Privacy Notice
Effective Date: 2019-1-18
Updated Date: 2018-12-28
Yankon Lighting, Inc., its affiliates and
subsidiaries (“we”, “us”, “our”, “Yankon”) 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”)
•
Energetic
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”
used in the smart lighting refers to those mobile applications developed by
Yankon that provide end users remote control to Smart Devices and with the
ability to connect to the third party IoT Platform.
For other branded mobile applications
powered by Yankon, 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
◦
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.
◦
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
◦
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.
◦
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.
◦
Log
information: When you use our
app, the application and exception log may be uploaded.
◦
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:
◦
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.
◦
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 Yankon, 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 privacy@yankon.com (for 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. Yankon provides various security strategies to
effectively ensure data security of user and device. As for device access,
Yankon 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 privacy@yankon.com.
Information
Retention Period
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.
Changes to this
Policy Notice
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:
Yankon Lighting, Inc.
660 International Parkway Ste.120
Richardson, TX 75081
Email: Privacy@yankon.com.