Updated: November 22, 2022
Effective: November 22, 2022
NEXiiO UAB. and its Affiliates (as hereinafter defined) (“we”, “us”, “our”, or “NEXiiO”) are committed to protecting your privacy. NEXiiO Smart Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data (as hereinafter defined) we process through your use of our products and services (collectively, the “Services”), for instance the NEXiiO Smart Mobile Application (the “App”), please carefully read this Policy which details our purposes for collecting and processing your Personal Data, as well as how we use, store, share and transfer your Personal Data. In this Policy you will also find ways to exercise your rights of access, update, delete or protect your Personal Data.
You are not obliged to provide to us your Personal Data (as defined below). However, we may be unable to provide you with certain products and/or Services if you decline to provide such data.
If you are a child under the age of 13 (or such other age provided by applicable law in your country/region of residence)
Definitions
In this Policy:
Affiliate means any company, firm or legal entity that: (1) is directly or indirectly controlled by NEXiiO; or (2) directly or indirectly controls NEXiiO; or (3) jointly with NEXiiO, controls the same company; or (4) is, directly or indirectly, under common control of the same company with NEXiiO. Affiliates shall include, without limitation, NEXiiO's parent companies, subsidiaries, and such subsidiaries under common control of the same parent company as NEXiiO.
Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.
Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.
1. What Personal Data Do We Collect?
In order to provide the Services to you, we will ask you to provide necessary Personal Data that is required to provide those Services. If you do not provide your Personal Data, we may not be able to provide you with the Services.
1) Information You Voluntarily Provide to Us
- Registered Account Data: When you register an account with us, we may collect your account name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with the Services, we may further collect your nickname, country code, language preference or time zone information into your account.
If you authorize login to the Services with a third-party account, we will obtain from such third party your account information (such as portrait, nickname, region etc.) which may be bound with your NEXiiO account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.
However, if the Services you request or purchase are based on your account, please go to the registration/login page for guidance.
- Feedback: When using feedback and suggestion features in the Services, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.
Information based on additional functions:
In order to offer you with more convenient and higher-quality Services with optimized user experiences, we may collect and use certain information if you consent to use of additional functions in the App. Please note, if you do not provide such information, you may continue to use basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:
Additional functions based on location information:
When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about your: a) real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Devices, or b) non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google’s Data Processing and Security Terms for more details.
You may disable the collection and use of your location information by changing your mobile device settings, upon which we will cease to collect and use your location information.
Additional services based on camera:
You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, etc.
You may opt-out the using of camera permission in your settings of your phone
Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):
You can use this function to upload your photos/pictures/videos after turning on the photo album permission, so as to realize functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.
You may opt-out the using of photo album permission in your settings of your phone
Additional services based on storage permission (Android):
The purpose is to ensure stable operation of the App by utilizing the storage permission. After you give or indicate the 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 recording the crash log information locally.
You may opt-out the using of storage permission in your settings of your phone
Additional services based on Notification permission:
The reason why we ask you for the permission is to send you notifications about using the Smart Devices or Services, especially if you have purchased security services and you require an alert or message so that you can capture the real-time status.
You may opt-out the using of App notifications in your settings of your phone
Additional services based on Bluetooth permission:
You can enable Bluetooth functions after turning on the permission, including controlling the Smart Devices, acquiring status of, discovering and configuring Smart Devices. In these functions, we will communicate with Smart Devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display device status on the home page and Smart Device panel; perform device control on the home page and Smart Device panel; discovering Smart Devices on the home page and the add device page, Smart Device distribution network.
You may opt-out the using of Bluetooth in your settings of your phone
2) Information We Collect Automatically
- Mobile Device Information: When you interact with our Services, in order to provide and maintain the normal operation of our Services, to improve and optimize our Services, and to protect your account security as well, we automatically collect mobile device information, such as mobile device model number, IP address, wireless connection information, the type and version of the operating system, application version number, push notification identifier, log files, and mobile network information. Meanwhile, we will collect your software version number. In order to ensure the security of the operating environment or to provide services.
Please note that one cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate or desensitize such information.
3) Smart Devices Related Information:
When you use a Smart Device, we will collect some basic and pre-embedded information of the Smart Device and the information generated during your use of the Smart Device.
- Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may collect basic information about your Smart Devices such as device ID, online status, activation time, firmware version, and upgrade information.
- Information collected during the process of connecting to a Smart Device: Based on the type of Smart Device you need to connect, the basic information collected includes:
- Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device MAC address;
- After establishing a local connection via Bluetooth, Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device MAC address;
- Smart Devices connected via Bluetooth: device MAC address;
- Smart Devices connected via Zig-bee: device MAC address.
- Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with the Services, we may collect different information reported by your Smart Devices. The following information reported by the Smart Device only applies when you use them
2. Purposes and Legal Basis for Processing Personal Data
The purpose for which we may process information about you are as follows:
- Provide You with Our Services: We process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services that you have requested. The legal basis for this processing is to perform our contract with you according to our terms.
- Improve Our Services: We process your mobile device information, usage data, Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyze the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our User Agreement.
- Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or
- detect, prevent or otherwise address security, fraud or technical issues.
If there is any change in the purposes for processing your Personal Data, we will inform such change to you with a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.
3. Who do We Share Personal Data with?
At NEXiiO, we only share Personal Data in ways that we tell you about. Without your consent, we will not disclose your Personal Data to third-party companies, organizations, or individuals except in the following cases:
- To subsidiaries or affiliates within our corporate family for purpose of regular business activities based on our instructions and in compliance with applicable law, this Policy and other appropriate confidentiality and security measures.
- As we believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:
(a)Comply with applicable law, regulation, legal process, or lawful governmental request;
(b)Enforce our User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or
(e)Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.
Except for the third parties mentioned above, we only disclose your Personal Data to other third parties with your consent.
Data Subject Rights
We respect your rights and control over your Personal Data. You may exercise any of the following rights:
You do not have to pay any fee for executing your personal rights. Subject to applicable data protection laws in relevant jurisdictions, your request of personal rights will be fulfilled within 15 business days, or within 30 calendar days due to different response requirement.
If you decide to email us, in your request, please make clear what information you would like to have changed, 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 we may ask you to verify your identity before taking further action on your request, for security purposes.
Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:
1)For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notification settings and other related functions;
2)Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected;
When you withdraw your consent or authorization, we may not be able to continue to provide you with certain products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.
About Deactivation of the Account: You can find the Deactivate function through “Me > Settings > Account and Security > Deactivate Account”
Security Measures
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. NEXiiO provides various security strategies to effectively ensure data security of user and device.
As for device access, proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization.
As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported.
As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing
informacija[at]nexiio.com
Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data.
- For as long as you require us to fulfill the products and services you request from us as defined in the agreement.
- Personal Data will no longer be retained when you request to remove your Personal Data, we will accordingly complete the task.
When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.
Children’s Privacy
Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information.
Changes to this Policy
We may update this Policy to reflect changes to our information practices, at least on an annual basis. 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 in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Us
If you have any questions about our practices or this Policy, please contact us as follows:
NEXiiO UAB.