Cootli Privacy Policy
Effective Date:25.08.2024
Updated: 25.08.2024
Cootli andsubsidiaries (“we”, “us”, “our”, “Cootli”) are committed to protecting yourprivacy. This Privacy Policy (“Policy”) describes our practices in connectionwith information privacy on Personal Data we process through your individualuse of the following services, products, and related mobile applications(collectively, the “Products”):
Cootli MobileApplication
Before you useour Products, please carefully read through this Policy and understand ourpurposes and practices of collection, processing of your Personal Data,including how we use, store, share and transfer Personal Data. In the Policyyou will also find ways to execute your rights of access, update, delete orprotect your Personal Data.
When you acceptthis Policy when you register with your Personal Data, or if you start to useour Products and does not expressly object to the contents of this Policy, wewill consider that you fully understand and agree with this Policy. If you haveany question r regarding this Policy, please do not hesitate to contact us via:
For otherbranded mobile applications powered by Cootli, our Clients control all thePersonal Data collected through our Products. We collect the information underthe direction of our Clients and the processing of such information shall belimited to the purpose of providing the service for which our Clients hasengaged us. If you are a customer of one of our Clients and would no longerlike to be contacted by one of our Clients that use our service, please contactthe Client that you interact with directly.
Definition
In this Policy,Personal Data means information generated, collected, recorded and/or stored,electronically or otherwise, that can be used to identify an individual orreflect the activity of an individual, either from that information alone, orfrom that information and other information we have access to about thatindividual.
PersonalSensitive Data includes personal biometric information, communication records andcontents, health information, transaction information, and precise locationinformation. When we collect Personal Sensitive Data from you, we will generatean explicit notification for your consent before we collection personalsensitive data about you.
Smart Devicesrefers to those computing devices produced or manufactured by hardwaremanufacturers, with human-machine interface and the ability to transmit datathat connect wirelessly to a network, including: smart home appliances, smartwearable devices, smart air cleaning devices, etc.
Apps refers tothose mobile applications developed by Cootli that provide end usersremote control to Smart Devices and with the ability to connect to the supplierIoT Platform.
What PersonalData do we collect
In order toprovide our services to you, we will ask you to provide necessary Personal Datathat is required to provide those services. If you do not provide your PersonalData, we may not be able to provide you with our products or services.
1.InformationYou Voluntarily Provide Us
RegisteredAccount Data: When you register an account with us, we may collect your nameand contact details, such as your email address, phone number, user name, andlogin credentials. During your interaction with our Products, we may furthercollect your nickname, profile picture, country code, language preference ortime zone information into your account.
Feedback: Whenusing feedback and suggestion features in our Products, we will collect youremail address, mobile phone number and your feedback content to address yourproblems and solve device failures on a timely basis.
Informationbased on additional functions:
Confirm: thesystem permissions that allow in the your App
In order tooffer you with more convenient and higher-quality Services with optimized userexperiences, we may collect and use certain information if you consent to useadditional functions in the App. Please note, if you do not provide suchinformation, you may continue to use basic Services of the App and connectedSmart Devices, but certain features based on these additional functions may notbe available. These additional functions may include:
1)Additionalfunctions based on location information:
When you enablethe location-based functions through permission settings on your mobile device,we will collect and process your location information to enable thesefunctions, such as pairing with your Smart Devices. Also, we may collectinformation about your: a) real-time and precise location, for instance when youchoose to use the automation scenarios for controlling your Smart Devices, orb) non-precise geo-location when you use certain Smart Devices or the Services,such as robot cleaner and weather service.
Based on yourconsent, when you enable the geo-fence feature, your location information willbe generated and shared with Google Maps services. Please note that Google hascorresponding data protection measures, which you may refer to Google’s DataProcessing and Security Terms for more details.
You may disablethe collection and use of your location information by changing your mobiledevice settings ("My - Setting - Privacy Right Setting - Switch on/offLocation Information"), upon which we will cease to collect and use yourlocation information.
2)Additionalservices based on camera:
You may use thecamera to scan the code by turning on the camera permission to pair with aSmart Device, take video, etc. Please be aware that even if you have agreed toenable the camera permission, we will only obtain information when you activelyuse the camera for scanning codes, video recording, etc.
You may opt-outthe 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 usethis function to upload your photos/pictures/videos after turning on the photoalbum permission, so as to realize functions such as changing the avatar,reporting device usage problems by providing photo proofs, etc.. When you usethe photos and other functions, we will not recognize this information; butwhen you report a device usage problem, we may use the photos/pictures youupload to locate your problem.
You may opt-outthe 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 themicrophone to send voice information after turning on the microphonepermission, such as shooting videos, waking up the voice assistant, etc. Forthese functions, we will collect your voice information to recognize yourcommand. Please be aware that even if you have agreed to enable the microphonepermission, we will only obtain voice information through the microphone whenyou voluntarily activate the microphone in the App.
You may opt-outthe using of microphone permission: "My - Setting - Privacy Right Setting- Switch on/off Microphone".
5)Additionalservices based on storage permission(Android):
The purpose isto ensure the stable operation of the App by utilizing the storage permission.After you give or indicate the permission to read/write your mobile device’sstorage, we will access pictures, files, crash log information and othernecessary information from your mobile device’s storage to provide you withfunctions, such as information publications, or record the crash loginformation locally.
You may opt-outthe using of storage permission: "My - Setting - Privacy Right Setting -Switch on/off Storage".
6)Additionalservices based on Notification permission:
The reason whywe ask you for the permission is to send you notifications about using theSmart Devices or Services, especially if you have purchased security servicesand you require an alert or message so that you can capture the real-timestatus.
You may opt-outthe using of App notifications: "My - Message Center - Setting - Switchon/off Notifications".
7) Additionalservices based on Alert Window permission：
You may chooseto bind a camera in the App and require the App to display the real-time imageof the camera in a separate window.
You may opt-outthe using of alert window information: "My - Setting - Privacy RightSetting - Switch on/off Alert Window".
8) Additionalservices based on Bluetooth permission:
You can enableBluetooth functions after turning on the permission, including controlling theSmart Devices, acquiring status of, discovering and configuring Smart Devices.In these functions, we will communicate with Smart Devices via Bluetooth.Please be aware that even if you have agreed to enable the Bluetoothpermission, we will only use Bluetooth for communication in these scenarios:display device status on the home page and Smart Device panel; perform devicecontrol on the home page and Smart Device panel; discovering Smart Devices onthe home page and the add device page, Smart Device distribution network.
You may opt-outthe using of Bluetooth via "My - Settings - Privacy Setting -Disable/Enable Bluetooth permission".
9）Additional services based onHomeKit permission (iOS):
You can enablerelated functions after enabling HomeKit permissions, including discoveringSmart Devices, enabling Smart Device network configuration, controlling SmartDevices, and checking device status. Among these functions, we will processdata with the "Home“ App that comes with the iOS system through HomeKit.Please be aware that even if you have agreed to enable the HomeKit permission,we will only use it in these scenarios: on the home page, to discover HomeKitdevices, HomeKit device network configuration; in "Settings -HomeKit" for discovering HomeKit devices, HomeKit device networkconfiguration.
You may opt-outthe using of HomeKit permission via "My - Settings - Privacy Settings-Turnoff/on HomeKit permission".
10）Additional services based onHealthKit (iOS):
You canproactively enable related functions after enabling HealthKit permission,including statistics on weight, height, running, and swimming. In thesefunctions, we will exchange data with the health-related functionalities thatcomes with the iOS system through HealthKit. Please be aware that even if youhave agreed to enable HealthKit permission, we will only use them in thesescenarios: when you use the health-related Smart Device, such as body fatscales, bracelets, watch and consent to use the HealthKit, the data reported bythe Smart Device will be transferred to HealthKit.
You may opt-outthe using of HealthKit permission via "My - Settings - Privacy Settings -Turn off/on HealthKit permission".
Please notethat if you turn on any permission, you authorize us to collect and userelevant personal information to provide you with corresponding Services. Onceyou turn off any permission, we will take it as canceling the authorization,and we will no longer continue to collect Personal Data based on thecorresponding permissions, and the related functions may be terminated.However, your decision to turn off the permission will not affect the previouscollection and use of information based on your authorization.
2.InformationWe Collect Automatically
Mobile DeviceInformation: When you interact with our Services, in order to provide andmaintain the normal operation of our Services, to improve and optimize ourServices, and to protect your account security as well, we automaticallycollect mobile device information, such as mobile device model number, IPaddress, wireless connection information, the type and version of the operatingsystem, application version number, push notification identifier, logfiles, and mobile network information. Meanwhile, we will collect your softwareversion number. In order to ensure the security of the operating environment orto provide services, we will collect information about the installed mobileapplications and other software you use.
Usage Data:During your interaction with our websites and Services, we automaticallycollect usage data relating to visits, clicks, downloads, messages sent/received,and other usage of our websites and Services.
LogInformation: When you use the App, in order to improve your user experience,the system and exception log may be uploaded, including your IP address,language preference setting, operating system version, date or time of access,so that we can facilitate and accurately identify problems and help you solvethem in timely manner.
Please note thatwe cannot identify a specific individual by using device information or loginformation 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 yourconsent or unless otherwise provided by data protection laws and regulations,we will aggregate or desensitize such information..
3.Smart DevicesRelated Information:
BasicInformation of Smart Devices: When you connect your Smart Devices with theServices, we may collect basic information about your Smart Devices such asdevice name, device ID, online status, activation time, firmware version, andupgrade information.
Informationcollected during the process of connecting to a Smart Device: Based on the typeof Smart Device you need to connect, the basic information collected includes:Wi-Fi information, device MAC address, etc.
InformationReported by Smart Devices: Depending on the different Smart Devices you electto connect with our Products or Services, we may collect different informationreported by your Smart Devices. For example, Please enter information about thesmart device report.
Confirm: If theproduct involves sensitive personal information, such as health products,please be sure to explain it in the privacy policy. For example: smart scalesor fitness trackers may report your height, weight, body fat content (BFM) ,Body mass index (BMI) and skeletal muscle content (SMM); Confirm: Whetherintegrated third-party health analysis functions, such as Apple Health, GoogleHealth, etc., if so, please refer to the following description; if not, you candelete then:
Please notethat when you actively agree to enter the App name and the application isconnected to the Apple Health(or some other Health related platform, name it?),we will share your measurement data with Apple Health (including only your BMI,height, weight and body fat% data). The purpose of sharing data is only tomeasure and analyze health-related indicators related to you, and it will neverbe disclosed to other third parties. You can close at any time by managing theHealthKit settings page.
Confirm: If theproduct involves sensitive personal information, such as camera products,especially with facial recognition equipment, please be sure to make relevantexplanations in the privacy policy. For example, smart cameras may collectimages or videos taken by them.
Purposes and legalbasis for processing Personal Data
The purpose forwhich we may process information about you are as follows:
Provide Youwith Our Services: We process your account data, mobile device information,usage data, location information, and Smart Device related information toprovide you with the Services that you have requested. The legal basis for thisprocessing is to perform our contract with you according to user agreement orsome other terms of user? Confirm.
Improve OurServices: We process your mobile device information, usage data, locationinformation and Smart Device related information to ensure the functions andsafety of the Services, to develop and improve the Services, to analyze theefficiency of our operations and to prevent and trace fraudulent orinappropriate usage. The legal basis for this processing is to perform ourcontract with you according to our user agreement or some other terms of user?Confirm.
Non-marketingCommunication: We process your Personal Data to send you important informationregarding the Services, changes to our terms, conditions, and policies and/orother administrative information. At the same time, we will also send younotifications related to the services you have purchased, such as alertservices. You can check the “App Notification” in the App ("Me &rt;Message Center &rt; Setting &rt; Notification Setting”) to manage thesecommunications. When you decide not to enable the Notifications function, wewill no longer process your information for such purpose. The legal basis forthis processing is to perform our contract with you according to our useragreement or some other terms of user? Confirm.
Data Analysis:In order to analyze the usage of the products we provide and improve your userexperience, we will analyze the data you provide us, a) we need to check yourproblems when you encounter any malfunctions during the usage of the product,under such circumstance, you may not able to opt-out because it is highlyrelate to your functionalities and quality of using our product and service,and b) analyze data about how you interface with the product or underparticular scenarios so that you can better enjoy the convenience brought byour Services, under such circumstance, if you do not agree to data analysis ofyour data, you can enter the privacy settings of App (“My &rt; Settings &rt;Privacy Settings &rt; Data Analysis”) to opt-out your selection. The legalbasis for such processing is based on your consent.
MarketingCommunication and Personalization: We may process your account data, usagedata, device information to personalize product design and to provide you withservices tailored for you, such as recommending and displaying information andadvertisements regarding products suited to you, and to invite you toparticipate in surveys relating to your use of the Services. If you do notallow us to process your Personal Data for personalization, you may opt outwhen you enter the App, or by changing your preferences in “Privacy Settings”(“Me&rt; Settings &rt; Privacy Settings &rt; Personalization”) in the App. Thelegal basis for this processing is your consent.
LegalCompliance. We disclose information if we are legally required to do so, or ifwe have a good faith belief that such use is reasonably necessary to:
comply with alegal obligation, process or request;
enforce ourUser Agreement and other agreements, policies, and standards, includinginvestigation of any potential violation thereof;
protect therights, property or safety of us, our users, a third party or the public asrequired or permitted by law; or
detect, preventor otherwise address security, fraud or technical issues.
If there is anychange in the purposes for processing your personal data, we will inform suchchange to you via email and/or a prominent notice on our website of suchchanges of purposes, and choices you may have regarding your Personal Data.
Who do we SharePersonal Data with?
At Cootli weonly share Personal Data in ways that we tell you about. We may share yourPersonal Data with the following recipients: Confirm the following details
To ourthird-party service providers who perform certain business-related functionsfor us, such as website hosting, data analysis, payment and credit cardprocessing, infrastructure provision, IT services, customer support service,e-mail delivery services, and other similar services to enable them to provideservices to us.
To ourcustomers and other business partners who provide you, directly or indirectly,with your Smart Devices, and/or networks and systems through which you accessand use our websites and Services.
To subsidiariesor affiliates within our corporate family for purpose of regular businessactivities based on our instructions and in compliance with applicable law,this Policy and other appropriate confidentiality and security measures.
To an affiliateor other third party in the event of any reorganization, merger, sale, jointventure, 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 believein good faith that access to, or use, preservation, or disclosure of theinformation is reasonably necessary or appropriate to:
(a)Comply withapplicable law, regulation, legal process, or lawful governmental request;
(b)Enforce ourUser Agreement and other agreements, policies, and standards, includinginvestigation of any potential violation thereof;
(c) Protect ouroperation and business systems;
(d)Protect therights, property or safety of us, our users, a third party or the public asrequired or permitted by law; or
(e)Perform riskmanagement, screening and checks for unlawful, fraudulent, deceptive ormalicious activities.
Except for thethird parties mentioned above, we only disclose your Personal Data to otherthird parties with your consent.
InternationalTransfer of Information Collected
Cootli 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 onthe basis of approved EU standard contractual clauses per GDPR Art. 46. Formore information,see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
Confirm: Pleaseadd if there is any international transfer mechanism you are relying on, forinstance Privacy Shield.
If you wouldlike further detail on the safeguards we have in place, you can contact usdirectly as described in this Privacy Policy.
Your RightsRelating to Your Personal Data
We respect yourrights and control over your Personal Data. You may exercise any of thefollowing rights:
Confirm: pleaseprovide at least 2 approaches for individual user executing their privacy rights,for instance, via the privacy office email address; ***@***.com, or via the route of Feedback imbedded in the App:Me&rt;Personal Center&rt;Account and Security&rt;, etc.
You do not haveto pay a fee and we will aim to respond you within 30 days. If you decide toemail us, in your request, please make clear what information you would like tohave changed, whether you would like to have your Personal Data deleted fromour database or otherwise let us know what limitations you would like to put onour use of your Personal Data. Please note that we may ask you to verify youridentity before taking further action on your request, for security purposes.
You may:
Request accessto the Personal Data that we process about you: "My-Setting-PrivacySettings-Personal Data Export";
Request that wecorrect inaccurate or incomplete Personal Data about you: 1) Modify youraccount number (email address or phone number): "My-Setting-Account andSecurity-Change your Account"; 2) Modify the nickname and/or time zone:"My-Personal Information";
Requestdeletion of Personal Data about you: "My-Setting-Account andSecurity-Delete Account", when you confirm the deletion of your account,your Personal Data will be deleted accordingly.
Requestrestrictions, temporarily or permanently, on our processing of some or allPersonal Data about you: Please send over your request through "My-FAQ& Feedback", or send over the email request to Confirm: the emailbox?;
Requesttransfer of Personal Data to you or a third party where we process the databased on your consent or a contract with you, and where our processing isautomated: Please send over your request through "My-FAQ &Feedback", or send over the email request to Confirm: the emailbox?;
Opt-out orobject to our use of Personal Data about you where our use is based on yourconsent or our legitimate interests.
Withdrawal ofconsent Confirm the following details: We will exercise your privacy right towithdraw consent through the following approaches:
1)For privacypermissions acquired through device system settings, your consent can bewithdrawn by changing device permissions, including Confirm: location, camera,photo album (picture library/video library), microphone, Bluetooth settings,notification settings and other related functions;
2)You mayopt-out the non-marketing communication through “Me &rt; Message Center &rt;Notification Settings” to manage your selection;
3)You mayopt-out the data analysis features through “Me &rt; Settings &rt; Privacy Settings”;
4)You mayopt-out the Personalization feature through “Me &rt; Settings &rt; PrivacySettings &rt; Personalization”;
5)Unbind theSmart Device through the App, and the information related to the Smart Devicewill not be collected;
6)By usingproduct with the "Try Now" mode, and not enable certainlocation setting for particular smart scene, we will not collect anyPersonal Data about you;
7)If youpreviously agreed to associate App account with a third-party service, such asa health platform, please unbind it on the third-party platform.
When youwithdraw your consent or authorization, we may not be able to continue toprovide you with certain products or services correspondingly. However, yourwithdrawal of your consent or authorization will not affect the processing ofpersonal information based on your consent before the withdrawal.
About Deletionof the Account: You can find the Delete function through “Me &rt; Settings &rt;Account and Security &rt; Delete Account” (Deactivate Account）
SecurityMeasures
We usecommercially reasonable physical, administrative, and technical safeguards topreserve the integrity and security of your Personal Data. Cootli providesvarious security strategies to effectively ensure data security of user anddevice. As for device access, Cootli proprietary algorithms are employedto ensure data isolation, access authentication, applying for authorization. Asfor data communication, communication using security algorithms andtransmission 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 Please enter your privacyemail address.
Data Retention
We process yourPersonal Data for the minimum period necessary for the purposes set out in thisPolicy, unless there is a specific legal requirement for us to keep the datafor a longer retention period. We determine the appropriate retention periodbased on the amount, nature, and sensitivity of your Personal Data, and afterthe retention period ends, we will destruct your Personal Data.
For as long asyou require us to fulfill the products and services you request from us asdefined in the Confirm user agreement or some other terms of use?;
Personal Datawill no longer be retained when you request to remove your Personal Data, wewill accordingly complete the task.
When we areunable to do so for technical reasons, we will ensure that appropriate measuresare put in place to prevent any further such use of your Personal Data.
Children’sPrivacy
Protecting theprivacy of young children is especially important to us. The Services are notdirected to individuals under the age of thirteen (13) (or such other ageprovided by applicable law in your country/region of residence), and we requestthat these individuals do not provide any Personal Data to us. We do notknowingly collect Personal Data from any child unless we first obtainpermission from that child’s parent or legal guardian. If we become aware thatwe have collected Personal Data from any child without permission from thatchild’s parent or legal guardian, we will take steps to remove thatinformation..
Changes to thisPrivacy Policy
We may updatethis Privacy Policy to reflect changes to our information practices. If we makeany material changes we will notify you by email (send to the e-mail addressspecified in your account) or by means of a notice in the mobile applicationsprior to the change becoming effective. We encourage you to periodically reviewthis page for the latest information on our privacy practices.
Contact Us
If you have anyquestions about our practices or this Privacy Policy, please contact us asfollows:
Cootli
Postal MailingAddress:
Email: