SMA (hereinafter referred to as "we") respects and protects user information very much, and treats such information with a high degree of responsibility and prudence. When you use the services provided by SMA, we will collect, process and disclose your information in accordance with this Privacy Policy. We hope to provide you with a clear understanding of how we treat your information through this Privacy Policy, so we recommend that you read this Privacy Policy in its entirety to help you understand how to maintain your privacy.

If you have any questions, comments or suggestions, you can contact us at smartwatch@yeah.net.

Contents：

1、Scope of application

2、Collection and use of user information

3、Sharing, transfer and public disclosure of user information

4、User business data and public information

5、Management of user information

6、User Information Security

7、Our policy towards children

8、Update of Privacy Policy

9、How to contact us

1、Scope of application

1.1 This Privacy Policy applies to all services provided by SMA. Services include providing you with web browsing and technical services provided to you through the SMA website.

1.2  This Privacy Policy also applies to your use of SMA applications. The personal registration information provided according to the application requirements when registering an application account includes but is not limited to your nickname, age, country, avatar, height, gender, weight, measurement unit used, etc. ; Bluetooth device data synchronized by the app when using the app, including but not limited to your exercise steps, heart rate data, blood pressure data, sleep data, exercise record data, and location data generated during some exercise.

1.3  User personal data obtained by this application from business partners through legal means.

2、Collection and use of user information

2.1 Help you become our user.

2.1.1. When you create an account on the SMA App, you must provide us with any item of email address, mobile phone number, and third-party login information as the key content of login. If you log in with your email or mobile phone number, we will send you a verification code For verification, you also need to set and confirm your login password. The email or mobile phone number you submit is used to accept the verification code when you register, log in, bind your account, and retrieve your password, and it will be used as the contact information designated by you and SMA. One, used to receive relevant business notifications (such as health reports, service changes, etc.). If you use a third login, such as Google and Facebook, we will apply for authorization from the corresponding third-party platform, and obtain your nickname and avatar after you agree to authenticate you. We obtain you from the third party The content of your data depends on the settings, permissions and privacy policies controlled by the third party, and you should always be careful to check the privacy settings and notices in these third-party services for the data that may be disclosed to us or shared with our services.

2.1.2.After you complete the registration of your Alibaba Cloud account, you can continue to fill in your information in the next process, including but not limited to your nickname, age, avatar, height, gender, weight, measurement unit used, etc.

2.2.Provide you with technical services

2.2.1 During your use, you can contact our sales staff at any time or through the built-in feedback function of the App, you can give us feedback on the difficulties or doubts you encounter, and fill in the email address that can contact you, we will receive the email We will contact you in time to provide support services.

The information we collect during your use of the SMA App includes:

2.2.2.Device information: We will receive and record information related to the device you use (such as device model, operating system version and other software and hardware feature information) according to the specific permissions you grant during software installation and use, and will also use the cookie function. to ensure the safe use of your data.

2.2.3.User health data: When you use our client to synchronize data with the Bluetooth devices we sell, we will automatically record your exercise steps, heart rate data, blood pressure data, sleep data, exercise record data, and data generated during some exercise. Location data and other content synchronization server under your account system.

2.2.4.Please note that individual device information, user health data, etc. are information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be considered personal information during the combined use, unless authorized by you Or unless otherwise provided by laws and regulations, we will anonymize and de-identify such personal information.

2.2.5.Support information for user accounts: Based on the user's consultation records, problem feedback records and processing procedures for user feedback (such as communication or call records) generated by your use of Ali SMA services or products, SMA will record and analyze this information to improve the information. To respond promptly to your help requests, as well as to improve the service.

2.3.We use the user information you submit and we collect for the following purposes:

2.3.1.In order to provide you with services (such as height, weight, age, is a prerequisite for continued access to services);

2.3.2.In order to maintain and improve the service (such as the mobile phone number or email you submit to receive the verification code, etc., to register, log in or receive business notifications and conduct business communication);

2.3.3.To the extent permitted by laws and regulations, promote and introduce products to you;

2.3.4.In order to improve the security of your use of the services provided by us and our affiliated companies and partners, to protect the personal and property safety of you or other users or the public, and to better prevent phishing websites, fraud, network vulnerabilities, computer viruses, and network attacks , network intrusion and other security risks, more accurately identify violations of laws and regulations or SMA related agreements and rules, we may use your user information, and integrate device information, relevant network logs and information shared by our affiliates and partners, To judge your account risk, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law;

2.3.5.Other uses with your permission.

2.4. If you purchase SMA merchandise on our website, you will be required to contact our salesperson, who may be asked to provide your payment information, including your name, credit or debit card number, card expiration date, CVV code and account number single address. We do not store this payment information. We store your shipping address to complete your order. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.

3、Sharing, transfer and public disclosure of user information

3.1.Shared

We will not share your user information with other organizations and individuals, with the following exceptions:

3.1.1.Sharing with express consent: We will share your user information with other parties after obtaining your express consent;

3.1.2.Sharing under statutory circumstances: We may share your user information externally in accordance with laws and regulations, litigation and arbitration resolution needs, or as required by administrative and judicial authorities in accordance with the law;

3.1.3.In order to help solve your feedback, in some cases, only sharing your user information can handle your problem. For example, when you use your mobile phone number to register your account or retrieve your password, you cannot receive the verification code information. The mobile phone number is provided to the SMS operator we access, so that they can check the SMS sending record of your specific verification code to confirm the problem.

3.1.4.Share with authorized partners：

We may entrust trusted partners to provide services, so we may share some of your user information with partners to provide better customer service and optimize user experience. We will only share your user information for legal, legitimate, necessary, specific and explicit purposes, and only share user information necessary to provide services. Our partners are not authorized to use the shared user information for any other purpose.

Currently, our authorized partners include the following types: authorized distributors, service providers and other partners. We send information to authorized distributors, service providers and other partners who support our business, including providing basic technical services, providing consulting, analysis and other professional services.

For companies, organizations and individuals with whom we share user information, we will sign strict confidentiality agreements and information protection agreements with them, requiring them to deal with users in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures information.

3.2.Transfer

We will not transfer your user information to any company, organization or individual, except in the following cases:

3.2.1.Transfer with express consent: After obtaining your express consent, we will transfer your user information to other parties;

3.2.2.In the event of a merger, acquisition or bankruptcy liquidation between SMA and other legal entities, or other situations involving merger, acquisition or bankruptcy liquidation, if the transfer of user information is involved, we will require the new company or organization holding your user information to continue Subject to this policy, otherwise we will require the company, organization and individual to seek authorization from you again.

3.3.Public Disclosure

We will only publicly disclose your user information under the following circumstances:

3.3.1 With your explicit consent or based on your active choice, we may publicly disclose your user information;

3.4. Exceptions to prior authorization and consent when sharing, transferring, and publicly disclosing user information

In the following cases, sharing, transferring and publicly disclosing your user information does not require your prior authorization and consent:

3.4.1.Related to national security and national defense security;

3.4.2. Related to public safety, public health, or major public interests;

3.4.3. Related to criminal investigation, prosecution, trial and execution of judgments;

3.4.4. In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain my consent;

3.4.5. Your personal information disclosed to the public by yourself;

3.4.6.Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

4、User business data and public information

Unlike your user information, for user movement data and public information, SMA will process it as follows:

4.1. User sports data

4.1.1.All data generated by the equipment you purchased through SMA or authorized distributors is your user movement data, and you fully own the ownership of your user movement data. As a service provider, SMA will only process your sports data according to scientific and legal health algorithms and only display sports data records and data processing results to you. Any unauthorized use or disclosure of your business data.

4.1.2. When you allow us to collect precise location information, we use that information to provide and improve the functionality of the Services, such as recording where your workouts take place and charting your path during exercise.

4.1.3. We use your information to correct some data, such as using your height, weight, gender, age and other information, to improve the accuracy of calculating your daily exercise data and activity statistics, common data are steps and calories; according to your For sleep data, we may infer your sleep status to present your data quality in a clearer way and help you improve your sleep quality.

4.2.Public information

4.2.1.Public information refers to any information you share publicly, and anyone can view or access the information during use and non-use of SMA services, such as content you share with third parties by taking screenshots of relevant pages of the SMA App. 

5、Management of user information

For user information management related operations, in order to ensure security, you need to send an email to the SMA comprehensive information maintenance email smartwatch@yeah.net, our staff will contact you by email after receiving the email, and after proving your identity, We will process your request according to the actual situation.

5.1.Access and update your information: You can use the App provided by SMA to log in, query, manage (change, delete) the basic business information (basic data) submitted when using SMA services.

5.2. Data Portability:You have the right to request a copy of your information, to request your information in a structured electronic format

5.3. Deletion of your information: You may request us to delete user information in the following circumstances:

5.3.1. If our processing of user information violates laws and regulations;

5.3.2. If we collect and use your user information without your express consent;

5.3.3. If our processing of personal information seriously violates our agreement with you.

5.3.4.  If you explicitly want to deactivate the SMA service.

6、User Information Security

6.1.SMA takes the security of your information very seriously. We endeavour to take all reasonable physical, electronic and managerial security measures to protect your user information. Protect user information from unauthorized access, public disclosure, use, modification, damage or loss. We will use encryption technology to improve the security of user information; we will use trusted protection mechanisms to prevent malicious attacks on user information; we will deploy access control mechanisms to try our best to ensure that only authorized personnel can access user information; and we will organize Security and privacy protection training courses to enhance employees' awareness of the importance of protecting user information.

6.2.We will take reasonable and practicable measures to try our best to avoid collecting irrelevant user information. We will only retain your user information for as long as is necessary to achieve the purposes described in this policy, unless an extension of the retention period is required or permitted by law. After the above-mentioned storage period of user information is exceeded, we will delete or anonymize your personal information.

6.3.Please use a complex password to help us keep your account secure. We will try our best to ensure the security of any information you send to us, and ensure that your information is not lost, abused and altered by encrypting user passwords and other security measures. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legitimate rights and interests, we will assume corresponding legal responsibilities.

6.4.After the unfortunate occurrence of a user information security incident (leakage, loss, etc.), we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and your options Advice on self-prevention and risk reduction, remedies for you, etc. We will promptly notify you of the relevant information of the event by email, letter, telephone, push notification, etc. When it is difficult to inform users of the information one by one, we will publish announcements in a reasonable and effective way.

6.5.At the same time, we will also report the handling of user information security incidents in accordance with the requirements of regulatory authorities.

6.6.We store your collected user information within the territory of the People's Republic of China. If the personal information is transferred overseas due to business needs in compliance with applicable laws, we will obtain your prior consent and inform you of the user information. The purpose of leaving the country, recipient, security measures, security risks, etc.

6.7.In the event that SMA products and services cease to operate, we will take reasonable measures to protect the security of your user information, including promptly stopping the collection of user information; the notice of cessation of operation will be notified to users in the form of one-by-one delivery or announcement; and The held personal information is deleted or anonymized, etc.

6.8.Before using user information beyond the stated purpose when collecting user information or beyond the scope of direct or reasonable connection, we will inform you again and obtain your express consent.

6.9.SMA's product server uses the server of China Aliyun Company (hereinafter referred to as "Aliyun"), and its official website access address is: https://www.aliyun.com/ , SMA's App products related to you The information and data of SMA are only stored on Alibaba Cloud servers, and SMA does not store relevant data locally.

6.10.User data retention time limit: As long as your account is active, we will keep your account information, and at the same time your sports data, our terminal device supports to display your data from the current time to the previous 6 months.

7、Our policy towards children

We comply with the EU General Data Protection Regulation ("GDPR") and Children's Online Privacy Protection Act ("COPPA") requirements. SMA services are aimed at people who are at least 16 years old or older. If you are the guardian of a child under the age of 16, you need to declare and warrant that you agree and have obtained the consent of the guardian to use this platform and agree to this Privacy Policy.

Statement on the use of App permissions

SMA's App uses Bluetooth (Ble) to communicate with the device, which belongs to the "supporting application of the connected device of the mobile phone". In daily use, the SMA's App will apply to the user for permission to read phone calls and read/receive text messages. In Before using these permissions, the user will be reminded to allow these permissions. These permissions are limited to the realization of the information push function, which pushes the incoming call information and text message information and content received by the mobile phone to the smart watch, thereby reminding the user that there are new messages, convenient User view. SMA solemnly declares: We will not upload or re-process any content of phone calls and text messages, and will never abuse these permissions. Applying for these permissions is only for implementing the message push function. You can refuse these permissions, but only Only affects the message push function. Generally, for the sake of functional integrity and user experience, SMA recommends that users agree to these permissions.

8、Updates to Privacy Policy

9.1.Our Privacy Policy may be revised.

9.2.We will not limit your rights under this Privacy Policy without your express consent.

9.4.Material changes referred to in this policy include, but are not limited to:

9.4.1. There has been a major change in our service model. Such as the purpose of processing user information, the type of user information processed, the way of using user information, etc.;

9.4.2. We have significant changes in control, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;

9.4.3. The main object of user information sharing, transfer or public disclosure changes;

9.4.4. Material changes in your rights to participate in the processing of user information and the way in which they are exercised;

9.4.5. When our responsible department responsible for handling user information security, contact information and complaint channels change;

9.4.6. When the user information security impact assessment report indicates that there is a high risk.

9、How to contact us

If you have any questions and comments about the contents of this statement and policy, or if you have any questions and comments about SMA's practice and operation of this Privacy Policy, you can contact our comprehensive information processor by mail.

E-Mail:smartwatch@yeah.net

Shenzhen Smart Care Technology Co., Ltd.

Add: Workshop 2601, Anda Electronics Industry Factory, Heping Community, Fuhai Street, Baoan, Shenzhen, Guangdon

Thank You!