ECORUSH Mobile Privacy Policy

Effective Date: 2022/1/5

Updated: 2022/1/5

ECORUSH andsubsidiaries (“we”, “us”, “our”, “ECORUSH”)are committed to protecting your privacy. This Privacy Policy (“Policy”)describes our practices in connection with information privacy on Personal Datawe process through your individual use of the following services, products, andrelated mobile applications (collectively, the “Products”):

Confirm1: If the App has integrated the ‘Try Now’ orother features representing non-login (visitor mode), if yes, please refer tothe following description and if no, please delete then.

If you do not want to provide your profile data whenyou start to use any of the Services, you may use the App without login orcreating an account, and you may still use certain ECORUSHservices, such as searching and browsing any features on the Services. At thismoment, we will not collect Personal Data about account or profile, and thecollected data will be limited to those you have authorized to be collected forpurpose of using the additional functions of the App and/or the Smart Devices,as well as corresponding usage information. However, if the Services yourequest or purchase are based on your account, please go to theregistration/login page for guidance.

·ECORUSH 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:

support@ecorush.eu

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 by ECORUSH thatprovide end users remote control to Smart Devices and with the ability toconnect to the supplier IoT Platform.

WhatPersonal 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.InformationYou Voluntarily Provide Us

·Account or Profile Data: When you register anaccount with us, we may collect your name and contact details, such as youremail address, phone number, user name, and login credentials. During yourinteraction with our Products, we may further collect your nickname, profilepicture, country code, language preference or time zone information into youraccount.

Confirm4: Determine whether the accountregistration/login is integrated with a third-party account system, such asWeChat or Facebook. If yes, please refer to the following description; if not,please delete then.

If you authorize login to the Products with a thirdparty account, we will obtain from such third party your account information(such as portrait, nickname, region, gender, etc.) which may be bound with yourECORUSH 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.

·Feedback: When using feedback and suggestionfeatures in our Products, we will collect your email address, mobile phonenumber and your feedback content to address your problems and solve devicefailures on a timely basis.

·Information based on additional functions: Inorder to offer you with more convenient and higher-quality Services withoptimized user experiences, we may collect and use certain information if youconsent to use additional functions in the App. Please note, if you do notprovide such information, you may continue to use basic Services of the App andconnected Smart Devices, but certain features based on these additionalfunctions may not be available. These additional functions may include:

1)Additional functions 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 real-time precise ornon-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-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 Data Protection Terms for more details:https://privacy.google.com/businesses/gdprservices/. You may reject such use ofyour location information by managing the permission settings in the Services,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.

3)Additional services for accessing and uploadingpictures/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.

4)Additional services related to microphone-basedservice:

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.

5)Additional services based on storage permissions:

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.

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.InformationWe Collect Automatically

·Device Information: When you interact withour Product, we automatically collect device information, such as the MACaddress of your devices, IP address, wireless connectioninformation, operatingsystem type and version, application version number, push notification identifier,log files, and mobile network information.

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

·Log Information: When you use our app, thesystem and exception log may be uploaded.

Please note that one cannot identify a specificindividual by using Device Information or Log Information alone. However, ifthese types of non-personal information, combined with other information , maybe used to identify a specific individual, such non-personal information willbe treated as Personal Data. Unless we have obtained your consent or unlessotherwise provided by data protection laws and regulations, we will anonymizeand desensitize such non-personal information.

·Location Information: When you enablelocation-based functions through permission settings on your mobile device, wewill collect and process your location information to enable certain functions,such as pairing with your Smart Devices. Also, we may collect information aboutyour real-time precise or non-precise geo-location when you use our specificProducts or Services, such as Please enter the product name.

Based on your consent, when you enable the geo-fencefeature on the Products, your location information will be generated and sharedwith Google Map services. Please note that Google has corresponding dataprotection measures, which you may refer to Google Data Protection Terms formore details: https://privacy.google.com/businesses/gdprservices/. You mayreject such use of your location information by managing the permissionsettings in the Products, upon which we will cease to collect and use your locationinformation.

3.SmartDevices Related Information:

·Basic Information of Smart Devices: When youconnect your Smart Devices with our Products or Services, we may collect basicinformation about your Smart Devices such as device name, device ID, onlinestatus, activation time, firmware version, and upgrade information.

·Information Reported by Smart Devices:Depending on the different Smart Devices you elect to connect with our Productsor Services, we may collect different information reported by your SmartDevices. For example, Please enter information about the smart devicereport.

Purposesand legal basis for processing Personal Data

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

·Provide You Services: We process your accountand profile data, device information, usage data, location information, andSmart Device related information to provide you with our Products and Servicesthat you have requested or purchased. The legal basis for this processing is toperform our contract with you according to our Terms of Use.,

·Improve Our Services: We process your deviceinformation, usage data, location information and Smart Device relatedinformation to ensure the functions and safety of our Products, to develop andimprove our Products and Services, to analyze the efficiency of our operations,and to prevent and trace fraudulent or inappropriate usage. The legal basis forthis processing is to perform our contract with you according toour Terms of Use.

·Non-marketing Communication: We process yourPersonal Data to send you important information regarding the Services, changesto our terms, conditions, and policies and/or other administrative information.At the same time, we will also send you notifications related to the servicesyou have purchased, such as alert services. You can check the [AppNotification] in the App to manage these communications. When you decide not toenable the Notifications function, we will no longer process your informationfor such purpose. The legal basis for this processing is to perform ourcontract with you according to our Terms of Use.

·Marketing Communication: We may process yourPersonal Data to provide marketing and promotional materials to you on theServices. If we do so, each communication we send you will contain instructionspermitting you to opt-out of receiving future communications of that nature. Ifyou do not agree to ECORUSH sending you marketingcommunications, you may opt out when you enter the App, or by changing yourpreferences in [Privacy Settings] of the App. The legal basis for thisprocessing is your consent..

·Personalization: We may process your accountand profile data, usage data, device information to personalize product designand to provide you with services tailored for you, such as recommending anddisplaying information and advertisements regarding products suited to you, andto 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 personalization, youmay opt out when you enter the App, or by changing your preferences in [PrivacySettings] in the App. The legal basis for this processing is your consent.

·Legal Compliance: We may process yourPersonal Data as we believe to be necessary or appropriate: (a) to comply withapplicable laws and regulations; (b) to comply with legal process; (c) torespond to requests from public and government authorities (d) to enforce our termsand conditions; (e) to protect our operations, business and systems; (f) toprotect our rights, privacy, safety or property, and/or that of other users,including you; and (g) to allow us to pursue available remedies or limit thedamages that we may sustain.

If there is any change in the purposes for processingyour personal data, we will inform such change to you via email and/or aprominent notice on our website of such changes of purposes, and choices youmay have regarding your Personal Data.

Who do weShare Personal Data with?

At ECORUSH,we only share Personal Data in ways that we tell you about. We may share yourPersonal Data with the following recipients:

·To our third-party service providers who performcertain business-related functions for us, such as website hosting, dataanalysis, payment and credit card processing, infrastructure provision, ITservices, customer support service, e-mail delivery services, and other similarservices to enable them to provide services to us.

·To our customers and other business partners whoprovide you, directly or indirectly, with your Smart Devices, and/or networksand systems through which you access and use our Sites and Services.

·To an affiliate or other third party in the event ofany reorganization, merger, sale, joint venture, assignment, transfer or otherdisposition of all or any portion of our business, assets or stock (includingwithout limitation in connection with any bankruptcy or similar proceedings).In such an event, you will be notified via email and/or a prominent notice onour website of any change in ownership, incompatible new uses of your PersonalData, and choices you may have regarding your Personal Data.

·As we believe to be necessary or appropriate: (a) tocomply with applicable laws and regulations; (b) to comply with legal process;(c) to respond to requests from public and government authorities, includingpublic and government authorities outside your country of residence; (d) toenforce our terms and conditions; (e) to protect our operations, business andsystems; (f) to protect our rights, privacy, safety or property, and/or that ofother users, including you; and (g) to allow us to pursue available remedies orlimit the damages that we may sustain.

·To subsidiaries or affiliates within our corporatefamily, to carry out regular business activities.

Except for the third parties described above, tothird parties only with your consent.

InternationalTransfer of Information Collected

ECORUSHwill comply with applicable data localization requirements incorresponding jurisdictions with respect to storage of data. To facilitate ouroperation, we may transfer, store and process your Personal Data injurisdictions other than where you live. Laws in these countries may differfrom the laws applicable to your country of residence. When we do so, we willensure that an adequate level of protection is provided for the information byusing one or more of the following approaches:

lAgreement on the basis of approved EU standardcontractual clauses per GDPR Art. 46. For more information,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.

YourRights Relating to Your Personal Data

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

Confirm6: please provide at least 2 approaches forindividual user executing their privacy rights, for instance, via the privacyoffice email address; support@ecorush.eu,or 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 Personal Data that we processabout you;

·Request that we correct inaccurate or incompletePersonal Data about you;

·Request deletion of Personal Data about you;

·Request restrictions, temporarily or permanently, onour processing of some or all Personal Data about you;

·Request transfer of Personal Data to you or a thirdparty where we process the data based on your consent or a contract with you,and where our processing is automated; and

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

•Withdrawal of consent: We will exercise your privacyright to withdraw consent through the following approaches:

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

2) In the marketing communications that you agree to,the information we send to you contains instructions that allow you to withdrawyour consent in accordance with the “unsubscribe” method described in theinformation;

3) Unbind the Smart Device through the app, and theinformation related to the Smart Device will not be collected;

4) By using product with the visitor mode, we willnot collect any personal data about you;

When you withdraw your consent or authorization, wemay not be able to continue to provide you with the products or servicescorrespondingly. However, your withdrawal of your consent or authorization willnot affect the processing of personal information based on your consent beforethe withdrawal.

Confirm7: if the App enables the accountdeletion/termination, please fill out the route in the App to delete/terminatethe account.

Security

We use commercially reasonable physical,administrative, and technical safeguards to preserve the integrity and securityof your Personal Data. ECORUSH providesvarious security strategies to effectively ensure data security of user anddevice. As for device access, ECORUSH proprietaryalgorithms are employed to ensure data isolation, access authentication,applying for authorization. As for data communication, communication usingsecurity algorithms 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 support@ecorush.eu.

DataRetention

We process your Personal Data for the minimum periodnecessary for the purposes set out in this Privacy Policy, unless there is aspecific legal requirement for us to keep the data for a longer retentionperiod. We determine the appropriate retention period based on the amount,nature, and sensitivity of your Personal Data, and after the retention periodends, we will destruct your Personal Data. When we are unable to do so fortechnical reasons, we will ensure that appropriate measures are put in place toprevent any further such use of your Personal Data.

Children’sPrivacy

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 fromanyone under the age of thirteen (13) unless we first obtain permission fromthat child’s parent or legal guardian. If we become aware that we have collectedPersonal Data from anyone under the age of thirteen (13) without permissionfrom that child’s parent or legal guardian, we will take steps to remove thatinformation.

Changesto 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.

ContactUs

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

ECORUSHIntelligent Technology

Postal Mailing Address: UNIT 8 OLDBURY POINT, ROOD ENDROAD

Email: support@ecorush.eu