Privacy policy

EffectiveDate: 20250502

Updated: 20250602

SPA CONDOR ELECTRONICS andsubsidiaries (“we”, “us”, “our”, “SPA CONDOR ELECTRONICS”) are committedto protecting your privacy. This Privacy Policy (“Policy”) describes ourpractices in connection with information privacy on Personal Data we processthrough your individual use of the following services, products, and relatedmobile applications (collectively, the “Products”):

Condor MobileApplication

Before you use our Products, please carefully readthrough this Policy and understand our purposes and practices of collection,processing of your Personal Data, including how we use, store, share andtransfer Personal Data. In the Policy you will also find ways to execute yourrights of access, update, delete or protect your Personal Data.

When you accept this Policy when you register withyour Personal Data, or if you start to use our Products and does not expresslyobject to the contents of this Policy, we will consider that you fullyunderstand and agree with this Policy. If you have any question r regardingthis Policy, please do not hesitate to contact us via:

For other branded mobile applications powered by SPACONDOR ELECTRONICS，our Clients control all the Personal Data collected through our Products. Wecollect the information under the direction of our Clients and the processingof such information shall be limited to the purpose of providing the servicefor which our Clients has engaged us. If you are a customer of one of ourClients and would no longer like to be contacted by one of our Clients that useour service, please contact the Client that you interact with directly.

Definition

In this Policy, Personal Data means informationgenerated, collected, recorded and/or stored, electronically or otherwise, thatcan be used to identify an individual or reflect the activity of an individual,either from that information alone, or from that information and otherinformation we have access to about that individual.

Personal Sensitive Data includes personal biometricinformation, communication records and contents, health information,transaction information, and precise location information. When we collectPersonal Sensitive Data from you, we will generate an explicit notification foryour consent before we collection personal sensitive data about you.

Smart Devices refers to those computing devicesproduced or manufactured by hardware manufacturers, with human-machineinterface and the ability to transmit data that connect wirelessly to anetwork, including: smart home appliances, smart wearable devices, smart aircleaning devices, etc.

Apps refers to those mobile applications developed bySPA CONDOR ELECTRONICS that provide end users remote control to SmartDevices and with the ability to connect to the supplier IoT Platform.

What Personal Data do we collect

In order to provide our services to you, we will askyou to provide necessary Personal Data that is required to provide thoseservices. If you do not provide your Personal Data, we may not be able toprovide you with our products or services.

1.Information You Voluntarily Provide Us

· Registered Account Data: When youregister an account with us, we may collect your name and contact details, suchas your email address, phone number, user name, and login credentials. Duringyour interaction with our Products, we may further collect your nickname,profile picture, country code, language preference or time zone informationinto your account.

Ifyou authorize login to the Products with a third party account, we will obtainfrom such third party your account information (such as portrait, nickname,region, gender, etc.) which may be bound with your SPA CONDOR ELECTRONICS accountfor quick login. We will ensure compliance with applicable data protection lawsand regulations, as well as agreements, policies or documentations agreed withsuch third party regarding sharing personal information, in processing yourPersonal Data.

Information based on additional functions:

Confirm: the system permissions that allow in theyour App

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

1)Additionalfunctions based on location information:

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

Based on your consent, when you enable the geo-fencefeature, your location information will be generated and shared with GoogleMaps services. Please note that Google has corresponding data protectionmeasures, which you may refer to Google’s Data Processing and Security Termsfor more details.

You may disable the collection and use of yourlocation information by changing your mobile device settings ("My -Setting - Privacy Right Setting - Switch on/off Location Information"),upon which we will cease to collect and use your location information.

2)Additional services based on camera:

You may use the camera to scan the code by turning onthe camera permission to pair with a Smart Device, take video, etc. Please beaware that even if you have agreed to enable the camera permission, we willonly 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".

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

You can use this function to upload yourphotos/pictures/videos after turning on the photo album permission, so as torealize functions such as changing the avatar, reporting device usage problemsby providing photo proofs, etc.. When you use the photos and other functions,we will not recognize this information; but when you report a device usageproblem, 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".

4)Additionalservices related to microphone-based service:

You can use the microphone to send voice informationafter turning on the microphone permission, such as shooting videos, waking upthe voice assistant, etc. For these functions, we will collect your voiceinformation to recognize your command. Please be aware that even if you haveagreed to enable the microphone permission, we will only obtain voiceinformation through the microphone when you voluntarily activate the microphonein the App.

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

5)Additionalservices based on storage permission(Android):

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

6)Additionalservices based on Notification permission:

The reason why we ask you for the permission is tosend you notifications about using the Smart Devices or Services, especially ifyou have purchased security services and you require an alert or message sothat you can capture the real-time status.

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

7)Additional services based on Alert Window permission：

You may choose to bind a camera in the App andrequire the App to display the real-time image of the camera in a separatewindow.

You may opt-out the using of alert windowinformation: "My - Setting - Privacy Right Setting - Switch on/off AlertWindow".

8)Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning onthe permission, including controlling the Smart Devices, acquiring status of,discovering and configuring Smart Devices. In these functions, we willcommunicate with Smart Devices via Bluetooth. Please be aware that even if youhave agreed to enable the Bluetooth permission, we will only use Bluetooth forcommunication in these scenarios: display device status on the home page andSmart Device panel; perform device control on the home page and Smart Devicepanel; discovering Smart Devices on the home page and the add device page,Smart Device distribution network.

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

9）Additional services based onHomeKit permission (iOS):

You can enable related functions after enablingHomeKit permissions, including discovering Smart Devices, enabling Smart Devicenetwork configuration, controlling Smart Devices, and checking device status.Among these functions, we will process data with the "Home“ App that comeswith the iOS system through HomeKit. Please be aware that even if you haveagreed to enable the HomeKit permission, we will only use it in thesescenarios: on the home page, to discover HomeKit devices, HomeKit device networkconfiguration; in "Settings - HomeKit" for discovering HomeKitdevices, HomeKit device network configuration.

You may opt-out the using of HomeKit permission via "My- Settings - Privacy Settings-Turn off/on HomeKit permission".

10）Additional services based onHealthKit (iOS):

You can proactively enable related functions afterenabling HealthKit permission, including statistics on weight, height, running,and swimming. In these functions, we will exchange data with the health-relatedfunctionalities that comes with the iOS system through HealthKit. Please beaware that even if you have agreed to enable HealthKit permission, we will onlyuse them in these scenarios: when you use the health-related Smart Device, suchas body fat scales, bracelets, watch and consent to use the HealthKit, the datareported by the Smart Device will be transferred to HealthKit.

You may opt-out the using of HealthKit permission via"My - Settings - Privacy Settings - Turn off/on HealthKitpermission".

Please note that if you turn on any permission, youauthorize us to collect and use relevant personal information to provide youwith corresponding Services. Once you turn off any permission, we will take itas canceling the authorization, and we will no longer continue to collectPersonal Data based on the corresponding permissions, and the related functionsmay be terminated. However, your decision to turn off the permission will notaffect the previous collection and use of information based on your authorization.

2.Information We Collect Automatically

· MobileDevice Information: When you interact with ourServices, in order to provide and maintain the normal operation of ourServices, to improve and optimize our Services, and to protect your accountsecurity as well, we automatically collect mobile device information, such as mobiledevice model number, IP address, wireless connection information, the type andversion of the operating system, application version number, pushnotification identifier, log files, and mobile network information. Meanwhile,we will collect your software version number. In order to ensure the securityof the operating environment or to provide services, we will collectinformation about the installed mobile applications and other software you use.

· UsageData: During your interaction with our websites andServices, we automatically collect usage data relating to visits, clicks,downloads, messages sent/received, and other usage of our websites andServices.

· LogInformation: When you use the App, in order to improve your userexperience, the system and exception log may be uploaded, including your IPaddress, language preference setting, operating system version, date or time ofaccess, so that we can facilitate and accurately identify problems and help yousolve them in timely manner.

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

3.Smart Devices Related Information:

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

· Informationcollected during the process of connecting to a Smart Device:Based on the type of Smart Device you need to connect, the basic informationcollected includes: Wi-Fi information, device MAC address, etc.

· InformationReported by Smart Devices: Depending on the differentSmart Devices you elect to connect with our Products or Services, we maycollect different information reported by your Smart Devices. For example, Please enter information about the smartdevice report.

Pleasenote that when you actively agree to enter the App name and the application isconnected to the Apple Health, we will share your measurement data with AppleHealth (including only your BMI, height, weight and body fat% data). Thepurpose of sharing data is only to measure and analyze health-relatedindicators related to you, and it will never be disclosed to other thirdparties. You can close at any time by managing the HealthKit settings page.

Who do we Share Personal Data with?

At Please enter the company name, we onlyshare Personal Data in ways that we tell you about. We may share your PersonalData with the following recipients:

Toour third-party service providers who perform certain business-relatedfunctions for us, such as website hosting, data analysis, payment and creditcard processing, infrastructure provision, IT services, customer supportservice, e-mail delivery services, and other similar services to enable them toprovide services to us.

· To our customers and otherbusiness partners who provide you, directly or indirectly, with your SmartDevices, and/or networks and systems through which you access and use ourwebsites and Services.

· To subsidiaries or affiliateswithin our corporate family for purpose of regular business activities based onour instructions and in compliance with applicable law, this Policy and otherappropriate confidentiality and security measures.

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

· As we believe in good faith thataccess to, or use, preservation, or disclosure of the information is reasonablynecessary or appropriate to:

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

(b)Enforceour User Agreement and other agreements, policies, and standards, includinginvestigation of any potential violation thereof;

(c)Protect our operation and business systems;

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

(e)Performrisk management, screening and checks for unlawful, fraudulent, deceptive ormalicious activities.

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

International Transfer of Information Collected

SPA CONDOR ELECTRONICS willcomply with applicable data localization requirements in correspondingjurisdictions with respect to storage of data. To facilitate our operation, wemay transfer, store and process your Personal Data in jurisdictions other thanwhere you live. Laws in these countries may differ from the laws applicable toyour country of residence. When we do so, we will ensure that an adequate levelof protection is provided for the information by using one or more of thefollowing approaches:

· Agreement on the basis ofapproved EU standard contractual clauses per GDPR Art. 46. For moreinformation,see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

If you would like further detail on the safeguards wehave in place, you can contact us directly as described in this Privacy Policy.

Your Rights Relating to Your Personal Data

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

please provide at least 2 approaches for individualuser executing their privacy rights, for instance, via the privacy office emailaddress; condor@condor.dzor via the route of Feedback imbedded in the App: Me&rt;PersonalCenter&rt;Account and Security&rt;, etc.

You do not have to pay a fee and we will aim torespond you within 30 days. If you decide to email us, in your request, pleasemake clear what information you would like to have changed, whether you wouldlike to have your Personal Data deleted from our database or otherwise let usknow 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 furtheraction on your request, for security purposes.

You may:

· Request access to the PersonalData that we process about you: "My-Setting-Privacy Settings-Personal DataExport";

· Request that we correctinaccurate or incomplete Personal Data about you: 1) Modify your account number(email address or phone number): "My-Setting-Account and Security-Changeyour Account"; 2) Modify the nickname and/or time zone: "My-PersonalInformation";

· Request deletion of Personal Dataabout you: "My-Setting-Account and Security-Delete Account", when youconfirm the deletion of your account, your Personal Data will be deletedaccordingly.

· Request restrictions, temporarilyor permanently, on our processing of some or all Personal Data about you:Please send over your request through "My-FAQ & Feedback", orsend over the email request to Confirm: the condor@condor.dz;

· Request transfer of Personal Datato you or a third party where we process the data based on your consent or acontract with you, and where our processing is automated: Please send over yourrequest through "My-FAQ & Feedback", or send over the emailrequest to condor@condor.dz Opt-out orobject to our use of Personal Data about you where our use is based on yourconsent or our legitimate interests.

About Deletionof the Account: You can find the Delete function through “Me &rt; Settings&rt; Account and Security &rt; Delete Account” (Deactivate Account）

Security Measures

We use commercially reasonable physical,administrative, and technical safeguards to preserve the integrity and securityof your Personal Data. SPA CONDOR ELECTRONICS provides varioussecurity strategies to effectively ensure data security of user and device. Asfor device access, SPA CONDOR ELECTRONICS proprietary algorithmsare employed to ensure data isolation, access authentication, applying forauthorization. As for data communication, communication using securityalgorithms and transmission encryption protocols and commercial level informationencryption transmission based on dynamic keys are supported. As for dataprocessing, strict data filtering and validation and complete data audit areapplied. As for data storage, all confidential information of users will besafely encrypted for storage. If you have reason to believe that yourinteraction with us is no longer secure (for example, if you feel that thesecurity of any account you might have with us has been compromised), you couldimmediately notify us of the problem by emailing condor@condor.dz

Data Retention

We process your Personal Data for the minimum periodnecessary for the purposes set out in this Policy, unless there is a specificlegal requirement for us to keep the data for a longer retention period. Wedetermine the appropriate retention period based on the amount, nature, andsensitivity of your Personal Data, and after the retention period ends, we willdestruct your Personal Data.

· For as long as you require us tofulfill the products and services you request from us as defined in the useragreement or some other terms of use;

· Personal Data will no longer beretained when you request to remove your Personal Data, we will accordinglycomplete the task.

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

Children’s Privacy

Protecting the privacy of young children isespecially important to us. The Services are not directed to individuals underthe age of thirteen (13) (or such other age provided by applicable law in yourcountry/region of residence), and we request that these individuals do notprovide any Personal Data to us. We do not knowingly collect Personal Data fromany child unless we first obtain permission from that child’s parent or legalguardian. If we become aware that we have collected Personal Data from any childwithout permission from that child’s parent or legal guardian, we will takesteps to remove that information..

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changesto our information practices. If we make any material changes we will notifyyou by email (send to the e-mail address specified in your account) or by meansof a notice in the mobile applications prior to the change becoming effective.We encourage you to periodically review this page for the latest information onour privacy practices.

Contact Us

If you have any questions about our practices or thisPrivacy Policy, please contact us as follows:

SPA CONDOR ELECTRONICS

Postal Mailing Address: Z.A route de M'sila BordjBou Arreridj 34000 Algerie

Email: condor@condor.dz