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Privacy Notice

Effective Date: 2019-08-01

Updated Date: 2019-08-15

SMART XTR Smart Life, its affiliates and subsidiaries (“we”, “us”, “our”, “SMART XTR”) are committed to protecting yourprivacy. This Privacy Statement (“Statement”) describes our practices in connectionwith information privacy on personal data we process through your individualuse of the following services, products, and related mobile applications(collectively, the “Products”)

    SMART XTR Smart Life Mobile Application

    Smart Life Mobile Application


In this Privacy Notice, “Personal Data”means information that can be used to identify an individual, either from thatinformation alone, or from that information and other information we haveaccess to about that individual.  “SmartDevices” refers to those nonstandard computing devices produced or manufacturedby hardware manufacturers, with human-machine interface and the ability totransmit data that connect wirelessly to a network, including: smart homeappliances, smart wearable devices, smart air cleaning devices, etc. “Apps”refers to those mobile applications developed by SMART XTR SmartLife that provide end users remote control to Smart Devices and with the abilityto connect to SMART XTR Smart Life IoT Platform.

For other branded mobile applicationspowered by Smart Life, our Clients control all the Personal Data collectedthrough our Products. We collect the information under the direction of ourClients and the processing of such information shall be limited to the purposeof providing the service for which our Clients has engaged us. If you are acustomer of one of our Clients and would no longer like to be contacted by oneof our Clients that use our service, please contact the Client that youinteract with directly.

What Personal Data do we Collect                                           In order to provide our services to you, we will ask you to providenecessary personal data that is required to provide those services. If you donot provide your personal data, we may not be able to provide you with ourproducts or services.

Information You Voluntarily Provide Us

                           Account or Profile Data: When you register an account with us, we may collect your contactdetails, such as your email address, phone number, and user name. During your interactionwith our Products, we may further collect your nickname, profile picture,country code, language preference or time zone information into your account.

                           Feedback: When using feedback and suggestion features in our Products, we willcollect your email address, mobile phone number and your feedback content toaddress your problems and solve device failures on a timely basis.


Information We Collect Automatically

                           Device Information: When you interact with our Product, we automatically collect deviceinformation, such as the MAC address of your devices, IP address, wirelessconnection information, operating system type and version, application versionnumber, push notification identifier, log files, and mobile networkinformation.

                           Usage Data: During your interaction with our Sites and Services, we automaticallycollect usage data relating to visits, clicks, downloads, messagessent/received, and other usage of our Sites and Services.

                           Log information: When you use our app, the application and exception log may be uploaded.

                           Location Information: We may collect information about your real-time precise or non-precisegeo-location when you use our specific Products or Services, such as robotcleaner and weather service.


Smart Devices Related Information:

                           Basic information of Smart Devices: When you connect your Smart Devices with our Products or Services, we maycollect basic information about your Smart Devices such as device name, deviceID, online status, activation time, firmware version, and upgrade information.

                           Information reported by SmartDevices: Depending on the different Smart Devicesyou elect to connect with our Products or Services, we may collect differentinformation reported by your Smart Devices. For example, smart weights orfitness trackers may report your height, weight, body fat mass (BFM), BMI andskeletal muscle mass (SMM); smart cameras may report images or videos capturedby it.

Purposes and legal basis for processingPersonal Data

The purpose for which we may processinformation about you are as follows:

   Provide You Services: We process your account and profile data, device information, usagedata, location information, and Smart Device related information to provide youwith our Products and Services that you have requested or purchased. The legalbasis for this processing is to perform our Agreement with you accordingto our Terms of Use.,

   Improve Our Services: We process your device information, usage data, location information andSmart Device related information to ensure the functions and safety of ourProducts, to develop and improve our Products and Services, to analyze the efficiencyof our operations, and to prevent and trace fraudulent or inappropriate usage.The legal basis for this processing is to perform our Agreement with youaccording to our Terms of Use.

   Non-marketing Communication: We process your personal data to send you important informationregarding the Services, changes to our terms, conditions, and policies and/orother administrative information. Because this information may be important,you may not opt-out of receiving such communications. The legal basis for thisprocessing is to perform our Agreement with you according to our Termsof Use.

   Marketing Communication: We may process your personal data to provide marketing and promotionalmaterials to you on our Products and Services. If we do so, each communicationwe send you will contain instructions permitting you to opt-out of receivingfuture communications of that nature. The legal basis for this processing isyour consent. Additionally, if you consent to participate in ourlottery, contest or other promotions, we may use your personal data to managesuch activities.

   Personalization: We may process your account and profile data, usage data, device informationto personalize product design and to provide you with services tailored foryou, such as recommending and displaying information and advertisementsregarding products suited to you, and to invite you to participate in surveysrelating to your use of our Products. The legal basis for this processing isyour consent.

   Legal Compliance: We may process your personal data as we believe to be necessary orappropriate: (a) to comply with applicable laws and regulations; (b) to complywith legal process; (c) to respond to requests from public and governmentauthorities (d) to enforce our terms and conditions; (e) to protect ouroperations, business and systems; (f) to protect our rights, privacy, safety orproperty, and/or that of other users, including you; and (g) to allow us topursue available remedies or limit the damages that we may sustain.


Who do we share Personal Data with?                                                                           We onlyshare personal data in ways that we tell you about.

We may share your Personal Data with thefollowing recipients:

    To our third-party serviceproviders who perform certain business-related functions for us, such as websitehosting, data analysis, payment and credit card processing, infrastructureprovision, IT services, customer support service, e-mail delivery services, andother similar services to enable them to provide services to us.

    To our customers and other businesspartners who provide you, directly or indirectly, with your Smart Devices,and/or networks and systems through which you access and use our Sites and Services.

    To an affiliate or other thirdparty in the event of any reorganization, merger, sale, joint venture,assignment, transfer or other disposition of all or any portion of ourbusiness, assets or stock (including without limitation in connection with anybankruptcy or similar proceedings). In such an event, you will be notified viaemail and/or a prominent notice on our website of any change in ownership,incompatible new uses of your personal information, and choices you may haveregarding your personal information.

    As we believe to be necessary orappropriate: (a) to comply with applicable laws and regulations; (b) to complywith legal process; (c) to respond to requests from public and governmentauthorities, including public and government authorities outside your countryof residence; (d) to enforce our terms and conditions; (e) to protect our operations,business and systems; (f) to protect our rights, privacy, safety or property,and/or that of other users, including you; and (g) to allow us to pursueavailable remedies or limit the damages that we may sustain.

    To subsidiaries or affiliates withinour corporate family, to carry out regular business activities.


Except for the third parties describedabove, to third parties only with your consent.

YourRights Relating to Your Personal Data

Werespect your rights and control over your personal data. You may exercise anyof the following rights:

     Via the “Profile – Personal Center” in our Products

     By emailing us at


We will aim to respond you within 30 days.If you decide to email us, in your request, please make clear what informationyou would like to have changed, whether you would like to have your personalinformation deleted from our database or otherwise let us know what limitationsyou would like to put on our use of your personal information. Please note thatwe may ask you to verify your identity before taking further action on yourrequest, for security purposes.

You may:

    Request access to the personal datathat we process about you;

    Request that we correct inaccurateor incomplete personal information about you;

    Request deletion of personal dataabout you;

    Request restrictions, temporarily orpermanently, on our processing of some or all personal data about you;

    Request transfer of personalinformation to you or a third party where we process the data based on yourconsent or a Agreement with you, and where our processing is automated; and

    Opt-out or object to our use of personaldata about you where our use is based on your consent or our legitimateinterests.


Information Security Safeguards                                                                                             We usecommercially reasonable physical, administrative, and technical safeguards topreserve the integrity and security of your personal information. We provide varioussecurity strategies to effectively ensure data security of user and device. Asfor device access, our proprietary algorithms are employed to ensure dataisolation, access authentication, applying for authorization. As for data communication,communication using security algorithms and transmission encryption protocolsand commercial level information encryption transmission based on dynamic keysare supported. As for data processing, strict data filtering and validation andcomplete data audit are applied. As for data storage, all confidentialinformation of users will be safely encrypted for storage. If you have reasonto believe that your interaction with us is no longer secure (for example, ifyou feel that the security of any account you might have with us has beencompromised), you must immediately notify us of the problem by

Information Retention Period                                                                                                 Weprocess your personal data for the minimum period necessary for the purposesset out in this Privacy Notice, unless there is a specific legal requirementfor us to keep the data for a longer retention period. We determine theappropriate retention period based on the amount, nature, and sensitivity ofyour personal data, and after the retention period ends, we will destroy yourpersonal data. When we are unable to do so for technical reasons, we willensure that appropriate measures are put in place to prevent any further suchuse of your personal data.

Changes to this Policy Notice                                                                                                  We mayupdate this Privacy Notice to reflect changes to our information practices. Ifwe make any material changes, we may not notify you in time by email (email sendto the e-mail address specified in your account) or inform by means of a noticein the mobile applications prior to the change becoming effective. We encourageyou to periodically review this page for the latest information on our privacypractices.

Legal application and jurisdiction                                          Thispolicy is formulated in accordance with the laws of the People's Republic ofChina and shall be governed by the laws of the People's Republic of China. Ifyou have any questions about our practices or this Privacy Notice, pleasecontact us as follows:                                                                                                                                       

Post: Deal Direct 2U Limited

Unit 1309, 13F, Wing Hing Industrial Building , 83-93 ChaiWan Kok Street, Tsuen Wan, N.T. , Hong Kong