Tuya Mobile Privacy Notice
Effective Date: 2024-10-14
Updated: 2024-10-14
PT Stella Satindo its affiliates andsubsidiaries (“we”, “us”, “our”, “Tuya”) are committed to protecting yourprivacy. This Privacy Statement (“Statement”) describes our practices inconnection with information privacy on personal data we process through yourindividual use of the following services, products, and related mobileapplications (collectively, the “Products”)
· BIOTASmart Home Mobile Application
In this Privacy Notice, “Personal Data”means information that can be used to identify an individual, either from thatinformation alone, or from that information and other information we haveaccess to about that individual. “Smart Devices” refers to those nonstandardcomputing devices produced or manufactured by hardware manufacturers, withhuman-machine interface and the ability to transmit data that connectwirelessly to a network, including: smart home appliances, smart wearabledevices, smart air cleaning devices, etc. “Apps” refers to those mobileapplications developed by Tuya that provide end users remote control to SmartDevices and with the ability to connect to Tuya IoT Platform.
For other branded mobile applicationspowered by Tuya, our Clients control all the Personal Data collected throughour Products. We collect the information under the direction of our Clients andthe processing of such information shall be limited to the purpose of providingthe service for which our Clients has engaged us. If you are a customer of oneof our Clients and would no longer like to be contacted by one of our Clientsthat use our service, please contact the Client that you interact withdirectly.
What Personal Data do we collect
In order to provide our services toyou, we will ask you to provide necessary personal data that is required toprovide those services. If you do not provide your personal data, we may not beable to provide you with our products or services.
· InformationYou Voluntarily Provide Us
o Account or Profile Data: When you register an account with us,we may collect your name and contact details, such as your name, email address,mailing 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.
o Feedback: When using feedback and suggestion features in our Products,we will collect your email address, mobile phone number and your feedbackcontent to address your problems and solve device failures on a timely basis.
· InformationWe Collect Automatically
o Device Information: When you interact with our Product,we automatically collect device information, such as the MAC address of yourdevices, IP address, wireless connection information, operating system type andversion, application version number, push notification identifier, log files,and mobile network information.
o Data Usage: During your interaction with our Sites and Services, weautomatically collect usage data relating to visits, clicks, downloads,messages sent/received, and other usage of our Sites and Services.
o Location information: We will collect information aboutyour real-time precise or non-precise geo-location when you use our specificproducts or services, such as robot cleaner and weather service.
· SmartDevices Related Information:When you use Smart Devices that are connected to our Services, depending on thecapability of your Smart Devices, we may collect certain types of your data inorder to provide your services you have requested or purchased.
o Basic information of smart devices: The basic information may includedevice name, device id, online status, activation time, firmware and upgradeinformation.
o Information reported by smart devices: When you use our products we maycollect different information reported by your devices. For example, smartweights or fitness trackers may report your height, weight, body fat mass(BFM), BMI and skeletal muscle mass (SMM), and smart camera may collect theimages or videos captured by it.
Purposesand legal basis for processing Personal Data
The purpose for which we may processinformation about you are as follows:
· ProvideYou Services: We processuseyour account and profile data, device information, usage data, locationinformation, and Smart Device related information Tto provide you with ourPproducts and Sservices that you have requested or purchased. The legal basisfor this processing this usage is to perform our contract with you according toour Terms of Use.
· ImproveOur Services: We processyour device information, usage data, location information and Smart Devicerelated information to ensure the functions and safety of our Products, todevelop and improve our Products and Services, to analyze the efficiency of ouroperations, and to prevent fraudulent or inappropriate usage.
· Non-marketingCommunication: We processyour personal data to send you important information regarding the Services,changes to our terms, conditions, and policies and/or other administrativeinformation. Because this information may be important, you may not opt-out ofreceiving such communications. The legal basis for this processing is toperform our contract with you according to our Terms of Use.
· MarketingCommunication: We mayprocess your personal data to provide marketing and promotional materials toyou on our Products and Services. If we do so, each communication we send youwill contain instructions permitting you to opt-out of receiving futurecommunications of that nature. Additionally, if you consent to participate inour lottery, contest or other promotions, we may use your personal data tomanage such activities.
· Personalization: We process your account and profiledata, usage data, device information to personalize product design and toprovide you with services tailored for you, such as recommending and displayinginformation and advertisements regarding products suited to you, and to inviteyou to participate in surveys relating to your use of our Products.
· LegalCompliance: We may process your personal data aswe believe to be necessary or appropriate: (a) to comply with applicable lawsand regulations; (b) to comply with legal process; (c) to respond to requestsfrom public and government authorities (d) to enforce our terms and conditions;(e) to protect our operations, business and systems; (f) to protect 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 the damages that we maysustain.
Whodo we share your informationPersonal Data with?
At Tuya, we only share personal data inways that we tell you about.
If Tuya shares your personal data witha third party under the circumstance described in this section, Tuya will ensurethat the third party is subject to practices and obligations to comply with therelevant data protection and privacy laws of your country. Tuya willcontractually ensure compliance by any foreign Third Party Service Providerswith the privacy standards that apply in your home jurisdiction.
We may share your Personal Data withthe 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.
· Toour customers 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 Sites and Services.
· Toan affiliate or other third party in the event of any reorganization, merger,sale, joint venture, assignment, transfer or other disposition of all or anyportion of our business, assets or stock (including without limitation inconnection with any bankruptcy or similar proceedings). In such an event, youwill be notified via email and/or a prominent notice on our website of anychange in ownership, incompatible new uses of your personal information, andchoices you may have regarding your personal information.
· Aswe believe to be necessary or appropriate: (a) to comply with applicable lawsand regulations; (b) to comply with legal process; (c) to respond to requestsfrom public and government authorities, including public and governmentauthorities outside your country of residence; (d) to enforce our terms andconditions; (e) to protect our operations, business and systems; (f) to protectour rights, privacy, safety or property, and/or that of other users, includingyou; and (g) to allow us to pursue available remedies or limit the damages thatwe may sustain.
· Tosubsidiaries or affiliates within our corporate family, to carry out regularbusiness activities.
Except for the third parties describedabove, to third parties only with your consent.
Your Rights Relating to Your Personal Data
We respect your rights and control overyour personal data. You may exercise any of the following rights:
· Viathe “Profile – Personal Center” in our Products (for Product version 3.2 andlater)
You do not have to pay a fee and wewill aim to respond you within 30 days. If you decide to email us, in yourrequest, please make clear what information you would like to have changed,whether you would like to have your personal information deleted from ourdatabase or otherwise let us know what limitations you would like to put on ouruse of your personal information. Please note that we may ask you to verifyyour identity before taking further action on your request, for securitypurposes.
You may:
· Requestaccess to the personal data that we process about you;
· Requestthat we correct inaccurate or incomplete personal information about you;
· Requestdeletion of personal data about you;
· Requestrestrictions, temporarily or permanently, on our processing of some or allpersonal data about you;
· Requesttransfer of personal information to you or a third party where we process thedata based on your consent or a contract with you, and where our processing isautomated; and
· Opt-outor object to our use of personal data about you where our use is based on yourconsent or our legitimate interests.
Information Security Safeguards
We use commercially reasonablephysical, administrative, and technical safeguards to preserve the integrityand security of your personal information. Tuya provides various securitystrategies to effectively ensure data security of user and device. As fordevice access, Tuya proprietary algorithms are employed to ensure dataisolation, access authentication, applying for authorization. As for datacommunication, communication using security algorithms, and transmissionencryption protocols and commercial level information encryption transmissionbased on dynamic keys are supported. As for data processing, strict datafiltering and validation and complete data audit are applied. As for datastorage, all confidential information of users will be safely encrypted forstorage. If you have reason to believe that your interaction with us is nolonger secure (for example, if you feel that the security of any account youmight have with us has been compromised), you must immediately notify us of theproblem by steven@biotahome.com. Information Retention Period
We process your personal data for theminimum period necessary for the purposes set out in this Privacy Notice,unless there is a specific legal requirement for us to keep the data for alonger retention period. We determine the appropriate retention period based onthe amount, nature, and sensitivity of your personal data, and after theretention period ends, we will destruct your personal data. When we are unableto do so for technical reasons, we will ensure that appropriate measures areput in place to prevent any further such use of your personal data.
Changes to this Policy Notice
We may update this Privacy Notice toreflect changes to our information practices. If we make any material changes,we will notify you by email (send to the e-mail address specified in youraccount) or by means of a notice in the mobile applications prior to the changebecoming effective. We encourage you to periodically review this page for thelatest information on our privacy practices.
Legal application and jurisdiction
This policy is formulated in accordancewith the laws of the People's Republic of China and shall be governed by thelaws of the People's Republic of China.
If you have any questions about ourpractices or this Privacy Notice, please contact us as follows:
Company Name: PT Stella Satindo
Postal Mailing Address: 75 E SantaClara St, 6th Floor, San Jose, CA 95113 177 E Colorado Blvd, 2nd Floor,Pasadena, CA 91105.
Email: Steven@biotahome.com.