Privacy Policy

Our Privacy Policy was published and took effect on March 22, 2023. If you no longer want to use our services, you can cancel your account by sending an e-mail to privacy@xclea.com.

Beginning with this effective date, in addition to the Privacy Policy provided separately for specific products or services, this Privacy Policy will provide privacy details about how we manage the personal information you disclose when using the xclea idea app (hereinafter referred to as "the app"). Please take some time to familiarize yourself with our privacy practices. If you have any questions, please send an e-mail to privacy@xclea.com .

Our commitment to you

This Privacy Policy stipulates how XCLEA Smart Technology Co., Ltd. and its affiliated companies ("XCLEA" or "We") collect, use, disclose, process and protect the information provided to us when you use the app. If we ask you to provide information to verify your identity when using our products and services, the information will only be used in accordance with this Privacy Policy and/or our User Agreement.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately you have control of any personal information provided to XCLEA.

In this Privacy Policy, "personal information" means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information XCLEA has access to about that individual. Such personal information may include but is not limited to the information you provide to us , mobile terminal or SIM card related information, location information, etc.

By using the app, you are deemed to have read, acknowledged, and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. To comply with applicable laws, including local data protection legislation (e.g., General Data Protection Regulation in European Union), we will specifically seek prior explicit consent to the particular processing (e.g., automated individual decision-making) of special categories of personal information. Furthermore, we are committed to protecting the privacy, confidentiality, and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. If you have any concerns with our data handling practices as summarized in this Privacy Policy, please contact us through privacy@xclea.com, so that we can handle your specific needs.We are glad to deal with your problem directly.

What information is collected and how we can use it

Types of information collected

To provide our services to you, we will ask you to provide personal information that is necessary for the provision of these services. If you do not provide your information, we will not be able to provide you with our products or services.

We will only collect information that is necessary for specified, explicit, and legitimate purposes. Information will not be further processed in a manner that is incompatible with those purposes. We may collect (even if the APP is in the background) the following types of information (which may or may not be personal information):

• Information you provide (including your contact information): We may collect personal information you provide to us, such as your mobile terminal number, your feedback, etc. Since your mobile terminal number is required for you to log in to the app, the information will always be stored in the mobile terminal running the app. If you want to delete the information, you can choose to cancel your account. For details, refer to "Delete Information" below.

• Mobile terminal or SIM card related information: We may collect information relating to the mobile terminal running the app, such as system version, language settings, time zone setting, mobile terminal manufacturer, model name, ANDROID ID, IMEI number and IMSI number. We may collect cellular network operator information used by your mobile terminal. We may also collect information about the device bound to your account, such as MAC address, DID (smart device hardware serial number), device network status (IP/network signal), firmware version, and MAC address of routers connected to the device.

• Coarse location information (only for specific services/functions): Information related to your location, such as region and country codes.

• Login information: Information required for you to log in to the app and the website, including IP address, network request information, temporary message history, standard system log, and system crash information.

• Network information: Including WiFi SSID and password for accessing the router. For the avoidance of doubt, the password is only stored on the device and will not be uploaded to the server.

• Account vouchers: Information about your account vouchers, such as account name, password, token, etc.

How personal information can be used

Personal information is collected for providing services and/or products to you and is collected in compliance with all applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies and Third-Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

• Providing, processing, maintaining, improving, and developing our goods and/or services to you, including services on your device or through our app.

• Communicating with you about your device, service, or any general queries, such as updates, device firmware/software upgrades, customer inquiry support, information about our events, notices.

• Carrying out marketing related activities, such as providing marketing and promotion related information and updates. For more information on marketing and promotional activities, please see the following section entitled "Direct Marketing".

• Improving our products and services by analyzing and developing statistics related to the use of our products and services.

• Storing and managing information about you that is related to our business operations and legal duties.

• Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information):

• Creating your XCLEA account: The mobile terminal number collected when creating accounts through the web page or your mobile terminal is used to create your account and information pages.

• Improving products and services: We use relevant information on your mobile terminal to analyze and develop statistics related to the use of our products and services to improve our products and services.

• Guaranteeing the realization of the basic app and device functionality: We collect your login information and details about your mobile terminal using account binding to ensure the realization of basic app functions.

• Providing location-based services: When using a device added in the app, we may use coarse location information to assist in judging the time zone of the device, to ensure the scheduling function of the device can be used normally.

• Connecting to the network: When the device needs to connect to the network, setting up the corresponding network through the app is required. This process requires you to enter the relevant WiFi name and password, and this data is combined with the time zone settings, coarse location information, account name, and token. This information is only used in the device distribution network. You can always delete your WiFi name and password by resetting the device.

• Displaying device status : This allows you to view the status of the device remotely so that you can check the online status of the device at all times.

• Providing push services: Account and mobile terminal number will be used to provide push services for sending device notifications and operational messages to users.

• Verifing user identity: The app uses passwords to authenticate users to prevent access by unauthorized uers.

• Maintaining login status: A token is used to help users maintain login status so that no login information needs to be re-entered after exiting the app.

• Collecting user feedback: The feedback you choose to provide is extremely valuable to help us improve the service and help you solve the problems encountered during use. In order to track the feedback you provide, your account name, input, the feedback information, the model name of the mobile terminal and the system version will be retained to the server.

• Providing firmware upgrade functionality: According to the firmware version information of all devices bound to your account through the app, you will receive notifications when a firmware upgrade is available.

• Provides camera-based functionality. Before using the camera function, the APP will ask you for permission, and you can continue to use it after you agree. You can use a photo taken with your camera as an avatar on your profile. You can also scan the QR code with the camera to obtain the devices shared by others to you.

• Provided for use by third-party SDKs. The third-party SDK will collect some sensitive information, such as the network information of your device and the language of the mobile terminal, ANDROID ID, IMEI number, IMSI number, location information, etc. For details, see "Details of personal information collected by the third-party SDK embedded in the XCLEA APP".

Details of personal information collected by the third-party SDK embedded in the XCLEA APP

In order to ensure the stable operation of XCLEA APP or realize related functions, we will access a software development kit (SDK) provided by a third party to achieve the aforementioned purposes. The third-party SDK we access mainly serves the needs of you and other users. Therefore, we may adjust the third-party SDK we access when meeting new service requirements and business function changes. We will promptly disclose to you the latest status of accessing third-party SDKs in this description.

The third-party SDKs currently connected to the XCLEA APP are listed as follows:

WeChat open SDK

Purpose of collection and use: account login

Scope of information collected: WeChat user openid, nickname and avatar

Xiaomi Push SDK

Purpose of collection and use: push messages to Xiaomi mobile phone users

The scope of information collected: device identifier

Privacy Policy: https://dev.mi.com/console/doc/detail?pId=1193

Xiaomi FDS SDK

Purpose of collection and use: file access

Scope of collected information: access to user avatars, log file storage of sweeper distribution network

Alibaba Feiyan platform own brand App-SDK-General SDK

Purpose of collection and use: to provide cloud services for the operation of sweepers

Scope of information collected:

For more information please visit https://terms.alicdn.com/legal-agreement/terms/privacy_sdk_description/20220901154750955/20220901154750955.html?spm=5176.2020520104.0.0.7fc2709aVZbuoE

Alibaba Message Push SDK

Purpose of collection and use: Provide push service for Aliyun Link SDK

The scope of information collected: network status information, Wi-Fi information, and device information.

Privacy Policy: http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud201902141711_54837.html?spm=5176.10695662.7y9jhqsfz.86.17883475PKzAAQ

tuya IoT SDK

Purpose of collection and use: Provide cloud services for the operation of the sweeper

The scope of information collected: information related to your mobile terminal, such as language, ANDROID ID, IMEI number, IMSI number. Information related to your location, such as region and country codes. Information related to your device, such as device ID, device name, MAC address, Wi-Fi information, firmware version information, network status information, cleaning data, operating status, cleaning records, consumables information, time information, area information, Information about your device settings.

VIVO Push SDK

Purpose of collection and use: to push messages to VIVO mobile phone users

Scope of collected information: read stored information

Privacy Policy: https://www.vivo.com/about-vivo/privacy-policy

Oppo Push SDK

Purpose of collection and use: to push messages to Oppo mobile phone users

The scope of collected information: device-related information (such as IMEI number, Serial Number, IMSI, User ID, Android ID, Google Advertising ID, mobile phone Region settings, device model, mobile phone power, mobile phone operating system version and language), use of push services Application information (such as APP package name and version number, running status), push SDK version number, network-related information (such as IP or domain name connection results, current network type), message sending results, notification bar status (such as notification bar permissions, user Click behavior), lock screen status (such as whether to lock the screen, whether to allow lock screen notifications)

Privacy Policy: https://open.oppomobile.com/wiki/doc#id=10288

Data Code UT SDK

Purpose of collection and use: statistical analysis

Scope of collected information: device information (IMEI, IMSI, MAC, IDFA, ANDROID ID, OAID, GAID, CLIENT IP)

Privacy Policy: https://terms.alicdn.com/legal-agreement/terms/suit_bu1_alibaba_group/suit_bu1_alibaba_group202110291512_80686.html

With whom we share your information

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that XCLEA will only share your personal information following your consent. Your consent to XCLEA will engage sub-processors for the processing of your personal information. You should know that when XCLEA shares your personal information with a Third-Party Service Provider under any circumstance described in this section, XCLEA will contractually specify that the third party is subject to practices and obligations that comply with applicable local data protection laws. XCLEA will contractually ensure compliance by any Third-Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Sharing with our group and third-party service providers

From time to time, in order to conduct business operations smoothly to provide you with the full capabilities of our products and services, we may disclose your personal information to XCLEA affiliated companies (which involve manufacturing, product sales, after-sales services, etc.), or third party service providers (our mail stores, delivery service providers, telecommunications companies, data centers, data storage facilities, technical support, customer service providers, advertising and promotion service providers, IOT service providers.). Such Third-Party Service Providers only process your personal information on XCLEA's behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this information, send an e-mail to privacy@xclea.com.

Information not requiring consent

For the avoidance of doubt, XCLEA may collect, use, or disclose your personal information without your consent to the extent it is allowed explicitly under local data protection laws.

Security safeguards

XCLEA's security measures

We are committed to ensuring that your personal information is secure. To prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect on your mobile terminal and XCLEA's websites. We will use all reasonable efforts to safeguard your personal information.

All your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations that will cause them to be disciplined or terminated if they fail to meet their obligations. We have special access controls for cloud-based data storage as well. In summary, we regularly review our information collection, storage, and processing practices, including physical security measures, to guard against any unauthorized access and use.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the internet.

We will notify the data breach to the relevant supervisory authority, or under some circumstances, notify the personal information breach to the data subjects by complying with applicable laws, including your local data protection legislation.

What you can do

You can safeguard your personal information by not disclosing your login password or account information to anybody unless you duly authorize such person.

XCLEA cannot be held responsible for lapses in security caused by third-party access to your personal information as a result of your failure to keep your personal information private. Notwithstanding the preceding, you must notify us immediately if there is any unauthorized use of your account or any other breach of security.

Your assistance will help us protect the privacy of your personal information.

Retention policy

Personal information will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by XCLEA even if the further processing is incompatible with original purposes.

Accessing other features on your mobile terminal

Our applications may need access to certain features on your device, such as WiFi network status and some other features. This information is used to allow the app to run on your mobile terminal and allow you to interact with these applications. At any time you may revoke your permissions by turning these off in the app or contacting us at privacy@xclea.com.

You have control over your personal information

XCLEA recognizes that privacy concerns differ from person to person. Therefore, we have provided some examples to describe the ways we can help you restrict collection, use, disclosure, or processing of your personal information and control your privacy settings.

Delete information

You may delete all your personal information as follows:

You can delete all your personal information locally by uninstalling the APP.

In addition, if you want to delete the personal information saved in our server, you can choose to delete personal data in the APP's About>User Rights Center. After receiving your request and confirming your identity, we will delete it within the specified time.

If you have previously agreed to us using your personal information for the purposes mentioned above, you may change your mind at any time by writing or emailing us at privacy@xclea.com.

Access, update, correct, erase or restrict processing your personal information

You have the rights to request access to and/or correction of any personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

A copy of your personal information collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

If you would like to request access to your personal information held by us or if you believe any information we are holding on you is incorrect or incomplete, email us as soon as possible at privacy@xclea.com.

If you are a European Union user under the General Data Protection Regulation (GDPR), you have the right to request us to erase your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.

If you are a European Union user under GDPR, you have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before lifting any processing restrictions.

If you are a European Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

Withdrawal of consent

You may withdraw your consent for the collection, use and/or disclosure of personal information in our possession or control at any time by clicking the "Withdraw Consent" button in the app (Mine ?C About us ?C User Agreement and Privacy Policy). We shall stop the collection of your personal information when you withdraw the consent, and after that, not use and/or disclose your personal information.

Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy our products and services.

Transfer of personal information outside of your jurisdiction

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies or Third-Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards.

XCLEA uses its own operations and global cloud service provider facilities to process and back up personal information. At present, XCLEA has owned or commissioned cloud service providers with data centers in China, Germany, and the United States. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different, and we may transfer to and store your personal information at our overseas facilities with your consent. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy. If you are a European Union user under the General Data Protection Regulation, your personal information will be stored in Germany's Server.

Miscellaneous

Minors

We consider it the responsibility of parents to monitor their children's use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.

XCLEA does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided XCLEA with personal information without their prior consent, contact privacy@xclea.com to ensure that the personal information is removed, and the minor is unsubscribed from any applicable XCLEA services.

Order of precedence

If you have agreed to our applicable User Agreement, in the event of inconsistency between such User Agreement and this Privacy Policy, this Privacy Policy shall prevail.

Updates to the Privacy Policy

We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you through your mobile terminal, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the app will be taken as acceptance of the updated Privacy Policy. We will seek renewed consent before we collect more personal information from you or if we wish to use or disclose your personal information for new purposes.

Do I have to agree to any third-party terms and conditions?

Our Privacy Policy does not apply to products and services offered by a third party. The app may include third party products, services, and links to third party websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party's Privacy Policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

About our systematic approach to managing your personal information

If you are a European Union user under GDPR, XCLEA will provide a systematic approach to protect personal information and deeply engages our people, management processes, and information systems to apply a risk management methodology. According to the GDPR, for instance, (1) XCLEA has set up a Data Protection Officer (DPO) in charge of data protection. The DPO can be reached at dpo@xclea.com; (2) operating procedures, including the data protection impact assessment (DPIA).

Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to XCLEA's collection, use or disclosure of your personal information, please contact us at the address below referencing "Privacy Policy":

XCLEA Smart Technology Co., Ltd.

4F 1719-17 Huishan Road,Life Science and Technology Park,Huishan District,Wuxi,Jiangsu,China

Email: privacy@xclea.com

Thank you for taking the time to understand our Privacy Policy!