Last updated on: Sep.,16, 2022
Effective date: Sep.,16, 2022
Thank
you for choosing UBTECH Robotics Corp. Ltd AIRROBO PET APP!
We will
provide you with detailed information about how we collect, use, and store
your personal information when you use the AIRROBO PET app, the relevant
rights that you are entitled to, and other matters in the Privacy Policy
of AIRROBO PET (hereinafter referred to as the "Policy").
The main
points, among others, are as follows:
1. For the purposes of the
Policy, UBTECH Robotics Corp. Ltd (hereinafter referred to as "we") is
AIRROBO PET's service provider, UBTECH Robotics Corp. Ltd Corp., with its
registered address at 22/F, Building C1, Nanshan Zhiyuan, 1001
Xueyuan Avenue, Nanshan District, Shenzhen.
Email: support-jp@ubtrobot.com
2. For the purposes of the
Policy, AIRROBO PET refers to the AIRROBO PET app and its corresponding
Smart Cat Litter Box.
3. We will collect some of your personal
or sensitive personal information after
obtaining your authorization or consent. For example, you are required to
verify your mobile phone number or email
address when you log in for the first time. We will record your mobile
phone number.
4. We will not transfer your personal information to
any third party other than UBTECH Robotics Corp. Ltd, except with your
consent or as required by relevant laws and regulations or competent
authorities.
5. We will not obtain your personal information from any
third party other than UBTECH Robotics Corp. Ltd, except with your consent
or as required by relevant laws and regulations or competent authorities.
For more detailed information, please refer to the following index to
read the relevant sections.
I. How Do We Collect and Use Your Personal Information
II. How Do We Use Cookies and Similar Technologies
III. How Do We Share, Transfer and Disclose Your Personal
Information
IV. How Do We Transfer Your Personal Information Worldwide
V. How Do We Protect Your Personal Information
VI. How Do We Handle Minors' Personal Information
VII. How Do We Ensure Your Exercise of Personal Rights
VIII. How to Update the Policy
IX. Our Contact Information
1.How Do We Collect and Use Your Personal Information
To ensure the product and services can operate as intended, we need
to process your personal information in certain circumstances. As a data
controller, we have implemented the appropriate technical and
organizational measures to protect the security of personal information in
accordance with the requirements of the law.
1. Purpose of collecting personal information
Your personal information will be collected and used for the
following purposes during your use of this product:
(a) to help you
become a user of AIRROBO PET and keep your personal information secure;
(b)
to help you control the machine and manage your cat's activities through
AIRROBO PET;
(c) to make it easier for you to quickly and
conveniently resolve any issues you have while using the product;
2. Types of personal information to be collected
(1) Personal information you provide to us directly
Identification information, including your mobile phone number and
email address. You can also choose to enter your name, gender, date of
birth, region, and other information to improve your account profile.
After you voluntarily deregister your account, your personal information
will be deleted or anonymized as required by law. In this case, you are
free to decide what personal data you want to provide to us. However, if
you refuse to provide your identification information, you may be
restricted to some of AIRROBO PET's functions or services.
(2) Personal data we automatically collect about you
■ Geolocation information. After you grant us permission to access geolocation (under the Google framework of the Android system, the location
information must be obtained before a Bluetooth connection is set up)
and Bluetooth, the app will collect your geolocation
information and connect to the litter box through the Bluetooth scan.
■
Network connection information. We will collect your Wi-Fi information
(SSID, Wi-Fi Mac address, and Wi-Fi password) and device SN in order to
connect your machine to the network of the app. Such information will be
stored locally on the device and will not be uploaded to the cloud. To
properly connect the device to the network the Wi-Fi information will be
sent to the device through the Bluetooth connection. If you refuse to
provide the above personal information, you will not be able to use the
network connection function.
■ Cat profile: when you use AIRROBO PET
to sync the data of the relevant device, we will record your cat's
profile, including the avatar, nickname, breed, gender, date of birth,
activities, toileting, pictures and weight of the cat.
(3) Information required to be collected to improve the product and
provide the services
■ Services and after-sales related personal information. If you contact our customer service hotline to report any issues,
we may ask you to provide the necessary personal information for identity
verification in order to protect the security of your account. We may also
store your contact information (mobile phone number, email address, or
other contact information you use or voluntarily provide), the record and
content of your call, and other information necessary to provide and
record the customer services for you.
■ Operation information on the device and the app. We will collect and record your personal frequently used device
information, fault information, and performance information according to
the specific permissions granted by you during the installation and use of
the product, in order to analyze the operation of our product and use such
information for product operation and maintenance and security. Personal
information include:
IP address, your device SN information
and android_id. we will notify you If we need to get your consent to
collect any additional personal information. Until you choose to give us
permission, we will not obtain the relevant personal information.
II. How Do We Use Cookies and Similar Technologies
To ensure the normal functioning of our services and to provide you
with a smoother and easier user experience, we occasionally access small
data files known as cookies on your computer, mobile communication
terminal, or device. We may collect and store data about your visits to
our website or mobile app through a variety of technologies for us to
identify you, save you from re-entering registration information or help
determine the security status of your account. Such data files may include
cookies, clickstreams, webs, and other local storage files provided by
your browser or associated apps (hereinafter collectively referred to as
the "Cookies"), allowing you to save time by not having to re-enter or
re-set your user settings each time you open the app or browser. You can
clear the cache in the corresponding settings of your browser or app.
Please be aware that some of our services are only available by using
Cookies.
III. How Do We Share, Transfer and Disclose Your Personal
Information
(I) Sharing
1. Service provider who is a data processor
• Please be aware that some functions and services of the product
provided by us cannot be completed by us alone. To provide you with
complete product functions and a good user experience, we will access
the software development kits (SDKs) provided by the service providers
to fulfill the relevant functions described in the Privacy
Policy. These functions include providing us access to data storage
services, data processing, and log analysis. We provide such information
in order to support the core functions of our product and/or services. We
will conduct strict security monitoring of the SDKs whereby the service
providers obtain information to protect data security. • For more
information about the types of personal information that our service
providers collect and the purposes of collection, please refer
to the List of Personal Information Collected and Used by Service
Providers.
2. Sharing of other personal information
We
may share your personal information with our affiliates. We will only
share necessary personal information for the purposes stated in the
Privacy Policy. Our affiliates will further request your authorization or
consent if they need to change the purposes for processing personal
information. We will not provide your personal information to companies,
organizations, and individuals other than the above-mentioned service
providers and affiliates of UBTECH Robotics Corp. Ltd, except with your
consent or as required by relevant laws, regulations, and competent
authorities.
(II) Transfer
We will not transfer
your personal information to any company, organization, or individual
except in the following circumstances:
(1) we have obtained your
explicit consent or authorization in advance;
(2) information must be
provided in accordance with the requirements of laws and regulations and
legal procedures as well as the mandatory administrative or judicial
requirements;
(3) it is provided in accordance with relevant
agreements you signed (including electronic agreements signed online and
corresponding platform rules) or other legal documents;
(4) in the
event of mergers, acquisitions, asset transfers, or similar transactions,
please note that the portion sold may contain your personal information.
In the event that your personal information is transferred, we will
require the new company or organization to continue to hold your personal
information in accordance with the Policy; otherwise, we will require the
new company or organization to request your authorization or consent
again.
(III) Disclosure
We will not disclose
your personal information to any company, organization, or individual
except with your consent or as required by relevant laws and regulations.
IV. How Do We Transfer Your Personal Information Worldwide
We use our global operation and control facilities to process and
back up personal information. At present, according to our business
expansion, we have servers in China, the United States and other
countries. For the purposes described in the Privacy Policy, your
information may be transmitted to these servers in accordance with
applicable laws. We will store personal information collected and
generated during our operations in the United States on servers in the
United States, unless cross-border transfers are permitted under
applicable law. If we need to transfer your personal information outside
of your jurisdiction, whether to our affiliates or service providers, we
will observe applicable laws. We ensure that all such transfers comply
with applicable local data protection laws by implementing uniform
safeguards. If you reside in the European Economic Area, we will share
your personal data in accordance with the GDPR transmission of personal
information requirements. We will make sure that the relevant laws are
followed when transmitting your personal information to organizations
outside the European Economic Area. We will only share your personal
information with organizations in countries with "adequate protection";
otherwise we will adopt appropriate safeguards (e.g. standard contract
terms) to transmit the information. Without the necessary safeguards
outlined above, we will only transmit personal information with your
consent.
V. How Do We Protect Your Personal Information
When
you provide us with your personal information, we will only retain your
personal information for as long as it is necessary to fulfill the
purposes set forth in the Policy, unless a longer retention period is
mandated or permitted by law. We have appropriate organizational
safeguards and security measures in place to protect your personal
information against accidental loss, unauthorized use or access,
alteration, or disclosure. For example, if possible, we use encryption to
transmit and store data. We use access controls and confidentiality
undertakings to further restrict access to such data. When using the
product or services, we advise you to give adequate consideration to the
protection of your personal information, particularly your login
credentials, password, and other important personal information.
Additionally, we will make every effort to ensure the security of your
personal information. In the event of a personal information security
incident, we will initiate an emergency plan to prevent the damage caused
by the security incident from getting worse and take the initiative to
report the disposal of the personal information security incident in
accordance with the requirements of relevant laws and regulations and
regulators. In accordance with the requirements of relevant laws and
regulations, if necessary, we will also inform you of the basic situation
of the security incident and the disposal and remedial measures we will
take or have taken via notification, email/SMS, telephone, etc. through
the app. If it is difficult to inform users individually, we will issue
warnings through announcements and otherwise.
VI. How Do We Handle Minors' Personal Information
Our app is not intended for use by minors, and we will not
intentionally collect personal information on children in accordance with
the Children's Online Privacy Protection Act (COPPA)
and other laws and regulations. If you are a parent or legal guardian and
you believe that your child may have given us his or her personal
information, please contact us to request an erasure.
VII. How Do We Ensure Your Exercise of Personal Rights
We are committed to observing data protection laws of different
countries and regions around the world, such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Subject to applicable laws, you may exercise the following
rights:
Right of access: Subject to any
limitations imposed by laws and regulations, you have the right to access
and review copies of your personal information;
Right to rectification: if you find that the personal information you provided is
inaccurate or incomplete you have the right to update or rectify it;
Right to erasure: you have the right to require us to erase your personal
information. If the proper conditions are met, we will evaluate your
request for erasure and take the relevant actions, including using
technical means.
Right to data portability: you
have the right to have your personal data transmitted 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 will
only process your personal information on the following lawful basis:
(1)
we have obtained your consent;
(2) to honor the contract between you
and us;
(3) to fulfill our legal obligations;
(4) to protect
your vital interests;
(5) for public interests;
(6) for our
legitimate interests without compromising your fundamental rights and
freedoms,
In certain circumstances, you also have the right to file a
complaint with regulatory authorities. We have also designated a data
protection officer to be in charge of overseeing the protection of your
personal information. For more information or to exercise your rights,
please contact us.
2. Californian privacy rights Right to information access and erasure.
After verifying your identity, Californian consumers have the right to request enterprises to disclose the following personal information they have collected during the past 12 months up to two times during a 12-month period:
(1) the categories of personal information collected;
(2) the categories of sources from which personal information is collected.
(3) the purposes for which the business uses the personal information;
(4) The categories of third parties that share the personal information;
(5) the categories of consumer personal information sold or disclosed to third parties;
(6) the categories of consumer personal information disclosed for commercial purposes;
(7) specific consumer personal information collected; To make such a request, please contact us.
Refusing to have personal information sold. If you
are a Californian consumer, you have the right to refuse us to sell your
personal information. It is important to note that under the CCPA, some of
the personal information shared to provide you with personalized
advertisements may be deemed to have been "sold", even though no money is
exchanged. Third-party marketing. Pursuant to Section 1798.83 of the
California Civil Code, you have the right to request from us third parties
to whom we disclose your personal information for direct marketing
purposes. Please contact us if you would like to make such a request.
3. Automated decision-making
If an automated
decision might affect you legally or significantly in another way, you
have the right to refuse the processing of your personal information
solely based on that decision. We will not use user personal information
to participate in automated decision-making that would have legal or other
significant impacts.
4. Deregistration of the account
You can apply to deregister your account directly in our app. Your
personal account is created using your mobile phone number/email address.
You can deregister your personal account through "My" - "Account
Management" - "Deregister Account". Please exercise caution since deregistration of your account could
result in the deletion of all information associated with it.
VIII. How to Update the Policy
We reserve the right
to periodically update or modify the Policy in response to changing
circumstances, such as those related to product functions, services, or
organization. Any modification to the Privacy Policy will be posted on
this page. If there are material modifications, we will notify you of the
modified Privacy Policy via a pop-up window when you log in.
IX. Our Contact Information
If you have any
questions about this Privacy Policy or have any complaints or comments
about the handling of your personal information, you can contact us
through the APP settings interface "My" - "Account Management" - "Customer
Services", or you can contact us at:
Email: support-jp@ubtrobot.com
Office address: 22/F, Building C1, Nanshan Zhiyuan, 1001 Xueyuan
Avenue, Nanshan District, Shenzhen, Guangdong Province
We will reply
to you within the legally required time frame. If you are not satisfied
with our reply, especially if our handling of your personal information
has harmed your legitimate rights and interests, you may also file a
complaint or tip-off with the data protection regulatory authority.
Appendix: Description of Keywords in the Policy
Sensitive personal information: personal
telephone number, identity card number, personal biometric information,
and precise positioning information.
Affiliate: refers to a party that is under direct or indirect control by
UBTECH Robotics Corp. Ltd; or an institution that is, together with a
party, under common direct or indirect control by another institution.
"Control" refers to having the ability, directly or indirectly, to
influence the management of an enterprise, whether through ownership,
voting shares, agreements, or otherwise.
De-identification: refers to the process used to remove the association between
personal information and a specific natural person, in such a way that it
cannot be used to identify a person without the help of additional
information.
Anonymization: refers to the
process used to permanently remove the association between personal
information and a specific natural person in such a way that it cannot be
used to identify a person.