Privacy statement

Effective Date:2019-12-12

Updated Date:2019-12-12

ShenZhen Vatilon Electronics Co., Ltd. and its affiliates and subsidiaries (hereinafter referred to as "we", "our", "Vatilon") 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

• HUBETOCH 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 Vatilon that can help end users remotely control smart devices and connect to Vatilon IOT platform mobile application .

For other brand app provided by Vatilon, 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 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 voluntarily provide to us:

Account or user profile data:When you register for our account, we may collect some of your information, such as your email address, phone number, and user name. During your interaction with our products, we may collect nicknames, avatars, country codes, language preferences, or time zone information in your account.

Feedback:When you use the feedback and suggestion functions in our products, we will collect your email address, mobile phone number and feedback content in order to deal with your problems and equipment failures in a timely manner.

Information we collect automatically:

Device information:When you interact with our products, we automatically collect device information, such as the device’s 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 websites and services, we will automatically collect usage data related to visits, clicks, downloads, sending/receiving messages, and other usage of our websites and services.

Log information:When you use our app, application logs and exception stacks may be uploaded.

Location information:Only when you use our specific products or services (such as sweeping robots and weather services), we will collect information about your real-time accurate or inaccurate Geolocation information.

Smart device related information:

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

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.

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.

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 Vatilon, 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:3007798606@qq.com Send us an email via "HUBETOCH and Suggestions-I Want to Feedback-Account-related" or directly in the "My-About Us" email 3007798606@qq.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. Vatilon provides a variety of security strategies to effectively ensure the security of user and device data. In terms of device access, we use Vatilon'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 Vatilon’s accounts has been compromised), please email us at 3007798606@qq.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 via 3007798606@qq.com

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: ShenZhen Vatilon Electronics Co., Ltd.

Mailing address: 1ST F No. 5th Bldg., SZCG Guanlan Automotive Electronics Characteristic Industrial Park, No.299 Guanping Rd. Longhua, Shenzhen, Guangdong.518110

Email: 3007798606@qq.com