Privacy and Personal Data Protection Notice

ANBOER product Privacy and Personal Data Protection Notice

Latest edition:  July 17 2021

Zhongshan An Bo Er Electrical Appliance Co., LTD (“ANBOER” or “us”) respects your privacy and recognizes it as our important social responsibility to handle your personal data lawfully and properly. This Privacy and Personal Data Protection Notice“ (hereafter “Privacy Notice”) aims at acquainting you with the way our ANBOER product (hereafter “ANBOER”) handles your personal data and how you may exercise your right of privacy.

This policy applies to “ANBOER” series products, but you are aware and acknowledge that there may be differences in some functions due to different versions, and the way we handle your personal information may be slightly different. Therefore, you are advised to follow the actual functions of the specific version.

Please note that this policy does not apply to scenarios in which your personal information may be processed by mobile applications that are carried by” ANBOER” products or downloaded by you. These apps are responsible for their own personal information collection and processing activities and will publish their applicable personal information collection and processing rules. Therefore, please read the privacy policy and user agreement rules of these apps carefully before downloading and using them.

Please read this policy carefully before using ANBOER products, especially those clauses (highlighted in bold) that may materially impair your rights, increase your obligations or release us from our responsibilities. If you do not agree with all or part of the contents described in this Policy, please stop using all or part of the corresponding functions of ANBOER products; If you have any questions or concerns about how we use your personal Information, please feel free to contact us through the means shown at the bottom of this policy.

This policy will inform and confirm the following on your own initiative:

l Related terms and definitions

l How do we collect and use your personal information

l How do we use cookies and other technologies

l How do we share, transfer or publicly disclose your personal information

l How do we protect your personal information

l How do we retain your personal information

l How do you manage your personal information

l How do we handle the personal information of minors under the age of 18

l How will we update this notice

l How can you contact us

Related terms and definitions

You agree that the following terms and their definitions in this Policy shall be construed as:

Personal information: all kinds of information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information, including the name, date of birth, id card number, biometric information, address, telephone number, E-mail address, health information, whereabouts information, etc.

Sensitive Personal information: personal information, including race, ethnicity, religious belief, personal bio metrics, medical and health care, financial accounts, and personal whereabouts, which, once disclosed or illegally used, may result in personal discrimination or serious harm to personal and property safety. Some sensitive personal information referred to in this policy has been highlighted in bold and underlined.

Processing of personal information: including collection, storage, usage, processing, transmission, provision and disclosure of personal information, etc.

Associated company: a company, legal entity or unincorporated organization that currently or hereafter controls ,Or is controlled by or under common control with ANBOER.

How do we collect and use your personal information

When you agree to this policy and use ampere products, we will collect your personal information through :

l Your voluntarily provide information to us;

l Information directly obtained by us during your use of ANBOER products or services;

l Obtaining your personal information from a third party; In addition, we will apply to you for the necessary equipment permissions to provide you with the necessary service functions.

Our products and services include both basic features and additional features. In accordance with laws and regulations, we collect and process personal information to the extent that is least necessary to provide services. When we collect information, you are not required to provide us with personal information. However, if you choose not to provide the personal information required by the basic functions, we may not be able to provide you with basic services, or respond to or solve the problems you encounter; For additional functions, you can voluntarily choose whether to agree with us to collect information. If you refuse to agree, the corresponding additional functions may not be realized, but it does not affect your use of our basic functions.

In order to assist you to complete equipment, you need to provide you the name of seller of ANBOER, electrical appliances, buyer of electrical products (name of company/individual), (company/individual) contact phone number, (company/individual) city/area, (company/individual) specific address, we will use this information to complete equipment activation.

2.When registering or adding an administrator account of the centralized management platform, you need to provide your email address and your name, post, nickname, and department name for organization management. The email address you provide when registering may be used by us to send important notifications, provide after-sales support and recommend product advertisements.

3.If you use our email service, you need to provide your sender email, SMTP server, port, user name and password (authorization code) to send files. Please note that ANBOER products devices do not automatically log out of logged email accounts or clear email Settings, and are generally used as a public device of their company. To protect your privacy, we recommend that you use a public email account as the sender's email and log out immediately after using the account. You shall be solely responsible for the leakage of your email account and Settings information.

4.In order to ensure the normal operation of the equipment, we will collect information about your equipment and how you and your equipment interact with The ANBOER products when you use them. The device information includes the device name, model, IP address, MAC address, operating system version, firmware version of the supporting hardware (camera, microphone, and touch frame), and device Settings. And the time and duration of your use of ANBOER products, software event information (such as open, close, restart, upgrade, error, crash, etc.) and other log records. We will collect the above information for analyzing business operation efficiency and risk control and network security maintenance scenarios, such as preventing network fraud.

5.In order to smoothly to you provide maintenance services and other after-sales service, you agree that we through distributors, service providers, suppliers and other partners to collect the master of your contact information and contact you, including your name, phone number, address, name of equipment information, unit, lot/records, if you don't want us to contact with you, You can refuse this service by contacting us at the end of this article.

6.Based on the customer pays a return visit, understand the repair order progress, customer satisfaction survey or other user research purposes, you will agree that we when necessary based on you provide to us or to our dealers and service providers, suppliers and other partners to provide contact information (name, address, unit, contact phone number or landline) take the initiative to contact you, If you do not wish to receive our phone, SMS, WECHAT or other contact information, you can refuse our active contact by informing us of the contact information at the end of this article.

7.In order to notify and push product warranty reminders, extended warranty activities, software update or upgrade information, product promotion information, new product release information or event preview information to you, we may use your phone, WECHAT, email, registered information of relevant interactive apps or platforms and contact you. If you do not want us to contact you, you can refuse to accept our extended warranty, upgrade, promotion, sales and other relevant information by informing us of the contact information at the end of this article.

8.If you order products from us, apply for returns or refunds, purchase extended warranty, or apply for paid repairs, we may also collect your delivery details, bank account number, billing address, mailing address, credit check, and other financial information, contact and communication records to facilitate us to process your order.

9.For the purpose of providing customer service to you and solving your specific problems, you agree that we collect your historical declaration records, maintenance records, consultation records, product purchase information and contact information for aggregation, integration and analysis, so as to provide you with better problem solutions.

10.To analyze the usage of our products and improve our services, when you use our products or services, We may conduct statistics and analysis on the status information of the product you use (including model, quantity, location, name, contact information, occupation, language, zip code, area code, unique device identifier, referral URL and the time zone you are in when you use the product).

To provide you with personalized service, recommend more suitable for ANBOER products, we will be on your location, unit name, model, purchase quantity, equipment, information analysis, and take the initiative to contact you through your contact information, if you do not want to receive our phone calls, text messages, WEHAT or other contact information, You can refuse personalized service by contacting us at the end of this article.

In general, we collect your personal Information only for the purposes we set out in this Policy or for the purposes we communicate when we collect your personal Information from you. However, where permitted by law, we may also use your personal information for new purposes that are not in conflict with the purposes we inform you in this Policy (for example, to conduct statistics). The collection and use of personal information authorized consent exceptions.

You are fully aware that, in accordance with relevant laws, regulations and standards, we may collect and use your personal information without prior authorization from you in the following situations:

l Relevant to our performance of obligations under laws and regulations

l Those directly related to national security or national defense security

l Those directly related to public security, public health or major public interests

l Those directly related to criminal investigation, prosecution, trial and execution of judgments

l For the protection of your or other personal life, property and other important legal rights and interests, but it is difficult to get your authorization and consent

l The personal information involved is disclosed to the public by you

l Necessary for the execution and performance of the contract entered into between you and us according to your requirements

l Collect your personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels

l Necessity to maintain the safe and stable operation of ANBOER’ products, such as finding and disposing of faults in products or services

How do we use cookies and other technologies

Our websites, online services, software, email and advertising may use "cookies" and other technologies, such as pixel tags and website beacons. These technologies help us better understand your behavior, tell us what parts of our site you visit, and measure and improve the effectiveness of advertising and web search. If Internet Protocol (IP) addresses or similar identifiers are required by law to be considered personal information, then such identifiers are also considered personal information. Similarly, where non-personal information is used in combination with personal information, we treat the combined information as personal information.

Like most Internet services, we automatically collect some information and store it in log files. This information includes Internet protocol (IP) addresses, browser types and languages, Internet service providers (ISPs), referral/exit sites and applications, operating systems, date/time stamps, and click-stream data. We use this information to understand and analyze trends, manage the site, understand user behavior on the site, improve our products and services, and gather information about the overall audience characteristics of our user base. We may use such information for our marketing and advertising services.

Clear/disable cookies

Managing cookies and Cookie preferences must be done within your browser's options/preferences. Here is a guide on how to do this in common browser software:

·MicrosoftInternetExplorer

·MicrosoftEdge

·MozillaFirefox

·GoogleChrome

·SafariformacOS

·SafariforiOS

More information about cookies

For more information about cookies and instructions on how to set up your browser to accept, delete, or disable cookies.Please log in https://allaboutcookies.org/.

How do we share, transfer or publicly disclose your personal information

How do we share your personal information

We may share some of your personal information with certain third parties (such as our affiliates and partners who cooperate with us to provide products and services) when necessary, so as to provide products or services that you choose or voluntarily request.

We will share data with third party service providers and partners (such as cloud service providers) who provide data processing services to our Company or other third parties who perform data processing for the purposes set forth in this Policy or disclosed by us when we collect personal Information from you.

We need to our associated companies, distributors, service providers, “Pei HuoShang” and other third-party partners to share your name, phone number, shipping address, so that they can provide you with product delivery and on-site installation, maintenance services, technical support and services, contact after-sale service, we will you are buying or provide the contact information of maintenance told logistics company, In order to complete distribution and after-sales service.

In some cases, we may entrust a third party to process your personal information on our behalf. For example, companies that send text messages or emails or provide technical support on our behalf may only use your personal information to provide services to you on our behalf.

How do we transfer your personal Information

Under normal circumstances, we will not transfer your personal information voluntarily. However, we may disclose to potential buyers (and their agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform such buyers that they must use your personal information only for the purposes disclosed in this policy.

In case of acquisition, merger, reorganization, bankruptcy and other changes, we will inform you of the relevant situation on our own initiative and require the acquirer or other subjects receiving your personal information to continue to perform their responsibilities and obligations under the original policy. If the purpose of using your personal information is changed, we shall obtain your express consent again.

How do we publicly disclose your personal information

Under normal circumstances, we will not publicly disclose your personal information. However, we may disclose it to relevant law enforcement agencies, regulatory agencies, governments, courts or other third parties. You acknowledge and acknowledge that such disclosure is necessary in our opinion to

l To comply with an applicable law and regulation;

l To exercise, establish or defend our legal rights,

l To protect your or any other person's very important rights.

We will only share, transfer or publicly disclose your personal Information for lawful, legitimate, necessary, specific and explicit purposes, and will only share personal information to the extent necessary for the service. At the same time, we will require, through agreement or other appropriate measures, the aforementioned third parties to take appropriate confidentiality and security measures in handling personal information.

Exceptions are made for authorization consent to share, transfer or publicly disclose personal information.

You are fully aware that, in accordance with laws, regulations and regulatory standards, we may share, transfer or publicly disclose your personal Information without prior authorization from you in the following situations:

l Relevant to our performance of obligations under laws and regulations

l Those directly related to national security and national defense security;

l Those directly related to public security, public health or major public interests

l Those directly related to criminal investigation, prosecution, trial and execution of judgments

l For the protection of your or other personal life, property and other important legal rights and interests, but it is difficult to obtain your authorization and consent;

l The personal information involved is disclosed to the public by you.

l Collect your personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels

By law, by sharing and transfer of the processing of personal information, and ensure the data receiver cannot recover and identify personal information main body, does not belong to the foreign share, transfer and disclosure of personal information, the preservation and processing of such data will be without prior notice to you and ask for your consent.

How do we retain your personal information

ANBOER has always taken user privacy seriously and has taken the following measures to protect your personal information:

We will take appropriate technical and administrative measures to protect your personal information that we collect and process.

Our access to personal information to carry on the strict access control, only allowed to help deal with personal information and we need to know the information of our employees and authorized officers to deal with the third party access to your personal information, and they will strictly perform the contract obligation to keep confidential, if its failure to meet these obligations, may be shall be investigated for legal responsibility.

When transmitting and storing your sensitive personal information, we will adopt appropriate means and security measures to protect the security of your personal information.

We will strictly select our business partners and service providers, and implement our requirements on personal information protection in our business cooperation.

The Internet environment is not 100% secure and we will do our best to ensure the security of any information you send us. In the unfortunate occurrence of personal information security incidents, we will in accordance with the requirements of laws and regulations, timely inform you of the basic situation and possible impact of security incidents, we have taken or will take measures to deal with, you can independently prevent and reduce the risk of recommendations, remedial measures for you. We will timely inform you of the information related to the event by email, letter, phone, push notification and other ways. If it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to release the announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.

How do we retain your personal information

We will store your personal information in our systems in China in accordance with the requirements of applicable Chinese laws and regulations. We will retain your personal information for the shortest period of time necessary for the purposes stated in this Policy, except as otherwise provided by laws and regulations. We will store your personal information we collect to meet our legitimate business needs (such as providing services to you or meeting corresponding legal, tax and financial requirements). In addition, we will perform operations to delete or anonymize your personal information at the end of any storage period or when the conditions for information deletion are met. When anonymity or deleting is technically impossible or too costly (for example, your personal information is already stored in a backup), we will store your personal information securely and separate it from other data processing.

How do you manage your personal information

ANBOER attaches great importance to your legitimate rights and interests in your personal information. The following describes how you can access, correct, update or delete your personal information. In addition, you may contact us through the means disclosed in this policy.

l Right to know

We are committed to ensuring transparency in the use of your information. We inform you of how we handle your personal Information by publishing this Policy and by means of specific announcements, SMS or email notices as required by laws and regulations. You can regularly check this Policy, receive emails and short messages about updates to this Policy, and contact us through the means disclosed in this Policy to learn about the collection and use of your personal information.

l Right to access

You can contact us in our products or services interface to query or access your personal information. If you are unable to query or access your personal Information, or encounter any problems in exercising your data access rights, you may contact us and request access to your personal Information by means disclosed in this policy.

l Right to recession

You have the right to request us to correct or supplement your personal information when you find it wrong or incomplete. For personal information that is not provided to you through self-modification channels, you can contact us through the means disclosed in this Policy and request correction or supplement of your personal information.

l Right to delete

You may choose to delete certain personal information that you provide to us. If you fail to provide you with your personal information that you delete by yourself, or if we collect or use your personal information in violation of our agreement with you, you may contact us and ask us to delete your personal information through the means disclosed in this policy.

l Right to withdrawal

Each business function requires some basic personal information to complete (see "How We Collect and Use Your Personal Information" section of this Policy). You can contact us to change or withdraw your license. If you withdraw your authorized consent, we will no longer be able to provide you with the services corresponding to the revoked consent or authorization. At the same time, we will no longer process the relevant personal information, but your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization

l Right to complain

You have the right to contact us and complain through the means disclosed in this Policy. We will reply you within 15 working days from the date of receipt of your complaint. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimate rights and interests, you also have the right to complain to relevant departments or file a lawsuit to Huangpu District People's Court of Guangzhou.

l The subject obtains a copy of personal information

You have the right to obtain a copy of your personal information and you can request it from us by contacting us through the contact information listed in this Privacy Policy. Where technically feasible, such as data interface matching, we may also transfer a copy of your personal information directly to the third party you specify upon your request.

We promise to respond to your request for personal information in strict accordance with laws and regulations. In the meantime, for security purposes, you may need to provide us with a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We don't charge any fees in principle. However, for repeated requests beyond reasonable limits, we will charge a certain cost depending on the circumstances. We may refuse requests that are unwarranted, require excessive technical means (for example, require the development of new systems or fundamental changes to existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical. We may specify the reasons in our response.

In addition, according to relevant laws, regulations and normative standards, we may not be able to respond to your exercise request under the following circumstances.

l If responding to your request prevents us from fulfilling our obligations under laws and regulations.

l If the requested information is directly related to national security and national defense security.

l If the requested information is directly related to public safety, public health, or vital public interest.

l If the requested information is directly relevant to the criminal investigation, prosecution, trial and execution of the sentence.

l If we have reasonable evidence of malicious intent or abuse of power.

l Responding to your exercise request will cause serious damage to the legitimate interests of you or other individuals or organizations.

l If the requested information involves trade secrets.

Third-party SDK

Our product application have access to the following third-party SDKS:

Huawei device management service SDK

Purpose Of collecting personal information:

Verify the end cloud authorization with HUAWEI Cloud to ensure that your products always meet the requirements of HarmonyOS Connect certification

Type of personal data to be collected:

Device-related hardware identifiers, hardware parameters, and system version information

Third-party SDK Privacy Statement: This statement is about HUAWEI device management services and privacy

How will we update this policy.

We will update this policy from time to time to accommodate legal, technical and commercial changes. When we update this Policy, we will notify you in appropriate ways (such as product interface message push, notification email or SMS) based on the significance of such changes and their material impact on your rights and obligations. We will obtain your consent for any major changes to this policy as required by laws and regulations.

You may obtain updates to the current version of this Policy at the beginning of this Policy. This policy update is effective as of the date of publication.

How can you contact us

We have established the Personal Information Protection Department and appointed the corresponding Personal Information Protection Commissioner. If you have any questions, comments or suggestions on this Privacy Policy, please contact us in the following ways, and we will reply to you in time in accordance with the requirements of applicable laws and regulations.

Hot line：0760-22222212

Address：No39, Rongye Street , Xiaolan Town, Zhongshan, Guangdong, China

Service：0760-22222212