PRIVACY POLICY

OUR COMMITMENT TO YOU

This Privacy Policy sets out how Shenzhen Elink Things Co.,Ltd ("Elink Things", "we", "our" or "us") collect, use, disclose, process and protect any information that you give us when you use our products and services located at http:// www.elinkthings.com and our Suite of applications that we offer. Should we ask you to provide certain information by which you can be identified when using Elink Things products and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to Elink Things.

In this Privacy Policy, "personal information" means information that can be used to identify an individual, either from that information alone or from that information combined with other information about that individual. Such personal information may include your name, address, telephone number and email address.

By using Elink Things products and services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarised in this Privacy Policy, please contact our Data Protection Officer at app@elinkthings.com to address your specific concerns. We will be happy to address them directly.

WHAT INFORMATION IS COLLECTED AND HOW DO WE USE IT?

TYPES OF INFORMATION COLLECTED

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.

We may collect the following types of information (which may or may not be personal information):

Information about you: We may collect and use features such as email, avatars, personalized signatures, nicknames, gender, time zones, languages, and regions.

Device Record information: When you use AILink to synchronize device data, personal data is recorded, including but not limited to: Brush record(brush time、Brushing range、Evnness etc.).

Phone Info: When you use the AILink, we need to get your phone operating system and version of the mobile phone brand model only to determine whether AILink is supported, and we will not keep this type of information .

Network Usage Information: We may collect network types, network signals, etc. related to certain features of the AILink only when provide corresponding service for you, and we will not keep this type of information.

Location information: When you use location-based program services or features, we may collect your location information.

Device Information: When you use AILink to connect a hardware device, including but not limited to, the device's unique identifier, firmware version, and approximate geographic location information (non-personal information) will be sent to the server. The collection of the above information may also apply to your update system or software, restore factory settings and so on.

Debug log information: We will not collect your debug log information unless when you choose to upload debug logs to help us analyze the problem, your application debug log file will be sent to the server.

We may also collect other types of information which are not linked to an individual and which is anonymous. For example, using behaviours and information about the problem may be collected when you agree to enter into User Experience Program . Such information is collected in order to improve the services we provide to you,and we will only keep it for one year .

HOW THE PERSONAL INFORMATION IS USED

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies (which are in the communications, social media, technology and cloud businesses), Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

Here are more details on how we use your information (which may include personal information)

Setting up your Account. Personal information collected when creating a Account on our web sites or through our mobile devices is used for creating the personal Account and profile page for the user.

Calculate exercise results. Personal body information are used to accurately calculate the exercise result information.

Providing AILink services. Information relating to device information will show the user the information associated with it.

Providing management devices. This information provides the ability to manage the bundled devices.

Improve software stability. Collect crash logs for analyzing software quality to provide better service.

DIRECT MARKETING

We may use your name, phone number, and email address, to provide marketing materials to you relating to goods and services of Elink Things companies and our business partners which offer network, mobile applications and cloud products and services. To provide better user experience, we may recommend above-mentioned products, services and activities based on information about your purchase history, website browsing history, birthday, age, gender, and location. We will only so use your personal data after we have obtained your consent or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication. We will not transfer your personal data to our business partners for use by our business partners in direct marketing.

WHO DO WE SHARE YOUR INFORMATION WITH?

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that Elink Things will only share your personal information in accordance with your consent. You should know that when Elink Things shares your personal information with a Third Party Service Provider under any circumstance described in this section, Elink Things will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Elink Things will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Third-party service information acquisition

Third-party integration SDKs are provided by external third-party subjects. Integration third-party SDKs include and are not limited to: Mob.com SDK, Tencent bugly SDK, 360 Qihoo SDK.

AILink APP does not have access to the information generated by your use of such third-party services. However, if you have explicitly consented to that third party obtaining your information, that third party will have access to it via the AILink APP interface to obtain your information, personal data, network usage data, etc. If you refuse to provide this information it will only prevent you from using the above mentioned third party services, but will not affect your normal use of the AILink App's functionality. All access to third-party services, AILink App promises to strictly follow the third-party product agreement and privacy policy.

SHARING WITH OUR GROUP AND THIRD PARTY SERVICE PROVIDERS

In order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other Elink Things affiliated companies (in communications, social media, technology or cloud businesses), or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centres, data storage facilities, customer service providers, advertising and marketing service providers, and Elink Things’s representatives. Such Third Party Service Providers would be processing your personal information on Elink Things’s behalf or for one or more of the purposes listed above.If you no longer wish to allow us to share this information, please contact us at app@elinkthings.com.

SHARING WITH OTHERS

Elink Things may disclose your personal information without further consent when required under applicable law.

INFORMATION NOT REQUIRING CONSENT

We may share anonymised information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

For the avoidance of doubt, Elink Things may collect, use or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws. Such disclosure may be brought about by the necessity to protect our rights, ensure the safety of you and other people, and comply with the requirements of the local government to facilitate the investigations of illegal activities.

SECURITY SAFEGUARDS

Elink Things’S SECURITY MEASURES

We are committed to ensuring that your personal information is secure. In order to prevent unauthorised access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect from your using of Elink Things products and services. We will use all reasonable efforts to safeguard your personal information.

All your personal information is stored on secure servers that are protected in controlled facilities. We nameify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorised access and use.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

WHAT YOU CAN DO

You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorised by you.

Elink Things cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorised use of your account by any other Internet user or any other breach of security.

Your assistance will help us protect the privacy of your personal information.

You can synchronize the data generated by using the APP, including but not limited to weight and body fat data, to Google Fit or Fitbit

The APP will not actively obtain your data from Google Fit or Fitbit

RETENTION POLICY

Personal information will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information, including the cases when the personal information is no longer required for resolving legal disputes, applying our Agreements, or achieving our business goals.

For clarity, personal body information and Information about you are totally in your control , you can choose when to delete it at your discretion，and we will cease to retain such information. If you have any comments, please send us an email: app@elinkthings.com.

ACCESSING OTHER FEATURES ON YOUR DEVICE

Our applications may need access to certain features on your device such as enabling emails to contacts, SMS storage and Wi-Fi network status, as well as other features. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at app@elinkthings.com.

YOU HAVE CONTROL OVER YOUR INFORMATION!

CONTROLLING SETTINGS

Elink Things recognises that privacy concerns differ from person to person. Therefore, we provide examples of ways Elink Things makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

Switch on/off user data upload to cloud.

Log in and out of the Account.

You may obtain more details in relation to your device’s security status in the UI Security Centre as well.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at app@elinkthings.com.

ACCESS, UPDATING, CORRECTING OR ERASURE YOUR PERSONAL INFORMATION

You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

We normally provide such services for free but reserve the right to charge a reasonable fee for your data access request.

If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete or if you believe any information we are holding on you is inappropriate or excessive, please write to or email us as soon as possible at the email address below. Email: iot@ Elink Things-tek.com.

WITHDRAWAL OF CONSENT

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. This may be done by accessing your Account management centre at account. Elink Things.com/pass/del

.We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.

Please recognise that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy Elink Things’s products and services.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF YOUR JURISDICTION

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, technology and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards.

MISCELLANEOUS

MINORS

We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.

Elink Things does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided Elink Things with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable Elink Things services.

ORDER OF PRECEDENCE

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

UPDATES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the Elink Things websites or through our software, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products and services offered by a third party. Elink Things products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

SOCIAL MEDIA (FEATURES) AND WIDGETS

Our websites include social media features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

SINGLE SIGN-ON

Depending on your jurisdiction, you may be able to log in to our website using sign-on services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this website to your profile page to share with others within your network.

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to Elink Things’s collection, use or disclosure of your personal information, please contact our Data Protection Officer at the E-mail below referencing "Privacy Policy":

E-mail: app@elinkthings.com

Thank you for taking the time to understand our Privacy Policy!