PRIVACY POLICY
Date of Publication: [May] [09], 2024
Effective Date: [May] [09], 2024
Ugreen is an intelligent device management platform provided by [Ugreen Group GmbH] (hereinafter referred to as "we" or "Ugreen"). We attach great importance to the security of your personal data and privacy protection. This policy aims to explain to you how we collect, use, store, share, and protect your personal data, as well as how you can exercise your rights. If you have any questions about this policy, you can contact us through the contact information at the end of this policy.
Users of Ugreen may come from all over the world. If you are a user from the European Economic Area (EEA), the state of California in the United States, or Japan, the special appendices for the respective regions after this policy also apply to you. In case of any conflict between the appendix and the main text, the provisions of the appendix shall prevail.
Before using our products or services, please carefully read and fully understand the contents of this policy, especially the bolded text.
I. How We Collect and Use Your Personal Data
The following are all the personal data collected by Ugreen's functions. For functions you do not use, we will not collect your personal data, and your consent to this policy does not involve functions you have not used. We will not use your personal data beyond the purposes disclosed in this policy.
1. Registration and Login
You can register and log in using your email. When registering, you need to provide us with the verification code received by your email.
For IOS System, You can also choose to register or log in through third-party applications (Facebook, Google, or Apple accounts), and we will collect your account information.
We collect your third-party account based on your consent. If you do not agree, you can browse as a guest.
2. Adding Devices
You can choose to add devices to Ugreen through Bluetooth scanning or manual methods. If you choose to add devices through Bluetooth scanning, we need to access the WIFI list and Bluetooth list to facilitate the connection between the device and Ugreen.
We collect this information based on your consent. If you do not agree, you can manually add devices.
3. Device Binding
When you bind a device, we will collect your device name, device ID, MAC address, SSID, and SSID password to confirm device information, identify device identity, and ensure device security.
We collect this information for the binding of your device, otherwise, the device cannot be bound to Ugreen.
4. Device Sharing and Reception
4.1 When you share a device with others, the recipient will be able to view your account, email, pictures of the device you shared, and device name for the recipient to confirm whether to accept the device you shared. After the recipient accepts the sharing, they can control the device on their mobile phone.
4.2 When you receive a device shared by others, the sharing party will obtain your avatar, nickname, and account name to facilitate viewing and managing device users.
5. Issue Feedback
If you encounter any problems while using the app, you are welcome to provide feedback to us. When providing feedback, you need to fill in the feedback content, feedback type, and optionally select the connected device (or provide the device SN code) and fill in the contact information. Selecting a connected device, the app will collect your device SN code, device model, and device MAC address to confirm device identity and ensure device security. You can also choose whether to upload pictures. The feedback content and feedback type are the information we need to understand and resolve the problem. Selecting a connected device or submitting a device SN code will help us locate the problem more accurately. By providing contact information, we may provide feedback on the handling of the issue. Uploading pictures will help us locate and resolve the problem.
We collect this information based on your consent, and not providing it will not affect your use of other functions.
6. Setting Avatar
You can use existing photos in your phone or take photos to set your personalized avatar, for which we will request access to your phone photos or camera.
We collect this information based on your consent, and not providing it will allow you to continue using the default avatar without affecting your use of other functions.
7. Selecting and Switching Countries (or Regions)
You can select or switch the country (or region) you are in on the login page, and we will switch servers accordingly, which will cause the logout of your existing account. If you have already bound devices on the current server, after switching servers, your bound devices and data will still be on the original server and cannot be accessed, and you will not be able to make settings in the application. We will remind you when you switch countries (or regions).
During use, we may request system permissions from your phone. You can click on the "System Permission List" to view the permissions requested by each function. We will only request the permission when you touch the corresponding function, and will inform you of the purpose of use before or during the request. You can choose whether to authorize it. At the same time, you can also click "My - Personal Data Protection - System Permission Management" to view the permissions you have opened and click to jump to the phone "Settings" to change the authorization.
II. How We Share Your Personal Data
When you share your device with others or accept devices shared by others, you will share information with each other. For details, please refer to "How We Collect and Use Your Personal Data - Device Sharing and Reception."
To ensure the stable operation of Ugreen and enable you to use and enjoy more services and functions, we embed third-party SDKs in the application. For the handling of your personal data by SDKs, please refer to the "Third-Party Information Sharing List"
In addition, we will not share your personal data with third parties (except with your consent).
III. The Legal Basis for Processing Your Personal Data
In addition to the legal bases already explained in "I. How We Collect and Use Your Personal Data," we may also process your personal data in the following cases without obtaining your consent:
1. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
2. Processing is necessary for compliance with a legal obligation to which we are subject;
3. Processing is necessary in order to protect the vital interests of you or another natural person;
4. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
5. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, particularly where the data subject is a child.
IV. How We Store Your Personal Data
We will store your personal data for the shortest period necessary to achieve the purposes stated in this privacy policy. After achieving the purposes stated in this policy, after we terminate the service, after you withdraw your consent to this policy, or after you cancel your account, we will delete your personal data. For specific content, please refer to "Your Rights - Cancel Your Account or Request Deletion of Your Personal Data."
The personal data collected and generated by us in mainland China will be stored in the People's Republic of China. Personal data collected outside mainland China will be stored on servers closer to your local area. For information on data cross-border transfers, please refer to the following section.
V. How Your Personal Data Will Be Transferred Globally
We have multiple servers worldwide, and your personal data will be stored on servers closer to you for your quick access to your account information. Data on each server is not shared, which is why you need to re-register your account when switching countries or regions.
Our operational and maintenance team comes from our Chinese company, LULIAN GROUP LIMITED. To assist you in managing your account, devices, after-sales, and maintenance issues encountered during the use of the app, our Chinese employees may access the personal data as stated in "1. How We Collect and Use Your Personal Data". We have taken a series of measures to protect the security of your personal data, including implementing data protection impact assessments and signing SCCs as required by applicable laws. We also strictly limit the purposes for which your personal data can be used, only for operational and maintenance purposes. We strictly limit access to data by position and restrict the data accessed by each position to the minimum necessary for the responsibilities of that position. Additionally, for specific types of data such as your registered email, we have implemented measures to make it "available but not visible".
If you need to inquire further about the SCCs we have signed, please feel free to contact us via support@ugreen.com
VI. How We Protect Your Personal Data
We attach great importance to the security of your personal data. To ensure the security of your personal data, we have taken technical measures such as encrypted transmission, secure storage, intrusion detection, firewall protection, and regular security vulnerability scanning. We have implemented a data security management system and ensured that our relevant employees receive personal data protection training.
We fully recognize that there is no flawless system. Therefore, we continuously strive to identify and manage potential risks, take preventive measures to reduce the risks of your personal data being disclosed, lost, tampered with, or accessed without authorization. In the event of a security incident, we will follow clear procedures and response mechanisms for handling, including taking timely remedial measures, notifying regulators and affected users, and taking measures to prevent similar incidents from occurring.
Please understand that despite our reasonable technical and managerial measures and compliance with relevant legal requirements, you should take active measures to ensure the security of personal data, such as setting complex passwords, regularly changing account passwords, etc., and do not disclose account password information to others.
VII. How to Exercise Your Right to Manage Personal Data
For your personal information, you have the following rights:
1. Inquire and Copy Your Personal Information
2. Correct and Supplement Your Personal Information
3. Transfer Your Personal Information to a Designated Third Party (or the Right to Portability under GDPR)
4. Change the Scope of Your Consent or Withdraw Consent
5. Cancel Your Account or Request Deletion of Your Personal Information
6. Refuse Automated Decisions
7. Refuse Direct Marketing (or Commercial Advertisements Sent to You Personally)
8. Complaints and Lawsuits
We provide the following ways for you to exercise your rights:
1. Inquire and Copy Your Personal Information
You can inquire about your avatar, nickname, account, and associated third-party accounts through the "My - Click Avatar" path. Under "My - Sharing Management," you can inquire about devices you have shared with others and devices you have received. For inquiries about other personal information, you can contact us via the email address provided at the end of this policy.
2. Correct and Supplement Your Personal Information
If you find that your personal information is incorrect or incomplete, you can contact us through the "My - Issue Feedback" path to make changes or supplements.
3. Transfer Your Personal Information to a Designated Third Party (or the Right to Portability under GDPR)
Subject to the conditions required by applicable laws and regulations, you have the right to transfer your personal information to a designated third party. You can contact us using the information provided in the "How to Contact Us" section of this policy to exercise your rights.
4. Change the Scope of Your Consent or Withdraw Consent
You can go to "My - Personal Data Protection - System Permission Management" to jump to the "Settings" page of your phone to change the system permissions you have authorized. You can also click on "My - Personal Data Protection - Withdraw Consent" to withdraw your consent to this privacy policy. After withdrawing consent, you will not be able to continue using the application. We will no longer collect and process your personal information and will delete the personal information collected. However, this will not affect our processing of your personal information prior to the withdrawal of consent.
5. Cancel Your Account or Request Deletion of Your Personal Information
You can cancel your account by going to "My - Account Security" .Before canceling, we will verify your identity. We will delete your personal information within 15 days after you submit the cancellation request.
If you have other deletion requests, you can contact us using the contact information provided in the "How to Contact Us" section of this policy.
Please note that after canceling your account, withdrawing consent, or exercising the right to deletion, not all of your personal information will be deleted. We will only delete it when the conditions for deletion specified by law are met. Situations in which deletion may not occur include (1) not reaching the minimum statutory retention period; (2) when deletion of personal information is technically difficult (such as when your data is archived in the backup system, but we will stop processing other than storage and take necessary security measures until it is anonymized or deleted).
6. Regarding Refusal of Automated Decisions
The application currently does not use automated decision-making technology.
7. Refuse Direct Marketing (or Commercial Advertisements Sent to You Personally)
Direct marketing refers to commercial entities sending commercial information directly to you by means such as mail, telephone, or sending brochures. We will not send you direct marketing information without your consent. After receiving direct marketing information, you can also unsubscribe, opt-out, or refuse according to the content prompted by the information.
8. Complaints and Lawsuits
If you are dissatisfied with our handling of your above requests or our processing activities, you have the right to complain to the regulatory authority or file a lawsuit in a court with jurisdiction. To obtain complaint channels in different countries or regions, you can contact us using the contact information provided at the end of this policy.
When you exercise these rights with us, to prevent identity theft, we will promptly accept and process your requests after verifying your identity. You can also request us to explain the contents of this policy through this email.
If you, as a close relative of the deceased, request to inquire, copy, correct, or delete personal information of the deceased, depending on the actual situation, you need to provide identity documents, death certificates of the deceased, proof of
your relationship with the deceased, and other materials. We will only use this information to verify your identity and process your request, and will not process any other personal information.
We will respond to your request within the time limit stipulated by law. If the information requested by you exceeds a reasonable range, requires excessive technical means (such as developing a new system or fundamentally changing existing practices), may harm the legitimate rights and interests of others, or is very impractical (such as requiring information stored on backup tapes to be extracted), we may refuse to fulfill your request in accordance with legal requirements and explain the reasons.
VIII. Updates to This Policy
We may update this policy from time to time. When the updated policy is released, we will provide a prompt within the application, and you can also view the updated content through the "My - Personal Data Protection - View Privacy Policy" path. If the update is a material change, we will also notify you through the official website, official blog, community forum, email, or push notification. By continuing to use our services, you agree to be bound by the updated policy.
IX. How to Contact Us
If you have any questions, comments, or suggestions about this policy or our privacy practices, or if you need to exercise your rights related to personal information protection, you can contact us through the following methods:
Email: [support@ugreen.com]
Address: Mannheimer Str.13, 30880 Laatzen]
[Ugreen Group GmbH] reserves the right to interpret and modify this policy to the extent permitted by law.
ADDITIONAL POLICY FOR CALIFORNIA RESIDENTS
If you are located in California, the provisions in this section supplement those in this Policy.
The California Consumer Privacy Act of 2018 and the California Privacy Rights Act (CPRA), as amended, along with their implementing regulations (collectively referred to as the "CCPA"), grant California residents specific rights regarding their personal information. This section details your rights under the CCPA and how to exercise them.
1.Your Personal Information Rights
(1)Right to Know of the Collection, Disclosure, and Sale of Your Personal Information
California residents are entitled to request that a business collecting their personal information disclose the following:
①Categories, purposes, and sources of personal information collected in the past 12 months;
②Specific personal information collected in the past 12 months;
③Types of personal information disclosed for commercial purposes in the past 12 months.
You are entitled to submit up to two free, verifiable consumer access or data portability requests to us within a 12-month period.
2.Right to Request the Deletion of Personal Information
California residents are entitled to request businesses delete any personal information they have collected, subject to exceptions as outlined in the CCPA. We will provide a clear base for any denied requests for deletion.
3.Right to Limit Use of Sensitive Personal Information
You have the right to limit the use of your sensitive personal information for any purpose, except as provided under Section 7027 (m) of the CCPA.
4.Right to Opt-Out of the Sale of Personal Information
We do not, nor have we in the past 12 months, sold any personal information we have collected.
5.Right to Non-Discrimination
UGREEN will not discriminate against individuals exercising their rights under the CCPA.
These rights are not absolute, and in some cases, we may be legally required or permitted not to fulfill your request.
If you are under 18 years of age and have a registered account, you may request that we remove content or information that you have posted on the Site or stored on our servers by submitting a written request as indicated in the "CONTACT INFORMATION" section below and clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.
ADDITIONAL POLICY FOR INDIVIDUALS IN THE EEA
This section applies only to individuals who access or use our Services while located in the European Economic Area.
The controller for the processing described in this Privacy Policy is 【Ugreen Group GmbH】 . You can contact our Data Protection Officer or DATAREP at 【support@ugreen.com】 .
In addition to the rights mentioned in the main text, you also have the right to restriction of processing.
We may process your personal information on the Lawfulness without your consent:
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freed.We also may extend the period for which we retain your personal data for public interest, scientific, historical research or statistical purposes.
We will protect your personal data in accordance with the Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect the personal data concerned in accordance with applicable laws.These steps include implementing the European Commission's Standard Contractual Clauses for the transfer of personal data to our service providers and business partners located in countries that are not considered by the EU to provide an adequate level of data protection.
ADDITIONAL POLICY FOR INDIVIDUALS IN JAPAN
In addition to the rights in the main text, Ugreen Group GmbH is the controller of your personal information, personal related information, pseudonymized personal information and anonymized information , you can require us to stop using your personal information in the case of meeting the Japanese laws and regulations, and if your personal information out of the country, we will obtain your consent in advance (except for the country or or other regions such as the European Union and the United Kingdom, etc., which have obtained the recognition).
