Xpert, its affiliates and subsidiaries (“we”,
“us”, “our”, Xpert) are committed to protecting your
privacy. This Privacy Policy describes our
practices in connection with information privacy on Personal
Data we process through your individual use of the following
services, products, and related mobile applications
(collectively, the “Products”):
• Xpert Smart Mobile Application
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. “Smart
Devices” refers to those nonstandard 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. “Apps” refers to those mobile applications
developed by Xpert that provide end users remote control
to Smart Devices and with the ability to connect to Xpert
IoT Platform.
What Personal Data do We Collect
In order to provide our 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 our
products or services.
1. Information You Voluntarily Provide Us
• Account or Profile Data: When you register an account
with us, we may collect your name and contact details,
such as your email address, phone number, user name, and
login credentials. During your interaction with our
Products, we may further collect your nickname, profile
picture, country code, language preference or time zone
information into your account.
• Feedback: When using feedback and suggestion features
in our Products, 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.
2. Information We Collect Automatically
• Device Information: When you interact with our
Product, we automatically collect device information,
such as the MAC address of your devices, IP address,
wireless connection information, operating system type
and version, application version number, push
notification identifier, log files, and mobile network
information.
• 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.
• Log Information: When you use our app, the system and
exception log may be uploaded.
• Location Information: We may collect information about
your real-time precise or non-precise geo-location when
you use our specific Products or Services, such as robot
cleaner and weather service.
3. Smart Devices Related Information:
• Basic Information of Smart Devices: When you connect
your Smart Devices with our Products or Services, we may
collect basic information about your Smart Devices such
as device name, device ID, online status, activation
time, firmware version, and upgrade information.
• Information Reported by Smart Devices: Depending on
the different Smart Devices you elect to connect with
our Products or Services, we may collect different
information reported by your Smart Devices. For example,
smart weights or fitness trackers may report your
height, weight, body fat mass (BFM), BMI and skeletal
muscle mass (SMM); smart cameras may report images or
videos captured by it.
Purposes and Legal Basis for Processing Personal Data
The purpose for which we may process information about you
are as follows:
• Provide You Services: We process your account and
profile data, device information, usage data, location
information, and Smart Device related information to
provide you with our Products and Services that you have
requested or purchased. The legal basis for this
processing is to perform our contract with you according
to our Terms of Use.,
• Improve Our Services: We process your device
information, usage data, location information and Smart
Device related information to ensure the functions and
safety of our Products, to develop and improve our
Products and 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 Terms
of Use.
• Non-marketing Communication: We process your Personal
Data to send you important information regarding the
Services, changes to our terms, conditions, and policies
and/or other administrative information. Because this
information may be important, you may not opt-out of
receiving such communications. The legal basis for this
processing is to perform our contract with you according
to our Terms of Use.
• Marketing Communication: We may process your Personal
Data to provide marketing and promotional materials to you
on our Products and Services. If we do so, each
communication we send you will contain instructions
permitting you to opt-out of receiving future
communications of that nature. The legal basis for this
processing is your consent. Additionally, if you consent
to participate in our lottery, contest or other
promotions, we may use your Personal Data to manage such
activities.
• Personalization: We may process your account and profile
data, usage data, device information to personalize
product design and to provide you with services tailored
for you, such as recommending and displaying information
and advertisements regarding products suited to you, and
to invite you to participate in surveys relating to your
use of our Products. The legal basis for this processing
is your consent.
• Legal Compliance: We may process your Personal Data as
we believe to be necessary or appropriate: (a) to comply
with applicable laws and regulations; (b) to comply with
legal process; (c) to respond to requests from public and
government authorities (d) to enforce our terms and
conditions; (e) to protect our operations, business and
systems; (f) to protect our rights, privacy, safety or
property, and/or that of other users, including you; and
(g) to allow us to pursue available remedies or limit the
damages that we may sustain.
If there is any change in the purposes for processing your
personal data, we will inform such change to you via email
and/or a prominent notice on our website of such changes
of purposes, and choices you may have regarding your
Personal Data.
Who do We Share Personal Data with?
At Xpert, we only share Personal Data in ways that we
tell you about. We may share your Personal Data with the
following recipients:
• To our third-party service providers who perform certain
business-related functions for us, such as website
hosting, data analysis, payment and credit card
processing, infrastructure provision, IT services,
customer support service, e-mail delivery services, and
other similar services to enable them to provide services
to us.
• To our customers and other business partners who provide
you, directly or indirectly, with your Smart Devices,
and/or networks and systems through which you access and
use our Sites and Services.
• To an affiliate or other third party in the event of any
reorganization, merger, sale, joint venture, assignment,
transfer or other disposition of all or any portion of our
business, assets or stock (including without limitation in
connection with any bankruptcy or similar proceedings). In
such an event, you will be notified via email and/or a
prominent notice on our website of any change in
ownership, incompatible new uses of your Personal Data,
and choices you may have regarding your Personal Data.
• As we believe to be necessary or appropriate: (a) to
comply with applicable laws and regulations; (b) to comply
with legal process; (c) to respond to requests from public
and government authorities, including public and
government authorities outside your country of residence;
(d) to enforce our terms and conditions; (e) to protect
our operations, business and systems; (f) to protect our
rights, privacy, safety or property, and/or that of other
users, including you; and (g) to allow us to pursue
available remedies or limit the damages that we may
sustain.
• To subsidiaries or affiliates within our corporate
family, to carry out regular business activities.
Except for the third parties described above, to third
parties only with your consent.
International Transfer of Information Collected
To facilitate our operation, we may transfer, store and
process your Personal Data in jurisdictions other than
where you live. Laws in these countries may differ from
the laws applicable to your country of residence. When we
do so, we will ensure that an adequate level of protection
is provided for the information by using one or more of
the following approaches:
agreement on the basis of approved EU standard
contractual clauses per GDPR Art. 46. For more
information, see
here.
If you would like further detail on the safeguards we have
in place, you can contact us directly as described in this
Privacy Policy.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal
Data. You may exercise any of the following rights:
• Via the “Profile – Personal Center” in our Products
You do not have to pay a fee and we will aim to respond
you within 30 days. 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.
You may:
• Request access to the Personal Data that we process
about you;
• Request that we correct inaccurate or incomplete
Personal Data about you;
• Request deletion of Personal Data about you;
• Request restrictions, temporarily or permanently, on our
processing of some or all Personal Data about you;
• Request transfer of Personal Data to you or a third
party where we process the data based on your consent or a
contract with you, and where our processing is automated;
• Opt-out or object to our use of Personal Data about you
where our use is based on your consent or our legitimate
interests.
Please be noted, if you put any limitation on our access, collection, transfer or dispose of your
Personal Data, part of all of the functions of our Products and services may be limited or disabled.
Security
We use commercially reasonable physical, administrative,
and technical safeguards to preserve the integrity and
security of your Personal Data. Xpert provides various
security strategies to effectively ensure data security
of user and device. As for device access, Xpert
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
cm@hansong-china.com.
Data Retention
We process your Personal Data for the minimum period
necessary for the purposes set out in this Privacy 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. 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.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to
our information practices, at least on an annual basis. If
we make any material change 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 question about our practices or this
Privacy Policy, please contact us as follows:
Xpert Technology.
Postal Mailing Address: 8th Kangping Road Jiangning Economy and Technology Development Zone,
Nanjing, China.