PRIVACY POLICY

 

 

Effective: March 10, 2023

 

Your privacy is important to us. We respect the privacy rights of all individuals and we are committed to handling your personal information responsibly and in accordance with the applicable law. Please take a moment to familiarize yourself with our Privacy Policy and let us know if you have any questions.

 

PURPOSE

 

This Privacy Policy describes how we manage your personal information for products and services provided by Anhui Huami Information Technology Co., Ltd. ("we", "our" or "us"). This Privacy Policy also applies to personal information that is processed by us in the course of our business, including on mobile applications, websites, services, products (such as Zepp Clarity ONE), and other online or offline offerings unless otherwise indicated. All individuals whose responsibilities include the processing of personal information on our behalf are expected to protect this data by adherence to this Privacy Policy.

 

OUR COMMITMENT TO YOU

 

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of and confidence in our personal information collection and usage practices of any personal information provided to us.

 

In this Privacy Policy, "personal information" means any information relating to an identified or identifiable natural person. Such personal information may include, but is not limited to the information you upload or provide to us and information we obtain through your devices as described below.

 

We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws. 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 practices as summarized in this Privacy Policy, please contact privacy@zepp.com. If your questions are not adequately addressed, you may then contact our Data Protection Officer at dpo@zepp.com to address your specific concerns.

 

TRANSPARENCY: WHAT INFORMATION IS COLLECTED AND HOW WE USE IT

 

The categories of personal information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable laws. Some of the ways that we may collect personal information include:

 

·       You may provide personal information directly to us through interacting with our products and services, or requesting services or information from us.

·       As you navigate the services, certain information may also be collected automatically, including through cookies and similar technologies as described below.

 

We endeavor to collect only that information which is relevant for the purposes of processing.

 

TYPES OF INFORMATION COLLECTED

 

·       Information You Provide Directly to Us. When you use our services or engage in certain activities, such as registering for an account, responding to surveys, requesting services or information, requesting customer or technical support, or contacting us directly, we may ask you to provide certain personal information, such as email address or phone number.

 

·       Automatic Data Collection. We may collect certain information automatically through our products, services or other methods of analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, MAC address and other device identifiers that are automatically assigned to device when you access the Internet, device name, hardware type, serial number, operating system, system version, SDK version, region & language, App version, operator information, screen resolution, Internet service provider, the usage of product and App features, pages that you visit before and after using the services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and other actions taken through use of the services such as preferences.

 

·       Specific Information Collected Through Our Products and Services. We may collect the following types of information (which may or may not be personal information):

 

o   Information about You: When you register for an account or log into our service using your credentials from your Google, Apple or Facebook accounts (with your approval), we may collect and use your gender, phone number, email address, nicknames, birthday, age, user ID.

o   Application Setting Information: We may collect information of your device settings on applications. For example, the bass and the treble settings for programs, the selected programs and their order, volume,  the status of noise suppression, the notification setting.

o   Network Usage Information: We may collect network types, network signals, WLAN information, Bluetooth information and other similar information related to certain features of the Zepp Clarity App.

o   Mobile Phone Information: When you use Zepp Clarity App, we may collect your mobile phone information, such as, the operating system version, network type, country, screen resolution, brand and model of your mobile phone.

o   Device Information: When you use Zepp Clarity App to connect hearing aids, we may obtain information, such as: the device's unique identifier, device ID, MAC address, serial number, firmware version, hardware version. The collection may also apply to your updated system or software and factory settings.

o   Commercial information: When you shop for and purchase our products or services on website, we obtain and use information about the products and services you have purchased, obtained, or considered. We may also collect your name, phone number, email, postal address, payment, and transaction information if you pay us for products or services.

o   Log Information: If you join our user experience plan, we may record some log information when you use the Zepp Clarity App. For example, we may collect operating information, hit log, firmware clicking statistics, and server log. When you give us feedback, at your option, your app log and device log will be collected by us.

o   Crash Information: When you choose to upload debug logs to help us analyze the problem, your application debug log file will be sent to the server.

o   Other Information: We may also collect other types of information which is not directly or indirectly linked to an individual and which is aggregated, anonymized or de-identified. For example, the device function, system status, battery status, App version, Startup & Shutdown status, charging status and connecting status of smartphone of your device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

 

HOW THE PERSONAL INFORMATION IS USED

 

We acquire, hold, use and process personal information for a variety of business purposes including for providing services and/or products to you, to respond to information requested and to fulfill legal compliance on our part under applicable laws. We may also process and disclose personal information to our affiliated companies and to third-party service providers for the purposes stated in this Privacy Policy.

 

·       To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for products, Services, or information, including:

 

o   Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device;

o   Communicating with you about your device, service or any general queries or other requests and comments, such as updates, customer inquiry support, information about our events, notices;

o   Providing access to certain areas, functionalities, and features of our products and services;

o   Conducting promotional activities, such as sweepstakes;

o   Analyzing and developing statistical information on the use of our products and services to better improve our products and services;

o   Optimizing the performance of your device;

o   Storing and maintaining information about you for our business operations or legal obligations; and

o   Providing local services without communicating with our servers.

 

·          Administrative Purposes. We may use personal information about you for administrative purposes, including to:

 

o   Measure interest in our services;

o   Develop new products and services;

o   Ensure internal quality control;

o   Verify your identity;

o   Communicate about accounts and activities on our services and systems, and, in our discretion, changes to any of our policies;

o   Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;

o   Prevent potentially prohibited or illegal activities; and

o   Enforce our Service Agreement and/or Privacy Policy.

 

·       Marketing Our Products and Services. If permitted by applicable laws, we may use your personal information, such as your email address, account ID, to provide you with materials directly or through third-party service provider(s) about offers, products, and services, including new content or services. We may provide you with these materials by phone, postal mail, facsimile, or email, or as otherwise permitted by applicable law. Such uses include:

o   To notify you about offers, products, and services that may be of interest to you;

o   For other purposes disclosed at the time that individuals provide personal information; and

o   Otherwise with your consent.

 

You have the right to opt out of our proposed use of your personal information for direct marketing. If you no longer wish to receive certain types of email communication you may opt-out by following the unsubscribe link located at the bottom of each communication.

 

·       Research and Development. We may use personal information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products and services and we may share these statistics with the public or third parties in order to present the preference and trend analysis.

 

·       De-identified, Anonymous and/or Aggregated Information Use. We may use personal information and other information about you to create de-identified, anonymized and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the mobile phone or device from which you access Zepp Clarity App, or other analyses we create. De-identified, anonymized and/or aggregated information is not personal information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

 

·       Improving User Experience. Some opt-in features allow us or our third party partners to analyze data about how users use our products and services, so as to improve the user experience, such as sending crash reports.

 

·       Specific Ways Personal Information is Used in Products and Services. Here are more details on how we may use your information (which may include personal information):

 

o   To Set Up Your Account for Zepp Clarity App. Personal information collected when creating an account through our Zepp Clarity App is used for creating the personal account and profile page for the user.

o   To Provide Zepp Clarity App Services. When you use Zepp Clarity App, your personal information will be used to provide certain services to you, such as enabling you to adjust treble and bass for different programs, to adjust the volume, to change the program selected, to help finding your device, to suppress the noise.

o   To Provide Program Recommendation Function. When you use our program recommendation function on Zepp Clarity App, we will collect your hearing loss information and use it to recommend the most suitable program for you.

o   To Provide Smart Phone-call Function. When you use the smart phone-call function, your personal information is used to enable you to switch to phone program, allowing you to speak more clearly and avoid whistling interference when calling.

o   To Provide Enhance Listening Function. When you enable the enhance listening function, your personal information is used to enable you to switch to relevant program, which will make it easier for you to hear the conversation.

o   To Provide Network Related Services. We use network types, network signals, etc. to prompt the user to download updates in different network environments.

o   To Provide Notification Reminder Service. When you enable the notification reminder function, you will be notified of the reminder information you set in the Zepp Clarity App.

o   To Optimize Our Products and Services. We use your personal information, such as, serial number, log information, debug information, the information automatically collected to provide functionality, analyze performance, fix errors, and improve the quality of our products and services. For example, we may use these information to optimize pages/function display, determining the importance of each product function, guiding us to adjust the priority of the development of product features.

o   To Manage Devices. This information provides the ability to manage the bundled devices, such as, to manage the hearing aid through bundled smartwatch.

o   To Improve Device/Software Stability. We may use the information collected, such as, crash logs for analyzing software and device quality to provide better service.

o   To Send Notices. From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies.

 

COOKIES AND OTHER TECHNOLOGIES

 

We, as well as our third-party service providers that provide content, advertising, or other functionality on our services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our websites, services, applications, messaging, and tools, and to recognize you across devices.

 

·        What Information is Collected and How We Use Them: Technologies such as cookies, tags, and scripts are used by us and our third-party service providers. These Technologies are used in analyzing trends, administering the website, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

 

·        Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the website may not work properly.

 

·        Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

 

·        Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

 

·        Mobile Analytics: Within some of our mobile applications, we use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where crashes occur within the application.

 

·        Local Storage – HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content and preferences. Third parties with whom we partner to provide certain features on our websites or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.

 

·        Website Analytics. We may use Technologies and other third-party tools to process analytics information on our Services (e.g., Google Analytics). For more about Google Analytics information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information on our website, please click here.

 

 Our Uses of Such Technologies Fall into the Following General Categories:

 

·       Operationally Necessary. We may use cookies, or other similar technologies that are necessary to the operation of our services, applications, and tools. This includes technologies that allow you access to our services, applications, and tools; that are required to identify irregular website behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

 

·       Performance Related. We may use cookies, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

 

·       Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our websites, services, applications, or tools. This may include identifying you when you sign into our websites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our websites;

 

If you would like to opt out of the Technologies we employ on our websites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

 

THIRD PARTY WEBSITES, SOFTWARE DEVELOPMENT KITS

 

Our App may contain links to other websites and other websites may reference or link to our website, products or other services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about third-party websites or social media platforms.

 

We encourage you to read the privacy policies of each and every website and application with which you interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

 

The website and our other services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our website or other services. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.

 

We may also use third party APIs and/or software development kits (“SDKs”) as part of the functionality of our products and services. APIs and SDKs may allow third parties (including advertisers) to collect your personal information to provide services and content that is more relevant to you.

 

HOW WE SHARE YOUR INFORMATION

 

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 we will only share your personal information in accordance with this Privacy Policy and the applicable terms that govern your use of our services. We will engage sub-processors for the processing of your personal information. You should know that when we share your personal information with a third-party service provider under any circumstance described in this section, we will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. We will contractually ensure compliance by any third-party service providers with the privacy standards that apply to them in your home jurisdiction.

 

ONWARD TRANSFER: SHARING WITH OUR GROUP, THIRD PARTY SERVICE PROVIDERS AND OTHERS

 

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 our affiliated companies. We may also share your information as described in this Privacy Policy with our third-party service providers, to comply with legal obligations, to protect and defend our rights and property or with your permission.

 

Our third-party service providers include, without limitation, our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers. Such third-party service providers will be processing your personal information on our behalf or for one or more of the purposes listed herein.

 

·       Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust personal information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) customer service activities; and (iv) in connection with the provision of the products, services and website. We have executed appropriate contracts with the service providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

 

·       Affiliates. We may share your personal information with our company affiliates for the purposes set forth in this Privacy Policy, including our administrative purposes, activities such as IT management, or for them to provide services to you or support and supplement the services we provide.

 

·       Disclosures to Protect Us or Others as Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena (including in a country other than your home country); (ii) respond to your requests; (iii) protect your, ours or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

 

·       Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, transition of service to another provider or asset sale of all or a portion of our assets, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. You will be notified via email and/or a prominent notice on our website or in the Zepp Clarity App of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information. We will endeavor to direct the transferee to use personal information in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.

 

SECURITY SAFEGUARDS

 

We are committed to ensuring that your personal information is secure, and 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 we process.

 

To prevent unauthorized access, disclosure or other similar risks and to comply with applicable privacy and security laws in the countries in which we operate, we have put in place reasonable administrative, technical and physical controls and procedures designed to safeguard and secure the information we collect from your use of our products and services. We will use reasonable efforts designed to safeguard your personal information.

 

For example, when you access your account, you can choose to use our two-step verification process for better security. When you send or receive data from your device to our servers, we make sure they are encrypted using Secure Sockets Layer ("SSL") and other algorithms.

 

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and endeavor to ensure that your personal information has an appropriate security level. The files and records containing your personal information will be kept in our offices and/or on our servers or those of our service providers and only those employees that require it for the purposes of their duties will have access to this file. We have also implemented controls to require that our third-party service providers and partners have appropriate safeguards designed to protect your personal information as well. 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. In some cases, 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, in an effort to guard against any unauthorized access and use.

 

However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent any interception or other type of misuse. We also depend on you to protect your information. If you become aware of any breach of security or privacy, please notify us immediately. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

 

By using our products and services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the website or through the product or service and/or by sending an e-mail to you. You may have a legal right to receive this notice in writing.

 

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 authorized by you. Whenever you log in the Zepp Clarity App, particularly on somebody else's mobile phones or on public Internet terminals, you should always log out at the end of your session.

·        We 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 unauthorized 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.

 

 

YOUR PRIVACY CHOICES AND RIGHTS

 

YOUR PRIVACY CHOICES

 

The privacy choices you may have about your personal information are determined by applicable law and are described below.

 

Mobile devices

We may occasionally send you push notifications through our mobile applications with version updates and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

 

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

Cookies and Interest-Based Advertising

As noted herein, you may stop or restrict the placement of cookies and other technologies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

 

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.

 

To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on third party websites that contain the Ad Choices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-personal information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

 

ACCESSING OTHER FEATURES ON YOUR DEVICE

 

Our applications may need access to certain features on your device such as Bluetooth. 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 your mobile phone/computer and/or contacting us at privacy@zepp.com.

 

CONTROLLING SETTINGS FOR PRODUCTS AND SERVICES

 

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

 

·        Log in and out of the account;

·        Toggle on/off for other services and functionalities which deal with sensitive or personal information.

 

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time through your device or privacy settings as described above. If you have any questions, please email us at privacy@zepp.com.

 

RETENTION POLICY

 

We retain personal information we receive as described in this Privacy Policy for as long as you use our products, services and websites or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with 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.

 

If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by us even if the further processing is incompatible with original purposes in certain jurisdictions.

 

YOUR PRIVACY RIGHTS

 

In accordance with applicable law, you may have the right to:

 

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;

 

  • Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;

 

  • Request Deletion or Anonymization of your personal information when processing is based on your consent or when processing is unnecessary, excessive or non-compliant;

 

  • Request Restriction or Blocking of or Object to our processing of your personal information;

 

  • Withdraw Your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;

 

  • Request Data Portability and receive an electronic copy of personal information that you have provided to us;

 

  • Be Informed about third parties with which your personal information has been shared; and

 

  • Request any review of decisions which may have been taken exclusively based on automated processing if that could affect data subject rights.

 

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

 

 

STORAGE AND TRANSFER OF PERSONAL INFORMATION

 

We have data center in the United States. Currently all users’ personal information is stored in data centers located in United States. To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies or Third Party Service Providers, we shall do so in accordance with the applicable laws. For example, when we transfer your personal information to countries outside the United States, we do so under the European Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses). In particular, we will ensure that all transfers will be in accordance with requirements under the applicable laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by us for this transfer of your personal information.

 

We may use overseas facilities operated and controlled by us to process or back up your personal information. You understand that your personal information collected via or by us may be stored outside of your jurisdiction. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you consent to the storage of your personal information in these locations.

 

MINORS/CHILDREN’S PRIVACY

 

Our products and services are not directed to children, minors or individuals under 18 years of age (the “Child” or “Children”) and Children are prohibited from using our products or services. We don’t seek or intend to seek to receive any personal information from Children. Should a parent or guardian have reasons to believe that a Child has provided us with personal information, please contact us to ensure that the personal information is removed and the Child unsubscribes from any of the applicable services. If we learn that we have collected any personal information from Children under 18, we will promptly take steps to delete such information and terminate the Child’s account.

 

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. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the products or services after the updated Privacy Policy is posted. If, at any point, you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the products and services. 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 in our App. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or in our App. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. Before we use personal information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where your consent for the processing of personal information is otherwise required by law or contract, we will endeavor to comply with the law or contract.

 

THIRD PARTY TERMS AND CONDITIONS

 

Our Privacy Policy does not apply to products and services offered by a third party. Our 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 websites linked from our services.

 

OUR APPROACH TO MANAGE YOUR PERSONAL INFORMATION

 

We will provide a systematic approach to managing personal information through our people, management processes and information systems by applying a risk management methodology. For instance, (1) we set up a Data Protection Officer (DPO) in charge the data protection, and the contact of the DPO is dpo@zepp.com, (2) we set up a procedure for conducting data protection impact assessments.

 

 

REDRESS/COMPLIANCE AND ACCOUNTABILITY

 

We are the controller of the personal information we process, unless otherwise stated. For information on how to contact us, please refer to “Contact Us” below. If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at privacy@zepp.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

 

CONTACT US

 

If you have any comments or questions about this Privacy Policy or any questions relating to our collection, use or disclosure of your personal information, please contact us at the address below referencing "Privacy Policy":

 

Anhui Huami Information Technology Co., Ltd.

Attn: Data Protection Officer

7/F, Building B2, Huami Global Innovation Center, No. 900, Wangjiang West Road, High-tech Zone, Hefei City, China (Anhui) Pilot Free Trade Zone.

Email: privacy@zepp.com

 

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

 

 

SUPPLEMENTAL CALIFORNIA ADDENDUM TO THIS PRIVACY POLICY

 

This Supplemental California Addendum to this Privacy Policy (“California Addendum”) supplements and should be read in conjunction with this Privacy Policy. This California Addendum only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

 

Category of Personal Information Collected by Us

Categories of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers such as name, online identifier, IP address, MAC address, cookie identifier, user ID or other similar identifiers.

·       Service providers

·       Affiliates

Personal information categories listed in Cal. Civ. Code § 1798.80(e), such as name, phone number, postal address

·       Service providers

·       Affiliates

Commercial information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·       Service providers

·       Affiliates

 

Characteristics of protected classifications under California or Federal law, such as gender or age. (“Characteristics of Protected Classifications”)

·       Service providers

·       Affiliates

Internet or other electronic network activity information such as browsing history, search history and information regarding a consumer's interaction with a website, application, or advertisement.

·       Service providers

·       Affiliates

Inferences drawn from other personal information to create a profile about a consumer

·       Service providers

·       Affiliates

 

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above in the relevant sections of this Privacy Policy.

 

Additional Privacy Rights for California Residents

 

·       “Sales” of Personal Information under the CCPA. For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

 

·       Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

 

·       Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

 

·       Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

 

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

 

SUPPLEMENTAL NEVADA ADDENDUM TO THIS PRIVACY POLICY

 

This Supplemental Nevada Addendum to this Privacy Policy supplements and should be read in conjunction with this Privacy Policy.

 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@zepp.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” above.