Privacy Policy
Effective Date:【Jan 4】, 2023
Chapter references
This Policy sets out：
I.How we collect and use your personal information
II.How we store and protect your personal information
III.How we entrust, share, transfer and disclose your personal information
IV.How to access to and control your personal information
V.Statement of liabilities to third parties
VI.Special provision on right to privacy of minors
VII.Cross-border transfer of personal information
IX.Scope of and amendments to this Policy
We, Ecovacs Robotics Co., Ltd. (Hereinafter referred to as “ we”, “ our” or “ Ecovacs”) respect and protect your privacy. This Policy explains the way Ecovacs collects, uses and stores your personal information and what rights you have under Ecovacs Privacy Policy (Hereinafter referred to as “ This Policy”), when you browse our website or use our products and services. Ecovacs shall strictly follow this Policy. Ecovacs hereby undertakes to you as set out below in this Policy. If you would like to have more detailed information, please refer to the corresponding chapters in accordance with the index above.
1.We explain the type and usage of your personal information in order to help you understand the type, reason to use and collection mode of specific personal information, which is collected by certain products, services or functions of Ecovacs.
2.Sometime when using certain Ecovacs functions, we will collect some information upon the receipt of your express authorization, unless such collection is mandatory pursuant to applicable laws (Hereinafter referred to as “Laws”). If you refuse to provide such information, you may be blocked from these functions but generally this should not affect your access to the core functions of products and services offered by Ecovacs.
3.Ecovacs generally will not share or transfer your personal information to any third parties unless otherwise expressly stated in this Policy or required or permitted by the Laws. If sharing or transferring information is necessary, we will explain reasons and obtain your express consent, including through this Policy.
4.You may access, correct or delete your personal information, or withdraw previous consent, cancel your account, file complaints or reports or apply privacy setting to control your personal information.
Understanding this Policy is necessary to browse our website or use the products and services of Ecovacs. We recommend that you carefully read and understand the full content of this Policy so that you may make relevant choices as you deem appropriate. We have tried to use plain and concise languages and to mark clauses that could materially affect your rights and interests in bold, to bring them to your attention.
If you have any questions, complaints or comments related to this Policy, please contact us with the information set out at Contact Us , we will respond to your needs in a timely manner. We are really glad to directly deal with your requests and fulfill your needs.
By browsing our website or using the products and service of Ecovacs, you are acknowledging that you have carefully read, understand and agree with this Policy. If you do not agree with this Policy, please refrain from using our website. We undertake to comply with applicable laws data protection laws of the place in which you reside) to protect your personal privacy and data security. We also ensure that all of our staff will perform the abovementioned obligations. The purpose of collecting, storing, using and sharing your information is to offer you better services and improve the quality of our products (e.g. to support the development of new products and function upgrades of existing products in order to provide you high-quality and suitable services). You are not required to provide us any personal information but if you voluntarily share your information listed in this Policy as we requested, you may enjoy better and more convenient services, faster responses and avoid any adverse consequences.
I.How we collect and use your personal information
To maintain the quality of our services and the safety of your information, when you visit our website on your computer or mobile device , and use the services provided by Ecovacs, we may record types and modes of services, the operation information during your services and any other log information in connection with your services including your IP address, system version, IMEI and MEID of your mobile device, and your location.
You understand and agree that we can provide your personal information to the competent regulatory agencies pursuant to the laws and regulations, the guidelines, the court orders or any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies without your authorization or consent.
II.How we store and protect your personal information
1.Location for storing your information. Personal information collected and generated from your use of the website, products and services will be stored in the servers housed by third-party cloud, which are physically located in the People’s Republic of China. To facilitate our operation, if we need to transfer your personal information to some overseas organizations outside of China, we will perform in accordance with the applicable laws, administrative regulations and relevant supervisory authorities, and request the overseas organizations to keep the confidentiality of the personal information obtained by taking measures including signing data processing agreements, verification and other effective measures. We will only store your personal data for the period necessary to fulfill the purpose outlined in this Policy or required or permitted by applicable Laws.
2.Management and policies concerning data security. We undertake to maintain information safety to the level as specified by the Law, etc. In order to keep your information safe, we commit to apply various safety technologies and associated management systems to protect your information from being disclosed, destroyed or lost. We have a personal information protection department. We have also developed a relevant internal control policy, where we seek to only give employees who may access to your information, the least authority and limited information access, sufficient for fulfilling their duties. We have further established access procedures and approval mechanisms to strictly control data.
3.Reporting mechanism for personal information safety accidents. Please understand that due to the limitation of technologies or potential malicious attacks, personal information safety accidents may unfortunately occur due to factors beyond our control. If a safety accident occurs, if required according to the Laws, etc., we will immediately notify you of: general facts and potential influences of the safety accident, measures we have adopted or will adopt, advice for you to protect your information and reduce risks as well as remedial measures, etc. We will inform you of the relevant facts of the accident by email, letter and telephone or by push notifications. If we cannot contact you individually, we will publish notifications in a reasonable and effective manner. We will also report the result of personal information safety accident to regulatory departments if required.
4.Delete your information. If we stop the provision of services or business operation, or your personal information become unnecessary to achieve the above purpose, we will promptly cease to continuously collect your personal information and may give notice to you individually or by publishing notifications. We will also delete or de-identify your personal information possessed by us without delay.
III.How we entrust, share, transfer and disclose your personal information
(i) Delegation of data processing
If it is necessary for providing you better or satisfactory products or services, we may engage third-party service providers to process your personal information. The above third-party service providers will process your information on behalf of Ecovacs. Ecovacs also ensures that we will comply with the following requirements when delegating such third parties to process your personal information:
1. Ecovacs will not process information beyond the scope authorized by you;
2. Ecovacs will make prior assessment on whether third-party service providers are qualified to maintain data security, in order to make sure they are eligible according to the Laws, etc.
3. Ecovacs will require the third-party service providers to comply with the applicable obligations by contract scheme, to follow all of the applicable Laws, regulations, industry rules and standards, business norms and practices of the jurisdiction in which you reside, and to be subject to obligations hereunder with the same or comparable standard adopted by Ecovacs to protect your information.
4. Ecovacs will accurately record and regularly audit the activities of the delegated third parties to process personal information in order to protect information safety and ensure your effective access to and control over your information.
5. Ecovacs shall ask third-party service providers to delete your personal information and destroy all data copies upon the termination of the principal-agent relationship.
(ii) Data sharing and transferring
In principle, we will not share or transfer your personal information to any third party companies, organizations and individuals. In the following exceptional circumstances, we will share your personal information for legal, reasonable and necessary purposes. Third parties receiving such data have no right to share and transfer personal information for any other usage that you are not advised of by this Policy.
1. Sharing information is necessary for providing products and services to you and upon your prior express authorization or consent
You understand and agree that if it is necessary to provide you better or satisfactory services, Ecovacs may share your personal information with its affiliates or any other third-party service providers upon your prior express authorization or consent. For example, when you make conduct transactions through our website (if applicable), we may need to share the transaction information to the bank or the other party of this transaction to certify the act of the relevant transaction, and protect your legal rights. Meanwhile, we need to share the address information to delivery service provider for their performing the delivery services. In some conditions, we may also engage some third parties to conduct the analyze service who may also have access to your information.
Ecovacs ensures that we will comply with the following requirements when sharing your personal information with the above third parties:
1) Ecovacs will conduct prior assessment of impacts on personal information safety and adopt effective measures to protect your personal information based on the result of the assessment.
2) Ecovacs will accurately keep the records of sharing or transferring your personal information, including but not limited to the date, scale, purpose of sharing and transferring your information, and basic information of data receiving parties, in order to help you to learn about storage and usage of your information by the receiving parties.
3) Ecovacs will keep your information safe, and ensure effective access to and control over the information, e.g. access to, correct, delete and cancel the account, etc.
2. Transfer information when Ecovacs has undergone acquisition, merger or reorganization
With the continuous development of our business, Ecovacs may engage in transactions including mergers, acquisitions and assets transfers. We will notify you of relevant facts and continuously protect or cause data receiving parties to continuously protect your personal information pursuant to the Laws, etc. or, in each as ask required by laws and regulations and with no less than the standard under this Policy.
3. Share your personal information pursuant to the Laws, etc. and mandatory requirements imposed by regulatory agencies
We may provide your personal information to the competent regulatory agencies pursuant to the Laws, etc. the court orders or any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies. Information sharing under this circumstance may not require your prior authorization or consent.
(iii) Disclose
We will not disclose your personal information to the public. If disclosure is needed, we will notify you of the purpose of such disclosure, the type of information disclosed and the scope of any sensitive information involved. We will disclose information with your prior explicit consent.
IV.How to access to and control your personal information
1. Please contact us with the information set out at Contact Us , If you need to access, rectify, delete, or you want to raise any other requests authorized by the applicable laws and regulations. We will contact you promptly respond to your request.
2. Notwithstanding the foregoing, under the following circumstances, we may not respond to your request pursuant to laws and regulations:
1) Directly related to the performing the legal obligations of us;
2) Directly related to national security or national defence;
3) Directly related to public safety, public health or vital public interests;
4) Directly related to criminal investigation, prosecution, trial and execution;
5) We have sufficient evidence to prove that you conduct acts in bad faith or abuse your rights;
6) It is necessary to safeguard the vital interests of you or other individuals, such as life, property, etc., and it is difficult to obtain your consent;
7) Responding your request will cause severe damages to your lawful rights and interests or those of any other individuals or organizations; or
8) Involving trade secrets.
V.Statement of liabilities to third parties
Please note that third-party website operators you visit, third-party service access to through us and third parties receiving your personal information from Ecovacs may have separate privacy policies; we will use commercially reasonable efforts to cause these parties to adopt protection measures on your personal information. However, we may not ensure they will 100%follow our requirements to do so. Please contact them directly to learn more about their privacy policies. If you find websites or applications developed by third parties have leakage risks, we recommend you to immediately stop providing them your information to protect your lawful rights and interests.
VI. Special provision on right to privacy of minors
We expect parents or guardians may instruct minors to use our services. If you are under 18 years old or you are a minor pursuant to the laws and regulations of the place in which you reside, we recommend you to ask your parents or guardians to read this Policy and use our services or provide your information to us with the prior consent from your parents or guardians. If your guardians do not allow you to use our services or provide your information to us according to this Policy, please stop using our services immediately and give a notice on time so that we can react accordingly. Ecovacs will keep personal information of minors confidential and safe in accordance with the relevant laws and regulations.
VII.Cross-border transfer of personal information
Since we provide products or services worldwide, your personal information might be transmitted to a jurisdiction or accessed from a jurisdiction outside of the country where you reside. Such destination jurisdictions include: (i) the jurisdiction where your personal information is stored (if it is the same as where you are located (cross-border transfer does not apply); (ii) China, where our affiliates’ registered office, our affiliates which are involved in our Websites products and services and most of our service providers, are located, and when our employees need to have access to your personal information for handling your issues and also conducting general analysis; (iii) the storage location of some other service providers which serve you on behalf of us through their API/SDK integrated into the Website, at your local jurisdictions, or at the jurisdiction where their relevant branch resides to specifically serve your local jurisdiction. For example, if you send to data-privacy@ecovacs.com an email, your personal information contained in such email and its delivery will be directed to China, where our email-box server is located. All such international transfers are made in connection by and between the relevant servers housed in third-party cloud facilities and physically located in such jurisdictions, and we will require third-party cloud suppliers to adopt appropriate safeguards in compliance with the Law.
IX.Scope of and amendment to this Policy
This Policy applies to all customers and users of Ecovacs website, products and services. Other websites (including those of our affiliates) will apply their separate privacy policies to their own data processing activities.
We may amend this Policy from time to time. If the clauses of this Policy are changed, we will show the amended privacy policy to you in the form of pushing notifications on our website. You may read this Policy at the bottom of the homepage in our official website. We encourage you check our privacy policy whenever you access to our services.