Effective Date: 2019-1-18
Updated Date: 2018-12-18
LSC., its affiliates and subsidiaries (“we”, “us”,
“our”, “:LSC”) are committed to protecting your privacy. This Privacy Statement
(“Statement”) 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”)
· LSC Smart Connect Smart Mobile
Application
·
Smart
Life Mobile Application
In this Privacy Notice, “Personal Data” means
information that can be used to identify an individual, either from that
information alone, or from that information and other information we have
access to about that individual. “Smart Devices” refers to those nonstandard
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 LSC that provide end users remote control to Smart
Devices and with the ability to connect to LSC IoT Platform.
For other branded mobile applications powered by LSC, our Clients control all the Personal Data collected
through our Products. We collect the information under the direction of our
Clients and the processing of such information shall be limited to the purpose
of providing the service for which our Clients has engaged us. If you are a
customer of one of our Clients and would no longer like to be contacted by one
of our Clients that use our service, please contact the Client that you
interact with directly.
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.
·
Information
You Voluntarily Provide Us
o
Account or Profile Data: When you register an account
with us, we may collect your contact details, such as your email address, phone
number, and user name. 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.
o
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
We Collect Automatically
o
Device Information: When you interact with our
Product, we automatically collect device information, such as the MAC address
of your devices, IP address, wireless connection information, operating system
type and version, application version number, push notification identifier, log
files, and mobile network information.
o
Usage Data: During your interaction with
our Sites and Services, we automatically collect usage data relating to visits,
clicks, downloads, messages sent/received, and other usage of our Sites and
Services.
o
Log information: When you use our app, the
application and exception log may be uploaded.
o
Location Information: We may collect information
about your real-time precise or non-precise geo-location when you use our
specific Products or Services, such as robot cleaner and weather service.
·
Smart
Devices Related Information:
o
Basic information of Smart Devices: When you connect your Smart
Devices with our Products or 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.
o
Information reported by Smart Devices: Depending on the different
Smart Devices you elect to connect with our Products or Services, we may
collect different information reported by your Smart Devices. For example,
smart weights or fitness trackers may report your height, weight, body fat mass
(BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or
videos captured by it.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about
you are as follows:
· Provide You Services: We process your account and
profile data, device information, usage data, location information, and Smart
Device related information to provide you with our Products and Services that
you have requested or purchased. The legal basis for this processing is to
perform our contract with you according to our Terms of Use.,
· Improve Our Services: We process your device
information, usage data, location information and Smart Device related
information to ensure the functions and safety of our Products, to develop and
improve our Products and 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
Terms of Use.
· 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.
Because this information may be important, you may not opt-out of receiving
such communications. The legal basis for this processing is to perform our contract
with you according to our Terms of Use.
· Marketing Communication: We may process your personal
data to provide marketing and promotional materials to you on our Products and
Services. If we do so, each communication we send you will contain instructions
permitting you to opt-out of receiving future communications of that nature.
The legal basis for this processing is your consent. Additionally, if
you consent to participate in our lottery, contest or other promotions, we may
use your personal data to manage such activities.
·
Personalization: We may process your account
and profile 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 our Products. The legal basis for this processing is your consent.
· Legal Compliance: We may process your personal
data as we believe to be necessary or appropriate: (a) to comply with
applicable laws and regulations; (b) to comply with legal process; (c) to
respond to requests from public and government authorities (d) to enforce our
terms and conditions; (e) to protect our operations, business and systems; (f)
to protect our rights, privacy, safety or property, and/or that of other users,
including you; and (g) to allow us to pursue available remedies or limit the
damages that we may sustain.
Who do we share Personal Data with?
At LSC, 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 Sites
and Services.
· 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,
incompatible new uses of your personal information, and choices you may have
regarding your personal information.
· As we believe to be necessary
or appropriate: (a) to comply with applicable laws and regulations; (b) to
comply with legal process; (c) to respond to requests from public and
government authorities, including public and government authorities outside
your country of residence; (d) to enforce our terms and conditions; (e) to
protect our operations, business and systems; (f) to protect our rights,
privacy, safety or property, and/or that of other users, including you; and (g)
to allow us to pursue available remedies or limit the damages that we may
sustain.
· To subsidiaries or affiliates
within our corporate family, to carry out regular business activities.
Except for the third parties described above, to third
parties only with your consent.
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:
· Via the “Profile – Personal
Center” in our Products (for Product version 3.2 and later)
· By emailing us at info@lscsmartconnect.com product version before 3.2)
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 information deleted from our database or otherwise let us
know what limitations you would like to put on our use of your personal
information. Please note that we may ask you to verify your identity before
taking further action on your request, for security purposes.
You
may:
· Request access to the personal
data that we process about you;
· Request that we correct
inaccurate or incomplete personal information about you;
· Request deletion of personal
data about you;
· Request restrictions,
temporarily or permanently, on our processing of some or all personal data
about you;
· Request transfer of personal
information 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; and
· Opt-out or object to our use
of personal data about you where our use is based on your consent or our
legitimate interests.
Information Security Safeguards
We use commercially reasonable physical,
administrative, and technical safeguards to preserve the integrity and security
of your personal information. LSC provides various security strategies to
effectively ensure data security of user and device. As for device access, LSC
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 must immediately notify us of the problem by info@lscsmartconnect.com.
We process your personal data for the minimum period
necessary for the purposes set out in this Privacy Notice, 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. 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.
We may update this Privacy Notice 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.
Legal application and jurisdiction
This policy is formulated in accordance with the laws
of the People's Republic of China and shall be governed by the laws of the
People's Republic of China.
If you have any questions about our practices or this
Privacy Notice, please contact us as follows:
LSC Smart Connect.
Email: info@lscsmartconnect.com