EVOLVEO Porta Privacy Policy
Effective as of May 1st, 2019
Dear user, welcome to EVOLVEO Porta. When you
use our services, you’re trusting us with your information.
Here, we provide you our service agreement and privacy policy to help you
understand what information we collect, why we collect it and how we protect
your information.
Please read it carefully and be sure you understand it.
READ
Welcome aboard!
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So you have purchased our EVOLVEO Porta device hardware and are starting to
use the EVOLVEO Porta device software and all its functionalities! Any
information you share with us (e.g. for creating an EVOLVEO Porta Account)
will help us to provide you with services related to EVOLVEO Porta device
and to improve them to make them even better. We explain here our ways of
collecting and using information, and how we protect your privacy. In this
privacy policy, “personal data” means information that can be used to
identify an individual, either from that information alone, or from that
information and other information we have access to about that individual.
We collect both personal and non-personal data to enable and facilitate the
best user experience possible.
We keep our Privacy Policy under regular review. If we change our Privacy
Policy, we will post the changes on all the EVOLVEO Porta websites, so that
you may be aware of the information we collect and how we use it. Such
changes to our Privacy Policy shall apply from the time that we post the
same on the EVOLVEO Porta websites. Your continued use of products and
services on the websites, mobile phones and/or any other device will be
taken as acceptance of the updated Privacy Policy. We will seek your fresh
consent before we collect more personal data from you or when we wish to use
or disclose your personal data for new purposes.
1. COLLECTION OF INFORMATION
Our collection of information will be based on your interaction with us and
the choices you have made, including your privacy settings and the products
and functions you use. The information we collect from you may cover the
SDK/API/JS version, software version, browser, Internet Service Provider
(ISP), IP address, platform, timestamp, application identifier, application
program version, application distribution channel, device’s unique
identification code, iOS Advertising Identifier (IDFA), Android advertiser
identifier, MAC address, International Mobile Equipment Identity (IMEI),
device model, terminal manufacturer, terminal OS version, start/time of
session, language location, time zone and network status (e.g. Wi-Fi),as
well as the usage of hard disk, CPU and battery. Personal data that are
collected for creating an EVOLVEO Porta Account may include your email
address or mobile phone number, device related information (e.g. IMEI
number) and various location related information (e.g. location area code,
mobile network and country codes).
We may collect information during the following procedures
- Set up and log in of EVOLVEO Porta Account. Personal data that are
collected for creating an EVOLVEO Porta Account may include your email
address or mobile phone number, device related information (e.g. IMEI
number) and various location related information (e.g. location area code,
mobile network and country codes).
- Purchasing your EVOLVEO Porta products. When you make purchases through
the EVOLVEO Porta e-commerce website, we may collect your EVOLVEO Porta
Account ID (or mobile phone number or email addressed used to create your
EVOLVEO Porta Account), name, phone number, delivery address, order details,
etc. EVOLVEO Porta provides logistics services to deliver the products
purchased on the e-commerce website. EVOLVEO Porta has an after sales system
to handle after sales related matters as well as an after sales centre for
walk-in support services for users. When you use these services, we may also
collect the order number, invoice date, list of purchased items and your
contact details in order to process the services.
- User feedback. When you submit a user feedback through the EVOLVEO Porta
app, we may collect information on the list of devices registered in your
account, as well as related device operation information and device
information.
- Syncing EVOLVEO Porta device data. When you synchronise the EVOLVEO Porta
device data, e.g. to EVOLVEO Porta device Cloud Service, we may collect data
relating to your activities and functionalities of EVOLVEO Porta device,
such as those obtained from our sensors and features on EVOLVEO Porta
device, your sleeping patterns, movement data and smart alarm related
information.
- Processing the services. In providing the above services, we may also
collect data in relation to your device, including your EVOLVEO Porta device
ID, firmware version, device OS version, model and system, and visiting IP
and time.
2. USE OF PERSONSAL DATA
Products improvement. We use data to improve our products continuously,
including adding new functions and increasing capacity. For example,
- To provide you with our products and services, processing your orders,
performing contractual obligations between you and us, to ensure the
functions and safety of our products, to verify your identity, to prevent
and trace fraudulent or inappropriate usage
- To develop our products and services, together with general and
statistical information
- To communicate with you, including providing you with notifications on
products and services that are updated or launched
- To provide marketing and promotional materials to you on our products and
services (please note that you may unsubscribe anytime)
- To personalise product design and to provide you with services tailored
for you, for example, recommending and displaying information and
advertisements regarding products suited to you, and to invite you to
participate in surveys relating to your use of EVOLVEO Porta device
- To conduct investigations regarding our products and services
- If you participate in our lottery, contest or other promotions, we may use
your personal data to manage such activities
- To provide maintenance services, monitor software licenses, to improve our
products or analyse the efficiency of our operations
When you use our services or functions that are based on location
information, e.g. adding EVOLVEO Porta devices, we may collect your
geographical information.
- When you use our website, online services, interactive applications, email
messages and advertising, we may use cookies and other technical elements
(e.g. pixel labels) to collect and store non-personal data. These enable us
to provide you with a better experience and improve our overall service
quality, e.g. in saving your preferred language settings, sending emails in
a readable format, to determine whether the emails have been opened or not,
etc.
- When you use the Internet browser in using our products and services, we
may collect log information, e.g. IP address, browser type, language,
reference source, operating system, date and time marking and click rate
data.
3. SHARING OF PERSONAL DATA
To perfect our products for better service, we may share your personal data
with our service providers or agents for purposes stipulated in this policy.
For example, our data analysis service provider may collect and access
personal data for statistics and analysis. In the context, these companies
must conform to our data privacy and safety requirements.
Who do we share your information with?
Unless we tell you in this privacy policy, we will keep your personal
information confidential. We may disclose your personal data on occasion to
third parties in order to provide the products or services that you have
requested. Some of these third parties may be located outside your home
country.
Disclosure may include the scenarios listed in this section below. In each
case described in this section, you can be assured that EVOLVEO Porta will
only share your personal data in accordance with your consent. You should
know that when EVOLVEO Porta shares your personal data with a third party
under any circumstance described in this section, EVOLVEO Porta will ensure
that the third party is subject to practices and obligations to comply with
the relevant data protection and privacy laws of your country. EVOLVEO Porta
will contractually ensure compliance by any foreign Third Party Service
Providers with the privacy standards that apply in your home jurisdiction.
Disclosure to EVOLVEO Porta group companies and Third Party Service
Providers
- In order to conduct business operations smoothly, the EVOLVEO Porta entity
which collects your personal data may disclose your personal data from time
to time to other EVOLVEO Porta group companies (in communications, social
media, technology or cloud business), or our third party service providers
which are our mailing houses, delivery service providers, telecommunications
companies, data centres, data storage facilities, and customer service
providers, agents, related corporations, and/or other third parties
(together “Third Party Service Providers”). Such Third Party Service
Providers would be processing your personal data on EVOLVEO Porta’s behalf
or for one or more of the purposes listed above.
- Personal data will only be shared by EVOLVEO Porta to provide or improve
our products or services and will not be shared for use for marketing
purposes.
Disclosure to others
EVOLVEO Porta may disclose your personal data without further consent if
required or permitted by law in the following cases:
- cases in which the disclosure is required or authorised based on the
applicable laws and/or regulations;
- cases in which the disclosure is necessary to respond to an emergency that
threatens the life, health or safety of the individual or another
individual;
- cases in which the disclosure is necessary for the prevention of crime or
legal proceedings;
- cases in which the purpose of such disclosure is clearly in the
individual’s interests, and if consent cannot be obtained in a timely way;
- cases in which the disclosure is necessary for any investigation or
proceedings;
- cases in which the disclosure is to any officer of a prescribed law
enforcement agency upon production of written authorisation signed by the
head or director of that law enforcement agency, or a person of a similar
rank, certifying that the personal data is necessary for the purposes of the
functions or duties of the officer; and/or
- cases in which the disclosure is to a public agency and such disclosure is
necessary in the public interest.
Information Not Requiring Consent
We may share anonymised information and statistics in aggregate form with
third parties for business purposes, for example with advertisers on our
website, or we may tell our business partners the number of customers in
certain demographic groups who purchased certain products or who carried out
certain transactions.
For the avoidance of doubt, in the event that we are permitted by law to
collect, use or disclose your personal data without your consent, such
permission granted by the law shall continue to apply.
4. LEGAL BASIS FOR DATA PROCESSING
We have introduced the purposes for processing personal data, the legal
basis for which include: to execute the contract between you and EVOLVEO
Porta (e.g. to provide you with the services you have requested, to conduct
identification and verification, in order for you to use our website); to
comply with legal requirements (e.g. to comply with applicable accounting
rules, to fulfill the requirement of compulsory disclosure from the law
enforcement); to safeguard our legitimate interests (e.g. to manage our
relationship with you, to ensure the security of our services, to
communicate with you about our products and services); and to build on the
consent of our clients (e.g. to use cookies, to share your information with
third parties for the purpose of advertising).
In some cases, you may need to provide us with your personal data for the
above-mentioned purposes, in order for us to offer the full range of
services and to facilitate the usage of all functions on our website.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Our business may call for transfer of personal data to countries outside the
European Economic Area, including China or Singapore. Appropriate measures
shall be taken to ensure that receivers of your personal data stick to their
confidentiality obligations and we make sure that we carry out measures such
as standard contract terms. Contact our support centre to find out about
these terms.
6. YOUR RIGHTS
According to applicable laws, you have the right to object to or request
limitations on our processing of your personal data, and to ask for access,
correction, deletion and portability of your data.
We may only use your information based on your consent. You are entitled to
withdrawal your consent at any time; however, it does not affect the
legitimacy for us to process the data we have collected with your permission
prior to your withdrawal.
You may make requests for withdrawal of account or withdrawal of consent to
privacy policy at the user centre on our app.
You may also send email to app@coolkit.cn to make requests on the processing
of your personal data.
In case you find changes or inaccuracies in your information, please notify
us of the changes so that we can update or correct the records. If you find
that our practices in relation to your personal data have breached certain
laws applicable, you have every right to file complaints to the regulatory
authority.
The duration of data retention will be determined by the services or
products that you have requested, or by the provisions or approval of
applicable laws, such as tax law and accounting law.
7. INFORMATION SAFETY SAFEGUARDS
We are committed to ensuring that your personal data is secure. In order to
prevent unauthorised access, disclosure or other similar risks, we have put
in place reasonable physical, electronic and managerial procedures to
safeguard and secure the information we collect. We have put in place the
following security procedures and technical and organisational measures to
safeguard your personal data:
- Your personal data is stored on secure servers that are protected in
controlled facilities.
- All data saved in the back-end is classified into different levels based
on the importance and sensitivity of the data, e.g. whether the data
contains personal data.
- In the data centres, clusters that contain sensitive data are grouped
together in the network topology, and will be placed in rooms with
additional physical security protection.
- Data exchanged between EVOLVEO Porta devices and servers are encrypted
using Secure Sockets Layer (“SSL”).
- There is an optional two-step verification process when users access their
EVOLVEO Porta Account.
- There is regular review of information collection, storage and processing
practices, including physical security measures, to guard against
unauthorised access to systems.
- Access is restricted to EVOLVEO Porta employees and Third Party Service
Providers who need to know that information in order to process it, and who
are subject to strict contractual confidentiality obligations and may be
disciplined or terminated if they fail to meet such obligations.
- There are also access controls for all server clusters used for
cloud-based data storage and process.
- Most data used for EVOLVEO Porta’s products and/or services is stored in a
storage system. By using column family based access control mechanism,
EVOLVEO Porta employees are only allowed access to the data column families
they are granted access to.
- Please note also that for the above, EVOLVEO Porta may use overseas
facilities operated and controlled by EVOLVEO Porta to process or back up
your personal data. Currently, EVOLVEO Porta has data centres in Beijing and
Singapore. As a result, we may transfer to and store your personal data at
our overseas facilities. However, this does not change any of our
commitments to safeguard your personal data in accordance with this Privacy
Policy.
Information safety is very important to us. We will take all practicable
steps to safeguard your personal data. Through our protective measures
above, especially encrypted storage and transmission, your data is as secure
as it can be. Certain details of encrypted data cannot be accessed by anyone
except by you.
If you have questions or concerns, please contact Consumer Services/Privacy: servis@evolveo.com