Privacy statement

Effective Date:2021-08-11

Updated Date:2021-08-11

Sanke Xiaocao (Shenzhen) IOT Technology Co., Ltd. and its affiliates and subsidiaries (hereinafter referred to as "we", "our", "Sanke Xiaocao") are committed to protect your privacy. This privacy statement (hereinafter referred to as "the statement") explains how to handle personal data and protect information privacy during your use of the following services, products and related mobile applications (collectively, "products"). In the period , how do we process personal data and protect information privacy

• BABIQ App

In this privacy statement, "personal data" refers to information that can be used to identify individuals, either alone or in combination with other information. "Smart device" refers to a non-standard computing device produced or manufactured by a hardware manufacturer that has a human-machine interface and can transmit data through a wireless network, including: smart home appliances, smart wearable devices, and smart air purification devices. "App" refers to a mobile application developed by Sanke Xiaocao that can help end users remotely control smart devices and connect to Sanke Xiaocao IOT platform mobile application .

For other brand app provided by Sanke Xiaocao, our customers will decide which personal data to collect through our products. We collect information based on customer requirements, and the processing of such information is limited to providing the services agreed between the customer and us. If you are a user of our customers and you do not want a customer who uses our services to contact you, please contact the customer directly and inform your claim.

What personal data do we collect?

In order to provide the 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 the Services.

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 BABIQ services, such as searching and browsing any features on the Services, by creating a guest ID. When you are using the Try Now mode, we will not collect Personal Data, the only data being collected is the time of entering the App, operating system of your mobile phone, etc. Use of the data collected here will be limited to 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 have 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.

1. INFORMATION YOU VOLUNTARILY PROVIDE TO US

Account Data: When you register an account with us, we may collect your account name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with the Services, 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 Services 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 BABIQ 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 the Services, 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 a) real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Device, 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 Data Protection Terms for more details. You may disable the collection and use of your location information by managing the device level settings, 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 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 common operation of our services, improve and optimize our service, and protect your account security as well, we automatically collect device information, such as mobile device model number, IP address, wireless connection information, operating system type and version, 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 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, 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 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 and 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 Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with the Services, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or videos captured by it. Particularly, when you proactively consent to the Services connecting with third party Health platform to enable the fundamental feature for you (such as Apple Health, Google Fit, Fitbit, etc), we will share your health data (exclusively to your BMI, height, weight and body fat%) with them for the sole purpose of measuring and analyzing heath related indicators about you. We will not disclose such health data to any other third party. You may disconnect the Services with third party Health platform at any time by managing your health settings on your mobile device.

Bugly Information Collection:When you use our products, we will also collect: log information (including third-party developer custom log, Logcat log and APP crash stack information), device ID (including: Androidid and IDFV), networking information, system name, system version, and country code.

About children using this app

Our service targets are mainly for adults over 18 years old. If you are under 18 years old but need to use this application, you need your legal guardian to read this statement together with you and obtain their consent. Meanwhile, we recommend your legal guardian to supervise and guide your use of this application.

Purpose and legal basis for processing personal data.

The purpose of our processing of your information is as follows:

To provide services for you:We process your account and user profile data, device information, usage data, location information, and smart device related information to provide products and services that you request or purchase. The legal basis for such processing is that we perform the terms of service in the contract with you in accordance with the contract.

Improve 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 our operational efficiency, and prevent Fraud or improper use. The legal basis for such processing is that we perform the relevant terms of service in the contract with you in accordance with the contract.

Non-marketing communications:We process your personal data in order to send you important information related to services; changes in terms, conditions and policies; and/or other management information. As this type of information is important, you may not choose not to receive such mail. The legal basis for such processing is that we perform the relevant terms of service in the contract with you in accordance with the contract.

Marketing communications:We process your personal data to provide you with marketing and promotional information related to our products and services. In the above case, each message we send you contains instructions that allow you to choose not to receive such emails. In addition, if you agree to participate in our sweepstakes, contests, or other promotional activities, we may use your personal data to manage such activities. The legal basis for such processing is based on your consent.

Personalized services:We process your account and user profile data, usage data, device information, in order to design personalize product and provide you with tailor-made services (such as recommending and displaying information and advertisements suitable for your product).We invite you to participate in surveys about product use. The legal basis for such processing is based on your consent.

After-sales maintenance service: to realize the specific service functions of various Bugly SDKS, such as checking Logcat logs and analyzing abnormal crashes encountered by the APP.

Compliance:We will process your personal data when we deem it necessary or appropriate:

(a) comply with applicable laws and regulations;

(b) comply with legal procedures;

(c) respond to requests from public and government agencies;

(d) Fulfill our terms and conditions;

(e) protect our operations, business and systems;

(f) protect our rights, our privacy, our safety or our property and/or other users including yours;

(g) and seek usable remedial measures may reduce the losses that we may suffer.

With whom do we share your information and personal data?

At SankeXiaoCao, we only share your personal data in a way that you know.

We may share your personal data with the following participants:

Disclosure of your personal data to third-party service providers that provide us with certain business-related services, such as website hosting, data analysis, payment and credit card processing, infrastructure supply, IT services, customer support services, email sending services, and others Similar services, so that they can provide services for us.

The disclosure of your personal data to customers and other business partners directly or indirectly allows to provide you smart devices and/or networks and systems that you use to access and use our websites and services.

When a reorganization, merger, sale, joint venture, transfer, transfer or other disposition of all or part of our business, assets or stocks (including but not limited to the above-mentioned circumstances related to any bankruptcy or similar procedures) occurs, other third parties disclose your personal data. In this case, you will receive clear notifications via email and/or our website regarding changes in ownership, incompatibilities in new ways of using personal information, and choices regarding personal information.

Where we deem it necessary or appropriate:

(a) to comply with applicable laws and regulations;

(b) to comply with legal procedures;

(c) to respond to requests from public and government agencies, including public and government agencies outside the country where you live ;

(d) fulfill our terms and conditions;

(e) protect our operations, business and systems;

(f) protect the rights, privacy, security or property of us and/or other users, including you;

(g) and Seeking available remedies or reducing the losses we may suffer.

Disclosure of your personal data to subsidiaries or affiliates within the group to conduct business activities on a regular basis.

In addition to the above third parties, we only disclose your personal data to other third parties with your consent.

International transfer of collected information

In order to make our operations convenient, we may transfer, store and process your personal information and basic device information in jurisdictions other than where you live. These countries may have different information protection laws. In such cases, we will ensure that your information is fully protected by the following methods:

Agreement reached under the "EU Standard Contract Clauses" approved under Article 46 of the GDPR.

If you want to learn more about our security measures, you can contact us directly through this policy.

Rights related to personal data

We respect your rights and also have access to your personal data. You can perform any of the following rights by contacting us:

Email:services@xciotapp.com

Send us an email via "My-Feedbacks and Suggestions-I Want to Feedback-Account-related" in the LianMo App or directly in the "My-About Us" email service@xciotapp.com

You don’t need to pay anything, and we will respond within 30 days. If you plan to send us an email, please clearly state in your request what information you wish to change, whether you wish to delete your personal information from our database, or if you want us to receive your personal information when you use it.

Please note that for security reasons, we may ask you to verify your identity before further processing your request.

You can request access to the personal data we process about you. In this case, you need to : ask us to correct inaccurate or incomplete personal information related to you; delete your personal data; request temporary or permanent restrictions on our processing of some or all of your personal data; ask us to transfer your personal information to you or a third party when we process your data based on your consent or a contract with you, and when we automatically process your data , based on your consent or our legitimate interests, we choose to oppose or reject our use of your personal data.

About cancelling acount

You can cancel your account in the following ways "My-Personal Information-Account and Security-Account cancellation"

Information security measures:

We take commercially reasonable physical, management and technical safeguards to maintain the integrity and security of your personal information. SankeXiaoCao provides a variety of security strategies to effectively ensure the security of user and device data. In terms of device access, we use SanKeXiaoCao's proprietary algorithm to ensure data isolation, access authentication, and authorization applications. In terms of data communication, it supports the use of security algorithms and transmission encryption protocols and commercial-grade information encrypted transmission based on dynamic keys for communication. In terms of data processing, strict data filtering and verification and a complete data audit process are used. In terms of data storage, all confidential information of users will be encrypted and stored securely for storage. If for any reason you believe that your interaction with us is no longer safe (for example, you believe that the security of your SanKeXiaoCao’s accounts has been compromised), please email us at services@xciotapp.com to let us know immediately.

Information retention period:

We will process your personal data within the shortest period of time(7 working days) for the purpose stated in the cost privacy statement, unless it is required to be retained for a longer period of time in accordance with specific legal requirements. We will determine the appropriate retention period based on the amount, nature and sensitivity of personal data. After the retention period ends, we will destroy your personal data. If we are unable to perform the above operations for technical reasons, we will take appropriate measures to protect your personal data from further use.

Dispute Resolution

If you have unresolved privacy or information usage issues, and we are unable to provide you with a satisfactory solution, please contact our EU regulatory authority at https://edpb.europa.eu/about-edpb/board/members_en.

Third-Party SDK

This APP integrates " com.huawei.hms (Huawei; Huawei push) com.huawei. agconnect (Huawei; Huawei intermodal app) com.tencent. bugly (bugly; Tencent Bugly)"

com.huawei.hms (Huawei; Huawei push) com.huawei. agconnect (Huawei; Huawei intermodal app) Privacy Service Agreement:

https://developer.huawei.com/consumer/cn/doc/distribution/app/20213

com.tencent. bugly (bugly; Tencent Bugly) privacy Protection Statement:

https://static.bugly.qq.com/bugly-sdk-privacy-statement.pdf

Changes to the policy statement:

We may update this privacy statement based on changes in information practices. If we make any major changes, we will notify you via email (sent to the email address specified in your account) or post a notice on the mobile application before the change takes effect. We recommend that you browse this page regularly to obtain the latest information on privacy practices.

If you do not agree to our privacy service, you will be unable to log in to the APP, because we will collect your login log, account number and other information during the login phase.

Application of law and jurisdiction:

This policy is formulated in accordance with the laws of the People’s Republic of China and is governed by the laws of the People’s Republic of China.

If you have any questions about our practices or this privacy statement, please contact us via:

Company Name: Sanke Xiaocao (Shenzhen) IOT Technology Co., Ltd.

Mailing address: N2-4-1-901, Global Center, Wuhou District, Chengdu City, Sichuan Province, China.

Email: services@xciotapp.com