Privacy Policy
Updated: 2023-10-08
Effective: 2023-10-15
Preface
T-Smart Light(hereinafter referred to as "We") attaches great importance to the protection of your personal data. In providing you with T-Smart Light App (hereinafter referred to as the "the App"), we will collect and process your personal data in strict accordance with the provisions of the EU General Data Protection Regulation and only to the extent stated in this Privacy Policy (hereinafter referred to as "the Policy").
Please read and understand this Policy carefully before you submit your personal data to us. Please note that this policy only applies to this App. If you use other products or services provided by us, please refer to other privacy policies applicable to this product or service.
This policy will help you understand the following:
1. Who we are
2. What personal data we collect about you
3. On what legal basis do we process your personal data
4. How do we manage your personal data
5. How do we entrust the processing, sharing, transfer and disclosure of your personal data
6. How is your personal data transferred outside EU/EEA borders
7. What rights do you have
8. How can we protect children's personal data
9. How is this policy updated
10. How to contact us
1. Who we are
We are [Shenzhen Topband Software Technology Co., Ltd], a company registered in [B302-306, 400-401, 411-412 Room ,Research Institute of Tsinghua University,Nanshan High tech Industrial Park, Shenzhen City]. We have full rights to the App as the data controller determining the data processing activities of the App and will be responsible for all matters relating to the App.
2. What personal data we collect about you
In order to provide you with better services and realize the basic functions of this App, we collect the following personal data of you:
(1) To enable you to successfully register and verify your account, we need to collect your user name, password, email address, mobile phone number, and when you choose to use a third-party account to log in, we will obtain your shared account information from the third party (such as: Your profile picture, nickname, region, etc.) are bound to your account of the App for quick login. We will use your personal information in accordance with the agreements with third parties and the terms of personal information sharing in the privacy policy published by the third party, and in accordance with relevant laws and regulations.
(2) To enable you to control devices and ensure the normal operation of devices , we need to collect your IP address, city, and time zone, device information (including but not limited to WIFI box number, WIFI box MAC address, SSID, hardware device number, hardware device identification code, MAC address, etc.) and real-time device data (including but not limited to software version, time, temperature, fault code, etc.).
(3) We need to collect your email address and mobile phone identification number so that you can successfully report the device failure and push fault information to you when necessary.
(4) When you use our specific products or services: for example, when you use our weather service or daylight saving time service, we may collect information about your city and time zone; For example, when you add devices, share your family, and change your profile picture, we need to obtain your camera permission. In addition, we need to obtain your location permission to obtain Wi-Fi information based on your city and time zone. In addition, we need to obtain your storage permission to read your local photos.
3. On what legal basis do we process your personal data
We collect and process your personal data only to the extent necessary for the above purposes. These processing activities are necessary for performing the obligations stipulated in the smart hardware equipment purchase agreement with you and the smart home and corresponding services (including the App) provided to you. Therefore, we take the necessary performance of the contract as the legal basis for the above data processing activities. When you use our specific products or services, the legal basis for such processing activities is based on your consent.
4. How do we manage your personal data
4.1 Store your personal data
Your personal data will be properly stored in Amazon Cloud Serveris,which we rent located in [Germany - Frankfurt], and [the United States - Virginia]. For 1 year in a row without login APP users will email alerts, if the user has no reply, a month after the destruction of the corresponding data.
4.2 Secure your personal data
The servers we use have industry-leading security capabilities to fully protect your personal data. In addition, we strive to protect your personal data from unauthorized access, use, disclosure, modification, destruction, damage, loss or other forms of illegal processing by strengthening management and technical security measures, such as access control, encryption, staff training and other measures.
The network environment is not completely secure. In the event of a personal data security incident, we will perform our obligation to inform you, which may include informing you of the following information: the basic information of the security incident and its possible impact, the disposal measures we have taken or will take, and the suggestions you can take to prevent and reduce the risk. We will endeavor to inform you in a timely manner by phone, email, push notification, etc. In certain circumstances, we may publish an announcement on the company's official website.
If you know or have reason to prove that your personal data has been lost, misused, misappropriated or otherwise compromised, or if there is any actual or suspected misappropriation of your personal data, you may contact us promptly.
5. How do we entrust the processing, sharing, transfer and disclosure of your personal data
In principle, we only inform and obtain your authorization to transmit your personal data to third parties. In order to ensure the security of your personal data, we share, transfer or disclose your personal data to the following third parties in accordance with the principle of minimization and in compliance with applicable legal requirements.
Service Providers: For example, service providers that support our IT systems and help us process data, and cloud service providers that provide our underlying cloud services. We have signed data processing agreements with relevant service providers to fully ensure the legal and secure processing of your personal data.
API/SDK Service Provider: In order to enable you to use the functions and services of the App normally, we will embed SDK or other similar applications of authorized partners in the App .
We will carry out strict security tests on the system program interface (API) and software work development kit (SDK) used by authorized partners to obtain personal information, and agree on strict data protection measures with authorized partners to ensure that they collect and process your personal data in accordance with our agreement and the provisions of this Privacy Policy.
Government agencies, regulatory agencies, etc. : If any applicable law or in response to legal procedures requires the disclosure of personal data, we will consult the specific law enforcement authorities for the basis of disclosure, on the basis of ensuring that the disclosure is safe, legal and legitimate, and provide information to law enforcement authorities on the principle of least necessary.
Business Transactions: In the event of a merger, acquisition, bankruptcy, asset transfer or similar transaction involving the transfer of personal data, we will require the new company or organization holding your personal data to continue to be bound by the requirements, commitments and security measures of this Privacy Policy, for example, not beyond the purposes for which the personal data is used, Otherwise, we will require the company or organization to seek authorization from you again.
6. How is your personal data transferred outside EU/EEA borders
For the purpose of normal operation and maintenance of this application, the service provider we entrust will need to remotely access your personal data from countries or regions outside the EU/EEA (including China), where the level of personal data protection may not be in the EU/EEA. In order to fully protect the security of your personal data, we have signed the standard Agreement text of data cross-border transmission as the corresponding transmission mechanism. You can obtain the corresponding transport protocol text by contacting us.
7. What rights do you have
In accordance with relevant laws and regulations, you have the following rights with respect to your personal data:
(1) Know and Access: You have the right to know information related to our processing of your personal data and have the right to access such personal data.
(2) Modification: If your personal data changes, please inform us in time. You have the right to request the update or correction of inaccurate or incomplete personal data; You shall have the right to change or delete your personal information, the registration information, the solution to the third party account (Apple ID, WeChat), cancel the authorization system position, the camera and storage access, but note that delete the related information, and cancel the relevant permissions at the same time may also delete any of your the information stored in the system and affect the use of the related functions, You are at your own risk.
(3) Deletion: You have the right to request the deletion of your personal data if the processing of your personal data is no longer necessary for the purposes for which we collected or processed the data.
(4) Data Portability: You have the right to request us to transfer your personal data to you or another controller in a structured, generic, machine-readable and technically feasible manner.
(5) Limit Discretion: If we no longer need to deal with your personal data, but you need to such legal claims related data, or for your personal data we have been dealt with illegal but you don't ask us to delete the data, such as in your request correction data or against data processing at the same time, you have the right to limit our handling of your personal data. While you exercise this right, we will continue to hold your personal data and will process them only with your consent and only for the purpose of filing, exercising or defending legal claims, protecting the legal rights of others or for purposes of vital public interest.
(6)Delete account: You can log out of your account in "My - Account and Security -Delete account". Please be aware and understand that the act of cancelling your account is irreversible. After you cancel your account, we will delete relevant information about you after the set time indicated. If deleting personal information is technically difficult, we will anonymize it or stop processing it except for storage and taking necessary security protection measures, except as otherwise provided by laws and regulations.
(7) Complaint to regulatory authorities: If you have any objection to our data processing activities and this policy, you have the right to complain to the regulatory authorities in your country or region.
We guarantee that you can contact us or set up or other means to legally exercise the relevant rights described in this article. Please note that we may ask you to verify your identity and request before taking further action on your request. In general, we will not charge you any fee, unless such request is beyond the usual requirements. If you have any questions, please feel free to contact us.
8. How can we protect children's personal data
Our products and services are mainly aimed at adults. We do not intentionally collect personal data from children under the age of 14 without the consent of their parents or guardians. For personal data collected with the consent of a parent or guardian, we will only use or disclose such data in strict accordance with the relevant requirements of the GDPR with the express consent of the parent or guardian. If we find that we have collected personal data from children without the prior consent of a verifiable parent or guardian, we will take appropriate steps to delete the personal data as soon as possible.
9. How is this policy updated
We may update this Privacy Policy from time to time. If the privacy Policy changes, we will promptly post the latest version in a prominent place on this page. If there is a major change in this policy, we will provide more prominent ways to inform you, such as email, SMS, website popup, etc.
10. How to contact us
If you have any comments, suggestions or questions about this Policy, or if you have any requests or inquiries about your personal data, you can contact us in the following ways. In principle, we can reply within 30 days.
Contact Information: 0755-27651888
Email：support@tp-led.com
Address：B302-306, 400-401, 411-412 Room ,Research Institute of Tsinghua University,Nanshan High tech Industrial Park, Shenzhen City
Thank you