Effective Date: March 23, 2023
This Policy sets out:
XII. Definitions of keywords in this Policy
1. We explain the type and usage of your personal information in order to help you understand the type, reason to use and collection mode of specific personal information, which is collected by certain products, services or functions of Ecovacs.
2. Sometime when using certain Ecovacs functions, we will collect some sensitive information upon the receipt of your express authorization, unless such collection is mandatory pursuant to applicable laws (Hereinafter referred to as “Laws”). If you refuse to provide such information, you may be blocked from these functions but generally this should not affect your access to the core functions of products and services offered by Ecovacs.
3. Ecovacs generally will not share or transfer your personal information to any third parties unless otherwise expressly stated in this Policy or required or permitted by the Laws. If sharing or transferring information is necessary, we will explain reasons and obtain your express consent, including through this Policy.
4. You may access, correct or delete your personal information, or withdraw previous consent, cancel your account, file complaints or reports or apply privacy setting to control your personal information.
Contact of the Data Protection Officer: email@example.com
Understanding this Policy is necessary to browse our website or use the products and services of Ecovacs. We recommend that you carefully read and understand the full content of this Policy so that you may make relevant choices as you deem appropriate. We have tried to use plain and concise languages and to mark clauses that could materially affect your rights and interests in bold, to bring them to your attention.
If you have any questions, complaints or comments related to this Policy, please contact firstname.lastname@example.org, we will respond to your needs in a timely manner. We are really glad to directly deal with your requests and fulfill your needs.
By browsing our website or using the products and service of Ecovacs, you are acknowledging that you have carefully read, understand and agree with this Policy. If you do not agree with this Policy, please refrain from using our website. We undertake to comply with applicable laws data protection laws of the place in which you reside) to protect your personal privacy and data security. We also ensure that all of our staff will perform the abovementioned obligations. The purpose of collecting, storing, using and sharing your information is to offer you better services and improve the quality of our products (e.g. to support the development of new products and function upgrades of existing products in order to provide you high-quality and suitable services). You are not required to provide us any personal information but if you voluntarily share your information listed in this Policy as we requested, you may enjoy better and more convenient services, faster responses and avoid any adverse consequences.
(i) Information Type, Collection Mode and Purpose
To maintain the quality of our services and the safety of your information, when you visit our website and use the services provided by Ecovacs, we may record types and modes of services, the operation information during your services and any other log information in connection with your services including your IP address, system version, IMEI and MEID of your mobile device, and your location.
When using these general data and information, Ecovacs does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisements, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Ecovacs analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal information we process.
When you intentionally seek our customer service through the website, we will also collect your communication records with us, your contact information other than email (if needed) and some other information required for handling your requests. To process your request, we are using Salesforce Support, provided by Salesforce.com Singapore Pte. Ltd., 5 Temasek Boulevard #13-01, Suntec Tower 5 Singapore, 038985. The information collected will be used to provide and improve our customer services. If the problem you meet would obtain a clearer description by taking a photo/screenshot, you may also consider sending to the customer service such pictures.
You understand and agree that we can provide your personal information to the competent regulatory agencies pursuant to the laws and regulations, the guidelines, the court orders or any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies (Hereinafter referred to as “Laws, etc.”) without your authorization or consent.
1. How we apply Cookie technology to automatically collect information. To facilitate your browse activity, when you access to the website or services of Ecovacs, we may identify you through small data files, which may assist you in skipping the repeat input of your information or help determine the safety of your account. This data may include Cookies, Flash Cookies, or other local stored data provided by your web browser or related applications (Collectively referred as “Cookie”). Our system may automatically collect the following information from you through Cookie:
§ Information of your device or software, e.g. configuration information of your mobile device, web browser and any other applications connected to our services, your IP address, system version and IMEI of your mobile device;
§ Information searched or browsed in the course of our services, e.g. search words on the webpage, URL addresses entered and any other information or details browsed or provided when using our services.
2. How we apply Beacon technology to automatically collect information. To further understand your preferences on our products and services, and improve our services, our website may also insert some digital images (namely “single-pixel GIF file” or “Web Beacon”), in order to collect information related to your web search activities, including webpage addresses you access to and cited webpage you previous visited, your browsing environments and display settings.
3. Our products and services may contain third parties’ Cookies or Beacon. Our products and services may have imported Cookies and Beacon placed by advertisers or other partners. These Cookies and Beacons may collect non-personal information from you to analyze your usage of services, send advertisements you may be interested in or assess the effects of advertisements. Cookies and Beacons applied by third parties for collecting and using such information are not bound by this Policy but only subject to their own privacy policies. Therefore, we shall not be liable for Cookies or Beacons used by third parties.
We use Google Analytics and Bazaarvoice to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics and Bazaarvoice collect and use data when you use our website, please visit:
4. How to refuse to apply Cookie technology or Beacon technology. You can refuse to or manage Cookies or Beacon through your web browser settings.
To opt out of Google Analytics or Bazaarvoice, please visit: https://tools.google.com/dlpage/gaoptout/
1. Location for storing your information. Personal information collected and generated from your use of the website, products and services will be stored in the servers housed in third-party cloud facilities, which are physically located in Singapore (if your use occurs within APAC area excluding mainland China), Germany (if your use occurs within EMEA) or U.S. (if your use occurs within America). Notwithstanding the foregoing, when we use Salesforce Support, your personal information collected for customer service will be stored on servers located in Japan.
2. Management and policies concerning data security. We undertake to maintain information safety to the level as specified by the Law, etc. In order to keep your information safe, we commit to apply various safety technologies and associated management systems to protect your information from being disclosed, destroyed or lost. We have a personal information protection department. We have also developed a relevant internal control policy, where we seek to only give employees who may access to your information, the least authority and limited information access, sufficient for fulfilling their duties. We have further established access procedures and approval mechanisms to strictly control data.
3. Reporting mechanism for personal information safety accidents. Please understand that due to the limitation of technologies or potential malicious attacks, personal information safety accidents may unfortunately occur due to factors beyond our control. If a safety accident occurs, if required according to the Laws, etc., we will immediately notify you of: general facts and potential influences of the safety accident, measures we have adopted or will adopt, advice for you to protect your information and reduce risks as well as remedial measures, etc. We will inform you of the relevant facts of the accident by email, letter and telephone or by push notifications. If we cannot contact you individually, we will publish notifications in a reasonable and effective manner. We will also report the result of personal information safety accident to regulatory departments if required.
4. Delete your information. If we stop the provision of services or business operation, or your personal information become unnecessary to achieve the above purpose, we will promptly cease to continuously collect your personal information and may give notice to you individually or by publishing notifications. We will also delete or de-identify your personal information possessed by us without delay.
(i) Delegation of data processing
If it is necessary for providing you better or satisfactory products or services, we may engage third-party service providers located your jurisdiction to analyze or process your personal information. Unless otherwise expressly stated in This Policy, we shall not engage third-party service providers located outside your jurisdiction without your prior express authorization or consent. The above third-party service providers will analyze or process your information on behalf of Ecovacs. Ecovacs also ensures that we will comply with the following requirements when delegating such third parties to process your personal information:
1. Ecovacs will not analyze or process information beyond the scope authorized by you;
2. Ecovacs will make prior assessment on whether third-party service providers are qualified to maintain data security, in order to make sure they are eligible according to the Laws, etc.
3. Ecovacs will require the third-party service providers to comply with the applicable obligations by contract scheme, to follow all of the applicable Laws, regulations, industry rules and standards, business norms and practices of the jurisdiction in which you reside, and to be subject to obligations hereunder with the same or comparable standard adopted by Ecovacs to protect your information.
4. Ecovacs will accurately record and regularly audit the activities of the delegated third parties to process personal information in order to protect information safety and ensure your effective access to and control over your information.
5. Ecovacs shall ask third-party service providers to delete your personal information and destroy all data copies upon the termination of the principal-agent relationship.
6. If Ecovacs engages the third-party service providers located outside your jurisdiction, we will accurately keep the records of providing of your personal information, including but not limited to the date, scale, type, item identifying the individual, purpose of providing your information, and basic information of the third-party service providers, in order to help you to learn the storage and usage of your information by the third-party service providers.
(ii) Data sharing and transferring
In principle, we will not share or transfer your personal information to any third party companies, organizations and individuals. In the following exceptional circumstances, we will share your personal information for legal, reasonable and necessary purposes. Third parties receiving such data have no right to share and transfer personal information for any other usage that you are not advised of by this Policy.
1. Sharing information is necessary for providing products and services to you and upon your prior express authorization or consent
You understand and agree that if it is necessary to provide you better or satisfactory services, Ecovacs may share your personal information with its affiliates or any other third-party service providers upon your prior express authorization or consent. These affiliates or third-party service providers may be located outside your jurisdiction. As for the cross-border transfer of your personal information, please refer to Chapter VIII of this Policy.
Ecovacs ensures that we will comply with the following requirements when sharing your personal information with the above third parties:
1) Ecovacs will conduct prior assessment of impacts on personal information safety and adopt effective measures to protect your personal information based on the result of the assessment.
2) Ecovacs will accurately keep the records of sharing or transferring your personal information, including but not limited to the date, scale, purpose of sharing and transferring your information, and basic information of data receiving parties, in order to help you to learn about storage and usage of your information by the receiving parties.
3) Ecovacs will exert commercially reasonable efforts to cause third parties to follow all applicable laws and regulations as well as agreed confidentiality and safety measures when processing your personal information.
4) Ecovacs will keep your information safe, and ensure effective access to and control over the information, e.g. access to, correct, delete and cancel the account, etc.
2. Transfer information when Ecovacs has undergone acquisition, merger or reorganization
With the continuous development of our business, Ecovacs may engage in transactions including mergers, acquisitions and assets transfers. We will notify you of relevant facts and continuously protect or cause data receiving parties to continuously protect your personal information pursuant to the Laws, etc. or, in each as ask required by laws and regulations and with no less than the standard under this Policy.
3. Share your personal information pursuant to the Laws, etc. and mandatory requirements imposed by regulatory agencies
We may provide your personal information to the competent regulatory agencies pursuant to the Laws, etc. the court orders or any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies. Information sharing under this circumstance may not require your prior authorization or consent.
Third parties to whom Ecovacs may, or is obliged to, transfer personal information on the basis of the above, can be located in another country. Ecovacs cannot be held responsible regarding the transfer of personal information and cannot be liable for the further processing of the personal information by third parties except to the extent required by applicable laws and regulations.
We will not disclose your personal information to the public. If disclosure is needed, we will notify you of the purpose of such disclosure, the type of information disclosed and the scope of any sensitive information involved. We will disclose information with your prior explicit consent (including through this Policy).
1. How to refuse to receive promotion notifications. You may click on “unsubscribe” button in any emails sent by us to refuse to receive promotion notifications.
2. How to delete your personal information. If you find our collection and usage of your personal information are in violation of the Laws, etc,. or our mutual agreements, you may contact us at email@example.com or talk to our online customer service staff, and ask them to delete your personal information collected through such acts.
3. How to correct your personal information. If you find the personal information we collected and stored has any errors, you may contact us at firstname.lastname@example.org or talk to our online customer service staff, and ask them to correct your information.
4. To ensure data security, we will need to verify your ID, evidence and materials before responding to your requests under the above Paragraph 2 and 3. We will complete the deletion or correction within five (5) business days after the verification; in special circumstances, we will respond to you within not more than thirty (30) days or any period specified by the Laws, etc., with reasonable explanations for the failure of prompt response. Furthermore, we will also notify third parties, who receive your information according to Chapter IV, to respond to your requests under Paragraph 2 or 3.
5. Notwithstanding the foregoing, under the following circumstances, we may not respond to your request pursuant to laws and regulations:
1) Directly related to national security or national defence;
2) Directly related to public safety, public health or vital public interests;
3) Directly related to criminal investigation, prosecution, trial and execution;
4) We have sufficient evidence to prove that you conduct acts in bad faith or abuse your rights;
5) Responding your request will cause severe damages to your lawful rights and interests or those of any other individuals or organizations; or
6) Involving trade secrets.
Please note that third-party website operators you visit, third-party service access to through us and third parties receiving your personal information from Ecovacs may have separate privacy policies; we will use commercially reasonable efforts to cause these parties to adopt protection measures on your personal information. However, we may not ensure they will 100%follow our requirements to do so. Please contact them directly to learn more about their privacy policies. If you find websites or applications developed by third parties have leakage risks, we recommend you to immediately stop providing them your information to protect your lawful rights and interests.
Ecovacs can solely be held accountable for damages which directly result from the processing of your personal information due to a fault or negligence of Ecovacs. In any event, you agree that Ecovacs cannot be held liable: (i) in circumstances of force majeure and/or (ii) for any indirect or consequential damage and/or (iii) for damages that result from errors, faults or negligence by you or third parties.
We expect parents or guardians may instruct minors to use our services. If you are under 18 years old or you are a minor pursuant to the laws and regulations of the place in which you reside, we recommend you to ask your parents or guardians to read this Policy and use our services or provide your information to us with the prior consent from your parents or guardians. If your guardians do not allow you to use our services or provide your information to us according to this Policy, please stop using our services immediately and give a notice on time so that we can react accordingly. Ecovacs will keep personal information of minors confidential and safe in accordance with the relevant laws and regulations.
Since we provide products or services based on our resources and servers worldwide, your personal information might be transmitted to a jurisdiction or accessed from a jurisdiction outside of the country where you reside. Such destination jurisdictions include: (i) the jurisdiction where your personal information is stored (if it is the same as where you are located (cross-border transfer does not apply); (ii) China, where our affiliates’ registered office, our affiliates which are involved in our Websites products and services and most of our service providers, are located, and when our employees need to have access to your personal information for handling your issues and also conducting general analysis; (iii) the storage location of some other service providers which serve you on behalf of us through their API/SDK integrated into the Website, mostly at your local jurisdictions, or at the jurisdiction where their relevant branch resides to specifically serve your local jurisdiction; and (iv) some other jurisdictions from where your Website account was once logged in, provided that the data storage location for such jurisdiction differs from your domicile country. Specifically, if you send to email@example.com an email, your personal information contained in such email and its delivery will be directed to China, where our email-box server is located. All such international transfers are made in connection by and between the relevant servers housed in third-party cloud facilities and physically located in such jurisdictions, and we will require third-party cloud suppliers to adopt appropriate safeguards in compliance with the Law.
X. Scope of and amendment to this Policy
This Policy applies to all customers and users of Ecovacs website, products and services.
Whenever possible, the provisions of this Policy shall be interpreted in such a manner as to be valid and enforceable under the applicable law. However, if one or more provisions of this Policy are found to be invalid, illegal or unenforceable, in whole or in part, the remainder of that provision and of this Policy shall remain in full force and effect as if such invalid, illegal or unenforceable provision had never been contained herein.
“Affiliates of Ecovacs” in this Policy refer to any companies, legal organizations and their lawful successors that are or will be controlled by one party, or one party is under the control of, or under the common control with Ecovacs Robotics Holdings Limited related to the data collection, storage and processing.
“Data subject” is any identified or identifiable natural person, whose personal information is processed by the controller responsible for the processing.