Privacy Policy

 

Our Privacy Policy was updated on 29 April 2019 and will take effect on 29 April 2019. If you no longer want to use our service, you can cancel your account by sending an e-mail to privacy@roborock.com (if you are an European Union user of the General Data Protection Regulations, please send e-mail to privacy@roborock-eu.com).

Beginning with this effective date, in addition to the privacy policy provided separately for our specific products or services, this privacy policy will provide privacy details about how we manage the personal information you disclose when using Roborock APP (hereinafter referred to as "APP"). Please take some time to familiarize yourself with our privacy practices. If you have any questions, please send an e-mail to privacy@roborock.com (if you are an European Union user of the General Data Protection Regulations, please send e-mail to privacy@roborock-eu.com) to let us know.

Our commitment to you

This Privacy Policy stipulates how Beijing Roborock Technology Co., Ltd. and its affiliated companies ("Roborock" or "We") collect, use, disclose, process and protect the information provided to us when you use APP. If we ask you to provide some information in order to verify your identity when using roborock technology products and services, the information will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to Roborock.

In this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Roborock has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, mobile terminal or SIM card related information, location information, etc.

By using Roborock products and services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e.g. General Data Protection Regulation in Europe Union), we will specifically seek prior explicit consent to the particular processing (e.g. automated individual decision-making) of special categories of personal data. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact us through privacy@roborock.com (if you are an European Union user under the General Data Protection Regulations, please use privacy@roborock-eu.com) so that we can handle your special needs. We will be happy to address them directly.

What information is collected and how we can use it

Types of information collected

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

·  Information you provide or upload (including your contact information): we may collect personal information you provide to us, such as your mobile phone number or feedback sent, etc. Since the mobile phone number is an important information for you to log on to APP, the information will always be stored in the mobile terminal running the APP. If you want to delete the information, you can choose to cancel the account. For the method of canceling the account, you can refer to "Delete Information" below.

·  Mobile terminal or SIM card related information: we may collect mobile terminal related information running APP, such as system version, language settings, mobile terminal manufacturer information and model name. Although authorization for the use of your IMSI information will be sought during the APP installation phase, we will not collect this information. We may also collect information about devices bound to your account, such as MAC address, DID (hardware serial number of smart devices), device network status (IP/network signal), firmware version, and MAC address of routers connected to devices.

·  Location information (only for specific services/functions): various types of information related to your location, such as regional and country codes. Although the authorization to use GPS information will be sought during the APP installation phase, we will not collect your GPS information.

·  Login information: related information for you to log in APP and the website, including: IP address, network request information, temporary message history, standard system log and system crash information.

·  Account vouchers: information about your account vouchers, such as password, token, etc.

·  Ordre Information : if you use Roborock to purchase goods online, we may collect information about the goods or services you use to purchase. For example, goods purchase record, after-sales service record, payment record, receiving address record, customer service voice call record, online conversation record, user evaluation record, etc.

How the personal information can be used

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies and Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

·  Providing, processing, maintaining, improving and developing our goods and/or services to you, including services on your device or through our APP.

·  Communicating with you about your device, service or any general queries, such as updates, device firmware/software upgrades, customer inquiry support, information about our events, notices.

·  Carrying out marketing related activities, such as providing marketing and promotion related information and updates. For more information on marketing and promotional activities, please see the following section entitled "Direct Marketing".

·  To analyze and develop statistics related to the use of our products and services in order to improve our products and services.

·  Storing and managing your related information for our business operation and legal duty.

·  Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information):

·  Create your roborock account. The mobile phone numbers collected when creating accounts through a web page or your mobile terminal are used to create your personal accounts and information pages.

·  Improve products and services. We use the relevant information of your mobile terminal to analyze and develop statistics related to the use of our products and services in order to improve our products and services.

·  Guarantee the realization of basic functions of APP and device. We collect your login information in order to ensure the realization of the basic functions of APP, and collect the information of related devices with account binding in order to ensure the realization of the basic functions of the device.

·  Provide location-based services. When using the device added by APP, we may use location information to judge the time zone of the device, so as to ensure the regular cleaning function of the device can be used normally.

·  When adding devices, you need to use WiFi to scan connectable devices near mobile terminals by acquiring GPS authorization.

·  Device access. When the device needs to connect to the network, setting up the corresponding network through APP is needed. This process requires you to enter the corresponding WiFi name and password. This information is only used in the device distribution network. You can always delete your WiFi name and password by resetting the device. At the same time, we need to determine the IP and network signals to select the optimal networking mode for device to ensure the stability of networking.

·  Device status display. It allows you to view the status of the device remotely so that you can view the online status of the device at all times.

·  Provide push service. Accounts and cell phone numbers will also be used to provide push services to send device notifications and operational messages to users.

·  Verify user identity. App uses passwords to authenticate users to ensure that hackers or unauthorized personnel cannot log in.

·  Maintain landing status. Token is used to help users maintain login status, and no login information needs to be re-entered after exit from APP.

·  Collect user feedback. The feedback you choose to provide is invaluable in helping us improve our service. In order to track the feedback you provide, the feedback will be retained on the server side.

·  Processing your order. Information related to E-Commerce orders can be used to process orders and related after-sales services, including customer support and re-shipment. In addition, the order number will be used to cross-check the actual delivery of orders and packages from delivery partners. Recipient information, including name, address, telephone number, etc., will be used for delivery. The list of items purchased is used to print invoices and enable customers to identify items in packages.

Direct Marketing

We may use your telephone number, roborock account and so on to provide you with the promotion information of roborock technology products and services. We strictly abide by your local data protection law (some laws may require independent explicit permission), so we will only confirming that we have obtained your consent or that you have no objection. If you do not want to receive any more promotional messages, please send an e-mail to privacy@roborock.com (if you are an EU user under the General Data Protection Regulations, please contact us by using the e-mail privacy@roborock-eu.com). We will not send your personal information to our business partners for direct marketing.

With whom we share your information

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that Roborock will only share your personal information in accordance with your consent. Your consent to Roborock will engage sub-processors for the processing of your personal information. You should know that when Roborock shares your personal information with a Third Party Service Provider under any circumstance described in this section, Roborock will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Rebook will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Sharing with our group and third party service providers

From time to time, in order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other Roborock affiliated companies (which involve manufacturing, product sales, after-sales services, etc.), or our third party service providers (our mail stores, delivery service providers, telecommunications companies, data centers, data storage facilities, technical support, customer service providers, advertising and promotion service providers, IOT service providers [affiliates and/or other third parties] (collectively referred to as "third-party service providers"). Such Third Party Service Providers would be processing your personal information on Roborock’s behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this information, please send an e-mail to privacy@roborock.com (if you are an European Union user under the General Data Protection Regulations, please send an e-mail to privacy@roborock-eu.com).

Information not requiring consent

·  For the avoidance of doubt, Roborock may collect, use or disclose your personal information without your consent if it is and 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. In order to prevent unauthorized 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 on your mobile device and on Roborock’s websites. We will use all reasonable efforts to safeguard your personal information.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and 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, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

We will take upon the personal data breach, notifying the breach to relevant supervisory authority or under some circumstances, notifying the personal data breach to the data subjects by complying with applicable laws, including your local data protection legislation.

What you can do

·  You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you.

·  Roborock cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.

·  Your assistance will help us protect the privacy of your personal information.

Retention policy

Personal information will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by Roborock even if the further processing is incompatible with original purposes.

Accessing other features on your device

Our applications may need access to certain features on your device, such as WiFi network status and some other features. This information is used to allow the APP to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the APP or contacting us at privacy@roborock.com.If you are Europe Union user under the General Data Protection Regulation, please contact the privacy@roborock-eu.com

You have control over your personal information

Roborock recognizes that privacy concerns differ from person to person. Therefore, we provide some examples to describe the ways in which we can help you restrict collection, use, disclosure or processing of your personal information and control your privacy settings.

Delete information

Delete all your personal information by following operation:

You may delete all your information by clicking “Clear Data” button in the APP,to delete all your personal information from APP.

Furthermore, If you want to delete all personal data in our servers, please contact privacy@roborock.com (If you are Europe Union user under the General Data Protection Regulation, please contact the privacy@roborock-eu.com).We will delete the data after receiving the request and confirming your identity.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at privacy@roborock.com.( If you are  Europe Union user under the General Data Protection Regulation, please contact the privacy@roborock-eu.com)

Access, update, correct, erase or restrict processing your personal information

·  You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

·  A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

·  If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the email address below. Email: privacy@roborock.com. ( If you are  Europe Union user under the General Data Protection Regulation, please contact the privacy@roborock-eu.com

·  If you are Europe Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.

·  If you are Europe Union user under GDPR, you have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.

·  If you are Europe Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

·  If you are Europe Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

Withdrawal of consent

·  You may withdraw your consent at any time for the collection, use and/or disclosure of your personal information in our possession or control by clicking the “Withdraw Consent” button in the APP Mine – About us – User agreement and Privacy policy.We shall stop the collection of your personal information when you withdraw the consent ,  and thereafter not use and/or disclose your personal information.

·  Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy Roborock’s products and services.

Transfer of personal information outside of your jurisdiction

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards.

Roborock uses its own operations and global facilities of cloud service providers to process and back up personal information. At present,Roborock  has its own or commissioned cloud service providers with data centers in China, Germany and the United States., These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities when you consent. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy. If you are Europe Union user under the General Data Protection Regulation, your personal information will store in the Germany’s Server.

Miscellaneous

Minors

·  We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.

·  Roborock does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided Roborock with personal information without their prior consent, please contact privacy@roborock.com. ( If you are  Europe Union user under the General Data Protection Regulation, please contact the privacy@roborock-eu.com)  to ensure that the personal information is removed and the minor unsubscribes from any of the applicable Roborock services.

Order of precedence

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, suchPrivacy Policy shall prevail.

Updates to the privacy policy

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you through our mobile devices, 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 effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

 

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

Our Privacy Policy does not apply to products and services offered by a third party. Roborock products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

 

About our systematic approach to manage your personal information

If you are Europe Union user under GDPR, Roborock will provide systematic approach to protect personal data and deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) Roborock set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is dpo@roborock.com; (2) procedure like data protection impact assessment (DPIA).

 

Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to Roborock’s collection, use or disclosure of your personal information, please contact us at the address below referencing “Privacy Policy:

 

Beijing Roborock Technology Co., Ltd.

Room #6016, #6017, #6018, Building C Baosheng Square, Heiquan Road

Haidian District

Beijing, China

Email: privacy@roborock.com ( If you are  Europe Union user under the General Data Protection Regulation, please contact the privacy@roborock-eu.com)

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