Privacy Policy of Shenzhen Ulanzi Technology Co., Ltd.

Effective Date: November 16, 2023

Updated Date: August 23, 2024

Shenzhen Ulanzi Technology Co., Ltd. (Hereinafter referred to as "Ulanzi", "we", "us" or "our") is committed to protecting your personal privacy. This Privacy Policy (hereinafter referred to as 'This Policy') outlines how we handle personal data and safeguard information privacy during your use of the following services, products, and related mobile applications (collectively referred to as 'Products')."

Ulanzi Connect Application

When you interact with our products, it is essential for you to carefully read this privacy policy and understand the purposes and security measures regarding the collection and processing of your personal data. This includes how we use, store, share, and transfer personal data. In this policy, you can exercise your privacy rights, access rights, deletion rights, etc., as indicated by us.

By agreeing to this privacy policy or by appropriately commencing or continuing to use our products or services, and failing to express dissent through appropriate channels, we will consider that you fully understand and agree to this policy. If you have any questions, comments, suggestions, or complaints during the reading process, please contact us through the following contact information."

Email address: ulanziapp@ulanzi.com

For mobile applications of other brand merchants supported by Shenzhen Ulanzi Technology Co., Ltd., it will be determined by our customers which personal information is collected through our products. Therefore, this privacy policy does not apply to the principles of other brand merchants collecting or processing personal information. We collect information based on customer requirements, and the processing of such information is limited to providing services agreed upon with the customer. If you are a user of our customer and do not wish for customer contacts related to our services, please contact the customer directly and communicate your preferences."

Definition:

Personal Information: Refers to any information that can directly identify you or can reasonably be used to identify you.

Sensitive Personal Information: This includes personal biometric data, communication records and content, health-related information, transaction-related information, and precise location information. When we provide you with specific products or services that involve the collection of sensitive personal data, we will seek your consent through prominent and explicit notifications before collecting such information about you.

Smart Device: Refers to a non-standard computing device produced or manufactured by hardware manufacturers, featuring a human-machine interface and the capability to transmit information through wireless networks. This includes smart home appliances, smart wearables, smart air purifiers, etc.

Application: Refers to the mobile application provided by Shenzhen Ulanzi Technology Co., Ltd., designed to assist end users in remotely controlling smart devices and connecting to the vendor's Internet of Things (IoT) platform.

We collect personal information

Certain Personal Data are required for specific services and if you fail to supply such Personal Data as requested from each specific service, we may not be able to deliver you the services or products.

1、 The information voluntarily provided by you.

Account or Personal Profile Data: When you register for our account, we collect your account and contact information, such as your email address, phone number, username, and login credentials. During your interaction with our products, we may additionally collect information from your account, including profile name, avatar, country code, language preferences, or timezone.

Feedback: When you use the feedback and suggestion features in our products, we collect your email address, phone number, and feedback content to promptly address your issues and device malfunctions.

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

1) Location-based additional services:

When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to pair with your Smart Devices. Additionally, when you use specific products or services from us, such as weather services, we may collect real-time precise or non-precise geographical location information about you.

2) Camera/Camera-based additional services:

After granting camera/camera access, you can use this function to scan codes for adding purchased devices, capturing videos, and other features. Please be aware that even if you have given consent to enable camera access, we will only retrieve information when you actively use the camera, such as scanning codes or capturing images.

3) Additional services based on photo/video access and upload from the album (photo library/video library:

After granting access to the photo library, you can use this function to upload your photos/images/videos, enabling features such as changing your avatar and providing evidence for reporting device usage issues. When you use features like avatars, we do not identify this information. However, when you report device usage issues, we will use the photos/images you upload to pinpoint the problem you are experiencing.

4) Additional services related to microphone-based service:

After granting microphone access, you can use the microphone to enable voice features, such as shooting videos or waking up voice assistants. In these features, we collect your voice information to recognize your command. Please be aware that even if you have given consent to enable microphone access, we will only retrieve voice information when you actively click on the microphone icon within the app or when recording a video.

5) Additional services based on storage permission:

We request this permission to ensure the stable operation of the client. After you grant us permission to read/write your mobile device’s storage, we will access pictures, files, crash log information, and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.

6) Based on self-boot and associated boot instructions:

This setting is to achieve the function of listening to the connection status between APP and Bluetooth devices, you need to always ensure that the software is running in the background. In order to ensure that the mobile phone can receive messages at any time, to avoid the application is retreated to the background and then killed, resulting in disconnection affecting the normal use of the function, so the software needs to be sent to wake up the APP application through the Android system broadcasting for self-launching or related to the start-up of the service, which is necessary to achieve the function of the product.You can also turn off this feature in the settings section of your mobile phone. (Android)

You understand and agree that the aforementioned additional services require you to enable location information (geographical location), camera, photo library, and microphone on your device to achieve the collection and use of information related to these permissions. You can review the status of these permissions individually in your device settings and can decide to turn on or turn off these permissions at any time.

Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect previous collection and use of information based on your authorization.

2、 Information We Collect Automatically

Device Information: When you interact with our products, we collect your device model, operating system, device hardware serial number (a string embedded by the device manufacturer as a unique identifier), Android ID, login IP address, WLAN access points, application version number, push notification identifier, log files, carrier identifier, BSSID of WIFI,SSID of WIFI,installed software list, device MAC address, mobile network information to provide and maintain the common operation of our services, optimize your user experience, and ensure the security of your account.

Usage Data: During your interaction with our website and services, we automatically collect usage data related to access, clicks, downloads, sending/receiving messages, and other interactions with our website and services.

Log Information: When you use our application, system and exception logs are uploaded, including your IP address, language used, operating system version, and the date or time of access.

Please note that individual device information and service log information are non-identifiable information. If we combine such non-personal information with other information to identify a specific individual or use it in conjunction with personal information, during the combined use, such non-personal information will be treated as personal information. Unless authorized by you or required by laws and regulations, we will anonymize or de-identify such information during processing.

Location Information: When you enable the location function on your mobile device through system authorization and use location-based services, we collect and use your location information to facilitate the pairing of your mobile device with smart devices through the Ulanzi Connect application. Additionally, when you use specific products or services from us, we may collect real-time precise or non-precise geographical location information about you.

3、 Smart Device-Related Information:

Basic Information of Smart Devices: When you connect your smart devices with our products and services, we collect basic information about smart devices, such as device name, device ID, online status, activation time, firmware version, and upgrade information.

Information Reported by Smart Devices: Depending on the different smart devices you choose to connect with our products or services, we collect information reported by your smart devices.

Purposes and Legal Basis for Processing Personal Data:

We process your information for the following purposes:

Providing Services to You: We process your account and personal profile data, device information, usage data, location information, and smart device-related information to provide the products and services you have requested or purchased. The legal basis for such processing is to fulfill our contract with you according to our terms of use.

Improving 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 improve our products and services, analyze our operational efficiency, and prevent and track fraud or improper use. The legal basis for such processing is to fulfill our contract with you according to our terms of use.

Non-Marketing Communications: We process your personal information to send you important information related to services, terms/conditions, policy changes, and/or other administrative information. Simultaneously, we may also send you notifications related to services you have purchased, such as alert services. You can manage whether you want to receive such message communications by checking the 'App Message Notification' under 'My - Settings - App Message Notification' in Ulanzi. When you choose to turn off push notifications, we will no longer send push notifications to you. The legal basis for such processing is to fulfill our contract with you according to our terms of use.

Data Analysis: To analyze the usage of the products we provide, enhance your user experience, and promptly address any issues you encounter during the usage of the product, we analyze the data you provide and report. This includes identifying problems you may have in using the product, analyzing products or usage scenarios relevant to you, and allowing you to better enjoy the convenience brought by our products. If you do not agree to the analysis of your data, you can go to the privacy settings in Ulanzi Connect('My - Settings - Privacy Settings - Data Analysis') to opt out of your choice. The legal basis for such processing is based on your consent.

Compliance: We will process your personal data when we deem it necessary or appropriate :

(a) Comply with applicable laws and regulations;

(b) Comply with legal processes;

(c) Respond to requests from public institutions and government authorities;

(d) Fulfill our terms and conditions;

(e) Protect our operations, business, and systems;

(f) Protect the rights, privacy, safety, or property of us and/or other users, including you;

(g) Seek available remedies or limit the damages we may sustain.

We also use collected personal information in other ways, and specific notices will be provided at the time of collection, obtaining your consent as required by applicable law. If there are any changes for the purposes of processing your personal information, we will notify you of such changes through email and/or prominent notices on our website, and inform you of choices regarding your personal information.

Who We Share Your Personal Data With:

Ulanzi shares your personal data only in ways you are aware of. We may share your personal data with the following entities:

  1. Third-party Service Providers: We disclose your personal data to third-party service providers who assist us with various business-related services, such as website hosting, data analytics, payment and credit card processing, infrastructure supply, IT services, customer support services, email delivery services, and other similar services to enable them to provide services to us.
  1. Customers and Business Partners: We disclose your personal data to customers and other business partners who directly or indirectly provide smart devices and/or the networks and systems you use to access and use our website and services.
  1. Business Transactions: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including, but not limited to, the aforementioned situations related to any bankruptcy or similar proceedings), we may disclose your personal data to subsidiaries or other third parties. In such cases, you will receive explicit notice via email and/or our website about changes in ownership, new incompatible uses of personal data, and choices regarding personal data.
  1. Legal Compliance and Protection: We may disclose your personal data when we deem it necessary or appropriate:

(a) To comply with applicable laws and regulations;

(b) To comply with legal processes;

(c) In response to requests from public institutions and government authorities, including those outside your country or region of residence;

(d) To fulfill our terms and conditions;

(e) To protect our operations, business, and systems;

(f) To protect the rights, privacy, safety, or property of us and/or other users, including you;

(g) To seek available remedies or limit the damages we may sustain.

  1. Corporate Affiliates: We may disclose your personal data to our corporate subsidiaries or affiliates for regular business activities.

Apart from the above-mentioned third parties, we will only disclose your personal data to other third parties with your consent.

To ensure the stable operation of the services provided by us. or to achieve related functions, we may integrate software development kits (SDKs) provided by third parties for the aforementioned purposes. We conduct strict security testing on application programming interfaces (APIs) and software development kits (SDKs) through which authorized partners obtain relevant information. We also establish strict data protection measures with authorized partners, requiring them to handle personal information in accordance with this policy and any other relevant confidentiality and security measures.

The third-party SDKs we integrate primarily serve the needs of you and other users. Therefore, as we meet new service requirements and business functional changes, we may adjust the third-party SDKs we integrate. We will promptly disclose the latest information about the integration of third-party SDKs in this statement.

The situations in which Shenzhen Ulanzi Technology Co., Ltd. integrates third-party SDKs are as follows (specifically determined based on whether you use the following third-party services that involve personal data collection):"

Third-Party Name 1: Xiaomi Message Push Service

Details of Personal Privacy Collection: Your IMEI/OAID (applicable to Android Q and above systems), IMEI MD5/MEIDMD5, Android ID, VAID, AAID, and your MID (applicable to MIUI systems), device model, and other information.

Privacy Policy Address:https://dev.mi.com/console/doc/detail?pId=1822

Third-Party Name 2: Huawei Message Push Service

Details of Personal Privacy Collection: Your ID, application ID, application package name, and server public IP address. If you create message push tasks on the AppGallery Connect website, we will collect information about the frequency of use of various functions of Huawei Push, task names, message content, and push scope (application token, topic name, or audience group name).

Privacy Policy Address:https://developer.huawei.com/consumer/cn/doc/HMSCore-Guides/sdk-data-security-0000001050042177

Third-Party Name 3: OPPO Message Push Service

Details of Personal Privacy Collection: Your device-related information (such as IMEI number, Serial Number, IMSI, User ID, Android ID, Google Advertising ID, phone Region settings, device model, phone battery level, phone operating system version, and language), information about the applications using the push service (such as app package name and version number, operation), push SDK version number, network-related information (such as IP or domain connection results, current network type), message sending results, notification bar status (such as notification bar permissions, user click behavior), and lock screen status (such as whether the screen is locked, whether lock screen communication is allowed).

Privacy Policy Address: https://open.oppomobile.com/wiki/doc#id=10288

Third-Party Name 4: VIVO Message Push Service

Details of Personal Privacy Collection: Device and Application Information: This includes the operating system version number, application information, device identifiers (such as IMEI number, SIM and IMSI, mobile country code, and mobile network code for vivo Android devices), MAC address, mobile carrier, language usage, system settings, and other system, device, and application data collected during your use of vivo devices and services.

Privacy Policy Address:https://www.vivo.com.cn/about-vivo/privacy-policy

Third-Party Name 5: Amap (Gaode Map)

Details of Personal Privacy Collection: WLAN status information, location information, terminal device unique identifier, application package name, mobile screen density/size/model/system version.

Privacy Policy Address:https://lbs.amap.com/pages/privacy/

Third-Party Name 6:Umeng SDK

SDK Service Provider:Youmeng Tongxin(Beijing)Technology Limited

Purpose: for APP operation analytics

Details of Personal Privacy Collection:Device information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI/ICCID), location information, network information

Privacy Policy Link:https://www.umeng.com/page/policy

Third-Party Name 7:Bugly SDK

SDK Service Provider:Shenzhen Tencent Computer Systems Company Limited

Purpose: upload crash reports and device logs for developers to debug app issues

Details of Personal Privacy Collection:Android device information(phone model, brand, Android version, Android system api level, vendor version, cpu architecture, device root, disk space usage, sdcard space usage, memory space usage, network type, and the Running application Name and PID) iOS device information(device model, OS version, OS build number, wifi status, cpu attributes, memory space usage, disk space/disk space usage, phone status at runtime (memory occupied by processes, virtual memory, etc.), idfv, whether or not the device is jailbroken, and region code).

Privacy Policy Link:https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

Third-Party Name 8:Ali Cloud Mobile User Feedback SDK

SDK Service Provider: Alibaba Cloud Computing Co., LTD.

Purpose: to gather feedback data from users, so as to check network status, identify feedback devices and record feedback content

Details of Personal Privacy Collection: network information, device information (including operating system, device model, operating system, device model, operator information, recordings, pictures, videos)

Privacy Policy Link:https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202112071754_83380.html?spm=a2c4g.435514.0.0.2be424b61FhXzN

Third-Party Name 9:Google Analytics for Firebase

SDK Service Provider:  Google LLC

Purpose: upload crash reports and device logs for developers to debug app issues

Details of Personal Privacy Collection: number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, number of in-app purchases

Privacy Policy Link:https://www.google.com/analytics/terms/

Rights Related to Personal Data

We respect your rights and control over your personal data. You can exercise any of the following rights:

Contact us via email:ulanziapp@ulanzi.com

You do not need to pay any fees, and we will complete the verification and processing within 15 working days or 30 natural days. If you choose to send your request via email, please specify which information you would like to change, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that for security purposes, we may request identity verification before further processing your request.

You have the right to:

  1. Request access to the personal data we process about you.
  1. Request correction of any inaccurate or incomplete personal data related to you.
  1. Request the deletion of your personal data.
  1. Request temporary or permanent restriction of our processing of all or part of your personal data.
  1. Request that we transmit your personal data to yourself or a third party when we process your data based on your consent or a contract you have entered into with us, and when we process your data automatically.
  1. Choose to oppose or refuse our use of your personal data when we process it based on your consent or our legitimate interests.

Revocation of Consent:

We ensure your right to revoke consent through the following methods:

  1. Privacy rights obtained through device system settings can be revoked by changing device permissions, including location, camera, photo gallery/video gallery, microphone, Bluetooth settings, notifications, and other related functions.
  1. For non-marketing communications you have agreed to, you can close your choices through [My] - [Settings] - [App Message Notifications].
  1. For data analysis functions you have agreed to, you can close your choices through [My] - [Settings] - [Privacy Settings] - [Data Analysis].
  1. By unbinding smart devices through the application, information about your use of smart devices will not be collected.
  1. By using the application's guest mode, we will not collect any personal data about you.When you revoke consent or authorization, it may affect our ability to continue providing services related to the revoked authorization. However, revoking consent or authorization does not affect the processing of personal information based on your consent before revocation.

Account Deactivation:

You can deactivate your account through the following path: [My] - [Settings] - [Account & Security] - [Deactivate Account].

Security Measures:

We employ commercially reasonable physical, administrative, and technical security measures to maintain the integrity and security of your personal data. Ulanzi provides various security strategies to effectively ensure the data security of users and devices. Regarding device access, we ensure data security, access authentication, and authorization applications. communication using security algorithms and encrypted transmission protocols and commercial-level information encryption transmission based on dynamic keys are supported. In data processing, we use strict data filtering and validation, as well as a complete data audit process. In terms of data storage, all confidential information of users will be securely encrypted for storage. If, for any reason, you believe that your interaction with us is no longer secure (for example, you believe that the security of your account you might have with us has been compromised), please email ulanziapp@ulanzi.com immediately.

Data Retention Period:

We will process your personal data within 15 working days for the purposes stated in this policy unless longer retention is required by specific legal requirements. We will determine the appropriate retention period based on the amount, nature, and sensitivity of personal data. At the end of the retention period, we will destroy your personal data. If, for technical reasons, we are unable to destroy the data, we will take appropriate measures to prevent further use of your personal data.

Protection of Children's Personal Information:

We place great importance on the protection of children's personal information. If you are under the age of 13 (or the designated age in your country/region), please obtain written consent from your parents or legal guardians before using our services. We protect children's personal information in accordance with relevant laws and regulations in various regions, countries, or territories. Please note that if we discover that we have collected personal information from children without verified prior parental or legal guardian consent, we will make efforts to delete such information as soon as possible.

Statement on Policy Changes:

We may adjust or change this privacy policy as needed. Any updates to this privacy policy will be published on the mobile client with a designated update time. Unless otherwise required by laws, regulations, or supervisory provisions, the adjusted or changed content will take effect within 7 days after notification or publication. Please pay attention to relevant announcements, prompts, agreements, rules, and other related changes from time to time.

If you do not agree with the adjusted or changed content of the privacy policy, you should immediately stop using the corresponding services and log out of the relevant account. We will cease collecting your relevant personal information. If you continue to use Ulanzi products or services, Ulanzi believes that this indicates you have fully read, understood, and accepted the modified personal information protection and privacy policy.

Please contact us as follows:

Ulanzi Connect App,

Shenzhen Ulanzi Technology Co., Ltd.

Email: ulanziapp@ulanzi.com

Address: A1705, Building A, Galaxy World, N0.1 Yabao Road, Bantian Street, Longgang District, Shenzhen