TUYO smart device
Privacy Policy
Welcome aboard!
You have purchased our TUYO smart device hardware and are
starting to use the TUYO smart device software and all its functionalities! Any
information you share with us (e.g., for creating a TUYO smart Account) will
help us to provide you with services related to TUYO smart devices 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 possible user experience.
What information is collected and how do we use it?
Types of Personal Data Collected
- 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.
- Set up and log in of a TUYO smart Account. Personal
data that are collected for creating a TUYO smart 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 TUYO smart products. When you make
purchases through the TUYO smart e-commerce website, we may collect your TUYO
smart Account ID (or mobile phone number or email addressed used to create
your TUYO smart Account), name, phone number, delivery address and order
details, etc. TUYO smart provides logistics services to deliver the
products purchased on the e-commerce website. TUYO smart has an after
sales system to handle after sales related matters as well as an after
sales center 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.
- Activating a TUYO smart device. When you activate
the TUYO smart device, we may collect your age, height, weight, and
gender. We may also collect other details you provide as part of your
profile such as your birthday, picture, and signature.
- Sync TUYO smart device data. When you synchronize
the TUYO smart device data (e.g., to TUYO smart device Cloud Service) we
may collect data relating to your activities and functionalities of TUYO
smart device, such as those obtained from our sensors and features on TUYO
smart device, your sleeping patterns, movement data and smart alarm
related information.
- Sharing your content. When you share content or
send information to family and friends, we may collect personal
information of those people, such as their names, email addresses,
telephone numbers, and mailing addresses (if we need to send a product to
them). You hereby represent and warrant that you have obtained necessary
consent for use of third parties’ personal data if you choose to provide
them to us. When you share content or invite users to use TUYO smart
device, please note that other users may see personal data you share.
- Processing the services. In providing the above
services, we may also collect data in relation to your device, including
your TUYO smart device ID, firmware version, device OS version, model and
system, and visiting IP and time.
How the Personal Data is used
- 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 personalize 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 TUYO smart
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 analyze the efficiency of our
operations
Other Information
We use statistical data that does not specifically identify
you (non-personal data) to help in our operations and improve our products and
services and provide a better user experience for you. Here are some of the
non-personal data we may collect and how we use them:
- When you create a TUYO smart Account, download our
software, register in our e-commerce website, participate in online surveys,
or interact with us in other ways, we may collect your language
preferences, postal code, area code number and time zone in which you use
our products and services, and your profession.
- When you opt-in to participate in our User Experience
Improvement Program, we may gather statistics relating to your use of our
products functions, on an anonymous basis. This may include information
relating to your use of our official website, products, and services. If
there is an abnormal shutdown or breakdown, we may collect information
relating to your mobile device to diagnose the problem.
- When you use our services or functions that are based on
location information (e.g., carry out a location search, take advantage of
advertising, use weather functions, access information based on maps, etc.)
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).
- When you first use and activate your TUYO smart device,
the device’s unique identification code and approximate geographical
information may be collected.
You have control over your information!
We recognize that privacy concerns differ from person to
person. Therefore, we provide examples of ways we make available for you to
choose to restrict the collection, use, disclosure, or processing of your
personal data and control your privacy settings, such as controlling the
settings under the User Experience Improvement Program, Location Access
functions, and your TUYO smart account.
Access, Updating or Correcting Your Personal Data
- You have the right to request access and/or correction of any
personal data that we hold about you. When you update your personal data,
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 or correction of your personal data, we shall process in
accordance with the laws of your country. While we try our utmost in
acceding to your requests, unreasonably repetitive or unrealistic requests
or those that put others’ privacy at risk may be declined.
- We normally provide such services for free but reserve the
right to charge a reasonable fee.
- 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 Email: support@TUYOsmart.com.
- For details relating to the personal data in your TUYO
smart Account, you may also request them at Email: support@TUYOsmart.com.
Withdrawal of Consent
- You may withdraw your consent for the collection, use
and/or disclosure of your personal data in our possession or control by
submitting a request. This may be done by sending your request at Email:
support@TUYOsmart.com. We will process your request within a reasonable
time from when the request was made, and thereafter not collect, use
and/or disclose your personal data as per your request.
- 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 data, it may mean
that you will not be able to enjoy TUYO smart’s products and services.
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 TUYO
smart will only share your personal data in accordance with your consent. You
should know that when TUYO smart shares your personal data with a third party
under any circumstance described in this section, TUYO smart 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. TUYO smart will
contractually ensure compliance by any foreign Third-Party Service Providers
with the privacy standards that apply in your home jurisdiction.
Disclosure to TUYO smart group companies and Third-Party
Service Providers
- In order to conduct business operations smoothly, the TUYO
smart entity which collects your personal data may disclose your personal
data from time to time to other TUYO smart 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 centers, 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 TUYO smart’s behalf or for one or more of the purposes listed above.
- Personal data will only be shared by TUYO smart to provide
or improve our products or services and will not be shared for use for
marketing purposes.
Disclosure to Others
TUYO smart 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 authorized
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 authorization
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 anonymized 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.
Information Safety Safeguards
We are committed to ensuring that your personal data 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. We have put in
place the following security procedures and technical and organizational
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 centers, 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 TUYO smart devices and servers are
encrypted using Secure Sockets Layer (“SSL”).
- There is an optional two-step verification process when
users access their TUYO smart Account.
- There is regular review of information collection, storage
and processing practices, including physical security measures, to guard
against unauthorized access to systems.
- Access is restricted to TUYO smart employees and Third-Party
Service Providers who need to know that the 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 TUYO smart’s products and/or services
is stored in a storage system. By using column family-based access control
mechanism, TUYO smart employees are only allowed access to the data column
families they are granted access to.
- Please also note that for the above, TUYO smart may use
overseas facilities operated and controlled by TUYO smart to process or
back up your personal data. Currently, TUYO smart has data centers 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.
When this Privacy Policy applies
Our Privacy Policy does not apply to products and services
offered by a third party. TUYO smart products and services may include third
party’s products or services. 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 data
which they collect from you. Our Privacy Policy does not apply to other sites
linked from our services.
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 data from minors or offer to send any
promotional materials to persons in that category. TUYO smart does not seek or
intend to seek to receive any personal data from minors. Should a parent or
guardian have reasons to believe that a minor has provided TUYO smart with
personal data without their prior consent, please contact us to ensure that the
personal data is removed and unsubscribe them from any of the applicable TUYO
smart services.
Updates to the Privacy Policy
We keep our Privacy Policy under regular review. If we
change our Privacy Policy, we will post the changes on all the TUYO smart
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 TUYO smart 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.