Legal Statement & Privacy Policy

Issue date: June 1st, 2023
Reminders:

Thank you for using our products and/or services! We are well aware of the importance of personal information to you, and your trust is of great importance to us. We will strictly abide by laws, regulations and take corresponding security protection measures to fully guarantee that your personal information is secure and under control. For this purpose, Zhuhai Tessan Power Technology Co., Ltd. (or“we”for short), the provider of [Diivoo] services, hereby establishes the [Diivoo] Legal Statement & Privacy Policy (hereinafter referred to as “the policy” or “the privacy policy”) to help you fully understand that how we collect, use, share, store, and protect your personal information and how you manage such information when using our products and/or services to help you make appropriate choices. Before using our products and/or services, please carefully read and understand the policy, in particular the articles indicated with bold/bold underlines, to guarantee that you use these articles after fully understanding and consenting to them. Besides the policy, in specific circumstances, we will specify the purpose, scope, and usage of corresponding information collected by using instant messages (including pop-up windows, page notes, etc.) and function updates notices. These instant messages and function updates notices constitute a part of the policy, and they and the policy shall have the equal legal effect. We will do our best to interpret the technical terms involved in the policy to facilitate your understanding. You may reach us through the contact information at the end of the policy if you have any question, suggestion, or advice. Your consent to the privacy policy implies that you have been aware of the functions of the application as well as the essential personal information required to operate the functions, and you authorize us the right to collect, use corresponding information; however, this does not mean that you have individually consented to that we enable additional functions and process non-essential personal information. We will individually ask for your consent according to your actual usage to enable additional functions and process non-essential personal information.

Legal Statement:

1. Ownership
1.1. The texts, graphs, and combinations of our Logo, “Diivoo” as well as our other identifications, symbols and service names are the registered trademarks of our company and its affiliated companies in China and other countries. Without our written authorization, no one is allowed to neither display, use, or anyhow process (including but not limited to duplicating, spreading, demonstrating, mirroring, uploading, or downloading) the above texts, graphs, and combinations in any form, nor indicate anyone that you have the right to display, use, or anyhow process such texts, graphs, and combinations.

1.2. The intellectual property rights of our products, services, technology, and all programs (hereinafter referred to as “technical services”) are owned by us or the right holders.
1.3. Unless otherwise specified, we have all the rights (including but not limited to copyrights, trademark rights, patent rights, trade secrets, and other relevant rights) to publish information including documents (including but not limited to texts, graphs, pictures, photos, audios, videos, icons, colors, layouts, and electronic documents) in the App. Without our permission, no one is allowed to use the above contents (including but not limited to monitoring, duplicating, spreading, displaying, mirroring, uploading, or downloading any of the contents by using any program or device). If anyone is authorized to browse, duplicate, print, and spread any content in the App, such content shall not be used for commercial purposes and the use of all information, contents and any part herein shall contain the legal statement.

2. Limitation of liability
We hereby remind you that, when using our services you shall abide by the laws of the People’s Republic of China, and you shall neither endanger network security nor violate, infringe the reputation, privacy, intellectual property, or other legal rights and interests of anyone by using our services. Notwithstanding the above, we assume no responsibility for any of your purposes to use our services.

3. Intellectual property protection
We value intellectual property rights, object to and fight against any behaviors violating such rights. In case any organization or individual thinks that the contents on our client page may infringe its legal rights and interests, it may present a written notice of right to us, and we will handle the issue as soon as possible after receiving the qualified notice from the holder of the intellectual property right.

Privacy Policy:
We value and protect user information and handle such information in a highly diligent, prudent manner. When you use our services, we will collect, process, and disclose your information in accordance with the privacy policy. We intend to explicitly introduce our ways of processing your personal information to you through the privacy policy. For this purpose, you are advised to read the privacy policy completely to help you know the ways to understand and safeguard your privacy right. The privacy policy applies to our services only. The services include the pairing, control, management of any intelligent device and other matters. The policy does not apply to any services provided by any third-party. For example, in case any of our third-party service providers provide services to you by relying on our platform, the information you provide to the service provider does not apply to the policy. Please reach us by using the contact information we provide if you have any question, suggestion or advice.

The privacy policy will help you understand the following contents:
A. Scope of application
B. Information collection and use
C. Partners involved in data use and transfer, disclosure of personal information
D. Your rights
E. Storage of information
F. Policy updates
G. Protection of minors
H. Contact us

Appendix: Relevant definitions
A. Scope of application
The policy applies to the products and/or services provided by the [Diivoo] service provider in the form of [website, client, and mini program] and new types as a result of technical development. If the products and/or services provided by us and our affiliated companies have individual privacy policies, such privacy policies apply to corresponding products and/or services.

Apart from the collection and use of relevant information specified herein, the policy does not apply to other services directly provided to you by any third-party smart hardware product, and the separately specified collection and use rules of personal information apply to such other services. For example, [when your device has any hardware failure to be repaired, the manufacturer of the device will collect your personal information, and then the manufacturer will specify the specific rules.]

B. Information collection and use
When you use our products and/or services, we need or may need to collect and use your personal information, including the following two types of information:

1. To provide the basic functions of our products and/or services and fulfill the obligations specified in laws and regulations, you have to authorize us to collect, use essential information. In case you refuse to provide relevant information, you will be unable to use our products and/or services properly;

2. To provide the additional functions of our products and/or services, you may individually agree or disagree to our collection and use of your personal information. If you refuse to provide such information, you will be unable to use the above additional functions or reach our desired functional effects, while our basic functions are not compromised.

We hereby remind you that: We have been committed to providing diverse products and/or services to meet your needs. Because we provide diverse products and/or services and the scopes of the specific products and/or services selected and used by different users are various, the basic functions or additional functions and the types and scopes of personal information collected and used correspondingly may vary. Please be subject to the specific products and/or service functions.

The specific functions and scenarios we provide include:
1.1 Account registration, log-in, and binding services
1.1.1 When you register an account on the App, you provide us with the information including your country/region, mobile phone number, email address, and password as well as the profile your upload and the nickname you set in personal settings after a successful registration. We need to obtain the privilege for your album when you upload your profile.
1.1.2 When you bind a desired smart speaker through Diivoo, you need to bind it as instructed as per the type of the speaker (Amazon Alexa, Google Assistant, etc.). We will synchronize your Diivoo account information and the smart speaker account you bind.

1.2 When providing technical services, such as adding, connecting a device and using our services for smart device control, the information you provide includes:
1.2.1 We will display the information you need to provide through our page. Please be subject to the page. You needn’t provide relevant information if you don’t use some services.
1.2.2 When you add a desired smart device, if you add it code scanning, we need to obtain the privilege for your camera; if you add it through Bluetooth pairing, you need to allow us to use the Bluetooth function of your client and authorize us to obtain your location information to scan nearby Bluetooth signals; if you add the device through Wi-Fi, we need to obtain the privilege for your location. You may add the device as instructed by the page.

The information we collect includes:
1.2.3 Device information: We will receive and record the information of the mobile phone you use according to the specific privilege you authorize for our software installation and use (including the model, operating system version, settings, environment, MAC address, IMEI, and IDFA of your mobile phone, and other software, hardware characteristics such as device identifiers, relevant information including location (including the GPS location you authorize, WLAN access point, Bluetooth, base station, and other sensor information)); information related to the smart device you use (e.g., the information of the smart device paired through our services, including model, operating system version, settings, device environment, operable functions (e.g., turn on/off), MAC address, IMEI, IDFA, and other software, hardware characteristics such as device identifiers).
1.2.4 Log information: When you use our or client services, we will automatically collect your detailed use of our services to be saved as network logs, such as your account information, device information, APP version, IP address, telecom operator, language used, region, access date and time, and the error log when a failure occurs.

The smart device service provider provides us with the following information:
1.2.5 The operation and location of the smart device (e.g., IP address, GPS location, and Wi-Fi access point, Bluetooth that can provide relevant information).
Please note that individual device information and device operation information is that specific natural person’s identity cannot be identified. If we combine that other than personal information with other information to identify specific natural person’s identity or combine it with personal information, such information other than personal information will be deemed as personal information during the combination; unless authorized by you or specified in laws, regulations, we will conduct anonymization, de-identification for such personal information.

The following information is that we and the service provider of the smart speaker you bind interact based on the purpose to control the device through voice:
1.2.6 To make the smart speaker you bind able to control your smart device, you need to finish the association authorization for your Diivoo account and that of the smart speaker. Please follow those specified in “1.1.3”. Besides, we will provide the service provider of the smart speaker with the list of your controlled devices and all operable functions (e.g., turn on/off, etc.).
1.2.7 If you use the music rhythm functions through the control panel of a smart lamp, we will obtain the privilege for your microphone to collect sound information through the microphone, transform it into digital signals to control the color, rhythm of the light and form music lighting effects. Please note that even you have agreed that we can obtain the privilege for your microphone, we will use the microphone only when you click the microphone icon in the client or record any video.

1.2.8 Interaction and exchange
Notification of messages: During our operation, we may simultaneously send one or multiple types of messages, such as service notification, identity verification, security verification, and user experience investigation, to you by using the contact information (e.g., phone number, email address) you provide when using our products and/or services. [In order to guarantee that you can receive messages properly and avoid missing relevant messages, we use the App auto-run and associated-start to enable other App functions.] We will send you messages (warnings, service messages) to you through the “Messages” on your client. You may enable/disable the notification function of the App in the “Settings” of your device.

1.2.9 Security guarantee for you
To fulfill the legal obligations in E-commerce trading security, enhance the safety of your use of the services provided by us, our affiliated companies, and partners, protect the personal security, property security, account security, and transaction security of you, other users, and general public, better prevent phishing sites, frauds, network vulnerability, computer viruses, cyber-attacks, network invasions, malicious programs, and other security risks, and accurately identify conditions violating laws and agreements, rules related to [Diivoo], we, our affiliated companies, and partners will collect your device information, service log information, may use or integrate your member information, trading information, device information, and service log information, and our affiliated companies, partners obtain the information you authorize or share according to laws (we may collect MAC address, IMEI, and other device identifiers during background operation for risk verification) to judge the risks of your account and transactions in an all-around manner, conduct identity verification, inspect and prevent safety incidents, and take necessary record, audit, analysis, and disposal measures as per laws.

1.2.10 Customer service and dispute settlement
When you contact us or apply for a dispute settlement, you need to provide essential personal information to verify your user identity to guarantee the security of your account and our system.
To facilitate contacts with you and rapidly help you solve problems or record the solutions and results of relevant problems, we may contact you via the phone number, email address or other information you provide for further communication. Besides, we will save the email/call records and relevant contents (including account information, other information you provide to prove relevant facts, or the contact information you provide) between you and us. If you consult, complain or suggest about a specific matter, we will use your account information and error log information.
To provide better services and improve service quality, we may use other information related to you, including relevant information you provide when you contact our customer service and that on the questionnaire you send to us when participating in a questionnaire survey.

1.2.11 Other additional services for you
1) Additional services based on system privileges
To provide you with more convenient, better products and/or services and promote your experience, we may collect and use your personal information by enabling system privileges when providing the following additional services. If you don’t agree to our use of such privileges, your use of basic [Diivoo] services will not be compromised. However, you may be unable to obtain the user experience brought by such additional services.
You may enable or disable such privileges any time at your discretion.
Please note that, enabling any privilege represents that you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you disable any privilege, you cancel the authorization and we will stop collecting, using relevant personal information based on corresponding privilege, and we cannot keep providing you with corresponding services any longer. The information collection and use based on your previous authorization will not be compromised by your decision to disable any privilege.
You may click here to view the description of privilege application and use. To provide you with more convenient, better products and/or services and promote your experience, we may collect and use your personal information when providing additional services. If you don’t provide such information, the basic services such as using [Diivoo] to add, control any device may not be compromised. However, you may be unable to obtain the user experience brought by such additional services.
2) Services of cookies and similar technologies
Cookies and similar device information identifying technologies are commonly used in the Internet. When you use our services, we may use relevant technologies to send one or more cookies or anonymous identifiers (hereinafter referred to as “cookies”) to your device to collect, identify, and store the information you access, use the product. We hereby make a commitment that we will not use cookies for any purpose other than those specified in the privacy policy. We use cookies to guarantee the security, efficiency operation of the products and/or services, so that we can confirm the security status of your account and transactions, find out unusual conditions including breakdown, delays, and help you save the steps and processes to repeatedly fill in forms and input search contents.

1.3 We may use the user information you provide and we collect for the following purposes:
1.3.1 To provide you with services and maintain, improve such services;
1.3.2 Permitted by laws and regulations, we may promote, introduce products to you through messages, emails;
1.3.3 We may use your personal information (device information, log information, etc.) to prevent, discover, and investigate frauds and illegal behaviors endangering security and violating the agreements, policies, or rules of the company and affiliated companies so as to protect the legal rights and interests of you, other users, the company, and our affiliated companies;
1.3.4 We may combine the information from one service with that from another to provide you with services and suggestions;
1.3.5 We may use the information for other purposes allowed by you.

C. Partners involved in data use and transfer, disclosure of personal information
(i) Our partners involved in data use
1. Basic principles
We will abide by the following principles when cooperating with our partners:
1) Principle of legitimacy and minimum necessity: Data processing shall be legal with legitimate purposes and shall not extend the minimum scope to achieve the purposes.
2) Principle of users’ right to know and decision-making power maximization: Users’ right to know and decision-making power for the processing of their personal information shall be fully respected during data processing.
3) Principle of security guarantee ability reinforcement: We will take necessary measures to guarantee the security of personal information, prudently assess partners’ purposes to use such data, conduct comprehensive assessments on the security guarantee ability of these partners, and ask them to follow the requirements of the cooperation agreements hereof.

2. Scope of partners
If specific functions and scenarios involve the services provided by our affiliated parties and third parties, the scope of partners includes our affiliated parties and third parties.

3. Authorized processing
We may authorize any of our partners to process your personal information, so that the partner can provide some services or fulfill duties for you on behalf of us. We authorize such partner to process your information only for the legal, legitimate, necessary, specific, and explicit purposes specified in the policy. Any authorized partner can access the information required to fulfill its duties only, and we will ask the partner to not use the information for any purpose other than that authorized according to agreements. If the authorized partner uses your information for any purpose not authorized by us, the partner will individually need your consent to this.

4. Joint processing
For scenarios to jointly process personal information, we will sign agreements with our partners in accordance with laws and regulations and specify respective rights and obligations to guarantee that relevant laws, regulations are followed when relevant personal information is used and protect data security.

5. Cooperative scenarios
1) Advertising and analysis services
In the premise of using common industrial safety technology, we will authorize our partners to process the information related to advertising, coverage, and validity. We will not authorize our partners to process your personal identity information.
2) Security and statistical analysis
a. Guarantee use security: We highly value the security of our products and/or services. To fully guarantee the legal rights and interests of [Diivoo] users, our partners may use essential device, account, and log information.
b. Analyze products: Any partner providing analysis services may need to use the information related to service conditions, device identification information, and overall installation and use of the App to analyze the stability of [Diivoo] products and/or services.
c. Academic and scientific research: In the premise of guaranteeing data security and legitimate purposes, we and our partners (e.g., scientific research institutes, universities) may use de-identified or anonymous data to enhance the scientific research ability of relevant fields and promote scientific and technological levels.
3) Other cooperative scenarios
Apart from the above cooperative scenarios, we may authorize information to other partners who support our business, including partners who are authorized by us to provide technical infrastructure services, analyze the usage pattern of our services, and provide membership services or other customer services.
The SDK or similar applications of our partners may be embedded in the App to guarantee the stable operation and functions of the client and make you use, enjoy more services and functions. We will conduct rigorous security tests for the application programming interfaces (API) and SDK of authorized partners to achieve relevant information. Besides, we will specify strict data protection measures for authorized partners, instructing them to process personal information in accordance with the policy and any other related confidentiality and security measure. The circumstances that our authorized partners individually obtain your consents are excluded.
(ii) Transfer
If we need to transfer personal information because of any merge, separation, dissolution, or bankruptcy, we will inform you the name and contact information of the receiver. The receiver will continue fulfilling the policy and other legal duties. The receiver will obtain your new consent if it changes the previous purposes and methods of processing personal information.
(iii) Public disclosure
We will disclose your personal information only in the following circumstances:
1. In the premise of you active choice and individual consent to other issues, we may disclose your personal information;
2. If we confirm that you violate laws, regulations or the agreements and rules of [Diivoo] or in order to protect the physical and property security of [Diivoo] users or general public from damages, we may disclose your personal information, including relevant violations and the measures taken by [Diivoo] against you.
(iv) Stop of operation
If we stop operating our products and/or services, we will promptly stop collecting your personal information. We will deliver notices one by one or send you the notice on the stop of our operation in the form of an announcement. Besides, we will delete or anonymize the personal information we hold related to the products and/or services that have been stopped.
(v) Circumstances that your authorized consent is not required according to laws
Please note that, in the following circumstances, your authorized consent is not required if your personal information is used by any of our partners or transferred, disclosed by us in accordance with laws, regulations and national standards:
1. Your personal information is required to establish or fulfill any contract according to your requirements.
2. It is required to fulfill legal obligations or duties: To follow laws, regulations, settle lawsuits and disputes, meet the requirements specified by administrative, judiciary organs, and fulfill other legal obligations, we may share your personal information.
3. To respond to public health emergencies or protect the life health and property security of natural persons in emergencies, it is required to disclose your personal information.
4. To perform news coverage, supervision by public opinions for public interests, it is required to dispose of personal information in a reasonable extent.
5. The personal information disclosed by yourself or that has been legally revealed (e.g., personal information legally disclosed through legal news coverage, government information disclosure, and other channels) is disposed within a reasonable extent.
6. Other circumstances specified in laws and regulations.

D. Your rights
You may view and manage your information through the following ways. We will respond to your requests in the circumstances required by laws, regulations:
View, correct, and supplement
You have the right to view, correct, and supplement your information through the following ways:
[Log in the Diivoo App; click your user profile to go to “Me” page, and click the “User information module” for personal account settings;


E. Storage of information
(i) Period of storage
We store your personal information only within the period required to achieve the purposes specified in the policy. For example, we will store your personal information for at least three years in accordance with the legal requirements of the People’s Republic of China on limitation of action. Unless compulsory storage is required in laws, we mainly judge the storage period for personal information as per the following criteria:
1. Finish the purposes of transactions related to you and maintain corresponding transactions and business records to cope with your potential inquiries or complaints;
2. Guarantee the safety and quality of our services for you;
3. Whether you agree to a longer storage period;
4. Whether there is any other special provision, law, or regulation on storage period.
After the storage period expires, we will delete or anonymize your personal information in accordance with applicable laws.

(ii) Storage security
1. Data protection technical measures
We have taken commonly-used, rational, and feasible safety protection measures to protect your information and prevent it from unauthorized access, public disclosure, use, modification, damage, or loss. For example, [we will use encryption technology to enhance the security of personal information; your information is protected by SSL Protocol when your browser exchanges data with our server, and we provide HTTPS protocol for safe browsing; we will use trustworthy protection mechanism to prevent your personal information from malicious attacks; we will deploy access control mechanism to guarantee that only authorized ones can access relevant personal information. ]
2. Data protection management and organization measures
We have established industry-leading data security management system focusing on data and data lifecycles to promote the security of personal information from the dimensions of organizational construction, institutional design, personnel management, and product technology. We keep reinforcing our workforce’s awareness on the importance of protecting personal information through training courses and exams.

3. Response to personal information security incidents
In case our physical, technical, or management protection facilities are destroyed, resulting in that information is subject to unauthorized access, public disclosure, manipulation or destruction and the losses or damages of your legal rights and interests, we will promptly launch an emergency plan and take reasonable, necessary measures to minimize the impacts on you. In case of any personal information security incident, we will inform you about the basic conditions and possible impacts of the incident, the measures we have taken and will take, the suggestions for your active prevention and risk reduction, and remedial measures for you. We will inform you through SMS, phone calls, messages, and other rational channels. In case it’s hard to inform any user one by one, we will take reasonable, valid ways to publish announcements. In addition, we will report the disposal of the personal information security incident to our superior authorities as per the requirements of regulatory departments.

F. Policy updates
We keep improving our products, services, and technology to provide you with better products and/or service experience. In case our new services and business processes have any changes, we may update our privacy policy and remind you of such updates through appropriate ways to make you promptly know the latest edition of privacy policy. Without your explicit consent, we will not restrict your rights under the privacy policy.
For major changes, we will provide more obvious notifications (including pop-up windows) to inform you about such changes. Besides, we will ask for your consent in accordance with laws and regulations.
The major changes specified herein include but not limited to:
1. Major changes in the business model of products, such as the purpose of processing personal information, type of personal information processed, and use of personal information;
2. Major changes in privacy policy caused by business adjustment, M & A, such as the new receiver changes previous purposes and methods of processing personal information;
3. Changes in the major objects of personal information sharing or public disclosure;
4. Major changes in users’ rights and ways of exercise for personal information;
5. Changes in the contact information of the leader for personal information protection and complaint channels;
6. According to the information protection impact assessment report, the products have major impacts on personal rights and interests.


G. Protection of minors
[We assume that you have corresponding capacity for civil conducts.] If you are a minor, we request you to ask your parents or any other guardian to read the policy carefully. You shall not use our services or provide us with information before you obtain the consent from your parents or any other guardian.


H. Contact us
1.If you have any question or suggestion for the legal statement and privacy policy or that for the practice and operation of the policy, you may reach us via support@diivoosmart.com, and your request will be answered within 15 days.
2.If you are not satisfied with our reply, especially you think that you legal rights and interests are damaged by our personal information processing practices, you may file a lawsuit to the court with jurisdiction over the location of the defendant for a solution.

Appendix: Relevant definitions
Personal information: It refers to all kinds of information, recorded in electronic form or other forms, that can individually or combine with other information to identify the personal status of natural persons, including but not limited to the name, date of birth, ID card, personal biological recognition information, address, and phone number of any natural person. The personal information in the privacy policy refers to that collected, transferred, stored, used, and shared by us to provide services for you.
Personal sensitive information: It refers to personal information including ID card, personal biological recognition information, bank account, property information, movement tracks, transaction information, and information on children under the age of 14 (including 14) (we will specifically highlight personal sensitive information in the privacy policy with boldfaced words).
Deletion of personal information: It refers to deleting personal information in systems involved in achieving routine service functions to make such information unsearchable and inaccessible.
Children: They refer to minors under the age of 14.
Device information: We will receive and record the information of the mobile phone you use (including the model, operation system version, settings, environment, MAC address, IMEI, IDFA, and other software, hardware characteristics such as device identifiers, relevant information including location (including the GPS location you authorize, WLAN access point, Bluetooth, base station, and other sensor information)); information related to the smart device you use (e.g., the information of the smart device paired through our services, including model, operating system version, settings, device environment, operable functions (e.g., turn on/off), MAC address, IMEI, IDFA, and other software, hardware characteristics such as device identifiers). The specific hardware model, serial number, software list, application installation list, software installation list, IMEI, MAC address, IMSI information of SIM card, Android ID, MEID, OpenUDID, GUID, Bluetooth information, broadcast module communication information, ICCID, operator information, sensors (gyroscope, gravity sensor, acceleration sensor, environmental sensor, and optical heart rate sensor), and shear plate shall be subject to the actually collected conditions.
Information related to smart device location (e.g., IP address, GPS position and Wi-Fi access point, Bluetooth that can provide relevant information).
Service log information: [IP address, browser type, telecom operator, language, and access date and time.]
De-identification: It refers to the process of handling personal information to make it impossible to identify any specific natural person without the help of additional information.
Anonymization: It refers to the process of handling personal information and making it impossible to identify any specific natural person and making such information irrecoverable.