Effective date: March 2nd , 2020
The terms “We”, “Our”, “Us” and “Ecovacs Robotics” refer exclusively to Ecovacs Robotics, Inc., a Delaware corporation, and its subsidiaries and affiliates. The terms “You” and “Your” refer exclusively to You, as a user of the Services.
1. INFORMATION WE COLLECT
While using Our Services, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You (“Personal Information”). Personal Information may include, but is not limited to:
- Your Account Information: You provide Your email, or log in for a third-party account, to create an online account or subscribe to Our communications. When creating Your account, You may be asked to enter certain information, such as: Your name, avatar, age, gender, address, telephone number, email address, username and password, nickname and portrait (possibly obtained through third-party software), etc. If You refuse to provide such information, You may not be able to create an account on Our Website, and You may not be able to use the Services completely or properly.
- Customer Support: When You contact us, You can provide Us with information about Your use of the Services, including information about Our Products that You own and Your contact details, so that We can provide customer support.
We may use Your Personal Information to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send.
Internet Usage Information
We may collect information that Your browser sends whenever You use Our Services or when You access the Services by or through a mobile Device (“Internet Usage Information”).
This Internet Usage Information may include information such as Your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Services that You visit, the time and date of Your visit, the time spent on those pages, unique Device identifiers and other diagnostic data.
When You access the Services by or through a mobile Device, this Internet Usage Information may include information such as the type of mobile Device You use, Your mobile Device unique ID, the IP address of Your mobile Device, Your mobile operating system, the type of mobile Internet browser You use, unique Device identifiers and other diagnostic data.
We may use and store information about Your location if You give Us permission to do so (“Location Information”). We use this Information to provide features of Our Services, to improve and customize Our Services. We also collect Your computer or mobile Device’s source IP address, which may disclose the location of Your computer or mobile Device at the time You access Our Website. While You can always decide not to share information about Your location with Us, You must agree to provide certain types of location information if You want to use Our Services.
You can enable or disable location Services when You use Our Services at any time, through Your computer or mobile Device settings.
We may collect and use information obtained from Facebook, Google, Amazon, and other accounts You use to login to the Services (“Third-Party Accounts”), such as: Your name, Your user name or handle, birth date, picture, and other details You may have on Your Third-Party Account profile (“Third-Party Information”). We do not have access to Your Third-Party Account passwords. The data We receive from Third-Party Accounts is dependent upon Your privacy settings with these third parties. You should always review, and if necessary, adjust Your privacy settings on Third-Party Accounts before linking or connecting them to Our Website or Services. We use Third-Party Information to operate, maintain, and provide to You the features and functionality of the Services, to process and ship orders, to provide customer Services, and to communicate directly with You, such as to send You information about Your orders, Product sales, special offers, and new site features.
Automatically Collected Information
- Device Signals: We collect information that Your smartphone, tablet, or personal computer (“Device”) sends out or receives to tailor the Services to Our users in different regions, such as: geo-location and IP addresses. You can enable and disable communicating such information to Us by adjusting Your Device security and privacy settings.
- Properties and Operations: We collect certain information from and about Your smartphone, such as: number, model, hardware and software version, signal intensity, Internet Protocol (IP) addresses, and other information.
- Analytics Information: We may collect analytics data or use third-party analytics tools to help Us measure traffic and usage trends for the Websites and to understand more about the demographics of Our users.
Third Party Name
To opt out: https://tools.google.com/dlpage/gaoptout/
To opt out: https://www.bazaarvoice.com/legal/privacy-policy/#opting-out
The Trade Desk
To opt out: https://www.adsrvr.org/
- Cookies: Cookies are small text files that are sent to or accessed from Your web browser or Your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about the Device, such as: user settings, browsing history, and activities conducted while using Our Services.
Our Services use the following cookies:
- Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, You would not be able to use Your account.
- Analytical/performance cookies, which allow Us to recognize and count the number of visitors, learn how visitors navigate the Services, and improve the Services.
- Functionality cookies, which We uses to recognize You when You return to the Services.
2. USE OF INFORMATION
We may use Your Personal Information for legitimate business purposes, including:
To provide the functionality of Our Services and related support.
· To create, and administer accounts, fulfil and record transactions, and provide You with related assistance (e.g., technical help, answer inquiries relating to Personal Information, etc.).
· To send administrative information to You, for example, information regarding Our Services and changes to Our terms, conditions, and policies.
We will engage in these activities to manage Our contractual relationship with You, with Your consent, and/or to comply with Our legal obligations.
To provide You with marketing and promotional materials and opportunities, and facilitate social sharing.
· To send You marketing communications and offer other materials that We believe may be of interest to You, such as to send You newsletters or other direct communications.
· To share information with other marketers (and their Services providers) to permit them to send You marketing communications, consistent with Your choices.
· To allow You to participate in sweepstakes, contests or similar promotions.
· To facilitate social sharing functionality if You choose to do so.
We will engage in this activity with Your consent, to manage Our contractual relationship with You, or where We have a legitimate interest.
For reporting and trending.
· To better understand You and Our other users, so that We can tune and personalize Our offering.
· For trending and statistics, and to improve Our Products and Services.
We will engage in this activity because We have a legitimate interest.
To accomplish Our business purposes.
· For audits, to verify that Our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
· For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
· For responding to legal duties, such as requests from public and government authorities.
We will engage in these activities to comply with a legal obligation or because We have a legitimate interest.
To the extent that We process Your Personal Information based on Your consent, You may withdraw Your consent at any time.
3. DATA RETENTION
We will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Services, or We are legally obligated to retain this data for longer time periods.
4. DATA TRANSFER
[If You are outside the United States, no matter where You live or where You happen to use Our Services, Your information, including Personal Information, may be shared with Our current and future parents, affiliates, subsidiaries and other companies under common control and ownership. We may collect Your Personal Date from, transfer it to, and store and process it in other countries outside of where You live.]
5. DATA DISCLOSURE
Disclosure for Law Enforcement
Under certain circumstances, Ecovacs Robotics may be required to disclose Your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose Your Personal Information in the good faith belief that such action is necessary:
- To comply with a legal obligation
- To protect and defend the rights or property of Ecovacs Robotics
- To prevent or investigate possible wrongdoing in connection with the Services
- To protect the personal safety of users of the Services or the public
- To protect against legal liability
6. DATA SECURITY
The security of Your data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security. In the event that any information under Our control is compromised as a result of a breach of security, We will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
7. YOUR PRIVACY RIGHTS
We aim to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your Personal Information.
Whenever made possible, You can update Your Personal Information directly within Your account settings section. If You are unable to change Your Personal Information, please contact Us to make the required changes.
If You wish to be informed what Personal Information We hold about You and if You want it to be removed from Our systems, please contact us.
In certain circumstances, You have the right:
- To access and receive a copy of the Personal Information We hold about You
- To rectify any Personal Information held about You that is inaccurate
- To request the deletion of Personal Information held about You
Although You cannot opt-out of all data collection when You use Our Services, You can limit the collection, use and sharing of Your personally identifiable information.
You have the right to data portability. You can request to obtain a copy of Your Personal Information in a commonly used electronic format so that You can manage and move it. Be advised that We may not be able to delete Your Personal Information without also deleting Your user account. You will not be permitted to examine the Personal Information of any other person or entity and may be required to provide Us with Personal Information to verify Your identity prior to accessing any records containing information about You. We may not accommodate a request to change or delete Personal Information if We believe doing so would violate any law or legal requirement or result in incorrect information.
If You do not want Us to collect Your Personal Information, please do not provide it to us. Please understand that if You choose not to provide certain Personal Information to us, Your choice will restrict Your ability to access some content and use some of the functionality of Our Services.
For Your protection, We may only implement requests with respect to the Personal Information associated with the particular email address that You use to send Us Your request, and We may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.
8. SERVICES PROVIDERS
We may employ third party providers to provide the Services on Our behalf, to perform or support Services, or to assist Us in analyzing how Our Services is used.
These third parties have access to Your Personal Information only to perform these tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
Third Party Name
Tracking and Online Advertising
We participate in interest-based advertising and use third-party advertising companies to serve You targeted advertisements based on Your online browsing history and Your interests. We permit third-party online advertising networks, social media companies and other third-party Services, to collect information about Your use of Our Website over time so that they may play or display ads on Our Website, on other websites, apps or Services that You may use, and on other Devices You may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with Our third-party advertising partners to help identify You across Devices. We and Our third-party partners use this information to make the advertisements You see online more relevant to Your interests, as well as to provide advertising-related Services such as reporting, attribution, analytics and market research.
We may provide paid Products and/or Services within Our Services. When You make payments or conduct transactions through Our Websites, We will receive Your transaction information. The information that We collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The payment method information that We collect will depend upon the payment method that You choose to use from the list of available payment methods that are offered to You by Us.
Links to Other Websites
Please note that We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other application developer, application provider, social media platform provider, operating system provider, wireless Services provider or Device manufacturer, including any Personal Information You disclose to other organizations through or in connection with Our Services.
The Services is intended for audiences above 13 years old. The Services is not directed to children 13 and under. We do not knowingly collect Personal Information from children under 13. If You become aware that a child has provided Us with Personal Information without parental consent, please contact Us. If We become aware that a child under 13 has provided Us with Personal Information without parental consent, We will take steps to remove such information and terminate the child's account.
10. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
If You are a California resident, You can learn more about Your consumer privacy rights by reviewing the California Privacy Notice [insert a weblink here].
Last Modified: March 2nd , 2020.
12. CONTACT US
487 Bryant Street, 1st Floor
San Francisco, CA 94107
Tel: (916) 445-1254
California Privacy Notice
When We say “Personal Information” in this Notice, We mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with You. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to You.
1. Information We Collect
The best way to learn about the kinds of information We collect and how We use it is to review Our Data Policy. Here is a summary of the CCPA-related categories of Personal Information We may have collected about You over the past 12 months, depending on how You use Our Products, as well as how We use it and with whom We may have shared it.
A real name, Internet Protocol address, email address, or other similar identifiers
B. Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Personal Information does not include:
· Publicly available information from government records.
· De-identified or aggregated consumer information.
· Information excluded from the CCPA’s scope, like:
1) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
2) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
2. Sources of Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources:
· Directly from You. For example, from Your Device(s): We collect information from and about the computers, phones, and other web-connected Devices You use that integrate with Our Products, and We combine this information across different Devices You use.
· Indirectly from You. For example, from observing Your actions on Our Website or interactions with Our advertisers.
3. Use of Personal Information
We may use, or disclose the Personal Information We collect for one or more of the following business purposes:
· To fulfill or meet the reason You provided the information. For example, if You share Your name and contact information to request a price quote or ask a question about Our Products or Services, We will use that Personal Information to respond to Your inquiry. If You provide Your Personal Information to purchase a Product or Service, We will use that information to process Your payment and facilitate delivery. We may also save Your information to facilitate new Product orders or process returns.
· To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our responses.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to You when collecting Your Personal Information or as otherwise set forth in the CCPA.
· We will not collect additional categories of Personal Information or use the Personal Information We collected for materially different, unrelated, or incompatible purposes without providing You notice.
4. Sharing Personal Information
We may disclose Your Personal Information to a third party for a business purpose [or sell Your Personal Information, subject to Your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When We disclose Personal Information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase the Personal Information We hold from reselling it unless You have received explicit notice and an opportunity to opt-out of further sales.]
5. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes Your CCPA rights and explains how to exercise those rights.
5.1 Access to Specific Information and Data Portability Rights
You have the right to request that We disclose certain information to You about Our collection and use of Your Personal Information over the past 12 months. Once We receive and confirm Your verifiable consumer request, We will disclose to You:
· The categories of Personal Information We collected about You.
· The categories of sources for the Personal Information We collected about You.
· Our business or commercial purpose for collecting or selling that Personal Information.
· The categories of third parties with whom We share that Personal Information.
· The specific pieces of Personal Information We collected about You (also called a data portability request).
· If We sold or disclosed Your Personal Information for a business purpose, two separate lists disclosing:
1) sales, identifying the Personal Information categories that each category of recipient purchased; and
2) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
5.2 Deletion Request Rights
You have the right to request that We delete any of Your Personal Information that We collected from You and retained, subject to certain exceptions. Once We receive and confirm Your verifiable consumer request, We will delete (and direct Our Service providers to delete) Your Personal Information from Our records, unless an exception applies.
We may deny Your deletion request if retaining the information is necessary for Us or Our Service provider(s) to:
· Complete the transaction for which We collected the Personal Information, provide a good or Service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform Our contract with You.
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
· Debug Products to identify and repair errors that impair existing intended functionality.
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
· Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
· Comply with a legal obligation.
· Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
6. Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by sending Us a message on Our Website. Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable consumer request related to Your Personal Information. You may also make a verifiable consumer request on behalf of Your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
· Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative.
· Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to Your request or provide You with Personal Information if We cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
7. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to [45/90] days), We will inform You of the reason and extension period in writing. We will deliver Our written response by mail or electronically, at Your option. Any disclosures We provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your Personal Information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.
8. Personal Information Sales Opt-Out and Opt-In Rights
If You are 16 years of age or older, You have the right to direct Us to not sell Your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by visiting the following Our webpage and sending Us a message.
Once You make an opt-out request, We will wait at least twelve (12) months before asking You to reauthorize Personal Information sales. However, You may change Your mind and opt back into Personal Information sales at any time by visiting Our Website and sending Us a message. We will only use Personal Information provided in an opt-out request to review and comply with the request.
We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, We will not:
· Deny You goods or Services.
· Charge You different prices or rates for goods or Services, including through granting discounts or other benefits, or imposing penalties.
· Provide You a different level or quality of goods or Services.
· Suggest that You may receive a different price or rate for goods or Services or a different level or quality of goods or Services.
However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to Your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires Your prior opt in consent, which You may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of Our Website that are California residents to request certain information regarding Our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact Us at www.ecovacs.com/us.
10. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at Our discretion and at any time. When We make changes to this privacy notice, We will post the updated notice on the Website and update the notice’s effective date. Your continued use of Our Website following t