Privacy Policy of Havalives
Havalives and subsidiaries (¡°we¡±, ¡°us¡±,
¡°our¡±, ¡°Havalives¡±) are committed to
protecting your privacy. This Privacy Policy (¡°Policy¡±) describes our practices
in connection with information privacy on Personal Data we process through your
individual use of the following services, products, and related mobile
applications (collectively, the ¡°Products¡±):
Havalives Mobile Application
Before you use our Products, please carefully read
through this Policy and understand our purposes and practices of collection,
processing of your Personal Data, including how we use, store, share and
transfer Personal Data. In the Policy you will also find ways to execute your
rights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register with
your Personal Data, or if you start to use our Products and does not expressly
object to the contents of this Policy, we will consider that you fully
understand and agree with this Policy. If you have any question r regarding
this Policy, please do not hesitate to contact us via:
Contact email: havalives@163.com
Definition
In this Policy, Personal Data means information
generated, collected, recorded and/or stored, electronically or otherwise, that
can be used to identify an individual or reflect the activity of an individual,
either from that information alone, or from that information and other
information we have access to about that individual.
Personal Sensitive Data includes precise location
information. When we collect Personal Sensitive Data from you, we will generate
an explicit notification for your consent before we collection personal
sensitive data about you.
Smart Devices refers to those computing devices
produced or manufactured by hardware manufacturers, with human-machine
interface and the ability to transmit data that connect wirelessly to a
network, including: smart home appliances, smart wearable devices, smart air
cleaning devices, etc.
Apps refers to those mobile applications developed by
Havalives that provide end users remote control to Smart Devices and
with the ability to connect to the supplier IoT Platform.
What Personal Data do we collect
In order to provide our 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 our products or services.
1.Information You Voluntarily Provide Us
¡¤Registered Account Data: When you register an
account with us, we may collect your name and contact details, such as your
email address, user name, and login credentials. During your interaction with
our Products, 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 Products 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
Havalives 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 our Products, 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 Devices, 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¡¯s Data Processing and Security Terms
for more details.
You may disable the collection and use of your
location information by changing your mobile device settings ("Me -
Setting - Privacy Settings - Switch on/off Location"), 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.
You may opt-out the using of camera permission:
"Me - Setting - Privacy Settings - Switch on/off Camera".
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.
You may opt-out the using of photo album permission:
"Me - Setting - Privacy Setting - Switch on/off Photo Album".
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.
You may opt-out the using of microphone permission:
"Me - Setting - Privacy Settings - Switch on/off
Microphone".
5)Additional services based on storage
permission(Android):
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.
You may opt-out the using of storage permission:
"Me - Setting - Privacy Settings - Switch on/off Access
storagepermission".
6)Additional services based on Notification
permission:
The reason why we ask you for the permission is to
send you notifications about using the Smart Devices or Services, especially if
you have purchased security services and you require an alert or message so
that you can capture the real-time status.
You may opt-out the using of App notifications:
"Me - Message Center - Setting - Switch on/off Notifications".
7) Additional services based on Bluetooth permission:
You can enable Bluetooth functions after turning on
the permission, including controlling the Smart Devices, acquiring status of,
discovering and configuring Smart Devices. In these functions, we will
communicate with Smart Devices via Bluetooth. Please be aware that even if you
have agreed to enable the Bluetooth permission, we will only use Bluetooth for
communication in these scenarios: display device status on the home page and
Smart Device panel; perform device control on the home page and Smart Device
panel; discovering Smart Devices on the home page and the add device page,
Smart Device distribution network.
You may opt-out the using of Bluetooth via
"Me - Settings - Privacy Settings - Disable/Enable Bluetooth
permission".
2.Information We Collect Automatically
¡¤Mobile Device Information: When you
interact with our Services, in order to provide and maintain the normal
operation of our Services, to improve and optimize our Services, and to protect
your account security as well, we automatically collect mobile device
information, such as mobile device model number, IP address, wireless
connection information, the type and version of the operating
system, 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 installed 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, in order to improve your user experience, the system and exception log may
be uploaded, including your IP address, language preference setting, operating
system version, date or time of access, so that we can facilitate and accurately
identify problems and help you solve them in timely manner.
Please notethat we 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 or 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 collected during the process of
connecting to a Smart Device: Based on the type of Smart Device you
need to connect, the basic information collected includes: Wi-Fi information,
device MAC address, etc.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information
about you are as follows:
¡¤Provide You with Our Services: We
process your account data, usage data, location information, and Smart Device
related information to provide you with the Services that you have requested.
The legal basis for this processing is to perform our contract with you
according to user agreement or some other terms of user.
¡¤Improve Our Services: We
process your usage data, location information and Smart Device related
information to ensure the functions and safety of the Services, to develop and
improve the Services, to analyze the efficiency of our operations and to
prevent and trace fraudulent or inappropriate usage. The legal basis for this
processing is to perform our contract with you according to our user agreement
or some other terms of user.
¡¤Non-marketing Communication: We
process your Personal Data to send you important information regarding the
Services, changes to our terms, conditions, and policies and/or other
administrative information. At the same time, we will also send you
notifications related to the services you have purchased, such as alert
services. You can check the ¡°App Notification¡± in the App ("Me &rt;
Message Center &rt; Setting &rt; Notification Setting¡±) to manage these
communications. When you decide not to enable the Notifications function, we
will no longer process your information for such purpose. The legal basis for
this processing is to perform our contract with you according to our user
agreement or some other terms of user.
¡¤Data Analysis: In order to
analyze the usage of the products we provide and improve your user experience,
we will analyze the data you provide us, a) we need to check your problems when
you encounter any malfunctions during the usage of the product, under such
circumstance, you may not able to opt-out because it is highly relate to your
functionalities and quality of using our product and service, and b) analyze
data about how you interface with the product or under particular scenarios so
that you can better enjoy the convenience brought by our Services, under such
circumstance, if you do not agree to data analysis of your data, you can enter
the privacy settings of App (¡°Me &rt; Settings &rt; Privacy
Settings &rt; Service Maintenance & Improvement Activity¡±) to
opt-out your selection. The legal basis for such processing is based on your
consent.
¡¤Marketing Communication and
Personalization: We may process your account data, usage data,
device information to personalize product design and to provide you with
services tailored for you, such as recommending and displaying information and
advertisements regarding products suited to you, and to invite you to
participate in surveys relating to your use of the Services. If you do not
allow us to process your Personal Data for personalization, you may opt out
when you enter the App, or by changing your preferences in ¡°Privacy Settings¡±
(¡°Me&rt; Settings &rt; Privacy Settings &rt; Personalized
Recommendations¡±) in the App. The legal basis for this processing is your
consent.
¡¤Legal Compliance. We disclose
information if we are legally required to do so, or if we have a good faith
belief that such use is reasonably necessary to:
¡¤comply with a legal obligation, process or request;
¡¤enforce our User Agreement and other agreements,
policies, and standards, including investigation of any potential violation
thereof;
¡¤protect the rights, property or safety of us, our
users, a third party or the public as required or permitted by law; or
¡¤detect, prevent or otherwise address security, fraud
or technical issues.
If there is any change in the purposes for processing
your personal data, we will inform such change to you via email and/or a
prominent notice on our website of such changes of purposes, and choices you
may have regarding your Personal Data.
Who do we Share Personal Data with?
At Havalives, we only share Personal Data
in ways that we tell you about. We may share your Personal Data with the
following recipients:
¡¤To our third-party service providers who perform
certain business-related functions for us, such as website hosting, data
analysis, payment and credit card processing, infrastructure provision, IT
services, customer support service, e-mail delivery services, and other similar
services to enable them to provide services to us.
¡¤To our customers and other business partners who
provide you, directly or indirectly, with your Smart Devices, and/or networks
and systems through which you access and use our websites and Services.
¡¤To subsidiaries or affiliates within our corporate
family for purpose of regular business activities based on our instructions and
in compliance with applicable law, this Policy and other appropriate
confidentiality and security measures.
¡¤To an affiliate or other third party in the event of
any reorganization, merger, sale, joint venture, assignment, transfer or other
disposition of all or any portion of our business, assets or stock (including
without limitation in connection with any bankruptcy or similar proceedings).
In such an event, you will be notified via email and/or a prominent notice on
our website of any change in ownership, and choices you may have regarding your
Personal Data.
¡¤As we believe in good faith that access to, or use,
preservation, or disclosure of the information is reasonably necessary or
appropriate to:
(a)Comply with applicable law, regulation, legal
process, or lawful governmental request;
(b)Enforce our User Agreement and other agreements,
policies, and standards, including investigation of any potential violation
thereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property or safety of us, our
users, a third party or the public as required or permitted by law; or
(e)Perform risk management, screening and checks for
unlawful, fraudulent, deceptive or malicious activities.
Except for the third parties mentioned above, we only
disclose your Personal Data to other third parties with your consent.
International Transfer of Information Collected
Havaliveswill comply with applicable data localization
requirements in corresponding jurisdictions with respect to storage of data. To
facilitate our operation, we may transfer, store and process your Personal Data
in jurisdictions other than where you live. Laws in these countries may differ
from the laws applicable to your country of residence. When we do so, we will
ensure that an adequate level of protection is provided for the information by
using one or more of the following approaches:
¡¤Agreement on the basis of approved EU standard
contractual clauses per GDPR Art. 46. For more information,
see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If you would like further detail on the safeguards we
have in place, you can contact us directly as described in this Privacy Policy.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal
Data. You may exercise any of the following rights:
You do not have to pay a fee and we will aim to
respond you within 30 days. If you decide to email us, in your request, please
make clear what information you would like to have changed, whether you would
like to have your Personal Data deleted from our database or otherwise let us
know what limitations you would like to put on our use of your Personal Data.
Please note that we may ask you to verify your identity before taking further
action on your request, for security purposes.
You may:
¡¤Request that we correct inaccurate or incomplete
Personal Data about you: 1) Modify your account number (email address or phone
number): "Me-Setting-Account and Security-Change your Account"; 2)
Modify the nickname and/or time zone: "My-Personal Information";
¡¤Request deletion of Personal Data about you:
"Me-Setting-Account and Security-Delete Account", when you confirm
the deletion of your account, your Personal Data will be deleted accordingly.
¡¤Request restrictions, temporarily or permanently, on
our processing of some or all Personal Data about you: Please send over your
request through "Me-FAQ & Feedback", or send over the email
request to jx3jijijiao@163.com;
¡¤Request transfer of Personal Data to you or a third
party where we process the data based on your consent or a contract with you,
and where our processing is automated: Please send over your request through
"Me-FAQ & Feedback", or send over the email request to
jx3jijijiao@163.com;
¡¤Opt-out or object to our use of Personal Data about
you where our use is based on your consent or our legitimate interests.
We will exercise your privacy right to withdraw
consent through the following approaches:
1)For privacy permissions acquired through device
system settings, your consent can be withdrawn by changing device permissions,
including location, camera, photo album (picture library/video library),
microphone, Bluetooth settings, notification settings and other related
functions;
2)You may opt-out the non-marketing communication
through ¡°Me &rt; Message Center &rt; Notification Settings¡± to manage
your selection;
3)You may opt-out the data analysis features through
¡°Me &rt; Settings &rt; Privacy Settings¡±;
4)You may opt-out the Personalization feature through
¡°Me &rt; Settings &rt; Privacy Settings &rt; Personalized
Recommendations¡±;
5)Unbind the Smart Device through the App, and the
information related to the Smart Device will not be collected;
6)By using product with the "Try
Now" mode, and not enable certain location setting for
particular smart scene, we will not collect any Personal Data about you;
7)If you previously agreed to associate App account
with a third-party service, such as a health platform, please unbind it on the
third-party platform.
When you withdraw your consent or authorization, we
may not be able to continue to provide you with certain products or services
correspondingly. However, your withdrawal of your consent or authorization will
not affect the processing of personal information based on your consent before
the withdrawal.
AboutDeletion of the Account: You
can find the Delete function through ¡°Me &rt; Settings &rt; Account and
Security &rt; Delete Account¡± (Deactivate Account£©
Security Measures
We use commercially reasonable physical,
administrative, and technical safeguards to preserve the integrity and security
of your Personal Data. Havalives provides various security strategies to
effectively ensure data security of user and device. As for device access, Havalives
proprietary algorithms are employed to ensure data isolation, access
authentication, applying for authorization. As for data communication,
communication using security algorithms and transmission encryption protocols
and commercial level information encryption transmission based on dynamic
keys are supported. As for data processing, strict data filtering and
validation and complete data audit are applied. As for data storage, all
confidential information of users will be safely encrypted for storage. If you
have reason to believe that your interaction with us is no longer secure (for
example, if you feel that the security of any account you might have with us
has been compromised), you could immediately notify us of the problem by emailing havalives@163.com.
Data Retention
We process your Personal Data for the minimum period
necessary for the purposes set out in this Policy, unless there is a specific
legal requirement for us to keep the data for a longer retention period. We
determine the appropriate retention period based on the amount, nature, and
sensitivity of your Personal Data, and after the retention period ends, we will
destruct your Personal Data.
¡¤For as long as you require us to fulfill the
products and services you request from us as defined in the user agreement or
some other terms of user;
¡¤Personal Data will no longer be retained when you
request to remove your Personal Data, we will accordingly complete the task.
When we are unable to do so for technical reasons, we
will ensure that appropriate measures are put in place to prevent any further
such use of your Personal Data.
Children¡¯s Privacy
Protecting the privacy of young children is
especially important to us. The Services are not directed to individuals under
the age of thirteen (13) (or such other age provided by applicable law in your
country/region of residence), and we request that these individuals do not
provide any Personal Data to us. We do not knowingly collect Personal Data from
any child unless we first obtain permission from that child¡¯s parent or legal
guardian. If we become aware that we have collected Personal Data from any child
without permission from that child¡¯s parent or legal guardian, we will take
steps to remove that information..
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes
to our information practices. If we make any material changes we will notify
you by email (send to the e-mail address specified in your account) or by means
of a notice in the mobile applications prior to the change becoming effective.
We encourage you to periodically review this page for the latest information on
our privacy practices.
Contact Us
If you have any questions about our practices or this
Privacy Policy, please contact us as follows:
Email: havalives@163.com
Postal Mailing Address: Room 217, 2nd Floor,
Forming Workshop (Building A), No. 8 Pingdong 2nd Road, Nanping, Zhuhai