RCV home privacy policy
Update Date: June 21, 2022
Effective date: June 21, 2022
summary
This policy will help you understand the following:
1、 How we collect and use your personal information
2、 How we store and protect your personal information
3、 Our general situation of providing your personal information externally
4、 Unconventional circumstances in which we provide your personal information externally
5、 How do you access and control your personal information
6、 Special agreement on personal information of minors
7、 Revision and publicity position of this policy
8、 How to contact us
[Shenzhen 3irobotix Co., Ltd.] (hereinafter referred to as "we" or "3i") respects and protects your privacy. If you use the home robot product (your "home robot") and its supporting online Application ("App") related services ("products and services") under the brand of 3i and are bound by the RCV Home User Agreement. Please understand how we will collect, use, disclose, share, transfer and store your personal information and what rights you have according to this policy. We will strictly abide by this policy. Through this policy, we make the following important commitments to you. If you want more detailed information, please read the corresponding chapters according to the above index:
1. We will explain the type of your personal information we collect and its corresponding purpose one by one, so that you can understand the category, reason and collection method of the specific personal information we collect for a specific product, service or function.
2. The personal information we collect may contain your personal sensitive information. Once the personal sensitive information is leaked, illegally provided or abused, it may endanger personal and property safety, and it is very easy to cause personal reputation, physical and mental health damage or discriminatory treatment. For such collection, the following bold words are used to remind you to pay attention.
3. You can access, correct and delete your personal information through the ways or channels listed in this policy. You can also withdraw your consent, cancel your App account, complain, report, and set privacy functions to achieve your control over your personal information.
You understand that this policy is closely related to your use of products and services. We recommend that you carefully read and understand all the contents of this policy and make the Appropriate choices you think. We strive to use easy-to-understand and concise words, make clear the clauses in this policy that have or may have a significant relationship with your rights and interests, and mark in bold to remind you of it.
If you have any questions about this policy, or any relevant complaints and opinions, please contact our data protection department through the contact information shown in Article 8 of this policy, which is responsible for dealing with your special needs in a timely manner. We are happy to handle your problems and meet your needs.
You understand and agree that as long as you click to accept this policy and complete the registration of the App account in the account registration procedure, or actually use our products and services, it means that you agree that we will collect, use, store and share your relevant information in accordance with this privacy policy.
The applicable law of this policy is the law of the people's Republic of China.
1、 How we collect and use your personal information
（1） Collect and use your personal information for basic business functions
The basic business functions of the products and services we provide to you include: (I) all functions of your home robot (subject to the product specifications); (II) the App is paired with your home robot, controls and records the operation of the product; (III) communication and handling related to the use and operation of the App and your home robot paired with the App. Specifically, for the following occasions, you need to agree to provide the following types of personal information, so that we can safely and effectively realize the above basic functions, otherwise you may not be able to enjoy the corresponding products and services.
1. Register an App account and associate your relevant operation records and various personal information. When you open the App for the first time, we will ask you to confirm your country and region and select the language of the App. The App account is the premise for you to use the App business functions on the mobile device containing the App ("your mobile device") after downloading the App, and will collect all kinds of data you provide and receive in the App based on this. When you register an account in the App, we will collect your mobile number (or email) and password. The above information will be used to verify your identity, match and collect a series of operation activities you make with your App account, match and feed back the operation status of your home robot, facilitate the handling of customer service and after-sales service requirements you put forward to us, and send you a notice about the above situation, a notice about major changes and updates of service functions, and technical and safety notices.
2. Operate your home robot through your App account on your mobile device. When you load an App on your mobile device and bind your App account to your home robot, you first need to configure the network, that is, establish the information flow path of your App account and your home robot through our server. In this regard, you need to connect your mobile device, App account and your home robot to your Wi-Fi network. The data collected during the network configuration process are not all personally identifiable information, including (I) App name; (II) network card (MAC) address, operating system and its version; (III) SSID, network system, displayed IP address, location, time zone and time of sending network configuration request to our server of the same Wi-Fi network accessed by your mobile device and your home robot; (IV) the model, SN code and MAC address of your home robot; (v) The status and fault type of your network configuration.
In order to let you know the operation, location and failure of your home robot through the App account page, we also need to collect some information from your home robot and transmit it to your App account page through our server. Most of this information is not personally identifiable (such as cleaning alarm information, cleaning report, etc.).
Related to this, we will need to call the following permissions of your mobile device: (I) in order to connect the network configuration and the App functions that need to be connected to the network, we need to call "mobile data", obtain "Wi-Fi information", and also need "local network" permission. In order to complete the network configuration more efficiently, we also need to obtain the "positioning" permission and "Bluetooth" permission of your mobile device; (II) in order to store the App usage log and update the App version, it is necessary to call the "store" permission; (III) to ensure the security of your App account, you need to obtain "device information"; (IV) in order to push various messages related to your account to your mobile device, we need the "notification" permission.
Some models of home robots we provide support the "Share devices" function. For the App account holders (i.e. "sharers") who are paired with them, they are allowed to share control equally with other App account holders
(i.e. "sharers"). If you are a sharer, your App account controls the home robots paired with other App accounts through the "Share devices" function. For the purpose of this policy, these home robots are regarded as your "home robots". For the avoidance of doubt, this privacy policy applies to all uses of such household robots by the sharer and the share. You can also delete the devices that have accepted sharing on the App, or turn off the permission to share to others as a whole.
3. The operation of your home robot. Due to technical limitations, all the data collected by your home robot cannot be processed and stored on the product side. Some of them need to be transmitted to our server for processing, or then transmitted to the App for presentation to you, resulting in the collection of data (which may include personal information).
In order to make your home robot clean in accordance with the specific cleaning environment and the requirements of your restricted area, your home robot will generate your cleaning environment map and cleaning path map when running the cleaning function, which will be transmitted to your App account page through our server for direct display, so that you can mark the area classification in the App (some household robot products of the brand of 3irobotix support different cleaning modes according to the area classification, subject to the list in the product manual), mark the location of restricted area, and then transmit it to your household robot through our server for execution.
Please note that the home robot products of specific models of brands under 3irobotix have AI recognition and radar functions, and their use purposes include the following business functions (please refer to the product manual to understand whether your home robot has such functions, whether such functions are automatically turned on, and how to turn off such functions (if applicable)):
(i) Build an environment map. Radar sensing related data will be used to build 2D maps, which you can access in the App.
(II) To record and identify the type and status of obstacles in a clean environment and avoid obstacles. When you use the device, the camera on the device will collect the image data of the object in front and extract the object features within milliseconds for recognition. The device will judge the obstacle avoidance according to the recognized object type, so as to bypass the obstacles in the cleaning process. After that, the photos will be deleted immediately. You can choose whether to turn on the recognition function and whether to display the recognized objects on the sweeping map. We fully understand the importance of personal privacy. Please rest assured that the collected photos will not be stored on local devices or uploaded to the server. They are only used to generate sweeping maps and support device obstacle avoidance, and will not be used for any other purpose.
This service will start running only after you choose to turn it on, and you can also turn it off. The records generated by this service are only for the use of robots. After the use of robots, the data will be deleted locally and will not be stored in any form. In order to realize AI recognition service, household robots may capture the indoor environment information of the equipment during work, including indoor pattern, ground object information, object distribution, indoor personnel, pets and furnishings. This information is necessary for you to use this service. At the same time, you also need to turn on the AI identification permission of home robots in the App to realize the collection and processing of the information involved in these services. If you refuse to open relevant permissions or refuse us to collect these information, we will not be able to provide you with AI recognition related services, but it will not affect your normal use of basic functions of home robots.
2、 How we store and protect personal information
1. Where we store your personal information. The personal information we collect and generate in China will be stored on our servers in China. If the relevant personal information collected in China is transmitted to overseas institutions due to business or applicable laws, we will implement it in accordance with laws, administrative regulations and the provisions of relevant regulatory authorities, and require overseas institutions to keep the personal information confidential through signing agreements, verification and other effective measures.
2. Our data security capabilities and policies. We promise to make the information security protection reach the security level required by laws and regulations. To protect your information security, we are committed to using various security technologies and supporting management systems to prevent your information from being leaked, damaged or lost. At the same time, we have set up a personal information protection responsibility department, established relevant internal control systems, adopted the principle of minimum sufficiency authorization for staff who may have access to your information, and strictly controlled the data access process and approval mechanism.
3. Our handling of personal information security incidents. Please understand that due to the limitation of technical level and various malicious means that may exist, personal information security incidents may unfortunately occur due to factors beyond our control. If a security incident occurs, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you, etc. in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant information of the incident by email, letter, telephone or push notification. When it is difficult to inform you one by one, we will take a reasonable and effective way to make an announcement. At the same time, we will actively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
4. We delete your personal information. We will only keep your personal information for the period necessary for the purpose stated in this policy and the longest time limit allowed by laws and regulations (whichever expires earlier). Beyond this time limit, we will delete or anonymize it in time. If we stop all or part of your services or relevant operations, we will stop collecting your relevant personal information in time, notify you according to the RCV Home User Agreement, and delete or anonymize your personal information. We will also respond to your request to delete the personal information we have collected in accordance with applicable laws. However, we have the right to continue to retain your personal information in accordance with the provisions of applicable laws (for example, the provisions on the retention time limit of weblogs), or in consideration of your personal information related to the preservation of other legal relationships that still exist between you, we will also continue to retain the consent you have given us to collect and use personal information, subsequent changes or withdrawal of consent records (we will avoid new personal information collection for such retention) in response to legal obligations and potential litigation requirements.
3、 Our general situation of providing your personal information externally
We may disclose your personal information to third parties (as defined below) in order to provide the products or services you require.
We may make disclosures to third-party service providers and affiliates listed below in this section. In all cases described in this section, you can rest assured that 3irobotix robot will only share your personal information according to your authorization. You should understand that in any case described below, when 3irobotix robot shares your personal information with a third-party service provider, 3irobotix robot will stipulate the practices and obligations of the third party through the contract and comply with the applicable local data protection law. 3irobotix robot will ensure that third-party service providers comply with the privacy standards applicable to them in your jurisdiction through contracts.
In order to successfully engage in business operations to provide you with all the functions of products and services, From time to time, we may disclose your personal information to other affiliated companies or our third-party service providers (our mail stores, delivery service providers, agents representing 3irobotix robot) [affiliated companies and / or other third parties] (collectively referred to as "third-party service providers"). Such third-party service providers may process your personal information on behalf of 3irobotix robot or for one or more of the above projects. If you no longer want to allow us to share this information, please send an email to privacy@3irobotics.com to contact us.
4、 Unconventional circumstances in which we provide your personal information externally
（1） Transfer
Transfer means that we lose control of your personal information and the transferee gains control of your personal information. In principle, we will not transfer your personal information to any company, organization or individual. If it is necessary to transfer personal information, we will transfer it in accordance with applicable laws, and inform you of the purpose of the transfer, the personal information involved, the transferee, etc.
One of the possible information transfer situations is that with the continuous development of our business, we may carry out mergers, acquisitions, asset transfers and other transactions (we will inform you of the relevant situations in accordance with the RCV Home User Agreement). If it involves the change of your personal information controller or the sharing and transfer of personal information, we will inform you of the relevant changes and any options you may have about your personal information. We will also require new companies and organizations holding your personal information to continue to be bound by this policy through contracts, etc., otherwise we will further require the company and organization to obtain your express consent again, and continue to protect your personal information in accordance with laws and regulations and standards not lower than those required by this policy, or require the data receiver to continue to protect your personal information.
We will handle the transfer of your personal information according to the above commitments on sharing, and inform you of the transferor's name, contact information, transfer purpose, transfer content, and the corresponding legal responsibilities of the transferor in accordance with applicable laws.
（2） Public disclosure
In principle, we will not publicly disclose your personal information. If public disclosure is really necessary, we will inform you in advance of the purpose of this public disclosure, the type of information disclosed and the content of personal sensitive information that may be involved, and obtain your express consent, as well as perform relevant obligations in accordance with applicable laws.
5、 How do you access and control your personal information
1. How do you access and correct your personal information. You can log in to your App account to view the "user information" and "Settings" interfaces, view or modify your submitted personal data, manage the receiving address and the associated third-party account, or make relevant privacy and security settings. However, for the sake of security and identification, or according to the mandatory provisions of laws and regulations, you may not be able to modify some of the initial registration information you provided at the time of registration. If you cannot access and correct your personal information through the above methods, please ask us for assistance through the contact information shown in Article 8 of this policy. We will continue to develop an interface that is convenient for you to operate by yourself. Please pay attention to the subsequent updated versions of the App.
2. How do you request to delete your personal information. If you find that our collection and use of your personal information violates the applicable law or the agreement with you, you can request to delete your personal information collected by us according to the illegal behavior through the contact information shown in Article 8 of this policy.
3. How do you change the scope of your authorized consent or withdraw your consent. You can change the scope of your authorization to continue to collect personal information or withdraw your authorization by asking us to delete personal information, prohibiting Apps from calling your mobile device permissions, setting in Apps, etc. You can also withdraw all our authorization to continue to collect your personal information by logging off the App account. When you withdraw your consent or authorization, we may be unable to continue to provide corresponding services due to the lack of necessary information. Your withdrawal of consent or authorization will not affect the legality and effectiveness of our previous personal information processing based on your consent.
4. How do you log off your App account. You can request to cancel your App account through the contact information shown in Article 8 of this policy, or in "App settings - account and security - cancel account". After you log off the App account, some functions of your home robot that do not involve App control can still be used.
5. Before responding to your above requirements, in order to ensure security, we may need to verify your identity and credential data first, and after verification, it will be processed within fifteen (15) working days; In case of special circumstances, we will respond or provide reasonable explanations for our failure to respond in a timely manner within no more than thirty (30) days or within the period specified by laws and regulations. In addition, we will notify any third party who receives your information according to Article 3 of this policy to respond to your above request at the same time.
6. Despite the above agreement, according to the requirements of laws and regulations, we may not be able to respond to your request under the following circumstances:
1) The reason for not responding is related to our performance of legal obligations;
2) The reasons for not responding are directly related to national security and national defense security;
3) The reasons for not responding are directly related to public safety, public health and major public interests;
4) The reasons for not responding are directly related to criminal investigation, prosecution, trial and execution of judgments;
5) We have sufficient evidence to show that there is subjective malice or abuse of power in your request;
6) The reason for not responding is that it is difficult to obtain your authorization and consent for the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property;
7) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
8) Your request involves trade secrets.
6、 Special agreement on personal information of minors
We attach great importance to the protection of minors' personal information. We will not take the initiative to collect personal information directly from minors. For the collection of minors' personal information with the consent of the guardian, we will only use, share, transfer or disclose it with the permission of the law, the consent of the guardian or when necessary to protect minors. We expect parents or guardians to guide minors to use our services. If you are under the age of 14, or under age according to the laws and regulations of your location, it is recommended that you ask your parents or guardians to read this policy and use our services with the consent of your parents or guardians, but please avoid providing us with any personal information that can identify you. If your guardian does not agree that you use our services in accordance with this policy, or you actually provide us with information that can identify you personally, please stop using our services immediately and notify us in time, so that we can take corresponding measures in accordance with the provisions of applicable laws.
7、 Revision and publicity position of this policy
We may revise this policy in due course. When the terms of this policy are changed, we will show you the changed privacy policy in the form of push notification when you log in and version update. For major changes (changes in business functions, exit conditions, purpose of use, contact information, etc.) or changes that may aggravate your responsibilities, we will also provide more obvious notices (we will explain the specific changes of this policy by including but not limited to email, SMS or special prompts on the browsing page). Please note that we will collect, use and store your personal information according to the updated privacy policy only after you click confirm to agree to the change of this policy.
You can view the latest version of this policy on the "my privacy security privacy policy" page in the App.
8、 How to contact us
1. If you have any questions, comments or suggestions about this policy or your personal information, please contact us through the following ways.
3irobotix registered address: 10th floor, Block A, DaZuChuangXin building, No. 9018, Beihuan Avenue, Songpingshan community, Xili street, Nanshan District, Shenzhen
Email of the Department responsible for data protection: privacy@3irobotics.com
2. Generally, we will reply within fifteen (15) working days. If you are not satisfied with our reply, especially our personal information processing behavior has damaged your legitimate rights and interests, you can also complain or report to the regulatory authorities such as CAC, OFTEL, public security and market supervision and administration.