DP Intelligence Privacy Policy
Last updated July 18, 2023
Effective date: July 18, 2023 (Note: Effective date can be categorized as immediate, or deferred as a public comment period, e.g., 30 days after update)
(hereinafter collectively referred to as "we") is committed to protecting your privacy.
The Privacy Policy of Guangdong DP Intelligent Technology Co., Ltd (hereinafter referred to as the "Policy") applies to the products and/or services we provide, including our mobile applications. When you use our services, we will collect and process information about you, so please read this Policy carefully and make sure you understand our rules for collecting and processing your personal information (including how to collect, use, save and share such information), as well as the ways to provide you with access to, update, delete and protect such information.
When you agree to this Privacy Policy, or start, continue to use our products or services in an appropriate manner, and do not contact us to express a contrary opinion through appropriate means, we will consider that you fully understand this policy. During the reading process, if you have any questions, comments, suggestions or complaints, especially if you believe that our personal information processing behavior has damaged your legitimate rights and interests, you can complain/suggest our services through the appropriate regulatory channels or contact us through the following contact information:
Contact e-mail: 136246690@qq.com
Tel: 18680152215
This policy is primarily explained to you:
1. What personal information we collect
2. Definition of the purposes and legal basis for the processing of personal information
3. Who we share your personal information with
4. Transfer of collected information
5. Rights relating to personal information
6. Information security safeguards
7. Information retention periods
8. Protection of children's personal information
9. Statement on policy changes
10. Contact us
Definition
For the purposes of this policy.
Personal information: Information recorded electronically or otherwise that can be used alone or in combination with other information to identify an individual or to reflect the activities of a particular individual.
Sensitive Personal Information: This includes personal biometric information, communication records and content, health information, transaction information, precise location information, and so on. When we provide you with certain products or services that involve the collection of sensitive personal information, we will ask for your consent by providing prominent and clear notification before collecting sensitive personal information about you.
Smart device: refers to non-standard computing devices produced or manufactured by hardware manufacturers that have a human-machine interface and can transmit information through a wireless network, including smart home appliances, smart wearable devices, smart air purification devices, etc.
Apps: refers to mobile apps （DP Intelligence) provided by us that help end-users remotely control their smart devices and connect to the Internet of Things (IoT) platform.
I. What personal information we collect
In order to provide you with our services, we may ask you to provide personal information necessary for such services. If you do not provide personal information, we will not be able to provide you with the corresponding products or services.
1. Information you voluntarily provide to us
· REGISTERED ACCOUNT INFORMATION: When you register for an account with us, we collect your account name and contact information, including your e-mail address, phone number, username, and login credentials. During your interaction with our products, we may further collect nicknames, country codes, language preferences, or time zone information in your account.
When you choose to authorize the use of third-party account login, we will obtain your shared account information (default system avatar, nickname, region information) from the third party to bind with your account for quick login, we will use your personal information in accordance with the agreement with the third party, as well as the terms of the third party's published privacy policy regarding the sharing of personal information, and in compliance with the relevant regulations.
· User Feedback: When you use our services and submit feedback and suggestions to us in relation to the services, we collect your filled-in email address, cell phone number and feedback content (added images or videos), as well as logs of submitted issues, which will be used to give us the opportunity to promptly address your application issues and smart device related malfunctions.
At the same time, depending on the application products and services, we may collect personal information that is necessary to provide you with the products and services.
Information collected based on additional functionality provided
In an effort to provide you with more convenient and better products and/or services, and in an effort to enhance your experience, we collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your ability to use the basic services of our App, but you will not be able to get the user experience that these additional services bring to you. These additional services include:
· Additional services based on location information:
When you turn on the location function of your mobile device through system authorization and use the services provided based on location, we will collect and use your location information so that you can use our App to network with smart devices. The reason why you need to get location permission in "Add Device" (only for Android system): When you enter "Add Device", you will be scanned by Bluetooth based on the function of searching for nearby devices, at this time, we need this permission in order to carry out Bluetooth communication, and since Bluetooth scanning needs to collect your location information, you need to turn on Bluetooth and apply for location and add devices, otherwise, your "Add Device" will not work. Add device, otherwise your "add device" function will not be realized.
When you use certain of our products or services (weather services/home management), based on your consent, we may collect real-time precise or non-precise geo-location information about you.
When you use the geofencing feature to generate location changes by creating scenarios, we request permission to collect backend locations for the purpose of acquiring locations to accomplish the automation capabilities you wish to implement.
You can stop our collection of information about your location by turning off location services on your mobile device's system.
Via [Home Drawer] - [Settings] - [Privacy Permission Settings] - turn off/on [Location Information] permission
· Additional services based on camera/camera:
You can use this feature to add your purchased device and take videos after you have enabled the camera/camera privilege. Please know that even if you have agreed to turn on the camera/camera privilege, we will only obtain information when you actively scan the code and use the camera/camera to take pictures. The code-sweeping function collects information from the light sensor and determines whether or not the flash function needs to be displayed based on the data from the light sensor.
Via [Home Drawer] - [Settings] - [Privacy Permission Settings] - Turn off/on [Camera/Camera]
· Additional service for image/video access and upload based on photo albums (photo gallery/video gallery):
You can use this feature to upload your photos/images/videos when you have enabled the Albums permission, in order to provide proof of the reported equipment problem. When you report a problem with your equipment, we will use the photos/pictures you uploaded to locate your problem.
Via [Home Drawer] - [Settings] - [Privacy Permission Settings] - turn off/on [Photo Album] permissions
· Additional services related to microphone-based speech technology:
You can use the microphone to perform voice functions, including shooting videos and waking up the voice assistant, when you turn on the microphone privilege, and we will collect your voice information in these functions to recognize your command needs. Please know that even if you have agreed to turn on the microphone privilege, we will only obtain voice information through the microphone when you actively tap the microphone icon in the App or record videos.
Via [Home Drawer] - [Settings] - [Privacy Permission Settings] - turn off/on [Microphone] permission
· Additional services based on storage permissions (Android only):
We ask you for this permission in order to ensure the stable operation of the client. After you enable our permission to read/write your device storage, we will read or write images, files, and crash log information necessary from or to your device storage for the purpose of providing you with the ability to publish information or record crash log information locally.
Via [Home Drawer] - [Settings] - [Privacy Permission Settings] - turn off/on [Storage] permission
· Additional functionality based on message notification permissions:
We request this permission from you in order to send you notifications about products or services, especially if you have purchased a service that requires us to send you alerts so that you can capture real-time status.
Through the [Home Drawer] - [Message Center] - [Settings] - turn off / on the [message push] permission
· Additional services based on Bluetooth technology:
You can use Bluetooth function after you open Bluetooth permission, including device control, device status acquisition, device discovery, and device mapping, in which we will communicate with terminal devices through Bluetooth. Please know that even if you have agreed to open Bluetooth permission, we will only use Bluetooth for communication in these scenarios: displaying device status in the home page and device panel; controlling devices in the home page and device panel; and discovering and networking devices in the home page and add device page.
Via [Home Drawer] - [Settings] - [Privacy Permission Settings] - turn off/on [Bluetooth] permission
You understand and agree that the above additional services require you to turn on the access rights to your location information (geolocation), camera (camcorder), photo albums (photo gallery), microphone (voice), and internal and external storage in your device in order to enable the collection and use of information covered by these rights. You can check the status of the above permissions item by item in your device settings and can turn them on or off at your own discretion.
Please note that by turning on any of the permissions, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, and once you turn off any of the permissions, it means that you cancel the authorization, and we will no longer continue to collect and use the relevant personal information on the basis of the corresponding permissions, and we will not be able to provide you with the corresponding services of the permissions. However, your decision to turn off the authorization will not affect the collection and use of information based on your previous authorization.
In addition, in order to ensure that the application is closed or background running state can be normal to receive the client pushed the broadcast message, the application shall use (self-start) ability, there will be a certain frequency through the system to send a broadcast to wake up the application self-start behavior, is necessary to achieve the function and service.
2. Information we collect automatically
· Mobile Device Information: When you interact with our products, in order to ensure your normal use of our services, to maintain the normal operation of our services, to improve and optimize the experience of our services, and to protect the security of your account, we automatically collect mobile device information, including mobile device model number, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier We also collect information about your mobile device, including mobile device model number, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information. At the same time, we collect your software version number. We may collect application install lists for applications that are necessary to ensure the security of the operating environment or to provide the Services.
· Usage Information: During your interaction with our website and services, we automatically collect usage information related to visits, clicks, downloads, sending/receiving messages and other uses of our website and services.
· Log Information: When you use our applications, in order to enhance your user experience, system and exception logs are uploaded for analysis, which include your IP address, customary language, operating system version, date or time of access, so that we can accurately identify problems and help you resolve issues during the use of the Services.
Please note that mobile device information and service log information alone is information that cannot identify a specific natural person. If we combine such non-personal information with other information for the purpose of identifying a specific natural person or use it in conjunction with personal information, such non-personal information will be treated as personal information for the duration of such combined use, and will be anonymized and de-identified unless we have obtained your authorization or are otherwise required by law or regulation.
3. Intelligent device-related information
When you use a smart device, we collect information inherent in the smart device itself as well as information generated by your use of the smart device.
· Basic Smart Device Information: When you use a smart device that is connected to our products or services, we collect basic information about the smart device, including the smart device's name, device ID, online status, activation time, firmware version, and upgrade information;
· Information collected during the connection of smart devices: Based on the type of smart device you need to connect, whether it is connected via Wi-Fi, via Wi-Fi after establishing a local connection via Bluetooth, via Bluetooth, or via Zig-bee, we will collect the Mac address of the smart device;
· SMART DEVICE REPORTED INFORMATION: Depending on the different smart devices you choose to connect to our products or services, we may collect information reported by your smart devices. The Smart Device Reported Information provided below applies to your use of that type of service:
When you voluntarily use Smart Camera (IPC service) and connect to our App: You have connected a doorbell, door lock, smart surveillance camera with camera through our App service to monitor the security of your residence or to view the content about the surveillance, after you add the device and use the Smart Camera, at this time, when the device recognizes that there is a person or an object moving, the Smart Camera will capture the surveillance footage (in image format) for you to view. The captured images will be automatically encrypted and saved locally and stored in the cloud server in the form of messages, and then the images will be deleted automatically after 30 days of storage. Please note that when you choose to turn off the motion detection function, the smart camera will not actively record the captured images, which will affect your intention of using the smart camera.
When you voluntarily use a health-related smart device and connect to our App: If you select one or more of these devices, the corresponding information will be recorded. Of course, when you do not use any of the above and related health devices, we will never collect any information from you:
1) Smart Body Fat Scale or Fitness Tracker: Height, Weight, Body Fat Mass (BFM), Body Mass Index (BMI) and Skeletal Muscle Mass (SMM), Body Fat Percentage, Muscle Mass, Body Fat Indicator, Obesity Levels, Ideal Body Weight, Weight Control, Visceral Fat Index, Net Body Weight, Body Moisture, Bone Mass, Protein Ratio, BMR, Metabolic Age, Body Score, Body Shape, Subcutaneous Fat Rate, Subcutaneous fat mass, heart rate;
2) Bracelets and similar smart devices: heart rate, steps, calories, mileage, heart rate, sleep record, training record, temperature, blood oxygen, systolic blood pressure, diastolic blood pressure, pressure.
3) Smart fitness equipment represented by smart jump rope: start time, jump mode, number of jumps, length of workout, calories burned, maximum number of jumps held, number of jumps, average speed, fastest speed, heart rate during workout.
II. Purpose and legal basis for the processing of personal information
The purposes for which we process your information are set out below:
· To provide you with services: We process your account information, mobile device information, usage information, location information and smart device-related information to provide the products and services you request. The legal basis for such processing is based on our "User Agreement" To fulfill our contract with you.
· Improving our services: We process your mobile device information, usage information, location information and smart device-related information to ensure the functionality and security of our products, to develop and improve our products and services, to analyze the efficiency of our operations, and to prevent and track fraud or misuse. The legal basis for such processing is to fulfill our contract with you in accordance with our User Agreement.
· Non-Marketing Communications: We process your personal information for the purpose of sending you important information relating to the Services, changes to terms/conditions and policies and/or other administrative information. At the same time, we may also send you notifications related to your purchase of services, including alert services. You can manage whether or not you have requested to receive such message communications by checking the relevant [Push Messages] in our App ([Home Drawer] - [Message Center] - [Settings] - [Push Messages]), and we will no longer continue to push such messages to you when you choose to turn off push notifications. The legal basis for such processing is the fulfillment of our contract with you in accordance with our User Agreement.
· Compliance: We only process your personal information when we are required by law to disclose it, or when we believe it is necessary or appropriate to do so:
· Comply with applicable laws and regulations, legal procedures or requests from public agencies and government authorities;
· To fulfill our Terms of Use and other agreements, policies or standards, including investigating any potential use violations;
· To protect the rights, privacy, safety or property of us and/or other users, including you; and to seek available detection, prevention, remedies or limitations on the damages we may be required to provide or to address security, fraud or technical issues.
We also use collect your personal information in other ways, and we will provide specific notice at the time of collection and obtain your consent as required by applicable law. If there are any changes in the purposes for which your personal information is processed, we will notify you of such changes and inform you of your choices regarding your personal information by means of prominent notices such as message notifications within our App, email, etc.
III. With whom do we share your personal information?
We only share your personal information in ways that you know and agree to. We may share your personal information with the following participants:
· When you use the products or services provided by the third-party subject apps through our App, we will pass your relevant information to the third party based on your authorization in specific scenarios. The specific authorization object and the type of authorization information will be displayed on the page where the third party obtains consent from you, and your information will be passed to the third party through an encrypted channel.
· To disclose your personal information to third party service providers who provide certain business-related services to us, including website hosting, data analytics, payment and credit card processing, infrastructure provisioning, IT services, customer support services, email delivery services, and other similar services, in order to ensure that they are able to provide their services to us.
· Disclose your personal information to customers and other business partners who directly or indirectly provide you with smart devices and/or networks and systems that you use to access and use our websites and services.
· To disclose your Personal Information to affiliates or other third parties in the event of a reorganization, merger, sale, joint venture, cession, transfer or other disposition of all or a portion of our business, assets or stock (including, without limitation, the foregoing in connection with any bankruptcy or similar proceeding). In such cases, you will receive clear notice of the change of ownership, incompatible new uses of personal information, and choices regarding personal information via e-mail and/or our website.
· Disclose your personal information to the Company's subsidiaries or affiliates to conduct business activities on a regular basis.
· We will share your personal information reasonably and lawfully for the following necessary or appropriate circumstances:
· Comply with applicable laws, regulations, legal procedures, policies and/or standards, or the requirements of appropriate public agencies and governmental authorities;
· To fulfill our Terms of Use and other agreements, policies and standards, including investigating any potential violations;
· Protect our operations, business and systems;
· Protect the rights, privacy, safety or property of us and/or other users, including you; and
· Risk management, detection and validation of illegal, fraudulent, deceptive or malicious activities.
In addition, in order to ensure the stable operation of our apps or to realize relevant independent functions, we may embed third-party SDKs in our apps, please note that third-party SDKs may change the type of personal information they handle due to version upgrades and policy adjustments, so please refer to the official instructions published by them. Please click here to view Third-party SDK details.
IV. Transfer of collected information
We operate globally and therefore the personal information we collect pursuant to this policy may be transferred, stored and processed between different countries or regions. The laws and regulations applicable in the country or region where we operate may differ from those applicable in the country/region where you reside, but we will strictly comply with the laws and regulations and requirements related to the protection of personal information. Therefore, within the framework of the protection of personal information, in order to facilitate our operations, we may transfer personal information to the country or region in which we conduct business. Our privacy and security practices are designed to provide global protection for your personal information regardless of where it is stored.
Including, the European Commission has identified certain countries outside the European Economic Area (EEA), the United Kingdom or Switzerland as having mechanisms in place to adequately protect personal information. Where personal information of users in the EEA, Switzerland or the UK is transferred to a recipient located in a country outside the EEA, Switzerland or the UK that is not considered to have an adequate level of protection for the information, we will ensure that the transfer of information is carried out in accordance with the EU Standard Contractual Clauses. You can click here to view the EU Standard Contractual Terms approved under Article 46 of the GDPR.
In particular, when you select the correct country code for mainland China and the registration account that corresponds to it, the personal information that we will collect and generate in the course of our operations within the mainland of the People's Republic of China will be stored and processed in data centers in the mainland of China, except where cross-border transfers are permitted in accordance with the provisions of applicable law.
If you would like to know more about our information storage and safeguards, you can contact us directly via the contact details at the bottom of this policy.
V. Rights related to personal information
While we respect your rights, we also hold personal information about you. You can exercise any of the following rights:
· Through the [Home Drawer] - [Questions and Feedback] in our application;
· And you can reach us at the information below:
Company name: Guangdong Dianpai Intelligent Technology Co.
Contact e-mail: 136246690@qq.com
Tel: 400 881 9128
Address：No.3 Building, Ju'an Industrial Park, No.8 Lianfeng Juxin Road, Xiaolan Town, Zhongshan City, Guangdong Province, China.
· You can exercise your rights in relation to your personal information through the routes indicated below:
· Ask us to correct inaccurate or incomplete personal information relating to you: 1) Modify "Nickname and/or Avatar": [Home Drawer] - [Profile];
· Request to delete your personal information: [Home Drawer] - [Settings] - [User Profile] - [Delete Account], according to the prompt display, you can delete your personal information;
· To request a temporary or permanent restriction on our processing of some or all of your personal information: please delete your account through the [Home Drawer] - [Settings] - [Account and Security] in the application or [Home Drawer] - [Questions and Feedback] to us, or submit your request through the contact number or email address above;
· To request us to process your information based on your consent or a contract with you, as well as to transfer personal information to yourself or to a third party when we process your information automatically: [My] - [FAQ & Feedback] within the application to us, or submit your request via the contact number and email address above;
If you decide to send us a request by e-mail, please indicate what information you would like to change, whether you would like your personal information to be deleted from our database, or what restrictions you would like to see on our use of your personal information. Please note that for security reasons, we may ask you to verify your identity before we process your request further.
· Require us to provide you with the means and instructions for withdrawing your consent to the processing and use of your personal information in the course of your use of our services on the basis of your consent or our legitimate interests, in respect of which you have chosen to object to or refuse our use of your personal information, in which case we will safeguard your right to withdraw your consent in the following manner:
(1) As mentioned above, you can revoke your consent through the application's [Home Drawer] - [Settings] - [Privacy Permission Settings] and thus change the device permissions to revoke your consent through the permissions settings obtained from the device's system settings, including the location, camera/camcorder, photo albums (photo gallery/video gallery), microphone, Bluetooth settings, and the relevant functions of the message notification push;
(2) In the case of non-marketing communications that you have agreed to, turn off your choice by going to [Home Drawer] - [Message Center] - [Settings];
(3) By unbundling your smart device through the app, information about your use of the smart device will not be collected;
When you withdraw your consent or authorization, we will not be able to continue to provide you with the services for which you have withdrawn your authorization. However, the withdrawal of your consent or authorization does not affect the withdrawal of the processing of personal information previously carried out on the basis of your consent.
You do not need to pay any fees to implement your personal rights. According to the requirements of the local information protection law, if your account service is in mainland China, then we will complete the verification and processing of your demand within 15 working days; if your account service is outside mainland China, then we will respond to your demand within 30 natural days (please modify the conclusions according to Chapter IV).
VI. Information security safeguards
We maintain commercially reasonable physical, managerial and technical safeguards to safeguard the integrity and security of your personal information. We provide a variety of security safeguard strategies to effectively ensure the security of user and device information.
For device access, we use reliable identity access authentication and authorization requests.
In terms of data communication, communication is supported using secure algorithms and transport encryption protocols, as well as commercial-grade encrypted transmission of information based on dynamic keys.
Strict data filtering and validation as well as a complete data review process are used for data processing.
In terms of data storage, all of the user's confidential information will be securely encrypted for storage.
In addition to the technical level of security mentioned above, a series of security safeguards have been put in place at the institutional and control level, including the setting of posts and responsibilities, the organization of training courses on security and privacy protection, the enhancement of employees' awareness of data protection, and the control of access privileges, in order to prevent the loss of data, its unlawful use, its receipt of unauthorized access or its leakage, tampering or destruction.
If for any reason you believe that your interactions with us are no longer secure (for example, you believe that the security of your account has been compromised), please let us know immediately by calling or emailing us as described below.
If a security incident occurs that affects the security of your personal information, we will notify you at the first time through your reserved email address, phone number, and message center push, and inform you of the recommendations to reduce or prevent related risks and other information. If necessary, we will take appropriate remedial measures in a timely manner in accordance with our internal security incident contingency plan and report to the relevant authorities in accordance with the regulations.
VII. Period of retention of information
We will process your personal information for the shortest period necessary to achieve the purposes described in this policy or as required by law or regulation, unless a longer retention period is required under specific legal requirements. We will determine the appropriate retention period based on the volume, nature and sensitivity of the personal information and will destroy your personal information at the end of the retention period.
1. According to the "the User Agreement" and this Policy to fulfill your requests for products and services;
2. When you explicitly request the deletion of your personal information, we make this an automatic task and no longer retain your personal information.
We will stop retaining and do the deletion of your personal information when we confirm the completion of the purpose of collection and processing of personal information on the basis of 1), or after we confirm your request for deletion or cancellation on the basis of 2), or after we terminate the operation of the corresponding product or service. Generally, we will no longer retain your personal information once the specified retention period of the information has been reached. If we are unable to destroy the information for technical reasons and the personal information is retained beyond the storage period, we will take appropriate measures to prevent further use of your personal information, including anonymization.
VIII. Protection of children's personal information
We take the protection of children's personal information very seriously and our products and services are primarily intended for adults. If you are a child, you should not create your own personal information subject account without the consent of a parent or guardian.
For personal information accounts created with parental and/or guardian consent, before you use our services, please be sure to certify that you have read the "Children's Privacy Statement" We protect children's personal information in accordance with regional, national or local laws and regulations. Please note that if we become aware that a child's Personal Information has been collected without the prior verifiable consent of a parent or legal guardian, we will attempt to delete the Personal Information as soon as possible.
IX. Statement on policy changes
We will update this Policy at least once a year in response to changes in information protection and handling practices. If we make any material changes, we will notify you by e-mail (sent to the e-mail address specified in your account) or by posting a notice within the Application before the changes take effect. We recommend that you periodically visit the Application for the most up-to-date information about our privacy practices.
X. Contact Us
If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us through the Dignity Intelligence App's [Home Drawer] - [Questions and Feedback] or the following methods, and specify the "Privacy Policy", and we will complete the verification and processing of your request within 15 working days. We will complete the verification and processing of your needs within 15 working days.
If your question itself relates to a more significant matter, we may ask you to provide additional information to confirm the nature and impact of the matter.
If you are not satisfied with the response you receive, you can refer your complaint to the appropriate regulatory body. When you consult us, we will provide you with information on the relevant complaint routes that may be used, depending on your circumstances.
Contact information and contact address:
Company name: Guangdong Dianpai Intelligent Technology Co.
Contact e-mail: 136246690@qq.com
Tel: 400 881 9128
Address：No.3 Building, Ju'an Industrial Park, No.8 Lianfeng Juxin Road, Xiaolan Town, Zhongshan City, Guangdong Province, China.