PRIVACY POLICY

Preface

BOTSLAB Network of Things Products (hereinafter referred to as BOTSLAB Products or this product) is a network of things product used to control smart hardware devices via the BOTSLAB APP. The product is provided by BOTSLAB INC. and its related company (hereinafter referred to as we or the Company), and is composed of smart hardware devices and a mobile terminal application ( i.e. BOTSLAB APP).

Network of things smart devices are BOTSLAB brand smart hardware devices and smart hardware devices from other third-party brands that can be connected to BOTSLAB APP, such as BOTSLAB smart camera and BOTSLAB smart doorbell (hereinafter referred to as network of things devices). BOTSLAB APP refers to the app that could control network of things devices after the device is binded to  it (hereinafter referred to as BOTSLAB APP).

Thank you for trusting us! We know by heart that your personal information is of high importance and understand that effective protection of your personal information is the cornerstone of the healthy and sustainable development of our business. We would like to express our gratitude for using and trusting our product and service. We are aware that this trust didn’t come easy, and therefore upholding the principle of openness and transparency, we hereby publish our rules and practices of handling your personal information. We will handle your information abide the law, in an appropriate manner, and only for a clear and reasonable purpose. We will cherish the trust you place on us by abiding by established safety standards in the business and adopting corresponding safety measures when protecting your personal information.

We hope to make our approach in dealing with your personal information and information related to network of things products clear to you while you are using this product as well as controlling this product through BOTSLAB APP via this Privacy Policy (hereinafter referred to as this policy). We promise to protect the privateness, confidentialness and safety of your personal information in compliance with applicable laws (including data protection laws in your region). To fully comply with applicable laws, such as the General Data Protection Regulations (GDPR) of the European Union, we will ask for your explicit consent for dealing with a particular type of personal information. When compiling this Privacy Policy, we have fully considered your needs, you will fully understand our extend and practices of us collecting and using your personal information, and you will be assured that you have the ultimate control of the personal information you provide to BOTSLAB, which is of crucial importance. Before using the product, please read through this policy carefully, and only use the product after you have understood and agreed with this policy. Once you have started using this product, it means that you have fully understood and agreed to this Policy, and agreed that we handle your relevant information in accordance with this policy. If you have any doubts, objections or suggestions regarding this policy, please contact us with the various contact methods provided in this policy.

I. How we use and process your personal data

We will use and process your personal data in accordance with this policy, and we will ask for your permission with compliance technology. In the meantime, for sensitive information, we will proactively adopt encrypted transmission and storage so that your personal data will be safe. Our purposes and uses for collecting and using your data are listed as follows:

1). To support the core functions of BOTSLAB products

Core functions are basic functions that support the normal operation of this product and the APP. Without your consent of us accessing and using essential personal information that is needed for us to provide the service, this product cannot be used.

1. Data acquired through registration information When you have installed the BOTSLAB APP on your cellphone that is connected to this product, you need to register or log in the APP before start using it. During the registration, we will collect your mobile phone number, email address, user name, non-plaintext password. Collecting this sort of data is for helping you finish registration and protect the safety of your account. Without your consent of providing the aforementioned information, you might not be able to register for the BOTSLAB APP successfully. You can go to 【My->Account Management】 to upload, fill in or change your profile picture, nickname, and password. Once you close your BOTSLAB APP, we will stop using and delete the said information, or will anonymize your personal data, unless otherwise required by laws and regulations.
2. Devices binded to the network of things After logging into the BOTSLAB APP, you can connect and bind devices to the BOTSLAB APP by going to 【Family->Add Device】 The authenticity of devices connected to the network of things via the BOTSLAB APP needs to be verified. Therefore, we will need to confirm the legal identity of the BOTSLAB APP device by checking the out-of-factory MAC, SN, and DIDI so that we could get the information of the hand-held terminal, such as the network type, mobile phone model, brand, system version, language, country and time zone. The information is used in troubleshooting and also for displaying the current time. When network of things devices need to access the Internet, it needs to retrieve your location information so that it can acquire your WIFI list and then conduct corresponding network configuration through cloud smart connection. You need to input the Wi-Fi name the password. The said information is only used when network of things devices are pairing. The Wi-Fi and password data will be encrypted and stored locally in the network of things smart device without uploading to the server. In the meantime, we will choose the best connection method for your device based on the IP and Internet signal so that a stable connection can be secured.
3. Control network of things smart devices Once you have binded the network of things smart device, you can control the function and service of this Product by going to 【Family->List of device】. When you are operating your device, we need to collect your device info and the command info so that the control could be achieved. Also, in the step of adding a device, please carefully read and agree with the detailed Privacy Policies related to network of things smart devices. Your settings and info you provided will be uploaded to our service as the command for network of things smart devices so that control over network of things smart devices could be achieved.
4. Set automated tasks Your network of things smart devices will report events info (the info comes from your added device, and detailed information that can be set is dependent on your privacy authorization of individual device. For each added device, you could choose whether you agree or not on the Privacy Policy of the device). The information could be used to create your own automated tasks.

2). To support the additional functions of BOTSLAB products

Additional functions are service functions apart from core functions and third-party functions. They would only come into effect if you choose to use them or authorizes to enable them. For functions that you did not enable, we would not collect your personal data.  Meanwhile, you can disable additional functions via the disabling route provided in this Policy. Once a function is disabled, we will not collect and use your personal data and your use of this product and of core functions of the BOTSLAB APP will not be affected.

1. Purchase of goods and services. After adding network of things smart devices, certain devices might provide options to purchase additional products or services, such as buying cloud storage so that you could review watch history, buying accessories and etc.. When you choose to buy relevant products or services, you can pay via a third-party payment method (including WeChat Pay, Alipay, Apple Pay). We will only acquire information about the merchandise name, order name, order amount, and payment status so that we could provide you with relevant cloud recording service, but we will not get any information regarding to the third-party payment account. You can go to 【My->Service Orders】 for information on services you have bought.
2. Share network of things devices You can share your network of things smart devices with your friends by mobile phone number. When you choose to invite your friends via the mobile phone number, you need to manually input the phone number of your family or friend to share the network of things smart device. We will upload the phone number you provided to the server via encrypting transmission so that the function of sharing network of things devices via phone numbers can be achieved.
3. Providing cloud push notification service In the meantime, the BOTSLAB APP will provide you push notification service so that you would get updates about network of things smart devices. You can enable/disable the push notification or adjust the time of push notification by changing the preference options under the “Dynamic Notification Settings” menu by going 【My->Settings->Notification Settings】
4. Internet test. You can choose to perform an Internet test, upload network test report, check the network status of your network of things smart devices, and solve abnormalities such as connection errors in 【My->Settings->Internet Test】. In realizing this process, we will collect information including network type, service provider, IP address and phone model. The information is only used for Internet tests and the solution to technological problems.
5. Notifications. We would send you important notifications or announcements using your personal information For example, we might send you push notifications on devices you have ordered or customized (depending on the devices you have purchased), our rule or policy change, or direct marketing notifications. We might use your phone number, email address and etc. to provide you products and services marketing materials from BOTSLAB and its business partners (who are providing network, mobile app or cloud products and services) We will strictly abide by the data protection laws in your area. As a result, before using your personal data, we will ask for your permission and only proceed after you have authorized us to use your personal data via a clear operation. If you don’t wish to receive a certain type of email, you can click the unsubscribe link at the bottom of the page.

3). Providing safety protection, solving technological problems, and handling problems that occurred with this product

i. Providing safety protection, solving technological problems, and handling problems that occurred with this product To ensure the safety of your account and device, address your questions related to this product, constantly improve our product, eliminate or decrease the circumstance of product failure, and provide you with better product functions and services, we will get the following information of your mobile terminal and binded network of things smart device: service provider, system ID, screen resolution, network access type, BOTSLAB APP version number, package name, APP usage time and frequency, and APP failure logs. This is for troubleshooting and optimizing product function and no personal data is involved in this process.

ii. Feedbacks and questions. You can go to 【My -> Suggestions and Feedback】 or 【Us -> Contact Us】for providing us with feedback or asking questions regarding to the problems you encounter when using the product. When providing feedback or asking questions, you will need to provide your contact info(phone number and email address), choose your question type, detailed description of your problem, phones and logs. We will try to find and solve the problem with the said information. The contact info you provide in your feedback and questions will only be used for communicating with you and providing you feedback. Without your clear consent or without a clear ruling in the laws, we would not provide any third-party with the contact info you provided.

iii. To better serve our clients and optimize our products, we might collect aggregated information that is directly or non-directly related to our service, anonymized information or anonymous information without tags.

II. Why we use and process your personal data

We use and process your personal data to provide you with products and/or services, and we promise you that we will abide by applicable laws. For this purpose, you agree us to use your personal data in compliance with this policy and provide our partner companies and third-party service providers your personal data. We might use your personal data for the following purposes:

         Provision, processing, maintenance, optimization, and development of our products and/or the service we provide you, and services provided through network of things smart devices or BOTSLAB APP.

         Communication with you regarding network of things smart devices, services or any regular inquiries (such as updates, firmware/software updates, customer question support, relevant news no notifications).

         Conduction of marketing activities such as providing marketing and promotion materials and updates. Acquisition of more marketing and promotion-related activity info.

         Analysis and development of our products and statistical information of product usage so that we can better improve our products and services.

         Storage and maintain your relevant information for operating our businesses and fulfilling our duties defined by the laws.

For details about how we use your data (including your personal data), please refer to Article I of this Privacy Policy, “how we use and process your personal data”.

III. How we store your personal data

Personal data we collected during our service will be stored in the USA, Germany, or Singapore.

If you are located in the European Economic Area (EEA) or African countries, the personal data we collected and generated will be stored in Germany.

If you are located in the Americas regions, the personal data we collected and generated will be stored in the USA.

If you are located in Southeast Asia, East Asia or Australia, the personal data we collected and generated will be stored in Singapore.

We will keep your personal data for the time period that is needed for the purpose of collecting your personal data as specified in this Privacy Policy, or in compliance with applicable laws and regulations. After the purpose is fulfilled or we have received your confirmation of deleting or closing the service or account, or we have stopped operating relevant products or services, we will cease keeping your personal data, and delete or anonymize your personal data. For purposes including public welfare, science, historical research, or historical research, we will keep the data in compliance with applicable laws, even though the late treatment of data has deviated from the original purpose.

IV. How we share your personal data

We will not sell any personal data to a third party. We might disclose your personal data to a third party to provide you with requested products or services. We might disclose your personal information to the listed third-party service providers or related companies below. Please be assured that for any circumstance included in this part, BOTSLAB will only share your personal data after your authorization. Your authorization to BOTSLAB includes your agreement for various sub-servers to handle your personal data. You should also be assured that under any circumstances described below, when BOTSLAB shares your personal data with a third-party service provider, BOTSLAB will regulate the practices and duties the third party will be engaged in via a contract that is strictly in compliance with applicable regional data protection law. BOTSLAB will make sure that the third-party service provider will abide by the privacy rights standard that is applicable in your jurisdiction area with contracts.

1. Sharing with our third-party service providers: we will only share for a lawful, legitimate, necessary, specific and clear purpose and purposes that are needed for fulfilling this Policy, and the share would only happen after your authorization. We will share necessary personal data, or aggregated data, anonymized data, or other data that would not be tracked back to you to our suppliers, service providers, consultants, agents, third-party commercial partners, mobile app developers, open platforms or other business partners (for example, we might tell mobile app developers how many people have installed their app), so as to provide better service and user experience. These suppliers, service providers, consultants and agents might provide us with technological infrastructures, analyzing usage patterns of our services, measure the effectiveness of our business commercials and services, provide customer services or payment services, conduct academic researches and surveys, or provide legal, financial or technological consulting services. For companies, organizations, and individuals we share information with, we require them to sign a strict data protection agreement, and ask them to handle personal data in compliance with our instruction, this Policy and any other related encryption and safety measures. If you don’t wish to allow us to share the said information, please contact us via privacy@botslab.com.

2. Sharing with our related companies: when our related companies are providing you with services, we might share your personal data with our related companies. However, we would only share necessary personal info that is within the scope of purposes you agreed upon, and our related company is restricted by this policy when handling your personal data. If the related company wants to change the purpose of using your personal data, we will ask you for your consent and authorization.
3. Sharing your personal data with other parties: We might share your personal data with outsiders based on the laws and regulations, for purposes of resolving conflicts or under the lawful requirement of the administrative or judicial department. In addition, BOTSLAB might collect, use, or disclosure your personal data without your consent under circumstances that are clearly defined and permitted by local data protection law (such as to respond to a summons); or we might disclose your personal data without your consent for purposes of protecting our rights, protecting your and other's safety, investigating fraud, or responding to government requirement. We might share anonymous information in an aggregated way with a third party (such as our online advertising agent) for business purposes.

Should we have to transfer your personal data outside of your jurisdiction area, whether it is to our related companies or third-party service providers, we will act in compliance with applicable laws. In particular, we will adopt appropriate safety measures to make sure such transfer satisfies the requirements of the local data protection law. You have the right to know the proper safety measures BOTSLAB adopts in transferring your personal data.

Under the premise of abiding by the laws, we might transfer your personal data to any sub-companies of BOTSLAB company around the globe in accordance with the purposes and measures described in this Privacy Policy. We might transmit your personal data to our third-party service providers, who might be located in countries or regions outside of the European Economic Area. Shall BOTSLAB share personal data within the EEA area with a third party, whether the third party is a sub-company of BOTSLAB outside EEA or not, we will take any additional protective measures required by European Union Standard Contract or GDPR.

When you choose to use other third-party services in our product and services (such as Amazon Alexa, Google Assistant voice service), the party might read your relevant information, and your information might be transferred to a third-party server outside of your jurisdiction area and you have agreed with a transfer under this circumstance.

V. How we protect your personal data

We have adopted safety protection measures meeting the industrial standard to prevent data from being visited, disclosed, used, edited without permission, or being damaged or lost. We will take all reasonable and feasible measures to protect your personal data.

1. We value the safety of your personal data and will perform encrypted transmission and storage of data that could be traced back to you so that the confidentialness of the data could be ensured. If you have registered for a BOTSLAB account, we might analyze your login time, IP address, times for logging in for risk management.
   Should any operation that might be coming from another person, we will notify you through text message or email to avoid the BOTSLAB account being operated by another person. For data change between your mobile phone and our client terminal, we will employ a dual-encrypted transmission method by using both our self-defined encryption method and https encryption method so that the security of data transmission can be ensured.
2. If WebView technology is used in our product, we will conduct URL verification for all the file agreements and limit its visit sensitive data stored in this app or in the SDCard to avoid any private documents or sensitive data of BOTSLAB being stolen and causing your personal data to be leaked.
3. We have installed visit control mechanisms to our server so that only a minimum amount of staff members are authorized to visit your data and we run a regular check on the list of visitors and visit logs. We assure you that staff members and third-party service providers who use the information to help provide you with products and services have the duty required by contracts to keep your data confidential.
4. Server systems that we store your personal data on are all operation systems enhanced with extra safety measures. We also conduct account monitor for server operations. Shall any server operation system in use is announced to be flawed with safety problems, we will perform security updates in a timely manner to ensure the safety of your server system and application.
5. In the unfortunate event that our physical, technical or management protection measures are destroyed, we will promptly activate emergency plans to prevent the expansion of security incidents, report to relevant regulatory agencies in accordance with the requirements of laws and regulations, and in some cases notify data subjects of personal data leakage in accordance with usage laws (including your local data protection laws).

You can also play a role in protecting your personal data: Do not disclose your login password or account information to anyone unless that person has obtained your formal authorization. Always log out your BOTSLAB account after finishing using it whenever you log into the account, especially when logging in with other’s computer or terminal devices connected to a public network. BOTSLAB will not take responsibility for safety concerns that are caused by you failing to keep personal data confidential and leading to a third party visiting your personal data. Notwithstanding the above provisions, if any other user on the Internet uses your account without authorization or any other security breach, you must notify us immediately.

VI. Your right to manage your personal data

While using the product, you can access and manage your personal data via the following methods:

1. Visit and edit your personal data

You can access your personal data following the routes and ways provided in “I. How we use and process your personal data” in an earlier article on this policy.

If you are unable to correct your personal information through the above methods, you can also submit a correction request to us through the contact information provided in Article X of this policy. Upon your request, we can provide you with a copy of your personal information we collected and processed for free. For any additional requests for the same information, we may charge a reasonable fee based on actual management expenditures in accordance with usage laws.

2. Delete your personal data

You can request us to delete your personal data via the contact information provided in Article X of this policy, and we will respond to your request within 15 working days. When we delete your personal information from the server, we may not delete the corresponding data from the backup system immediately, but we will delete the data when the system updates the backups. When you request us to delete information, we may ask you to provide additional information to verify your identity and ensure that it is you who made the deletion request.

3. Withdraw your consent or change the scope of the consent

In BOTSLAB APP, you can withdraw your consent or change the scope of consent via the following methods.

         You can access the permission management interface on your mobile phone following 【Setting->Privacy->Privacy Management】 to withdraw your consent to the app binded with this product or change the scope of the consent

         You can disable relevant functions and unbind smart hardware devices following the routes and ways provided in “I. How we use and process your personal data” in an earlier article of this policy. Disabling of a function leads to the withdrawal of corresponding authorization.

         You can contact us to submit a request by sending an email to privacy@botslab.com to withdraw your consent to the collection, use and/or disclosure of your personal information that we hold or control. We will process your request within a reasonable time after you make the request, and will no longer collect, use and/or disclose your personal information in accordance with your request.

Please be noted that for almost every service function, some basic personal data is needed (see Article I of this policy). When you withdraw your consent or change the scope of your consent, we will not be able to provide relevant services and will not process relevant personal data. However, even if you withdraw your consent or change the scope of your consent, it would not affect previous service activities that involved the processing of your personal data.

4. Close your account

You can contact us at any time by going to 【My -> Suggestions and Feedback】 or 【Us -> Contact Us】 or email us at privacy@botslab.com to close your BOTSLAB account. Please note that if you choose to cancel your BOTSLAB account, your BOTSLAB account will be unavailable and the relevant account information will be cleared. You will no longer be able to log in through your BOTSLAB account and use BOTSLAB product features and services (but it will not affect your using services and functions that can be used without account login). In order to protect the legitimate rights and interests of you or others, we will determine whether to support your cancellation request based on your use of BOTSLAB's products and services.

After you close your account, unless laws and regulations require us to save relevant information, we will stop providing you with the corresponding products (or services), and delete or anonymize your personal information within 15 working days.

5. Other specific instructions

If you are an EU user under the administration of the General Data Protection Regulation (GDPR), you have the right to request us to erase your personal information. If there are relevant regulations in the GDPR, we will consider the rationality of the erase requirements and take reasonable steps including technical measures.

If you are an EU user under the administration of the General Data Protection Regulation (GDPR), you have the right to restrict our process of your personal information, and we will consider the rationality of the restriction. If there are relevant regulations in the GDPR, we will only process your personal information in methods that are in compliance GDPR regulations, and we will notify you when the restriction is removed.

If you are an EU user under the administration of the General Data Protection Regulation (GDPR), you have the right not to be affected by automated processed decisions that may have a legal effect on you or have a similarly significant impact on you.

If you are an EU user under the administration of the General Data Protection Regulation (GDPR), you have the right to receive your personal data in a commonly used structured format and to transmit the data to another data controller. 

VII. Protection of personal information of minors

This product is not specifically designed for minors. For minors using this product, consent or authorization from minors themselves or their guardians is needed. When children use this product, their parents and other guardians need to read this policy, and children should seek the consent and guidance of their parents and other guardians before submitting personal information. If you are the parent or guardian of a child, when you have questions about the personal information of the child under your supervision, or you have reason to believe that a minor or child has provided personal information to BOTSLAB without prior consent, you can use the contact information in Article X of the policy to protect the legal rights and interests of minors and children.

IIX. Scope of Privacy Policy

This policy only applies to this product and does not apply to products and services provided by third parties. BOTSLAB products and services may include third-party products and services, as well as links to third-party websites. When you use these products and services, they might also collect your information. We hereby remind you that when you use third-party products and/or services, please carefully read the relevant user agreements and personal information protection policies shown to you by the third party, and keep and provide your personal information carefully. We do not take responsibility for how third parties collect your personal information, nor can control their use of your information. Our privacy policy does not apply to other websites that are linked to your service.

IX. Changes and revisions to personal information protection policies

This policy may change. Without your explicit consent, we will not restrict your rights in accordance with this policy. For major changes to this policy, we will also provide noticeable notifications (for example, in the form of a pop-up window to notify you in time when the APP is revised or upgraded, or when you log in again).

X. How to contact us

If you have any doubts, objections or suggestions regarding this policy, please contact us with the following method:
 

Contact email: privacy@botslab.com