User Privacy Statement for WholeHome Assistant

Hangzhou BroadLink Technology Co., Ltd, its affiliates and subsidiaries (“we”, “us”, “our”, “BroadLink”) recognizes that your privacy is important, and we take it seriously. Please read this privacy policy carefully to understand our practices about how we collect, use and share your personal information.

This privacy policy describes how the personal information that is collected when you visit the WholeHome Assistant application that posts a link to this privacy policy ('Service') will be used by Hangzhou BroadLink Technology Co., Ltd. that owns the Service ('BroadLink,' 'we,' 'us' or 'our'). This policy may be supplemented by additional privacy terms or notices set forth on certain areas of the Service.

The Service collects information from you in two ways: directly from your input and automatically through the Service's technologies.

Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your name, email address, mailing address, phone number, username, and login credentials. During your interaction with our products, we may further collect your information such as nickname, avatar, country code, language preference or time zone in your account.

Feedback: When you use our feedback and advice features in our products, we may collect your email address, mobile phone number and feedback content for our further processing of your issue and device troubleshooting..

4.1. Account Information: Your account nickname, avatar, mobile phone number and email address; Google authorized login account, etc.

4.2. Device Information: When you interact with our products, we automatically collect device information, such as positioning permission (required for obtaining Wi-Fi SSIDs during device setup for Android 6.0 and above versions), bluethooth information, the MAC address of your devices, IP address, wireless connection information, operating system type and version, App version, push notification identifier, log file and mobile network information.

4.3. Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

4.4. Log information: When you use our App, the system and abnormity logs might be uploaded.

4.5. Location Information: We may collect information about your real-time precise or non-precise geo-location when you interact with our Products and Services (e.g. sweeping robot and weather service).

4.6. Home name, home location (specified manually), room info, home background picture and local electricity tariff.

4.7. Normally generated data during use: scene info, trigger info and remote panel info.

4.8. Smart device related information:

4.8.1. Basic information of smart devices: When you use Smart Devices that are connected to our Products or Services, we may collect basic information related to smart devices, such as device name, device ID, online status, activated time, firmware version and updates information.

4.8.2 We will apply for permission to use the following devices. If you decline, you may not be able to use the corresponding functions in the scene described：

Permission function description: Send and receive control commands through Bluetooth devices to control smart home devices.

Usage scenarios and purposes: Sending and receiving control commands through Bluetooth devices can help you control Bluetooth-enabled smart home devices, including smart lights, smart sockets, smart panels, etc.

Permission function description: send and receive messages via wifi, and control the gateway.

Usage scenario and purpose: Communicate with smart gateway via Wi-Fi.

Permission function description: use the mobile phone mic to record and access the mobile phone's local media library

Usage scenario and purpose: In the music rhythm function, it is used for rhythm pickup. Through this function, users can select music from the built-in music according to their own preferences.

Permission function description: release the built-in music to the user's local storage space.

Use scenario and purpose: In the music rhythm function, the user selects a piece of music from the built-in music according to his own preferences.

Permission function description: Use this permission to obtain mobile phone information and Bluetooth device scanning function.

Usage scenarios and purposes: for gateway and Bluetooth device configuration, smart device control.

Permission function description: Use this permission to obtain mobile phone information and Bluetooth device scanning function.

Usage scenario and purpose: When sharing a family, the camera needs to be turned on when scanning the QR code.

Permission function description: permission to access the album.

Usage scenario and purpose: When sharing a family, you can scan the 2D code image of the album.

4.8.3 You can withdraw part of the authorization by unbinding, modifying and deleting related information, and withdrawing authorization by turning off the function (for specific methods, you are recommended to refer to or contact your mobile device service provider or manufacturer). Once you turn off the above functions through the system authorization, you may not be able to continue to use the services based on the relevant information, or you may not be able to achieve the expected effects of the services based on the relevant information.

4.9. We do not collect your data which may reveal personal race or its source, political opinion, religion/philosophical belief, labor union membership, personal gene identification, biological data, or data related to heath, sexual life or sexual orientation. We do not collect personal data of users under age of 16 without permission from their legal guardians. If you are under age of 16, you need to get permission from your parent or other legal guardian before using the App and products..

We may use your personal information to:

•Provide the Service to you, such as allow access to or delivery of our products or services, process or fulfill an order or transaction, or administer surveys or promotional programs;

•Respond to your requests, inquiries, comments or concerns;

•Provide technical, product and other support and help keep the Service working, safe and secure;

•Offer you customized content and individualized personalization of the Service to make it more relevant to your interests and needs;

•Enhance, evaluate and improve the Service, its advertisements and promotional campaigns and our products and services and to develop new products and services;

•Identify and analyze usage trends, including for the purposes of research, audits, reporting and paying royalties and license fees to third-party content providers;

•Notify you about changes or updates to the Service and our products and services;

•Provide you special offers, promotions, surveys and other information about the Service as well as products, events and services of ours, our affiliates and non-affiliated third parties such as societies and sponsors.

We may on occasion also match or combine the personal information that you provide with information that we obtain from other sources or that is already in our records, whether collected online or offline or by predecessor or affiliated group companies, for the purposes described above.

We may share your personal information with:

•Relevant agents, representatives, joint venturers, and entities for which we are acting as an agent, licensee or publisher, such as societies and sponsors;

•Applicable suppliers and service providers, including editors, reviewers, credit card processors, customer support, email service providers, mailing houses and shipping agents, and IT service providers;

to assist us with producing and delivering our products and services, developing and operating our businesses, systems and applications, processing payments, customer support, marketing, promotion and communications and for other purposes set forth in this privacy policy.

We also may share your personal information with our affiliated group companies worldwide and with societies, sponsors and other non-affiliated third parties that wish to send you information about their products and services that may be of interest to you as determined by your choices in managing your communications preferences following the process described below.

If the Service offers a content database or learning service ('Subscription Service') and you access the Subscription Service through an institution-sponsored subscription, your personal information and certain usage data gathered through the Subscription Service, such as the number of items you downloaded, any non-subscribed items you accessed, and test scores, may be shared with your institution for the purposes of usage analysis, subscription management, course management and testing and remediation. If your institution is a corporation or other business entity, additional usage data, such as the types of records you viewed and the number of searches you ran, also may be shared for the purposes of cost attribution and departmental budgeting.

We also may need to disclose your personal information:

•to respond to or comply with any law, regulation, subpoena, court order or other legal obligation;

•to enforce and protect our rights and properties;

•to detect, investigate and help prevent security threats, fraud or other malicious activity;

•to protect the rights, property or safety of our users, employees or others;

•if BroadLink, the Service or a related asset or line of business is acquired by, transferred to or merged with another company.

The Service may let you post and share personal information, comments, materials and other content. Any information you disclose publicly may be collected and used by others, may be indexable by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.

You can manage your communications preferences when you register with the Service, by updating your account preferences, by using the 'opt-out' or unsubscribe mechanism or other means provided within the communications that you receive from us or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

The Service may allow registered users to access their account information and make corrections or updates upon log in at any time. The accuracy of such information is solely the responsibility of the user. You may also request access to other personal information about you that may be held in the Service. If you request to deactivate your account or delete your personal information, we will endeavor to fulfill your request but some personal information may persist in backup copies for a certain period of time and may be retained as necessary for legitimate business purposes or to comply with our legal obligations.

BroadLink takes precautions to safeguard your personal information against loss, theft and misuse and unauthorized access, disclosure, alteration and destruction through the use of appropriate administrative, physical and technical security measures.

Your personal information may be transferred to other countries for processing. By using the Service you consent to the transfer of information to countries outside of your country of residence, which may have different personal data protection rules than in your country.

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (send to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

Email: support@ismarthomeplus.com

For European Union data subject, you have the right to lodge a complaint with a supervisory authority concerning BroadLink’s data processing activities. For questions, or to exercise your rights as an EU data subject, please contact our EU Representative here: Email: support@ismarthomeplus.com