ACL-WIFI-106 Privacy Policy

Your privacy is extremely important to us.This Privacy Policy is a statement and commitment covering the aspect of privacy for ACL-WIFI-106 App and constitutes an integral part of the ACL-WIFI-106 Privacy Policy. This Privacy Policy was formulated to fully take your needs into account. It is important that you fully understand our personal information collection and usage practices and ensure that you are ultimately able to exercise control over the personal information you provide to us. This Privacy Policy sets out how we collect, use, disclose, process, and store any information that you provide to us when you use our ACL-WIFI-106 App. As used in this Privacy Policy, “personal information” means information that can be used to identify an individual, either from that information alone or in conjunction with other related information. We will only use this information in strict accordance with this Privacy Policy.

We hope to give our users the best experience possible. Should you have any questions about our data handling practices as described in this Privacy Policy, please contact us by visiting https://allanson.com/ so that we can respond to your specific concerns. We would be happy to receive any feedback you may have.

Personal information is collected in order to provide you with products and/or services as well as to ensure legal compliance on our part with applicable laws, regulations, and other regulatory documents. You have the right to choose whether or not to provide this information. However, in most cases, if you do not provide such information, we may be unable to provide corresponding services to you, or we may be unable to respond to a problem you encounter. These features include:

In order to provide you with ACL-WIFI-106 services and allow you to securely connect to and manage smart devices, we may collect your Wi-Fi information, location information, account login information, information related to your mobile phone and smart device. This information will be used to provide you with various functionality including pairing with and connecting to smart devices, discovering nearby devices, and device management. Specific examples involving the above information are set out below:

● The first time you log in，you need to provide your phone number or email address to register an account and set a password. If you do not provide any relevant information, ACL-WIFI-106 will not be able to create an account and provide services for you.

● After you successfully register an account, you can log in and modify your personal information, like your phone number/email,nickname,profile picture. If you do not fill out the relevant personal information, it will not affect the normal use of the basic features.

● In order to identify the abnormal state of the device, understand or optimize the compatibility and adaptability of products, and provide application upgrade or firmware version upgrade service, when you use the app, we will collect your mobile phone related information, including hardware-based identifiers (IMEI/OAID, MAC address, Android ID), phone model, OS version, OS language, country or region, App Store version, screen size and resolution, CPU, and display device related information.

● When you connect the WIFI device to a network for the first time or change another network on the device, you need to configure the device to a network. In order to accurately select and connect to the WiFi network, the app needs to request your location to search for available Wi-Fi networks. At the same time, your WiFi network and password will be recorded to complete the network connection. WiFi passwords are sensitive personal information that will be only stored locally on your device and will not be uploaded to the cloud server. ACL-WIFI-106 App will not collect WiFi passwords.Besides, for conveniently binding devices afterwards, the App will encrypt the WiFi password and save it locally, which will be filled automatically the next time you connect devices to the WiFi network. So you can get the devices connected to the network more quickly.

● In order to provide you with a better service experience, when you add and connect WIFI, Bluetooth devices, we will collect your device related information, including device model, device status, MAC address of the device, and device ID.

We use Alibaba Cloud Push Service that can provide expediency to you. For instance, you can receive and process home notifications timely, like inviting home members, changing home member permissions.We may collect information that you provide relating to room settings for smart devices in order to facilitate smart home management. This will allow you to enjoy greater convenience when using smart devices (for example, when using multiple smart lights, being able to quickly identify that a light is in a bedroom instead of a living room).

We provide support for you to share smart devices with others through your account. Sharing a smart device with someone else allows them to also control the device. In order to enjoy this feature, we may collect your account ID, the ID you provide relating to the account with which you share access, and shared device information (including device ID, device name, device verification key, and sharing status of device). Such information allows us to give you the ability to share device control and usage with the accounts of other ACL-WIFI-106 account users as well as to display the device’s sharing status on the My Devices page in the ACL-WIFI-106 App.

To ensure you can continue enjoying the latest ACL-WIFI-106 services, we may use the version information of your ACL-WIFI-106 App and phone model in order to provide you with updates to the ACL-WIFI-106 App. We may also collect a list of your connected smart devices and associated version information in order to provide you with smart device updates so that you can use the latest version of the service (including firmware version).

We provide support for you to configure certain rules to establish smart connections between devices under specific conditions. In order to enjoy this feature, we may collect your location information, smart scene rule settings, and designated device status so as to enable specific device functions to be executed according to the commands you give. (For example, enabling a light to turn on whenever a sensor detects someone passing by). Please rest assured that this functionality cannot be enabled without your express consent and rule configurations. When you turn on the device or location access for ACL-WIFI-106 App to use our location-based services,we will collect your location information so that you do not need to enter it manually. A network, GPS and other technologies are used to access your location. Also, you can turn off the location access to prevent the App from collecting your location information. After turn it off, you’ll not be able to use related features or the services we provide won’t achieve the intended results. Please note that collecting your current location information is for connecting your devices to a network more quickly, and detecting when you leave and arrive a target area so as to trigger the scenes you predefine. Doing so will not track your whereabouts.

To help you make better use of smart devices, we will provide you with selected articles on such devices. When you view these articles, we will not collect any information from you.

If you’ve gotten connected to ACL-WIFI-106 a smart device that plays media content, you can select and control on the corresponding support page the music or content to be played. We may collect smart device type registered with your account, to make available corresponding smart device control functions.

When you activate or wake up smart devices, we will automatically receive and record the audio information generated by the interaction between you and end devices. And we will use this information to improve the intelligent recognition system's ability to understand your content. Please note that devices or the app will not collect your voice information until the wake-up feature is turned on. If you disallow above information being collecting, please turn off the information collection feature on the device or do not wake up devices. After turning it off, you’ll not be able to gain related services.

To make you enjoy better control and management of smart devices provided by ACL-WIFI-106, we may collect and use your personal information in the following additional features. If you do not provide these personal information, you can still use the basic services of ACL-WIFI-106, but you may not be able to use such valuable additional features. These additional features include:

We may collect feedback from you on issues that you report to us, a feedback log, and any phone numbers or email addresses that you provide to us. This information will be used to help us better understand any problems you encounter as well as to allow us to contact you.

The ACL-WIFI-106 App may request permissions on your Android device. The information below is the corresponding features you can use,the purposes of requesting permissions, and the situations we will ask you when requesting permissions.

App permissions	Features you can use	Purposes of requesting permissions	Request or not	Whether user can turn off permissions or not
Camera	Scan QR codes on devices; scan codes to join a home, upload your profile picture	Use the camera to scan QR codes on devices to finish network connection, scan codes to apply for joining the home, change personal information, upload and update your profile picture.	Yes	Yes
Read the album (photo gallery)	Upload a picture to change your profile picture	Directly select the picture saved in your phone to change the profile picture	Yes	Yes
Microphone	Record music or your speech	The lighting changes according to the rhythm of music or speech	Yes	Yes
Read the information on your SIM card of your phone	Service function	Build a unique identification code for the user's identity	Yes	Yes
Read location information	Location service, add devices	Obtain your location information to provide you with services, including triggering the scenes by detecting when you leave and arrive a target area, searching for available WiFi or Bluetooth nearby when adding device	Yes	Yes
Read and write mobile phone storage	Update plug-in; Store pictures and other info;upgrade App	Update APP and upgrade plug-in, store APP exception logs at the same time for analyzing problems of accessing the location	Yes	Yes
Turn on Bluetooth	Connect Bluetooth devices to a network	Connect Bluetooth devices to a network and control them	Yes	Yes

For above permissions, you can choose to turn off some or all of them by heading to "Settings"— "App Permission".Doing so means you deny the permissions we request and refuse us collecting your information. Different Android system versions and different mobile phone brands may have different ways to display App permissions and turn them off. For details, please contact the device and system developers.

1. Related to national security and national defense security;

2. Related to public safety, public health, and major public interests;

3. Related to criminal investigation, prosecution, trial and execution of judgments, etc;

4. When it is for protecting vital legitimate interests of you or of other individuals, such as right of life, property, and reputation, while it’s hardly to obtain the consent of the individual;

5. The personal information collected is disclosed to the public by yourself;

6. Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

7. Necessary for signing and fulfilling the contract according to your requirements;

8. It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;

9. Necessary for the development of legal news reports;

10. When it is necessary to carry out statistical or academic research for the public interest, and when it provides the results of academic research or description to the outside, the personal information contained in the results is de-identified.

Under certain conditions permitted by law, we may obtain your personal information from a third party. For example, with the smart scenes function (smart device connections), if you provide authorization, we may obtain the device status of the smart device from the area where the smart device is located in order to determine whether to activate a smart scene (for example, if you configure a rule to turn on a light whenever someone walks by a sensor). You can add or remove smart connection rules on the “Smart” page. You can also choose whether to enable or disable smart connections on the Smart Devices page.

We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service, such as including clicks, page redirects, and browsing time Such information is collected in order to improve the services we provide to you.

We do not sell any personal information to third parties. To help us provide you with products and services described in this Privacy Policy, we may, where necessary, share your personal information with our third party service providers and business partners. We will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. Location-based service providers: The location-based services component of our services is provided by third party providers including AutoNavi. In order to offer you location-based services, we may provide information such as your device identifier information to any of these service providers. If we share your personal information with these third parties, we will use encryption technology or other means to keep your information secure. We perform reasonable reviews of the data security practices of companies and organizations with which we share personal information and also sign strict data processing agreements with them. Furthermore, we require third parties to take adequate measures to safeguard your information and to strictly comply with applicable laws, regulations, and regulatory requirements.

We will retain personal information for the period of time needed to fulfill the purpose for which it was collected as described in this Privacy Policy, or we will retain personal information in order to comply with applicable legal requirements. We will cease to retain your personal information and will delete or anonymize it once the purpose of collection is fulfilled, or after we confirm your request for deletion or cancellation, or after we discontinue the corresponding product or service. We will continue to retain relevant information in accordance with applicable laws even if further information processing is unrelated to the original purpose of collection, provided that doing so would be in the public interest or for scientific or historical research or statistical purposes.

We recognize that privacy concerns differ from person to person. Therefore, we provide examples of ways ACL-WIFI-106 makes available for you to choose to restrict the collection, use, disclosure, or processing of your personal information and control your privacy settings: Enable or disable location access, camera, microphone, and read/write access permissions on your phone:

● Modify personal information such as your nickname or profile picture. To do so, open the ACL-WIFI-106 App and go to "Me > Settings";

● Enable or disable smart device connections;

● Log into or out of your ACL-WIFI-106 Account;

If you have previously agreed to our using of your personal information for the above mentioned purposes,you may change your mind at any time by writing us a letter or visiting https://allanson.com/

Subject to the applicable laws and regulations of your country or region, you have the right to request access to, correct, and/or delete any personal information we have about you (hereinafter referred to as a "request").

For details relating to the personal information in your ACL-WIFI-106 account, you may also access and change them at https://allanson.com/ or by logging into your account on your device. For more information, please write us a letter or contact us by visiting https://allanson.com/ Most laws require a data subject to meet certain requirements when making a request. This Privacy Policy requires any request you make to meet the following conditions:

● To safeguard your personal information, your request should be made in writing through our designated request channel (unless oral requests are expressly permitted by local law);

● Provide enough information for us to verify your identity and ensure that the requester is the data subject or is otherwise legally authorized to request the information;

● Once we have a sufficient amount of information and confirm that we are able to process your request, we will respond to your request within the period specified by applicable data protection laws. Specifically:

● We may provide to you, in accordance with your request and applicable laws and regulations, a free copy of the record of personal information about you that we have collected and processed. However, if you make an additional request regarding related information, we reserve the right, pursuant to applicable law, to charge you a reasonable fee for your data access request based on actual management costs involved.

● If you believe that any information we have about you is incorrect or incomplete, you may request to correct or modify your personal information based on the purpose of use.

● Subject to your applicable laws and regulations, you may have the right to ask us to delete your personal data. We will conduct an evaluation according to your request for deletion and, if corresponding rules are met, we will take corresponding steps, including technical measures, to carry out your request. After you delete or after we assist you in deleting your information, it may not be possible for us to immediately delete corresponding information from our backup systems due to applicable laws and security technologies. In such event, we will ensure your personal information is kept secure and prevent it from being subjected to any further processing until the backup can be cleared or anonymized. For example, the “E-Commerce Law of the People’s Republic of China” requires your goods and services information and transaction information to be retained for a period of no less than three years from the date of completion of the transaction.

● We have the right to refuse to process requests considered to be frivolous or vexatious, requests that harm the privacy of others, extremely unrealistic requests, requests that would require a disproportionate technical effort, requests that are not required to be granted under local law, and requests involving information already available to the public or given under confidential conditions. We may also refuse a request in cases where we believe that certain aspects of a request to delete or access data might cause us to be unable to legally use the data for the aforementioned anti-fraud and security purposes.

● You may withdraw your consent for the collection, use, and/or disclosure of your personal information in our possession or control by submitting a request. You may contact us for relevant requests by visiting https://allanson.com/ based on the specific service you are using. We will process your request within a reasonable time frame from the time when the request was received, and thereafter not collect, use and/or disclose your personal information as per your request.

● Please note that your withdrawal of consent could result in certain legal consequences. Depending on the extent to which you authorize us to process your personal information, it may mean that you will no longer be able to enjoy the use of products or services. However, any decision on your part to withdraw your consent or authorization will not affect personal information processing previously performed with your permission.

If you wish to cancel a specific product or service, you may do so by visiting https://allanson.com/ If you wish to cancel your ACL-WIFI-106 account, please exercise caution before doing so, as canceling your account will prevent you from being able to enjoy the full line of products and services. To protect the legitimate rights and interests of you and others, we will determine whether to grant your cancellation request based on your usage of products and services. For example, if you have an outstanding amount due, we will not be able to immediately grant your request.

If you have any questions or feedback regarding this Privacy Policy, or if you have any questions regarding how we collect, use, or disclose your personal information, please contact us at the following address or by visiting https://allanson.com/ and mention that your message is in reference to the “Privacy Policy”. Our dedicated response team will be able to handle any issues you may have about rights requests or questions about your personal information. If you have a particularly critical issue that needs to be addressed, we may ask you to provide us with more information. If you are not satisfied with the response you receive, you may escalate your complaint to the applicable regulatory authority in your jurisdiction. Upon request, we will provide you with information on how to file a complaint based on your actual circumstances.