories of such consumer's personal information sold, and third parties who purchased the personal information;

(6) Categories of such consumer's personal information disclosed for business purposes;

(7) Specific personal information of such consumer collected;

To make such a request, please contact us.

Objection to our sale of your personal information. Consumers in California have the right to object to the sale of their personal information by us. It is important to note that some personal information shared to provide you with personalized advertising may be considered a "sale" under the CCPA, even though no actual monetary exchange is involved.

Third-party marketing. You have the right to request that we specify the third parties receiving your personal information for the purpose of direct marketing pursuant to Section 1798.83 of the California Civil Code. To make such a request, please contact us.

  1. Automated decision-making

You have the right to object to the processing of your personal information based solely on automated decision-making if the automated decision-making has a legal effect on you or otherwise materially affects you. We do not use any personal information of users in any automated decision-making with legal or other material implications.

  1. Closing your account

(I) You may apply to close your account directly in our APP. Your personal account is created with your mobile phone number/email. You may close your personal account through "My" - "Account Management" - "Close My Account”. Please be cautious since the process of closing your account may result in the deletion of all information related to your account.

 

IX.  How to Update this Policy

We reserve the right to periodically update or amend this Policy as circumstances such as product features, services, or organizations change. Any updates to this privacy policy will be posted on this page. When you log in, a pop-up window with the updated Privacy Policy will be displayed if there have been major changes.

 

X.  How to Contact Us

We have designated a Data Protection Officer. If you have any questions about this Privacy Policy, or have any complaints or comments about the processing of your personal data, you may go through “My" - "FAQs and Feedback" - "Submit Questions/Suggestions" in the APP setting interface to submit your feedback, or contact us in the following ways:

Email address: policy@air-robo.com Office 

Address: 22F, Building C1, Nanshan iPark, No.1001 Xueyuan Avenue, Nanshan District, Shenzhen


 

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