Lock Butler Privacy Policy

Date of last update: 2023/05/01 Effective date: 2023/05/01

Guangzhou Kuodao Internet of Things Technology Co., Ltd. (hereinafter referred to as "we") is committed to protecting your personal privacy.

Lock Butler is a product developed by Guangzhou Kuodao Internet of Things Technology Co., Ltd.

This "Privacy Policy" (hereinafter referred to as "this Policy") applies to the products and/or services we provide. When you use our services, we will collect and process your relevant information, so please read this policy carefully and make sure you understand our rules for collecting and processing your personal information (including how to collect, use, store, share this Information), and provide you with ways to access, update, delete and protect this information.

When you agree to this Privacy Policy, or start and continue to use our products or services in an appropriate way, and do not contact us to express contrary opinions in an appropriate way, we will consider that you fully understand and agree to this policy. During the reading process, if you have any questions, comments, suggestions or complaints, especially if you think that our personal information processing behavior has damaged your legitimate rights and interests, you can complain/suggest our services through appropriate regulatory channels, or contact us through the following Ways to contact us:

Privacy matters: cpj@kdware.cn

This policy mainly explains to you:

  1. What personal information do we collect
  2. Definition of purpose and legal basis for processing personal information
  3. Who we share your personal information with
  4. Transfer of collected information
  5. Rights related to personal information
  6. Information security measures
  7. Information retention period
  8. Protection of children's personal information
  9. Statement Regarding Policy Changes
  10. Contact us

define

In this policy,

1. Personal information:

Information recorded electronically or in other ways that can be used alone or in combination with other information to identify personally identifiable information or reflect specific personal activities.

2. Personal sensitive information:

Including personal biometric information, communication records and content, health information, transaction information, precise location information, etc. When we provide you with specific products or services that involve the collection of sensitive personal information, we will obtain your consent through a prominent and clear notice before collecting sensitive personal information about you.

3. Smart device:

Refers to a non-standard computing device produced or manufactured by a hardware manufacturer that has a human-machine interface and can transmit information over a wireless network.

4. Application:

Refers to the mobile application (client) developed by us that can help end users remotely control smart devices.

1. What personal information do we collect

In order to provide our services to you, we will ask you to provide personal information necessary for such services. If you do not provide personal information, we cannot provide you with corresponding products or services.

1. Information you voluntarily provide to us

Registration account information: When you register for an account with us, we collect your account name and contact details, including your email address, phone number, username and login credentials. During your interaction with our products, we will further collect your nickname, country and country code, language preference or time zone information in your account.

When you choose to authorize the use of a third-party account to log in, we will obtain your shared account information (default system avatar, nickname, region information) from the third party for quick login, and we will follow the agreement with the third party and the third party's announcement The terms of sharing personal information in the Privacy Policy, use your personal information under the premise of complying with relevant laws and regulations.

2. User feedback:

When you use our services and submit service-related feedback and suggestions to us, we will collect your email address, mobile phone number, feedback content (added pictures or videos), and submitted problem logs. Both will be used for us to deal with your application problems and smart device related failures in a timely manner.

At the same time, according to different application products and services, we will collect corresponding and necessary personal information in order to provide you with products and services.

Information collected based on additional features provided

In order to provide you with more convenient and better products and/or services, and strive to improve your experience, we will collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of the basic services of this application, but you cannot obtain the user experience brought to you by these additional services. These additional services include:

1. Additional services based on location information;

When you enable the positioning function of your mobile device through the system authorization and use location-based services, we will collect and use your location information so that you can use the application to configure the network with the smart device. You can turn off the location service in the system of your mobile device to stop our collection of your location information.

2. Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library);

You can use this function to upload your photos/pictures/videos after enabling the photo album permission, so as to realize the function of reporting device usage problems and providing proof. When you report a device use problem, we will use the photos/pictures you upload to locate your problem.

3. Additional services based on storage permissions (Android system);

We apply to you for this permission in order to ensure the stable operation of the client. After you enable us to read/write your device storage, we will read or write the necessary information of pictures, files, and crash log information from your device storage space to provide you with information release Or the ability to log crash log information locally.

4. Additional functions based on message notification permissions;

We apply for this permission to you in order to push notifications about products or services to you, especially if you have purchased related services and need to send you an alert so that you can capture real-time conditions.

5. Additional functions based on "floating window" (Android system);

We apply for this permission from you. When you bind the camera in the application, it can be used to display the real-time video of the camera in the floating window.

6. Additional services based on Bluetooth technology;

You can use the Bluetooth function after enabling the Bluetooth permission, including device control, device status acquisition, device discovery, and device network configuration. In these functions, we will communicate with the terminal device through Bluetooth. Please know that even if you have agreed to turn on the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display device status on the home page and device panel; perform device control on the home page and device panel; It is used to discover devices and configure the network.

7. Additional services based on Face ID (iOS system only);

After turning on Face ID, you can use the relevant functions to log in safely and conveniently through the face recognition verification provided by the iOS system, eliminating the need to repeatedly enter the account password. The iOS system will not provide us with face ID data, and we will not and cannot collect and store your face ID data. You can also turn this feature on/off at any time.

You understand and agree that the above additional services require you to enable access to your location information (geographic location), photo album (picture library), internal and external storage, "floating window", Bluetooth, and Face ID in your device to achieve these Collection and use of information involved in permissions. You can check the status of the above permissions item by item in your device settings, and you can decide whether to turn these permissions on or off at your own discretion.

Please note that if you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you close any permission, it means that you cancel the authorization, and we will no longer continue to collect based on the corresponding permission And use relevant personal information, and cannot provide you with the services corresponding to this permission. However, your decision to close the permission will not affect the previous collection and use of information based on your authorization.

2. Information We Collect Automatically

1. Mobile device information;

When you interact with our products, in order to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience and protect your account security, we will automatically collect mobile device information, including mobile devices Model number, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files and mobile network information. At the same time, we collect your software version number.

2. Usage information;

During your interactions with our Site and Services, we automatically collect usage information related to visits, clicks, downloads, sent/received messages and other use of our Site and Services.

3. Log information;

When you use our application, in order to improve your user experience, system and abnormal logs will be uploaded for analysis, including your IP address, language used, operating system version, date or time of access, so that We accurately identify problems and help you solve problems during service use.

Please note that individual mobile device information and service log information cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, during the combined use, such non-personal information will be regarded as personal information, unless authorized by you Unless otherwise stipulated by laws and regulations, we will anonymize and de-identify such information.

3. Information about smart devices

When you use a smart device, we collect the inherent information of the smart device itself and the information generated during your use of the smart device.

1. Basic information of smart devices:

When you use a smart device connected to our products or services, we will collect basic information about the smart device, including the name of the smart device, device ID, online status, activation time, firmware version and upgrade information.

2. Information collected during the process of connecting smart devices:

Based on the type of smart device you need to connect, the basic information collected includes: (1) Smart devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device Mac address; (2) After establishing a local connection via Bluetooth, the smart device connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device Mac address; (3) Smart devices connected via Bluetooth: Mac address of the device; (4) Smart devices connected via Zig-bee: device Mac address; (5) Information reported by smart devices: According to the different smart devices you choose to connect with our products or services, we will collect the information reported by your smart devices;

We process your information for the following purposes:

1. To provide you with services:

We process your account information, mobile device information, usage information, location information and smart device related information to provide the products and services you request.

2. To improve our services:

We process your mobile device information, usage information, location information and smart device related information to ensure the functionality and security of our products, to develop and improve our products and services, to analyze the efficiency of our operations, and to prevent and track fraud or Misuse.

3. Non-Marketing Communications:

We process your personal information in order to send you important information about the Services, changes to terms/conditions and policies and/or other administrative information.

4. Compliance:

We only process your personal information when we are required by law to disclose it, or when we consider it necessary or appropriate to: (1) To comply with applicable laws and regulations, legal process or requests from public institutions and government authorities; (2) To enforce our Terms of Use and other agreements, policies or standards, including investigating any potential usage violations; (3) to protect the rights, privacy, safety or property of us and/or other users, including you; and to seek available detection, prevention, remedial measures or to limit damages we may be required to provide or to address security, fraud or technical question; We also use and collect your personal information in other ways for which we will provide specific notices and obtain your consent as required by applicable law. If there are any changes to the purposes for which your personal information is processed, we will notify you of such changes by email and/or a prominent notice on our website and inform you of your choices regarding your personal information.

3. Who do we share your personal information with?

We only share your personal information with means known to you. We share your personal information with the following parties:

  1. Disclosing your personal information to third-party service providers who provide us with certain business-related services, including website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support services, email sending services and other similar services to ensure that they can provide services to us.
  2. Disclosing your personal information to customers and other business partners who directly or indirectly provide you with smart devices and/or the networks and systems you use to access and use our website and services.
  3. In the event of a reorganization, merger, sale, joint venture, assignment, assignment, or other disposition of all or a portion of our business, assets, or stock (including, but not limited to, the foregoing in connection with any bankruptcy or similar proceeding), to the subsidiary Company or other third parties disclose your personal information. In such event, you will receive clear notice of the change of ownership, new incompatible uses of the personal information, and choices regarding the personal information via email and/or our website.
  4. For the following necessary or appropriate situations, we will share your personal information reasonably and legally: (1) To comply with applicable laws and regulations, legal process, policies and/or standards, or the requirements of appropriate public agencies and government authorities; (2) enforce our Terms of Use and other agreements, policies and standards, including investigating any potential violations; (3) to protect our operations, business and systems; (4) to protect the rights, privacy, safety or property of us and/or other users including you; (5) Risk management, detection and identification of illegal, fraudulent, deceptive or malicious activities.
  5. Disclosing your personal information to the company's subsidiaries or affiliates for regular business activities. In addition to the above-mentioned third parties, we will only disclose your personal information to other third parties with your consent.

When you use services provided by a third party, we will share corresponding information after ensuring that the third party has obtained your authorization and consent, and in other situations that comply with laws and regulations. You can learn how third parties will process your personal information through the relevant information listed in this list.

In addition, in order to ensure the stable operation of the application or realize related independent functions, we will embed the third-party SDK in the application. Please note that the third-party SDK may change its personal information processing type due to version upgrades, policy adjustments, etc., please refer to its official announcement. Currently used third-party SDKs include:

1. WeChat SDK:

Types of personal information involved: device identifiers (e.g. IMEI, Android ID, Serial), MAC addresses, WLAN access points

Package name: com.tencent.mm.opensdk

Purpose of use: support WeChat login and sharing

Usage scenario: used when users use WeChat to log in or share

Third party subject: Shenzhen Tencent Computer System Co., Ltd.

Collection method: SDK collection

Official website link: https://open.weixin.qq.com

Privacy Policy: https://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy

2. Code Push SDK:

Types of personal information involved: device identifiers (e.g. IMEI, Android ID, Serial), MAC addresses, WLAN access points

Package name: com.microsoft

Purpose of use: Mobile APP update

Usage scenario: for the update of mobile APP

Third party entity: Microsoft

Collection method: SDK collection

Official website link: https://github.com/microsoft/react-native-code-push

Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement

4. Self-start and associated start instructions

  1. In order to ensure that the app can normally receive the broadcast information pushed by the client when it is closed or running in the background, the app must use the (self-starting) capability, and there will be a certain frequency of sending broadcasts through the system to wake up the app from starting or associated starting Behavior is necessary to realize functions and services.
  2. When you open the app content push message, after obtaining your explicit consent, it will jump to the app to open the relevant content. No association will be initiated without your consent.
  3. When you open the file downloaded in the App, it will start the third-party APP.

    5. Transfer of collected information

    We conduct business globally, so the personal information we collect in accordance with this policy may be transferred, stored and processed between different countries or regions. The applicable laws and regulations of the country or region where we operate may be different from the applicable laws of your country of residence, but we will strictly abide by the laws, regulations and requirements related to personal information protection. Therefore, under the framework of personal information protection, in order to facilitate our operations, we may transfer personal information to the countries or regions where we do business. No matter where your information is stored, our privacy and security practices are designed to protect your personal information globally.

Including, the European Commission has determined that certain countries outside the European Economic Area (EEA), the United Kingdom or Switzerland have mechanisms in place to adequately protect personal information. When personal information from users in the EEA, Switzerland or the UK is transferred to recipients located in countries outside the EEA, Switzerland or the UK that are not considered to have an adequate level of data protection, we ensure compliance with the EU Standard Contract Terms” for information transfer.

In particular, we will store and process the personal information collected and generated in the mainland of the People's Republic of China in the data centers in the mainland of China, except for the cross-border transmission allowed in accordance with the provisions of applicable laws.

If you want to learn more about our security measures, you can contact us directly through this policy.

We respect your rights and will also hold your personal information. You can enforce your personal rights without paying any fees. According to the relevant requirements of the local information protection law, if your account service is in mainland China, then we will complete the verification and processing of your needs within 15 working days; if your account service scope is outside mainland China, then We will respond to your needs within 30 days.

You can exercise your rights related to your personal information through the following indicated paths:

  1. To request access to the personal information we process about you (i.e. to obtain a copy of the personal information): please contact cpj@kdware.cn;
  2. Request to change the scope of authorization: please contact cpj@kdware.cn
  3. When we use your personal information based on your consent or our legitimate interests, if you choose to object or refuse us to use your personal information, please refer to the following "withdrawal of consent"

We will safeguard your right to withdraw your consent by:

  1. As mentioned above, you can revoke your consent through the mobile phone system permission settings of the application and then change the device permissions in the permission settings obtained in the device system settings, including location, camera/camera, photo album (picture library/video library), microphone , Bluetooth settings, message notification push and other related functions;

When you withdraw your consent or authorization, we will not be able to continue to provide you with the services corresponding to the part of the withdrawal of authorization. However, your withdrawal of consent or authorization will not affect the withdrawal of the previous processing of personal information based on your consent.

7. Information security measures

We employ commercially reasonable physical, managerial and technical safeguards to maintain the integrity and security of your personal information. We provide a variety of security policies to effectively ensure the information security of users and devices.

In terms of device access, we use algorithms to ensure data isolation, access authentication and authorization applications.

In terms of data communication, it supports communication using security algorithms and transmission encryption protocols, as well as commercial-grade information encryption transmission based on dynamic keys.

In terms of data processing, strict data filtering and verification and a complete data review process are adopted.

In terms of data storage, all confidential information of users will be safely encrypted for storage.

In addition to the above-mentioned security guarantees at the technical level, we have also formulated a series of security guarantees at the system and control level, including setting positions and assigning responsibilities, holding security and privacy protection training courses, strengthening employees' awareness of data protection, and controlling access permissions. To prevent data loss, illegal use, unauthorized access or disclosure, tampering or damage.

If for any reason you believe that your interaction with us is no longer safe, please email us at cpj@kdware.cn.

If a security incident occurs that affects the security of your personal information, we will notify you as soon as possible through your reserved email address, phone number, message center push, etc., and inform you of suggestions to reduce or prevent related risks and other information . When necessary, we will take corresponding remedial measures in a timely manner in accordance with the internal security incident emergency plan, and report to the relevant competent authorities in accordance with regulations.

8. Information retention period

We will process your personal information within the shortest period required to achieve the purpose stated in this policy or as required by laws and regulations, unless a longer period of retention is required according to specific legal requirements. We will determine an appropriate retention period based on the amount, nature and sensitivity of the personal information, and we will destroy your personal information after the retention period ends.

  1. To fulfill your request for products and services in accordance with this policy;
  2. When you explicitly request to delete your personal information, we will set this as a task and no longer retain your personal information.

When we confirm the purpose of collecting and processing personal information on the basis of (1), or after we confirm your deletion or cancellation application according to (2), or after we terminate the operation of the corresponding product or service, we will stop retaining it, And delete your personal information. Generally, once the specified information retention period is reached, we will no longer retain your personal information. If we are unable to destroy the information for technical reasons and the retention of personal information exceeds the storage period, we will take appropriate measures to prevent further use of your personal information, including anonymization.

9. Children's Personal Information Protection

We attach great importance to the protection of children's personal information. If you are under the age of 14 (or the specified age in your country/region), you must obtain the written consent of your parents or legal guardians before you use our services. We protect children's personal information in accordance with the relevant laws and regulations of each region, country or region. Please note that if we become aware that a child's personal information has been collected without the prior consent of a verifiable parent or legal guardian, we will attempt to delete the relevant personal information as soon as possible.

10. Statement on Policy Changes

We will update this Policy at least annually to reflect changes in our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by posting a notice within the App before the changes become effective. We recommend that you periodically review the App for the latest information on privacy practices.

11, contact us

If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us by the methods provided below, specifying "Privacy Policy". For your rights requests and inquiries about personal information, we have a professional privacy and security team to solve your problems. If your question itself involves a major matter, we may ask you to provide more information to confirm the nature and scope of the matter. If you are not satisfied with the response you have received, you can refer your complaint to the appropriate supervisory authority. When you consult us, we will provide information on possible complaint channels based on your actual situation.

Contact information

E-mail: cpj@kdware.cn

Contact number: 020-31075825

company address

Room 219, Hongye Complex Building, Shiqi Town, Panyu District, Guangzhou, China