We respect your data and your privacy is very important to us. Please read this carefully.

For the purposes of the General Data Protection Regulation and all other relevant legislation, Ikconect Ltd (‘we’ or ‘us’) is the ‘data controller’ (i.e., the company who is responsible for, and controls the processing of, your personal data).

This Privacy Policy explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.

You have the right to object to some of the processing which Ikconect Ltd carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

Registered office is: IKCONECT LTD,

20-22 Wenlock Road, London N1 7GU

Personal data we may collect about you

Information that you provide

We use your personal data to provide and improve our products and services.

Personal information about you (such as your name, email address, phone number, comments, date of birth, gender, region, feedback, marketing opinions and competition entries.) will be obtained, whenever you complete forms on our Website or App.

We will also obtain personal information you provide when you send feedback, post material, contact us for any reason and by any medium, sign up to a service, make purchases through the website or app, share information via the Website or App’s social media functions or report a problem with the Website or App. This may include transaction information; your username and password and your username for social networking.

We may ask you to provide sensitive personal data from time to time.  If such data is requested, you will be given additional information as to why the sensitive personal data is being requested and how it will be used.

We may retain a record of any contact you make with us.

Personal Information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his/her data;
• receive on his/her behalf any data protection notices;
• give consent to any transfer of his/her data;

We collect information when you enquire, purchase something or use our services. This includes using our websites or apps and corresponding with us.

Information from third parties

Occasionally we may receive information about you from other sources (such as our international affiliates, subsidiaries or agents), which will be added to the information already held about you in order for us to help supply our services and products to you.

Information that will be collected automatically

Cookies: We may monitor your use of the Website or App through the use of cookies and similar tracking devices. For example, we may monitor how many times you use the Website or App, which pages you go to and traffic data.  This information helps to build a profile of users to the Website or App. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on the use of cookies and how we use them, please see https://ikconect.com/cookies-policy 

Device information: We may also collect information about your device each time you use the Website or App. For example, we may collect information on the type of mobile device that you are using, browser and service provider, IP address, MAC address, the type of mobile browser that you are using, the mobile operating system that you are using, mobile network information and the time zone setting.

Third party cookies

We work with third-party suppliers who may also set cookies on the Website or app which, for example, we may use to display video content. These third-party suppliers are responsible for the cookies they set on our Website. If you want further information, please go to the website for the relevant third party.

How your personal data will be used

We will use your personal data for the following purposes:

• to help identify you and any accounts you hold with us;
• administration;
• research, statistical analysis and behavioural analysis;
• customer profiling and analysing your purchasing preferences;
• marketing—see ' Marketing and Opting Out', below;
• fraud prevention and detection;
• billing and order fulfilment for purchases made;
• customising the Website and App content to your particular preferences;
• to notify you of any changes to the Website and App or to our services or products that may affect you
• improving our services and products.
• We use CCTV around our sites for the prevention and detection of crime and for safety and security reasons.

What is our lawful basis or ground for using your personal data?

Under laws that are designed to protect your personal data, we need to have what is called a lawful basis or ground each time we use, share or otherwise process your personal data.

By reading and agreeing to this Privacy Policy, you are consenting to us processing your personal data as detailed within this Privacy Policy.

We may also need to process your personal data to comply with any legal obligations which may be applicable. Likewise, we may process your personal data where this is in the public interest or it is to protect your vital interests, but this will only be in rare circumstances.

In most cases, our processing of your personal data is necessary for the performance of our services to you.

Certain uses of your personal data, or other processing activities, may not be strictly necessary to perform our services to you, however, they may be necessary for the purposes of our legitimate interests or the legitimate interests of a third party. They may also be in your interests.

When we say "legitimate interests", we mean our (or a third party's) interests in enabling us to provide our services to you as efficiently and securely as possible. For example, we may choose to use a third party to store your personal data; we may do this in part because our use of that service means that your personal data is more secure.

Marketing and Opting Out

If you have provided your consent to receive news, special offers and promotions from us, we may contact you by mail, telephone and email.

If you no longer wish to be contacted by us, you are able to withdraw that consent at any time by contacting us, for instance by emailing datacontroller@ikconect.com if you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.

Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time. You can opt out of marketing by selecting “unsubscribe” in emails or by emailing datacontroller@ikconect.com

The website and app may contain links to other websites or apps which we or our partners own, or websites or apps of our partners or third parties. Please note that if you follow any of these links, the websites, apps and services provided through them will have their own privacy policies/terms of use. We do not accept any responsibility or liability for their respective privacy policies/terms of use or the collection and use of any personal data collected through these websites, apps or services. Please ensure that you review the relevant privacy policies/terms of use prior to providing any personal data to, or using these websites, apps and services.

Disclosure of your personal data

We may disclose your personal data to:

• other companies that become partners or part of a group with Ikconect Ltd.
• a third party who acquires Ikconect Ltd or acquires substantially all of its assets, in which case the personal data shall be one of the acquired assets;
• our agents and service providers;
• law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law;
• business partners in accordance with the ' Marketing and Opting Out' section above;
• our affiliates, subsidiaries or agents.

For some activities we use third party service providers to assist in the carrying out of our contractual duties. All third parties are thoroughly vetted and any data passed is GDPR compliant.

We do not pass your data to any external company for marketing.

Keeping your data secure

We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active customer, where required by law or to protect legal rights.

We will use technical and organisational measures to safeguard your personal data, for example:

• where you create an account on the website or app, this will be controlled by a password and username that are unique to you;
• we will store your personal data on secure servers;
• payment details are encrypted using SSL technology on the PayPal website;
• we will guard your account information when you are viewing your bills or orders on our website;
• secure all logs of settings and online services of your device(s).

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

Monitoring

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, establishing facts, fraud prevention and compliance.

Your Rights

We will collect and store information about you, as detailed above. You will be provided with opportunities to consent to this Privacy Policy and marketing when you provide your personal details to us.

You can change your mind or remove or add your consent at any time.

• You have the right of access to your personal records or other information that we hold about you. There is no administrative charge for this service.
• You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
• You have the right to have the data we hold about you erased.
• If you wish us to continue to store your information but wish us to keep your data separate and not process it in any way, please let us know.
• You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email of telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
• You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you in digital format. There is no administrative charge for this service.

Some rights, however, may be limited. We may be obliged by law or regulation to keep information. We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data. On occasion there may be a compelling legitimate interest to keep processing data.

To revise your consent, access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us at datacontroller@ikconect.com

You will need to provide proof of identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, amended or removed.

How long we will store your data

We will store your data for as long as necessary for the purpose of processing. The data may be deleted in the following circumstances:

• You have withdrawn your consent to data processing
• The original purpose for processing the data is no longer relevant or cannot be performed any more.
• The data is no longer up to date or accurate

Contact details

To exercise any of your rights or to withdraw consent you can email: datacontroller@ikconect.com

For any queries relating to data protection please contact

datacontroller@ikconect.com

or by writing to the Data Controller,

If we make any changes or updates to this policy, we will inform you.

IKCONECT Mobile APP Privacy Policy

Updated: March 31,2023
Effective: March 31,2023

Ikconect Ltd and its Affiliates (as hereinafter defined) (“we”, “us”, “our”, or “Ikconect”) are committed to protecting your privacy. IKCONECT Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data (as hereinafter defined) we process through your use of our products and services (collectively, the “Services”), for instance the Ikconect Mobile Application (the “App”)

Before you start using the Services, please carefully read this Policy which details our purposes for collecting and processing your Personal Data, as well as how we use, store, share and transfer your Personal Data. In this Policy you will also find ways to exercise your rights of access, update, delete or protect your Personal Data.

If you have any question regarding this Policy, please do not hesitate to contact us via:

Ikconect Customer Support: support@ikconect.com

Ikconect Data Control: datacontroller@ikconect.com

You are not obliged to provide to us your Personal Data (as defined below). However, we may be unable to provide you with certain products and/or Services if you decline to provide such data.

If you are a child under the age of 18 (or such other age provided by applicable law in your country/region of residence), please read this agreement and the “Ikconect Children's Privacy Statement" with your legal guardian or parent and make sure that you and your guardian or parent have clear understanding about our privacy protection practices.

Definitions

In this Policy:

Affiliate means any company, firm or legal entity that: (1) is directly or indirectly controlled by Ikconect; or (2) directly or indirectly controls Ikconect; or (3) jointly with Ikconect, controls the same company; or (4) is, directly or indirectly, under common control of the same company with Ikconect. Affiliates shall include, without limitation, Ikconect ’s parent companies, subsidiaries, and such subsidiaries under common control of the same parent company as Ikconect.

Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.

Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information, etc. according to various data protection laws and regulations. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collection personal sensitive data about you.

Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.

1. What Personal Data Do We Collect?

In order to provide the Services to you, we will ask you to provide necessary Personal Data that is required to provide those Services. If you do not provide your Personal Data, we may not be able to provide you with the Services.

1) Information You Voluntarily Provide to Us

• Registered Account Data: When you register an account with us, we may collect your account name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with the Services, we may further collect your nickname, country code, language preference or time zone information into your account.

If you authorise login to the Services with a third party account, we will obtain from such third party your account information (such as portrait, nickname, region etc.) which may be bound with your Ikconect account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.

• Feedback: When using feedback and suggestion features in the Services, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

Information based on additional functions:

In order to offer you with more convenient and higher-quality Services with optimised user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:

Additional functions based on location information:

When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about you) real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Device, or b) non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details. You may disable the collection and use of your location information by managing the device level settings, upon which we will cease to collect and use your location information.

You may opt-out the using of location information: "My - Setting - Privacy Right Setting - Switch on/off Location Information"

Additional services based on camera:

You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.

You may opt-out the using of camera permission: "My - Setting - Privacy Right Setting - Switch on/off Camera"

Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):

You can use this function to upload your photos/pictures/videos after turning on the photo album permission, so as to realise functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc.. When you use the photos and other functions, we will not recognise this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.

You may opt-out the using of photo album permission: "My - Setting - Privacy Right Setting - Switch on/off Photo Album"

Additional services related to microphone-based service:

You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognise your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App.

You may opt-out the using of microphone permission: "My - Setting - Privacy Right Setting - Switch on/off Microphone"

Additional services based on storage permission (Android):

The purpose is to ensure the stable operation of the App by utilising the storage permission. After you give or indicate the permission to read/write your mobile device’s storage, we will access pictures, files, crash log information and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.

You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switch on/off Storage"

Additional services based on Notification permission:

The reason why we ask you the permission is to send you notifications about using the products or services, especially if you have purchased security services and you require an alert or message so that you can capture the real-time status.

You may opt-out the using of App notifications: "My - Message Centre - Setting - Switch on/off Notifications"

Additional services based on Alert Window permission：

If you choose to bind a camera in the App and you require the App to display the real-time image of the camera in a separate window.

You may opt-out the using of navigation information: "My - Setting - Privacy Right Setting - Switch on/off Alert Window".

Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning on the permission, including control the Smart Device, acquiring device status, device discovery, and device network configuration. In these functions, we will communicate with terminal devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display the device status on the home page and Smart device panel; perform device control on the home page and device panel; we would use it on the home page and the add device page for discovering equipment, equipment distribution network.

You may opt-out the using of Bluetooth via "My - Settings - Privacy Setting - Disable/Enable Bluetooth permission".

Please note that if you turn on any permission, you authorise us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as a cancellation of the authorisation, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect previous collection and use of information based on your authorisation.

2) Information We Collect Automatically

• Mobile Device Information: When you interact with our Services, in order to provide and maintain the common operation of our Services, improve and optimise our Service, and protect your account security as well, we automatically collect mobile device information, such as mobile device model number, IP address, wireless connection information, the type and version of the operating system, application version number, push notification identifier, log files, and mobile network information. Meanwhile, we will collect your software version number. In order to ensure the security of the operating environment or to provide services, we will collect information about the installed mobile applications and other software you use.

• Usage Data: During your interaction with our websites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our websites and Services.

• Log Information: When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, preference language setting, operating system version, date or time of access, so that we can facilitate and accurately identify problems and help you solve them in timely manner.

Please note that one cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate or desensitise such information.

3) Smart Devices Related Information:

• When you use a Smart device, we will collect some basic and pre-embedded information of the Smart Device and the information generated during your use of the Smart Device.

• Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

• Information collected during the process of connecting to a Smart Device: Based on the type of Smart Device you need to connect, the basic information collected includes:

• Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device Mac address;

• After establishing a local connection via Bluetooth, Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device Mac address;

• Smart Devices connected via Bluetooth: device Mac address;

• Smart Devices connected via Zig-bee: device Mac address.

• Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with the Services, we may collect different information reported by your Smart Devices. The following information reported by the Smart Device only applies when you use them:

• When you voluntarily use a smart camera (IPC service) and connect to the Ikconect platform: When you connect a doorbell camera, a door lock, or a smart surveillance camera through Ikconect service to monitor the security of your residence, during the process, the device may capture the images if it recognises someone or an object is moving around, and then provide you a playback of related surveillance content. At this time, we will automatically encrypt the captured image and save it locally on the device. When you actively choose and successfully purchase cloud storage service, the smart camera will upload the pictures or video files you have taken to the cloud for further storage so that you can review them on the App. We will keep your information based on the cloud storage service you purchase. When you choose to delete the picture in advance in the Ikconect App, you can delete it in the message center and if you need to delete a video on the App, the cloud will respond to delete immediately the video files you stored in the cloud service.

• When you voluntarily use a certain health smart device and connect to the Ikconect platform: If you choose one or more of the following Smart Devices, the corresponding information will be recorded:

• Body Fat Scale: height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM), body fat rate, muscle mass, muscle rate, body fat index, obesity level, ideal weight, weight control, visceral fat index, lean body mass, body water, bone mass, protein rate, BMR, metabolic age, body score, body type, subcutaneous fat rate, subcutaneous fat mass, heart rate.

• Wrist Band and other devices: heart rate, steps, calories, mileages, heart rate, sleeping records, training records, body temperature, blood oxygen, systolic blood pressure, diastolic blood pressure, stress.

• Smart rope skipping and other smart fitness equipment: start time, jump mode, jump rope count, workout duration, calories burned, most keep jump count, trip on times, average speed, fastest speed, heart rate during workout.

Particularly, when you proactively consent to the Services connecting with third party health platform to enable the fundamental feature for you, such as Apple Health, Google Fit, Fitbit, we will share your health data with them for the sole purpose of measuring and analysing heath related indicators about you.


Smart Devices Wrist Band Body Fat Scale

GoogleFit steps, calories, miles weight, body fat%

Apple Health steps, calories, miles, heart rate, record of sleeping height, weight, body fat%, BMI, lean body mass

Fitbit / weight, body fat%

If you select GoogleFit, please go to the Google Term of Use and Privacy Policy for further reference: https://policies.google.com/privacy

If you select Apple Health, please go to the Apple Term of Use and Privacy Policy for further reference: https://www.apple.com/legal/privacy/en-ww/

If you select Fitbit, please go to the Fitbit Term of Use and Policy Privacy for further reference: https://www.fitbit.com/global/us/legal/privacy-policy

We will not disclose such health data to any other third party or use health related data for other purposes that not defined in the Policy. You may disconnect the Services with third party Health platform at any time by managing your health settings on your mobile device.

2. Purposes and Legal Basis for Processing Personal Data

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

• Provide You Services: We process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our User Agreement.

• Improve Our Services: We process your mobile device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyse the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our User Agreement.

• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, we will also send you notifications related to the services you have purchased, such as alert services. You can check the “App Notification” in the App ("Me - Message Center – Setting - Notification Setting”) to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such purpose. The legal basis for this processing is to perform our contract with you according to our User Agreement.

• Data Analysis: In order to analyse the usage of the products we provide and improve your user experience, we will analyse the data you provide us, a) we need to check your problems when you encounter any malfunctions during the usage of the product, under such circumstance, you may not able to opt-out because it is highly relate to your functionalities and quality of using our product and service, and b) analyse data about how you interface with the product or under particular scenarios so that you can better enjoy the convenience brought by our Services, under such circumstance, if you do not agree to data analysis of your data, you can enter the privacy settings of Ikconect App (“My - Settings - Privacy Settings - Data Analysis”) to opt-out your selection. The legal basis for such processing is based on your consent.

• Marketing Communication and Personalisation: We may process your account data, usage data, device information to personalise product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of the Services. If you do not allow us to process your Personal Data for personalisation, you may opt out when you enter the App, or by changing your preferences in “Privacy Settings” (“Me - Settings - Privacy Settings - Personalisation”) in the App. The legal basis for this processing is your consent.

• Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• comply with a legal obligation, process or request;

• enforce our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof;

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or

• detect, prevent or otherwise address security, fraud or technical issues.

If there is any change in the purposes for processing your Personal Data, we will inform such change to you with a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

3. Who do We Share Personal Data with?

At Ikconect, we only share Personal Data in ways that we tell you about. Without your consent, we will not disclose your Personal Data to third-party companies, organisations, or individuals except in the following cases:

• To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

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

• To subsidiaries or affiliates within our corporate family for purpose of regular business activities based on our instructions and in compliance with applicable law, this Privacy Policy and other appropriate confidentiality and security measures.

• To an affiliate or other third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, and choices you may have regarding your Personal Data.

• As we believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:

(a)Comply with applicable law, regulation, legal process, or lawful governmental request;

(b)Enforce our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof;

(c) Protect our operation and business systems;

(d)Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law;

(e)Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.

Except for the third parties mentioned above, we only disclose your Personal Data to other third parties with your consent.

Data Transfer

Ikconect operates globally, and Personal Data may be transferred, stored and processed outside of the country or region where it was initially collected. Also, the applicable laws in the countries and regions where we operate may differ from the laws applicable to your country of residence

Under the Personal Data protection framework and in order to facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live.

We protect Personal Data in accordance with this Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws.

The European Commission has determined that certain countries outside of the European Economic Area (EEA), the UK or Switzerland can provide adequate protection of Personal Data. Where Personal Data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognised as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. You can review the agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46.

If you would like further details on the safeguards we have in place under the data transfer, you can contact us directly as described in this Privacy Policy.

Data Subject Rights

We respect your rights and control over your Personal Data. You may exercise any of the following rights:

• Via the “Me - Settings - Account and Security” or via “Me - FAQ & Feedback” in the Services (for Product version 1.0.2 and later).

• By emailing us at datacontroller@ikconect.com

You do not have to pay a fee for executing your personal rights. Subject to applicable data protection laws in relevant jurisdictions, your request of personal rights will be fulfilled within 15 business days, or within 30 calendar days due to different response requirement.

If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may:

• Request access to the Personal Data that we process about you: "My-Setting-Privacy Settings-Personal Data Export";

• Request that we correct inaccurate or incomplete Personal Data about you: 1) Modify your account number (email address or phone number): "My-Setting-Account and Security-Change your Account"; 2) Modify the nickname and/or time zone: "My-Personal Information";

• Request deletion of Personal Data about you: "My-Setting-Account and Security-Delete Account", when you confirm the deletion of your account, your Personal Data will be deleted accordingly.

• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you: Please send over your request through "My-FAQ & Feedback", or send over the email request to datacontroller@ikconect.com;

• Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated: Please send over your request through "My-FAQ & Feedback", or send over the email request to datacontroller@ikconect.com;

• Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:

1)For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notification settings and other related functions;

2)You may opt-out the non-marketing communication through “Me - Message Center - Notification Settings” to manage your selection;

3)You may opt-out the data analysis features through “Me - Settings - Privacy Settings”;

4)You may opt-out the Personalisation feature through “Me - Settings - Privacy Settings - Personalization”;

5)Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected;

6)By using product with the Try Now mode, and not enable certain location setting for particular smart scene, we will not collect any Personal Data about you.

7)If you previously agreed to associate Ikconect account with a third-party service, such as a health platform, please unbind it on the third-party platform.

When you withdraw your consent or authorisation, we may not be able to continue to provide you with certain products or services correspondingly. However, your withdrawal of your consent or authorisation will not affect the processing of personal information based on your consent before the withdrawal.

About Deletion of the Account: You can find the Delete function through “Me - Settings - Account and Security - Delete Account” (“Deactivate Account” for the App version under 1.0.2).

Security Measures

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Ikconect provides various security strategies to effectively ensure data security of user and device.

As for device access, Ikconect proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorisation.

As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported.

As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing datacontroller@ikconect.com.

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data.

• For as long as you require us to fulfil the products and services you request from us as defined in the User Agreement;

• Personal Data will no longer be retained when you request to remove your Personal Data, we will accordingly complete the task.

When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

How to Complain

You have a right to complain to a data protection authority. In the UK, the data protection supervisory authority is the Information Commissioner’s Office (the “ICO”). Should you have any complaints about the way we handle your data, you may direct them to the ICO. More information on the ICO can be found on their website here: www.ico.org.uk

Children’s Privacy

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information.

Changes to this Policy

We may update this Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes, we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

To exercise any of your rights or to withdraw consent you can email: datacontroller@ikconect.com

For any queries relating to data protection please contact datacontroller@ikconect.com

or by writing to the Data Controller,

IKCONECT LTD

1st Floor

415 High Street

London

E15 4QZ

If we make any changes or updates to this policy, we will inform you