Last Update: December 10, 2023
DONGGUAN LULUSHUN ELECTRONIC SCIENCE & TECHNOLOGY CO., LTD. and its affiliates and subsidiaries ("we", "our", "Arpha","LULUSHUN") are committed to protecting your privacy. This Privacy Statement ("Statement") outlines how we handle personal data and safeguard privacy when you use the following services, products, and related mobile applications (collectively referred to as "Products"):
In this Privacy Statement, "personal data" refers to information that alone or together with other information can identify an individual. "Smart devices" refer to non-standard computing devices with human-machine interfaces that are produced or manufactured by hardware manufacturers and can transmit data through wireless networks, including smart home appliances, smart wearable devices, smart air purifiers, etc. "App" refers to mobile applications developed by DONGGUAN LULUSHUN ELECTRONIC SCIENCE & TECHNOLOGY CO., LTD. that help end users remotely control smart devices and connect to Arpha's IoT platform.
For other brand Apps supported by our customer support services, what personal data is collected through our Products will be determined by our customers. We collect information based on our customers' requirements, and the processing of such information is limited to providing the services agreed upon between our customers and us. If you are a user of one of our customers and do not want to be contacted by us using the services of our customer, please contact the customer directly to inform them of your concerns.
What Personal Data We Collect
In order to provide our services to you, we will require personal information that is necessary for such services. If you do not provide personal information, we may not be able to provide our products or services to you.
- Information You Voluntarily Provide to Us
- Account or user profile data: When you register an account with us, we may collect some information such as your email address, phone number, username. During your interactions with our Products, we may further collect your nickname, avatar, country code, language preference, or time zone information in your account.
- Feedback:When you use our feedback and suggestion features within our Products, we will collect your email address, phone number, and feedback content to properly address any issues or device malfunctions in a timely manner.
- Information We Automatically Collect
- Device information: When you interact with our Products, we will automatically collect device information such as the device's MAC address, IP address, wireless connection information, operating system type and version, application version number, push notification identifiers, log files, and mobile network information.
- Usage data: During your interactions with our websites and services, we will automatically collect usage data related to accessing, clicking, downloading, sending/receiving messages and other use of our websites and services.
- Log information: Application logs and exception stacks may be uploaded when you use our app.
- Location information: We only collect information about your precise or approximate real-time geographic location through certain Products or services (e.g. robot vacuums and weather services) if you use them.
- Smart Device Related Information：
Basic smart device information: When you use smart devices connected to our services, we may collect some basic information about the smart devices, including device name, device ID, online status, activation time, firmware version, and upgrade information.
Basic smart device information: When you use our Products, we may collect information reported by your devices. For example, a smart scale may report your height, weight, body fat percentage (BFM), body mass index (BMI), and skeletal muscle mass (SMM), a smart camera may capture and collect images or videos.
Purposes and Legal Bases for Processing Personal Data
We process your information for the following purposes:
- We process your information for the following purposes:We process your account and user profile data, device information, usage data, location information, and smart device related information for the purpose of providing the products and services you request or purchase. The legal basis for this processing is our performance of a contract with you.
- To improve our services:We process your device information, usage data, location information, and smart device related information to ensure the functionality and security of our products, develop and enhance our products and services, analyze our operational efficiency, and prevent fraud or misuse. The legal basis for this processing is our performance of a contract with you.
- Non-marketing communications:We process your personal data for the purpose of sending you important communications regarding service terms, conditions, and policy changes; and/or other administrative information. As such information is important, you may not opt out of receiving these emails. The legal basis for this processing is our performance of a contract with you.
- Marketing communications:We process your personal data for the purpose of providing you with marketing and promotional information related to our products and services. In the above cases, each email sent contains instructions on how you can opt out of receiving further emails of this nature. Additionally, if you consent to participate in our contests, sweepstakes, or other promotional activities, we may use your personal data to administer such activities. The legal basis for this processing is your consent.
- Personalized services:We process your account and user profile data, usage data, and device information for the purpose of personalizing product design and providing customized services tailored for you (e.g. recommending and displaying products and advertisements suitable for you) as well as inviting you to participate in surveys regarding your product usage. The legal basis for this processing is your consent.
- Compliance: We will process your personal data when we deem it necessary or appropriate for: (a) compliance with applicable laws and regulations; (b) compliance with legal process; (c) responding to requests from public and governmental authorities, including those outside your country/region of residence; (d) enforcement of our terms and conditions; (e) protection of our operations, business and systems; (f) protection of the rights, privacy, safety or property of ourselves and/or other users; and (g) seeking available remedies or limiting any damages we may sustain.
Who We Share Your Information and Personal Data With
At Arpha, we only share your personal data in ways you would reasonably expect. We may share your personal data with:
- Third party service providers that provide certain business-related services to us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support services, email delivery services and other similar services, so that they can provide services to us.
- Our customers and other business partners who directly or indirectly provide you with smart devices and/or the network and systems you use to access and use our websites and services.
- Affiliates or other third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).In such an event, you will be provided notice through email and/or by posting a notice on our mobile applications regarding any changes in ownership, new uses of your personal data that are incompatible with this policy and choices available to you regarding your personal data.
- Entities within our corporate group for routine business purposes.
Except for the third parties mentioned above, we only disclose your personal data to other third parties with your consent.Rights Related to Personal Data
We respect your rights, while also gaining value from your personal data. You may exercise any of the following rights:
- By sending an email to dglls.2024@gmail.com
We will respond within 30 days at no cost. If you plan to send us an email, please explicitly state in your request which information you would like to change, if you want your personal information deleted from our databases, or the restrictions you want placed on our use of your personal information. Please note that for security purposes, we may request further verification of your identity before processing your request further.
You can:
- Request access to personal data relating to you that we process;- Request correction of inaccurate or incomplete personal information relating to you;
- Request deletion of your personal data;
- Request temporary or permanent restriction of processing of your personal data that we hold;
- Request personal data portability, i.e. to receive personal data relating to you which you have provided to us and/or have us transmit this data to another controller;
- Object to or withdraw consent for our use of your personal data where such use is based on your consent or our legitimate interests.
Information Security Safeguards
We take commercially reasonable physical, organizational and technical measures to maintain the integrity and security of your personal information. Arpha provides multi-level security policies to effectively ensure security of user and device data. For device access, we employ proprietary algorithms for data isolation, authentication and authorization. For data communication, secure algorithms and encrypted transmission protocols are supported along with dynamic key-based commercial-grade information encryption. For data processing, strict data filtering and validation as well as complete data audit processes are implemented. For data storage, all confidential user information receives secure encryption handling for storage. If for any reason you believe your interactions with us are no longer secure (e.g. if you believe the security of your Arpha account has been compromised), please promptly notify us by emailing dglls.2024@gmail.com.
Data Retention Period
We will process your personal data for the shortest period necessary to fulfill the purposes stated in this Privacy Statement, unless longer retention is required by specific legal obligations. We will determine appropriate retention periods for personal data depending on the amount, nature and sensitivity of the personal data, at the end of which we will delete your personal data. If we are unable to execute the above for technical reasons, we will take appropriate measures to prevent further use of your personal data.
Changes to this Policy Statement
We may update this Privacy Statement from time to time to reflect changes in our data practices. If we make any material changes, we will notify you by email sent to the email address specified in your account or by making notifications available on our mobile applications before the changes take effect. We advise you to check this page periodically for updates to our privacy practices.
Governing Law and Jurisdiction
This policy is governed by the laws of the People's Republic of China and is subject to the jurisdiction of the courts of the People's Republic of China.
If you have any questions about our practices or this Privacy Statement, please contact us through:
Company Name: DONGGUAN LULUSHUN ELECTRONIC SCIENCE & TECHNOLOGY CO., LTD.
Email: dglls.2024@gmail.com