HDL Automation Co., Ltd.
1. Collection of Information (no matter it is personal information or not)
2. Use of Similar Technologies (such as Cookie and network Beacon)
3. How We Use Information
4. How We Share Information
6. General Storage Period
7. How We Safeguard Your Information
8. How to Contact Us
9. Amendments and Modifications
HDL is well aware of the importance of personal information to you and will try our best to protect the security and reliability of your personal information. We are committed to maintaining your trust in us and abiding by basic legal principles to protect your personal information. Meanwhile, we promise to take appropriate security measures to protect your personal information in accordance with the mature safety standards of the industry.
1. Collection of Information (no matter it is personal information or not)
To provide you with our services, we will require for your personal information which is necessary for the further services. If you do not provide personal information, we are not able to offer our products or services to you.
"Personal Information" means information that can be recorded electronically or in other way to identify a particular natural person individually or in combination with other information or to reflect the activities of a particular natural person.
Information you provide or upload directly: in some services, we may require you to provide us with information directly, such as membership registration, purchase, delivery and installation services.
① Membership Registration:
Information that you fill in and/or submit when you register as a HDL member and when you use the services provided by HDL, include your name, gender, date of birth, ID number, cell phone number, email address, address, profile picture, nickname, password, etc. (e.g. your province and city, zip code, longitude, latitude, etc.), as well as information and data that may be synchronized with the devices possible involved in the HDL platform.
② Purchase, Delivery and Installation Services:
We may ask for your name, contact information, shipping and billing address, and credit card information to process your order. When you use certain services, you may also need to provide us with additional information, such as the number of families, food preferences, etc. If sensitive personal information is involved, such as sound patterns, fingerprints, facial recognition features, health physiological information, location, etc., we will provide special prompts before collection, as well as feasible and alternative options (e.g., if you refuse to use facial recognition as identification, we will allow you, where feasible, to choose to use password verification, document verification, etc.).
Personal Sensitive Information Special Reminder: certain special personal information may be considered personally sensitive information, such as your identifiable information, account information, behavioral information, biometric information and network identity information, contact information. Before providing such personally sensitive information, you need to carefully consider it and ensure its accuracy.
③ Information from the Device:
We may also adopt the software used in your device or take other methods to collect the information about your use of our services, such as device information, logs, location etc.
Device information: when you download or use HDL client-end software, or visit a web page to accept relevant services, we may get the information related to your mobile devices, including but not limited to, hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings for devices used to access the services. We may read the usage of your appliances for the Internet of Things, including but not limited to, the device model, the operating status of the device, the use frequency of the device, the built-in camera and so on.
Logs: when you use HDL service or visit HDL website, we automatically receive and record the information on your browser and computer, including but not limited to your IP address, type of browser, language used, date and time accessed, software and hardware features and web page records you need; logs of your devices for the Internet of Things.
Location (for specific services / functions only): when you download or use HDL client-side software or visit HDL web pages, and when you are having some HDL services, we may read all kinds of information related to your location, such as the GPS signal of the device or information about nearby Wi-Fi access points and cell phone towers, country code, city code, mobile network code, community identification, latitude and longitude information and language settings, which may be transmitted to us while you are having some of the services.
Usage information: when you use some of HDL services, the HDL devices connected with the HDL client-end software will upload measurement data or other information, for example, health data measured by those devices such as body fat scale, skin meter, health butler, skin instrument, glucometer, urine tester, etc., storage data and photos of the ingredients.
④ Information from Third-party:
We may obtain your information from third-party users or third-party partners, such as our resellers, third-party social networking services to which you choose to connect, etc.
⑤ Other Information We Have Collected:
In addition to the above information, we may collect other information, for instance, the questionnaire response you sent to us, the information we collected from your participation in the user experience program and your interaction with us and your HDL partner. We will clarify the specific content and method of collection to you during the collection, with your consent. When we are about to apply the information for other purposes, which has been purposely collected, we will seek your consent in advance.
⑥ You may choose not to provide certain types of information (for example, location, health data measured through HDL devices), but this may affect your uses-permission to some certain services. For example, if needed, to separately cancel the connection between each networked device and the Internet, you can proceed via APP and the device itself (applicable to some devices), or you can restore factory settings. Thereby, the usage information and logs of HDL Internet of Things will not be transmitted to HDL server.
But please note that in the case above, you can only operate the appliance through the appliance itself rather than the APP. For another example, you can disable the access to read the APP location on your cell phone so as to stop transmitting your location to HDL server, or in some cases you can choose to store it locally and not upload it. However, this lead to the access limitation for some functions of the APP.
⑦ Data Storage
We will arrange the storage location of the above information reasonably according to your choice. In general, it is stored within the territory of the People's Republic of China. If you would like to choose a foreign server, and you need cross-border transmission, we will strictly abide by the laws and regulations of the location of the server to safeguard your information privacy and will obtain your authorization separately. The above information you provide will be used continuously by us, as you have authorized us to proceed during your use of the services we provide.
2. Use of Similar Technologies (such as Cookie and network Beacon)
Cookie: when you visit HDL websites or use the services provided by HDL, we may identify you through micro data files in order to help you save time from repeatedly entering registration information or to help safeguard your account. These data files may refer to Cookie, Flash Cookie, or other local storage provided by your browser or associated application (collectively referred to as "Cookie").
Cookies are micro data and files that store on computers, televisions, mobile phones, or other devices.
The entity that places Cookie on your device can identify you in different websites, services, devices, and / or browsing sessions through Cookie. Cookie has many uses. For example, Cookie can remember your login credentials so that you do not have to enter them every time you log in to the service. Cookie helps us and third parties analyze which parts of our services are the most popular, because Cookie helps us check which pages and features visitors visit and how long they spend on those pages.
With this kind of information, we can improve our services more effectively and provide you with a better experience. Cookie helps us and third parties know more about which ads you watch so that you will not receive the same ads every time you receive the service. Cookie helps us and third parties provide you with relevant content and advertising by collecting information about your use of our services, other websites and applications. If you use a Web browser to access the service, you can configure the browser by accepting all Cookie, rejecting all Cookie, or notifying you when Cookie is sent. Each browser is different, so check out the browser's help menu to learn how to change your Cookie preferences. The operating system of your device may contain other Cookie controls.
Please kindly understand that some of our services can only be implemented by using "Cookie". If it is allowed by your browser or browser add-on service, you can modify the acceptance of Cookie or reject Cookie from HDL according to your preferences. You can clear all Cookie saved on your computer. Most web browsers are configured with the function to block Cookie and to modify or delete Cookie. Please refer to the help menu on your browser.
However, the case above may affect your safe access to HDL-related websites and the use of the services provided by HDL.
① Website Beacons and Pixel Tags
In addition to Cookie, we will also use other similar technologies such as website beacons and pixel tags on the website. For example, the web page usually contains some electronic images (called "single pixel" GIF file or "web beacon"). Using the web beacon can help the website calculate the number of users who are browsing the web or visit some cookie. We will collect information about your browsing activities through the web beacon, such as the address of the page you visited, the location of the page you previously visited, the time you stayed on the page, your browsing environment and display settings, and so on. For another instance, the email we send to you may contain a click URL that links to the content of our website. If you click on the link, we will follow the clicking so as to help us understand your product and service preferences. We can ultimately improve customer service. A website beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags attached in the e-mail, we can know whether the e-mail has been opened or not. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.
② Mobile Analysis Software
In some APP, we adopt mobile analysis software, such as YouMeng data analysis SDK, HDL behavior analysis SDK, to better understand the function of our APP in your phone. This kind of software may record the following information, such as how often you use the application, events that occur within the application, cumulative usage, performance data, and where the application crashed. We do not associate the information stored in the analysis software with any personal information you submit through APP.
3. How We Use Information
We may use the personal information collected for the following purposes:
① Create your HDL account. The personal information collected while creating an HDL account through a website or mobile device is used to establish the user's HDL account and profile.
② Verify your identity. We verify the user’s identity through cloud JWS to ensure that hackers or unauthorized personnel cannot log in.
③ Process your order. Information related to e-commerce orders can be used to process purchase orders and related after-sales services, including customer support and re-shipment. In addition, the order number will be used to cross-check the delivery partner's order and the actual delivery of the package. Recipient information, including name, address, phone number and zip code, will be used for delivery. The e-mail address is used to send package tracking information to the user. The list of purchased items is used to print invoices and for customers’ confirmation of the items in the package.
④ Enable you to activate, to control and to use the device. To control some of your HDL devices, you are required to log-in by means of the APP. At the same time, you should properly complete the distribution and binding process of the devices. After completing those processes, you can control the devices remotely or within the local network through APP. Part of the HDL devices need to be activated before use. The activation process requires the use of relevant device information, including MAC address, machine code, TYPEID, WIFI password and so on. If the activation fails, we may read the relevant device information and log information to evaluate the cause of the activation failure. Meanwhile, you may need to use information such as username / password to control your networked devices.
⑤ The status of your device can be displayed. It allows you to view the status of the device remotely, as a result, you can see the operation of the device at any time.
⑥ Enable you to find your device. HDL may provide a "find device" function in some services, which can help you find and protect your device after it is lost or stolen. You can use the location information provided by APP or the website to locate your device on the map, then clear the device content or lock the device. We may collect location information directly from your mobile device; in some cases, we collect this information through cell towers or Wi-Fi hotspots.
⑦ Provide location-based services. When using some HDL services, we or third-party service providers may use location information to provide you with the correct version of the service and offer the exact location so that you can get the best user experience, for example, by reading your location to know your nearest warehouse and to estimate the delivery time. Or by reading your location information to predict your distance from home, we remind you to turn on some HDL devices before going back home, or remind you turn off some HDL devices after leaving home, and so on. You can enter the device settings at any time or stop using this application to turn off the relevant function.
⑧ Allow you to use third-party functions. Some of the functions we offer are operated by third-party service suppliers. Therefore, we need to share your information with third parties so that you can fully experience the functionality. For example, when you use our service to search for recipes, audio, video, ingredients, weather, traffic conditions, etc., we need to send your search request to the third-party service suppliers.
⑨ Automation. The information uploaded by your device (the information comes from the device you added) can be used to create your own automation tasks.
⑩ Provide push notification. The account number and IMEI number will also be used to provide HDL push notification to send device notifications to users. You can turn off this function at any moment by changing the preferences in the “Message Settings”.
⑪ Make automatic preference based on your information. In some business scenarios, we may only make decisions based on non-manual automatic decision-making mechanisms, including information systems, algorithms, and so on. If these decisions significantly affect your legitimate rights and interests, you have the right to require for an explanation, and we will provide appropriate remedies. Unless otherwise provided for by laws and regulations.
⑫ Collect user feedback. The feedback you have chosen to provide is invaluable to help HDL in service improvement. In order to track the feedback provided by you, HDL may use the personal information you submitted to contact you and keep records.
⑬ Evaluate and analyze markets, customers, products and services (including asking for your opinions on our products and services and conducting customer surveys) to enhance the user experience. We may combine personal information from one service with other to improve services and develop new products and services. We may use data from some selective joint features (such as user experience programs) to analyze how users use devices and HDL services and to optimize the user experience.
⑭ Provide you with community interactive services. You can participate in the HDL user community and communicate with others within the community, and your profile picture, nickname and other personal information will be displayed on the forum page.
⑮ Send notification. We may use your personal information from time to time to send important notifications, such as notification of abnormal operation of the device, push notification for your customized device, logistics information about your purchases and the changes in our terms, conditions and policies.
⑯ Manage promotional activities such as lucky draw. If you participate in a lottery, competition or similar promotion, we will use the information you provide to manage such activities. If you win the lottery, your cell phone number or nickname may be included and announced in the winning list. If the activity is jointly promoted by us and a third party, we may share with them the personal information which is needed for completing the activity (the number of users participating in the activity, the list of winners, and the contact information of the winners). As a result, the third party can distribute prizes or provide services to you timely.
⑰ Direct promotion. We may use your name, phone number, email address and HDL account to provide you with promotional materials related to the products and services of HDL and its partners. To provide a better user experience, we will recommend the above products, services and activities on the basis of your previous purchase, website browsing history, birthday, age, gender and geographical location. If you no longer want to receive certain types of email or marketing messages, you can follow the prompts to unsubscribe. Without your other consent, we will not transmit your personal information to our business partners for direct promotion.
4. How We Share Information
Without your consent, we will not sell your information to a third party other than HDL. However, we may share your information with the following third parties:
① The Companies Associated with HDL
Based on the unified account system of HDL platform, to help facilitate better services to you and to recommend information that you may be interested in or to protect the personal and property safety of HDL users or the public from infringement, your personal information may be shared among the companies associated with HDL. We will only share the necessary personal information (for example, in order to help you use the products or services of our affiliated company by using [HDL account], we will share your necessary account information with the companies associated with HDL). If we share your personal sensitive information or if those company changes the processing purpose of your personal information, we will seek your authorization again.
② Authorized Partner
We may share your information with trusted authorized partners. We may share your account information, device information and location with authorized partners to ensure the completion of the services provided to you. However, we will only share your personal information for legitimate, necessary, specific and clear purposes, and we will only share the personal information if they are needed for the services. Our partners do not have the right to use the shared personal information for any other purpose. Currently, our authorized partners include the following types:
Authorized partners of advertising and analytical services.
Suppliers, service providers and other partners. Our suppliers and service providers include institutions providing technical services, telecommunications services, customer services, risk control services, audit services, legal services, financial institutions, e-commerce companies and platforms, offline stores, etc.
③ Other Parties Who Separately Obtain You Consent
① In accordance with relevant laws and regulations and national standards, we may collect and use your relevant personal information under the following circumstances without your authorization.
② Directly related to national security, national defense security and other national interests; directly related to major public interests such as public security, public health, public knowledge, etc.
③ Directly related to criminal investigation, prosecution, examination and approval, and execution of judgments, etc.
④ In order to protect your or other personal life, property, reputation and other important legitimate rights and interests, but it is difficult to get your consent.
⑤ The personal information collected is disclosed to the public by yourself.
⑥ Collecting personal information from legally publicly disclosed information, such as legitimate news reports, disclosure of government information, etc.
⑦ It is necessary to sign and perform the contract according to your request.
⑧ Necessary to maintain the safe and stable operation of the product or service provided, such as discovering and dealing with the troubleshooting.
⑨ Necessary for legitimate news reporting.
⑩ When it is necessary to conduct statistical or academic research in the public interest, and when the results of academic research or description are provided to the public, and the personal information contained in the results is de-identified.
⑪ Other circumstances prescribed by laws and regulations.
6. General Storage Period
For the sake of maintaining the continuity of the service and the consistency of the user experience, personal information is usually not deleted immediately after the completion of a single service. For example, regarding the shipping address in the user's historical order, to enable the user to select the shipping address more quickly in the next purchase, HDL will save the address until the user chooses to delete it in his/her own user settings.
7. How We Safeguard Your Information
① We have strictly followed the industry-wide standard and have adopted corresponding security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, it is protected by SSL encryption when exchanging data (such as credit card information) between your browser and the "service"; we also provide https secure browsing for some websites; we use encryption technology to ensure the confidentiality of the data; we use md5 salting mechanism to hash the user's password; we use a trusted protection mechanism to prevent data from malicious attacks. We will deploy access control mechanisms to ensure that only authorized individuals can access personal information, and we will conduct training courses of security and personal information protection to enhance employees' awareness of the importance of protecting personal information. In order to ensure the security of your information, we are committed to taking a variety of reasonable physical, electronic and management security measures to protect your information from leakage, damage or loss, including but not limited to SSL, encrypted information storage, data access control. We have also taken strict management of employees or outsourcers who may have access to your information, including but not limited to, taking different access controls according to different positions, signing confidentiality agreements with them, monitoring their operations, and so on. HDL will take corresponding security measures according to the existing technology to protect your information and provide you with reasonable security. We will try our best to avoid data leak, damage or loss.
② We have acquired different certifications in a variety of products and services, such as EAL3+, ISO27001 certification.
③ The Internet environment is not 100% secure and we will try our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or administrative protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which lead to damage to your legitimate rights and interests, we will bear the corresponding legal liability.
④ After the occurrence of the personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions that you can independently prevent and reduce risks, remedial measures for you, and so on. We will timely inform you of the incident.
⑤ Your account has been configured with security protection function, please take good care of your account and password. At the same time, to ensure your information security, before permanently selling or transferring your device use rights to a third party, be sure to log out of your account and delete the matching website or APP. As a result, your device will be no longer re-matched to your account. If you are selling equipment (such as household appliances), you should reset the device and restore factory settings. In this way, your device will no longer be associated with your account. If you have purchased pre-owned equipment, please check the APP or the vendor's account settings to make sure that no unknown users are associated with your home appliances. If you have any questions, you can choose to restore the factory settings. HDL will prevent your personal information from data loss, abuse and modification, through data backup, encryption of user passwords and other security measures. Despite the aforementioned security measures, please note that there are no "perfect security measures" on the information network.
⑥ HDL is not responsible for security omissions caused by third parties' access to your personal information due to your failure to maintain the privacy of your personal information. Notwithstanding the above, you should inform us immediately of any unauthorized use of your account or any other security breach on the Internet. Your assistance will greatly support us in the protection for your personal information privacy.
⑦ If we share personal data originating from the EEA with a third party, whether the third party is within the EEA, or it is HDL’s affiliated company, partner, authorized company and individual, we will proceed the information protection in accordance with the terms and clauses in EU standard or any other safeguard measures defined in GDPR.
8. Right for User
① Access to your personal information: you have access to your personal information. If you would like to exercise data access, you can access it by yourself in the following ways:
Account information: if you would like to access or edit profile and payment information in your account, as well as change your password and add security information or close your account, you can log into your account and proceed visiting the settings page.
Other personal information: regarding other personal information generated during your use of our products or services, if available, we herein will offer you with them all, please contact us by referring to the contact information in Section 12.
② Correct your personal information: when you find that there are errors in your personal information which have been processed by us, you have the right to correct it or ask us to correct it. As for account information, you can log into your account and proceed visiting the settings page. For other personal information, please contact us by referring to the contact information in Section 12.
③ You can make a request to delete your personal information in the following cases:
if we deal with personal information in violation of laws and regulations.
if we collect and use your personal information without your consent.
if our handling of personal information are again the terms and rules of the agreement that we signed with you.
if you cancel your account.
if we no longer provide you with products and services.
After you delete the information from our service, we may not delete the corresponding information from the backup system immediately, but we will delete the information while backup updating.
④ By submitting a request to change the scope of your authorization, you may revoke our access to collect, use and / or disclose your personal information that we have hold or controlled. You can contact us for relevant operations through the contact information listed in Section 12. We will process your request within a reasonable time after receiving, and we will not collect, use and / or disclose your personal information in accordance with your request. Please note that because every single business scenario requires some basic personal information to be completed, your revocation of your consent may cause limitation or inaccessibility of HDL services. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.
⑤ You can apply for cancellation of your HDL account by submitting a request. We will not set unreasonable conditions to prevent you from canceling your account, but your account cancellation will affect the legitimate rights and interests of you or others, such as goods you have yet to receive, paid services, etc. In addition, we will judge and inform whether your cancellation request is supported with regards to your use of HDL services. Your cancellation will affect your normal use of all related applications and services. We would like to kindly remind you that the cancellation of your account will cause you a lot of inconvenience to use the HDL service in the future, and after the cancellation, we will stop providing services to you, and your personal information will remain unsearchable, inaccessible or anonymized, unless otherwise stipulated by laws and regulations. If you log in quickly through a third-party account, you need to contact the third party to handle the cancellation of the account. If you are definitely sure to log off your account and have meet all the conditions for cancellation, you can contact us through the contact information listed in Section 12. Once the HDL account is cancelled, it will not be recoverable. Please back up all the information and data related to the HDL account before operation. We will not bear any responsibility for the adverse impact on you caused by your application for cancellation of your account.
⑥ We usually provide services like access, correction, updates and deletion free of charge, but we reserve the right to charge a reasonable fee for your data access request.
9. How We Deal with the Personal Information of the Minors
Our products, websites and services are mainly for adults. Regarding the personal information of minors which are collected with the parents or guardians’ consent, we will use or publicly disclose this information only if we are permitted by law, and we are with the parents or guardians’ consent, or we are allowed to do so out of the protection of the minors.
If we have collected the personal information of minors without the prior consent of parents or guardians, we will delete the relevant data as soon as possible. If parents or guardians believe that minors have submitted personal information to HDL without their prior consent, please contact us to make sure that such personal information is deleted and that minors unsubscribe to any services applicable to HDL.
10. Storage Location of Your Personal Information.
The personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China, just to be on principle.
Since we provide products or services through resources and servers around the world, this means that with your authorized consent, your personal information may be transferred to or accessed from outside the jurisdiction of the country in which you use the product or service.
Such jurisdictions may have different data protection laws or even no relevant regulations. In this case, we will ensure that your personal information is adequately and equally protected within the territory of the People's Republic of China. For example, we will request your consent for cross-border transfer of personal information through push notifications or text messages, or we will implement security measures, such as data de-identification before cross-border data transfer.
When you use these specific products (for example only, not detailly list), following third-party terms and privacy policies can be applicable:
③ Quick login: you can use third-party accounts (such as Wechat, QQ, Taobao, JD.com, etc.) to log into our website or application. These services will verify your identity and guide you to choose whether to share some personal information (such as your name and email address) with us so as to pre-fill out the form of user registration or to bind your existing HDL account. The third party accounts you use are subject to the corresponding privacy policies of these third parties.
④ Third-party functions: you may use third-party services through the application provided by HDL, such as opening, visiting, browsing, searching or registering to login to video websites, music applications, map applications, weather query applications, etc. You may be required to comply with the third party's terms of service and privacy policies when using third-party features.
12. How to Contact Us
You can contact us through firstname.lastname@example.org, and we will reply as soon as possible.
If you are not satisfied with our reply, especially if our processing for your personal information has impaired your rights and interests, you can also solve the problem through external channels such as filing a lawsuit with a people's court that has jurisdiction or making a complaint to the industry self-discipline association or the relevant government organization.
13. Amendments and Modifications
The important amendments and modifications referred to in this agreement include, but are not limited to:
① Great changes in our service mode (such as the purpose of processing personal information, the type of personal information processed, the usage of personal information is used, etc.).
② We have undergone major changes in the ownership structure (such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.).
③ The target audience of public disclosure of personal information has changed.
④ Significant changes have been made in your exercise of rights, as well as in the way you participate in the processing of personal information.
⑤ The departments responsible for handling personal information security, the contact information and complaint channels have been changes greatly.
⑥ The personal information security assessment indicates that there is a high risk. (End)