Privacy statement

Zhejiang Oulun Electric Co., Ltd. (hereinafter referred to as "we", "our", "Oulun") are committed to protecting your privacy. This Privacy Statement (hereinafter referred to as the "statement") describes how we process personal data and protect information privacy during your use of the following services, products and related mobile applications (collectively referred to as the "products").

? AI Life app

In this privacy statement, "personal data" refers to information that can be used to identify individuals alone or in combination with other information. "Smart devices" refer to non-standard computing devices with man-machine interface and capable of transmitting data through wireless network produced or manufactured by hardware manufacturers, including smart appliances, smart wearable devices, smart air purification devices, etc. "App" refers to the mobile application developed by Oulun company that can help end users remotely control intelligent devices and connect to  Oulun iot platform.

For other brand apps supported by Oulun, our customers will decide what personal data to collect through our products. We collect information according to the customer's 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 the customers who use our services to contact you, please contact the customer directly and tell your demands.

What personal data do we collect

In order to provide you with our services, we will ask you to provide the personal information necessary for such services. If you do not provide personal information, we may not be able to provide you with our products or services.

Information you volunteered to provide us

? Account or user profile data: when you register our account, we may collect some information about you, such as your e-mail address, telephone number and user name. During your interaction with our products, we may further collect nicknames, avatars, country codes, language preferences or time zone information in your account.

? Feedback: when you use the feedback and suggestion function in our products, we will collect your email address, mobile phone number and feedback content, so as to deal with your problems and equipment faults in time.

We automatically collect information

? Device information: when you interact with our products, we will automatically collect device information, such as MAC address, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log file and mobile network information.

? Usage data: during your interaction with our website and services, we will automatically collect usage data related to accessing, clicking, downloading, sending / receiving messages and other uses of our website and services.

? Log information: when you use our app, the application log and exception stack may be uploaded.

? Location information: we collect information about your real-time accurate or imprecise geolocation only when you use our specific products or services, such as sweeping robots and meteorological services.

Information about smart devices:

? Basic information of smart device: when you use a smart device connected to our service, we may collect some basic information of smart device, including device name, device ID, online status, activation time, firmware version and upgrade information.

? Smart device report information: when you use our products, we may collect the information reported by your device. For example, a smart scale may report your height, weight, body fat content (BFM), body mass index (BMI), and skeletal muscle content (SMM), and a smart camera may collect images or videos captured by it.

Purpose and legal basis for processing personal data

We process your information for the following purposes:

? Provide services for you: we process your account and user data, device information, usage data, location information and smart device related information to provide products and services you require or purchase. The legal basis for such treatment is that we perform the terms of service in the contract signed with you.

? Improve our services: we process your device information, usage data, location information and smart device related information to ensure the function and security 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 treatment is that we perform the relevant terms of service in the contract signed with you.

? Non Marketing Communications: we process your personal data to send you services; Changes in terms, conditions and policies; And / or other management information. Because such information is important, you may not be able to choose not to receive such messages. The legal basis for such treatment is that we perform the relevant terms of service in the contract signed with you.

? Marketing Communications: we process your personal data to provide you with marketing and promotional information related to our products and services. In the above cases, each email we send you contains instructions that allow you to choose not to receive such emails again. In addition, if you agree to participate in our lucky draw, competition or other promotional activities, we may use your personal data to manage such activities. The legal basis for such treatment is based on your consent.

? Compliance: we will process your personal data as we deem necessary or appropriate: (a) comply with applicable laws and regulations; (b) Compliance with legal procedures; (c) Respond to the requirements of public and government agencies; (d) Fulfill our terms and conditions; (e) Protect our operations, businesses and systems; (f) Protect the rights, privacy, security or property of us and / or other users, including you; And (g) seek available remedies or reduce the losses we may suffer.

Who do we share your information and personal data with?

At Oulun we share your personal data only in ways you know.

We may share your personal data with the following participants:

? Disclose 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, e-mail sending services and other similar services, so that they can provide services for us.

? Disclose your personal data to customers and other business partners who directly or indirectly provide you with smart devices and / or the networks and systems you use to access and use our websites and services.

? Disclose your personal data to subsidiaries or other third parties in the event of reorganization, merger, sale, joint venture, assignment, transfer or other disposal of all or part of our business, assets or shares (including but not limited to the above in connection with any bankruptcy or similar proceedings). In this case, you will receive explicit notification of changes in ownership, incompatibility of new ways of using personal information and selection of personal information via email and / or our website.

? Where we deem it necessary or appropriate: (a) comply with applicable laws and regulations; (b) Compliance with legal procedures; (c) Respond to the requirements of public and government agencies, including those outside your country of residence; (d) Fulfill our terms and conditions; (e) Protect our operations, businesses and systems; (f) Protect the rights, privacy, security or property of us and / or other users, including you; And (g) seek available remedies or reduce the losses we may suffer.

? Disclose your personal data to subsidiaries or subsidiaries within the group to carry out 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.

Rights relating to personal data

We respect your rights and will have access to your personal data. You may exercise any of the following rights:

? Through the "user data - personal center" in our products (applicable to products of version 3.2 and above)

? umspark@Oulun.com.cn. Send us an email (for products under version 3.2)

You do not need to pay any fee, we will reply within 30 days. If you plan to send us an email, please specify in your request what information you want to change, whether you want to delete your personal information from our database, or what restrictions you want us to be subject to when using your personal information. Please note that for security reasons, we may ask you to verify your identity before further processing your request.

You can:

? Request access to personal data related to you processed by us;

? Ask us to correct inaccurate or incomplete personal information related to you;

? Request to delete your personal data;

? Require us to temporarily or permanently restrict the processing of some or all of your personal data;

? Require us to transmit personal information to you or a third party when we process your data based on your consent or the contract signed with you, and when we automatically process your data;

? When we use your data based on your consent or our legitimate interests, we choose to oppose or refuse us to use your personal data.

Information security measures

We take commercially reasonable physical, management and technical guarantee measures to maintain the integrity and security of your personal information. Oulun provides a variety of security policies to effectively ensure the security of user and equipment data. In terms of device access, we use Oulun proprietary algorithm to ensure data isolation, access authentication and authorization application. In terms of data communication, it supports the use of security algorithms, transmission encryption protocols and business level information encryption transmission based on dynamic keys. In terms of data processing, strict data filtering and verification and complete data audit process are adopted. In terms of data storage, all confidential information of users will be securely encrypted for storage. If for any reason you think your interaction with us is no longer secure (for example, you think the security of your Oulun account has been compromised), please send an email to umspark@Oulun.com.cn to let us know immediately.

Information retention period

We will process your personal data for the shortest period of time to achieve the purpose stated in the privacy statement, unless it needs to be retained for a longer period of time according to specific legal requirements. We will determine the appropriate retention period according to the quantity, nature and sensitivity of personal data. After the retention period, we will destroy your personal data. If we are unable to perform the above operations for technical reasons, we will take appropriate measures to prevent further use of your personal data.

Change of policy statement

We may update this privacy statement according to changes in information practice. If we make any significant changes, we will notify you by email (sent to the email address specified in your account) or publish the notice on the mobile app before the change takes effect. We recommend that you visit this page regularly to get the latest information about privacy practices.

List of third-party SDKs

In order to ensure the stable operation of our equipment or realize relevant functions, we may access the software development kit (SDK) provided by a third party to achieve the above purpose. We will do our duty of prudence to strictly monitor the security of the software tool development kit (SDK) for partners to obtain information, so as to protect data security.

The third-party SDK we access mainly serves the needs of you and other users. Therefore, when meeting new service requirements and business function changes, we may adjust the third-party SDK we access. We will promptly disclose the latest situation of accessing the third-party SDK to you in this description. At present, the third-party SDK accessed by our equipment is listed as follows:

Huawei equipment management service SDK

Purpose of collecting personal information: complete the end cloud authorization verification with Huawei cloud to ensure that your products always meet the requirements of HarmonyOS Connect certification.

Type of personal data collected: device hardware identifier, device hardware parameters and system version information related to the device.

Third party SDK privacy statement: Statement on Huawei equipment management service and privacy.

We will provide corresponding security protection measures for your personal information in accordance with legal requirements and mature, reliable and secure solutions in the industry.