Privacy Policy

Our Privacy Policy was updated and became effective on September 20, 2020. In this Privacy Policy, we have deleted the description of the information that will no longer be collected based on our business needs and have optimized some of the text. If you no longer wish to use our services, you can request your account to be deleted by sending an email to privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the General Data Protection Regulation (GDPR) or a Russian user under the Russian Federal Law on Personal Data or applicable laws).

As of the effective date, in addition to the privacy policies separately developed for our specific products or services, this Privacy Policy provides details on how we protect the privacy of your personal information disclosed when you use the Roborock app ("App"). Please take some time to familiarize yourself with our privacy practices. If you have any questions, you can contact us by sending an email to privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws).

Our Commitments to You

This Privacy Policy explains how Beijing Roborock Technology Co., Ltd. and its affiliates ("Roborock", "we", "us", or "our") collect, use, disclose, process, and protect the information you provide to us when using the App. If we ask you for certain information to verify your identity when you use Roborock products and services, we will use such information in strict accordance with this Privacy Policy and/or our User Agreement.

This Privacy Policy has been designed with you in mind, and it is important that you have a full understanding of our personal information collection and usage practices and feel assured that you have ultimate control over your personal information provided to Roborock.

In this Privacy Policy, "personal information" means any information that can be used alone or in combination with other information about an individual to which Roborock has access to identify that individual, including but not limited to information you provide and information about your mobile device.

By using the App, you agree and acknowledge that you have read and accept all of the terms of this Privacy Policy, including any changes that we may make from time to time. To comply with applicable laws, including local data protection legislation (such as the GDPR and the Russian Federal Law on Personal Data), we will specifically seek your prior explicit consent to the processing (such as automated decision-making) of special categories of personal information. Furthermore, we are committed to protecting the privacy, confidentiality, and security of your personal information in accordance with applicable laws, and we are equally committed to ensuring that all of our employees and agents comply with these obligations.

Our ultimate goal is to provide the best experience for all users. If you have any questions about the data processing practices described in this Privacy Policy, you can contact us by email at privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws) so that we can process your special requests. We are happy to deal with your questions directly.

What Information We Collect and How We Use It

Types of information collected

To provide you with our services, we will ask you for your personal information that is necessary for the provision of these services. If you do not provide your personal information, we may be unable to provide you with our products or services.

To help you a have a better understanding of this Privacy Policy, some common terms used in this Privacy Policy are defined as follows:

"Mobile device" refers to any mobile device on which the App runs, such as a mobile phone or tablet.

"Device" refers to any smart hardware device that can be connected to the IoT platform via the App, such as the Roborock Vacuum Cleaner.

We will only collect information that is necessary for specific, explicit, and legitimate purposes and will not further process it for any other purposes. We may collect the following types of information (which may or may not be personal information):

How personal information can be used

We collect your personal information to provide you with our products and/or services and ensure that we comply with applicable laws. You hereby agree that we may process your personal information and disclose your personal information to our affiliates and third-party service providers (as defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

More details on how we use your information, possibly including your personal information, are provided below:

With whom we share your information

We will not sell any personal information to third parties.

We may sometimes disclose your personal information to third parties (as defined below) to provide the products or services that you have requested.

Disclosure may be made to third-party service providers and affiliates listed in this section below. In each case described in this section, you can be assured that Roborock will share your personal information only with your authorization. Your authorization granted to Roborock also applies to sub-processors which process your personal information. You acknowledge that when Roborock shares your personal information with a third-party service provider under any circumstance described below, Roborock will contractually specify the practices and obligations of such third party in accordance with applicable local data protection laws. Roborock will contractually ensure compliance by third-party service providers with the privacy standards that apply to them in your jurisdiction.

Sharing information with our affiliates and third-party service providers

In order to operate smoothly by providing you with all of the features of our products and services, we may disclose your personal information to our affiliates (in connection with manufacturing, product sales, or after-sales service) or our third-party service providers (such as our mailing service providers, delivery service providers, telecommunications companies, data centers, data storage facilities, technical support and customer service providers, and IoT service providers). Such third-party service providers may process your personal information on behalf of Roborock or for one or more of the purposes described above. If you no longer wish to allow us to share this information, you can request us to delete your account by sending an email to privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws), or you can stop us from sharing it by withdrawing your authorization (as described below).

Information not requiring consent

For the avoidance of doubt, Roborock will collect, use, or disclose your personal information without your consent only to the extent it is allowed explicitly under local data protection laws.

Security safeguards

Roborock's security measures

We are committed to ensuring that your personal information is secure. To prevent any unauthorized access, disclosure, or other similar risks, we have put in place reasonable physical, electronic, and managerial procedures to secure the information we collect from your mobile device or the Roborock website. We will use all reasonable efforts to safeguard your personal information.

All of your personal information will be stored on a secure server and protected in a controlled facility. We classify your data based on importance and sensitivity, and ensure that your personal information is provided with the highest level of security. We ensure that our employees and third-party service providers who access this information to help provide you with our products and services are bound by strict contractual confidentiality obligations, and that if they fail to perform these obligations, they will be disciplined or terminated. Moreover, we have implemented access controls specifically for cloud-based data storage. All in all, we will regularly review our information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access or use.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the internet is not entirely secure. Therefore, we cannot guarantee the security or integrity of any personal information which is transferred via the internet.

We will promptly notify the competent regulatory authority of any leakage of personal information, and in some special circumstances, we will notify the data subject of any data leakage in order to comply with applicable laws, including local data protection regulations.

What you can do

Retention policy

Your personal information will be retained for as long as necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. As soon as it is reasonable to assume that any personal information is no longer necessary for the purpose for which it was collected, we will no longer retain that personal information, or will eliminate the means by which it can be associated with the specific individual. Roborock will continue to retain any data which will be further processed solely for achieving purposes in the public interest, scientific or historical research purposes, or statistical purposes, even if the further processing of such data has nothing to do with the purpose for which it was collected.

Accessing other features on your mobile terminal

Our App may access certain features on your mobile device, such as the Wi-Fi network status. This information is used to allow the App to run properly on your mobile device and allow you to interact with it. You can withdraw your authorization at any time by closing the App on your mobile device or by contacting us at privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws).

You have control over your information

Roborock recognizes that privacy concerns differ from person to person. Therefore, we have provided some examples to show how you can restrict the collection, use, disclosure, or processing of your personal information and control your privacy settings.

Deleting information

You can delete all of your personal information from the App in the following way:

You can delete your cached personal information from the App by selecting "Clear Cache" in the App.

In addition, if you wish to have your personal information stored on our server deleted, you can contact us at privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws). After receiving your request and verifying your identity, we will delete the information within the specified period of time.

If you have previously agreed to our use of your personal information for the purposes mentioned above, you can change your decision at any time by contacting us in writing or via email at privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws).

Accessing, updating, or correcting your personal information
Withdrawing your consent

Transferring Your Personal Information Outside of Your Jurisdiction

If we need to transfer your personal information outside of your jurisdiction, either to an affiliate or a third-party service provider, we will do so in accordance with applicable laws. In particular, we will ensure that all transfers comply with the requirements imposed by applicable local data protection laws by putting in place appropriate safeguards.

Roborock uses its own facilities and the facilities of cloud service providers worldwide to process and back up your personal information. Currently, Roborock itself has set up, or has appointed cloud service providers to set up, data centers in China, Germany, Russia, and the United States. The jurisdictions in which these global facilities are located may or may not provide data protection laws that are similar to those in your jurisdiction. We may transfer and store your personal information overseas after we have obtained your prior explicit consent and your thorough understanding of the risks associated with a lack of applicable laws and appropriate safeguards. However, this will not change any of our commitments to protecting your personal information in accordance with this Privacy Policy. If you are a European Union user under the GDPR, your personal information will be stored on the server in Germany. If you are a Russian user under the Russian Federal Law on Personal Data or applicable laws, your personal information will be stored on the server in Russia.

Miscellaneous

Minors
Order of precedence

If you have agreed to any applicable User Agreement which is inconsistent with this Privacy Policy, this Privacy Policy shall prevail.

Updates to this Privacy Policy

We will regularly review this Privacy Policy and may update it to reflect any changes to our information practices. We will notify you of any material changes to this Privacy Policy via your mobile device so that you understand what information we collect and how we use it. Such changes to this Privacy Policy shall apply as of the effective date set out in the notice. We encourage you to regularly view this page to keep updated on our privacy practices. Your continued use of the App will be deemed as your acceptance of the updated Privacy Policy. We will once again seek your consent before we collect more personal information from you or if we wish to use or disclose your personal information for any additional purposes.

Do I have to agree to any third-party terms and conditions?

Our Privacy Policy does not apply to products or services offered by any third party. The App may contain third-party products and services, as well as links to third-party websites. When you use such products or services, they may collect your information. For this reason, we strongly recommend that you read the third party's privacy policy, just as you have taken time to read ours. We are not responsible for the use of your personal information collected from you by any third party, nor do we have control over such use. Our Privacy Policy does not apply to other websites linked from our services.

Our Systematic Approach to Managing Your Personal Information under the GDPR

If you are a European Union user under the GDPR, Roborock will adopt a systematic approach to protecting your personal information and make full use of our personnel, management processes, and information systems to apply a risk management mechanism. Under the GDPR, (1) Roborock has appointed a Data Protection Officer (DPO) to take charge of data protection (email address: dpo@roborock.com); (2) Roborock implements appropriate management processes, such as data protection impact assessment.

Contact us

If you have any comments or questions about this Privacy Policy, or if you have any questions regarding Roborock's collection, use, or disclosure of your personal information, please contact us at the following address and reference our Privacy Policy:

Beijing Roborock Technology Co., Ltd.

Suites 6016, 6017, and 6018, 6/F, Building C, Kangjian Baosheng Plaza, No. 8 Heiquan Road, Haidian District, Beijing, P.R. China

Email address: privacy@roborock.com (or privacy@roborock-eu.com if you are a European Union user under the GDPR or a Russian user under the Russian Federal Law on Personal Data or applicable laws)

Thank you for taking the time to understand our Privacy Policy.