This Policy applies to Xinle websites, products, devices and applications that display or provide links to this Policy(collectively referred to as our "services"). All the text, images, user interfaces, visual interfaces, photos, trademarks, logos, sounds, music, works of art and computer code (collectively, the "content") included in the services provided by Xinle, including but not limited to such content in the design, structure, selection and collocation, expression, appearance, style and arrangement form, are owned ,controlled and authorized by Xinle, or authorized to Xinle, moreover are protected by commercial appearance, copyright, patent and trademark laws, and various other intellectual property rights and anti-unfair competition laws.
This Policy describes how Xinle processes your data(personal data or not), but it may not address all possible data processing scenarios. Xinle may inform you of product- or service-specific data collection and the purpose, scope and use of collection of such information through supplementary policies or notices provided before collection. Meanwhile, we will provide you with the consent modes of independent choice, and collect and use them with your consent.
Xinle reserves the right to change, modify, add or delete portions of this Policy at any time at its discretion.You can check this Policy periodically to see if it has changed. If you disagree with this Policy or any content thereof during reading, you shall immediately stop using the relevant services provided by Xinle. If you use the relevant services provided by Xinle, it means that you agree to the whole content of this statement.
This Policy describes:
(1) How We Collect & Use Your Personal Data
(2)Cookies & Similar Technologies
(3) How We Disclose Personal Data
(4) How to Access & Control Your Personal Data
(5) How We Process Children's Personal Data
(6)How We Retain and Protect your Personal data
(7)Third-Party Providers and Their Services
(8) Updates to This Policy
Personal data means any data that, either on its own or jointly with other data, can be used to identify a natural person. You directly provide us with such data when you use our websites, products, or services, or interact with us , for example,
1.1 The information you fill in when registering a Xinle account or using the relevant services provided by Xinle or other platforms, such as your name, gender, date of birth, ID number, phone number, email address, address, profile picture, nickname, location and other relevant information.
1.2 When you choose services such as purchase, delivery and installation, we may ask for your name, contact information, shipping and billing address and bank card information to process your order.
1.3 When you download or use the client software, Xinle may read information related to your device, including but not limited to hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version and settings of the device used to access the services.
1.4 When you use Internet of things devices, we may read your usage without prior notice, including but not limited to the equipment types, equipment operation, using frequency of equipment function, log information of the Internet of things devices , the measurement data uploaded or other information, the using condition recorded by the some of the built-in camera , etc.
We may use your personal data for the following purposes:
(1)The personal information collected when creating an account on website or mobile device is used to create a user's personal account and profile page.
(2)fulfilling your transaction or service request, such as fulfilling orders, information related to e-commerce orders can be used to process purchase orders and related after-sales services, including customer support and reshipment.consignee information including name, address, phone number and zip code will be used for delivery. Email addresses are used to send package tracking information to users. Shipping list is used to print invoices and permit the customer to confirm the items in the package.When you asking we to provide you with product installation, maintenance, consulting services through customer service phone number, WeChat official account and other self-service platform, according to your various demands, you need to provide us with your name, address, contact information, information of the products waiting to install or maintain, so that we can provide you the required services promptly.
(3)Activating or verifying products or services, controlling and using equipment.You need to to log in APP account when controlling some devices and complete the network configuration and binding process. After completing these procedures, you can control the device remotely or within the LAN through APP. Some devices need to be activated before using. The activation process requires device information, including the MAC address, machine code, and WIFI password. If the activation fails, we may read related device information and log information to evaluate the cause of the activation failure. At the same time, you may need to use information such as username/password to control your connected devices.
(4)Sending you important notifications, such as notifications of
operating system or application updates and installations
(5)Conducting internal audit, data analysis and research to improve our products and services.
(6)Synchronizing, share, and store the data you upload or download and the data needed to perform the upload and download.
(7)Complying with and enforce applicable legal requirements, relevant industry standards or our policies. Xinle may also collect and use non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, Xinle will collect statistical data, such as the numbers of visits to its website. We collect this data to understand how users use our websites, products, and services so that we can improve our services and better satisfy your needs. Xinle may collect, use, process, transfer, or disclose non-PII for other purposes at its own discretion.We will endeavor to isolate your personal data from non-PII and ensure that the two types of data are used separately. If personal data is combined with non-PII, it will still be treated as personal data during processing.Xinlewill process your personal data following the requirements of applicable laws on an appropriate legal basis, including:
(a)Processing your personal data to fulfill the contract when responding to a transaction or service request;
(b)Processing your personal data with your consent;
(c)Processing based on the legitimate interests of Xinle or a third party when we use your personal data to contact you, conduct marketing or market surveys, improve our products and services, execute and improve our loss prevention and anti-fraud programs, and other purposes.
(d)We may also process your personal data based on compliance and enforcement of legal obligations.
We may also use other similar technologies on our websites such as web beacons and pixel tags. For example, when you receive an email from Xinle, it may contain a click-through URL that links to a Xinle web page. If you click the link, Xinle will track your visit to help us learn about your preferences for products and services and improve our customer service. A web beacon is a transparent graphic image embedded in a website or in an email. We use pixel tags in emails to find out whether an email has been opened. You can unsubscribe from the Xinle mailing list at any time if you do not want to be tracked in this manner.
2.3 Mobile Analytics Cookies
Within some of our mobile applications we use analytics cookies to collect information about the function of our APP in your mobile phone . These cookies collect 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.
2.4 List of third-party SDKs
In order to ensure the stable operation of our equipment or realize relevant functions, we may access the software development kit (SDK) provided by a third party to achieve the above purpose. We will do our duty of prudence to strictly monitor the security of the software tool development kit (SDK) for partners to obtain information, so as to protect data security.
The third-party SDK we access mainly serves the needs of you and other users. Therefore, when meeting new service requirements and business function changes, we may adjust the third-party SDK we access. We will promptly disclose the latest situation of accessing the third-party SDK to you in this description. At present, the third-party SDK accessed by our equipment is listed as follows:
Huawei equipment management service SDK
Purpose of collecting personal information: complete the end cloud authorization verification with Huawei cloud to ensure that your products always meet the requirements of HarmonyOS Connect certification
Type of personal data collected: device hardware identifier, device hardware parameters and system version information related to the device
Third party SDK privacy statement: Statement on Huawei equipment management service and privacy
3. How We Disclose and Share Your Personal Data
Your personal information will be treated confidentially and be shared with data recipients in the categories listed below. In addition, we wont’ share your information with third parties without your consent, and you will have the option of allowing us to share your information or not.
3.1 Xinle affiliates
In order to facilitate us to provide services to you , protect the personal and property safety of Xinle , other users or the public from infringement, your personal information may be shared between affiliated companies of Xinle. We will only share essential personal information. Before we share your sensitive personal information or our affiliates change the purpose of using and processing your personal information, we will ask for your authorization again.
3.2 Authorized Partners
We may share your information with credible authorized partners. Your information about account , device and location may be shared with authorized partners to ensure the successful completion of the provided services. However, We are committed to ensuring that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. Our partners do not have the right to use the shared personal information for any other purpose.Currently, our authorized partners include: authorized partners of advertising, analytics services, dealers, suppliers, service suppliers and other partners. Our distributors, suppliers and service suppliers including the institutions to provide technical services, telecommunications services, customer services, risk control services, audit services, legal services, and financial institutions, e-commerce companies , platforms and offline stores, etc.We will sign confidentiality agreements with companies, organizations and individuals with whom we share personal Information and in an appropriate manner, require them to handle personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures. For sensitive personal data, we require third parties to adopt encryption technology to protect user data in a better way. Once violation of the agreement is detected ,effective measures will be taken or even the cooperation will be terminated. We will comply with mandatory requirements of laws and regulations, court orders or government department requirements , protect public interests, or protect the personal and property safety or legitimate rights and interests of our customers, Xinle or our employees. Other Purposes with your consent. In addition to the condition described in this Policy, we may also share your information with third parties when you agree to share or apply for share
3.3 Dates Without Consent
We may share anonymous information with third parties for commercial purposes in a summary form; We may share with it general usage trends of our services, such as the number of customers among certain groups of people who buy certain products or engage in certain transactions. In accordance with relevant laws and regulations, we may share, transfer and disclose your personal information in public without your authorization and consent under the following circumstances:
(1)related to national security and national defense;
(2)related to public safety, public health or major public interest;
(3)Related to criminal investigation, prosecution, trial and execution of judgment;
(4) Out of consideration for to protect your life and property or other important legal rights and interests, but difficult to get my consent;
(5)Personal information you disclose to the public voluntarily;
(6)personal information collected from legally sources, such as legitimate news reports and government disclosure.
(7)Maintaining the safe and stable running of the products or services, for example, finding out and handling faults of the products or services.
(8) Other legal and regulatory situations.
In accordance with the law, sharing and transfer the de-identification personal data , and the data receiver cannot recover and identify personal information subject, does not belong to the share, transfer and disclosure of personal information. Such data can be preserved and processed without your consent. If you do not agree that we provide your personal information to third parties in accordance with the above terms, please immediately stop using our services.
It is your responsibility to ensure that all personal data submitted to Xinle is correct. Xinle is dedicated to maintaining the accuracy and completeness of personal data and keeping the data up-to-date.To the extent required by applicable law, you may (i) have the right to access certain personal data we maintain about you, (ii) request that we update or correct inaccuracies in that data, (iii) object or restrict to our use of your personal data, and (iv) ask us to delete your personal data from our database. To exercise these rights, please give your feedback online to LAB01@XINLESDA.COM.
Your written request may be required for security(including written request or in other way). We may decline the request if we have reasonable grounds to believe that the request is a fraudulent, unfeasible or may jeopardize the privacy of others.After yourself or under our assistant to delete the relevant information, please note that we may not be able to immediately remove the information from the backup system due to applicable law and/or technological limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be deleted or be made anonymous.Before deleting your personal data or unsubscribing your account, please back up and properly keep your account information and other relevant data, as well as the transaction vouchers and bills of your products and services, otherwise, you are unable to enjoy relevant after-sales services or extra fees. After your personal data is deleted or your account is unsubscribed, you may no longer be able to use our services, and you may not be able to retrieve any content or information in or related to your account.If allowed by applicable laws, you have the right to withdraw your consent at any time when Xinle processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.
Our websites, products and services are primarily intended for adults. If you are under the age of 14, before using our services and providing us with your information,you should read this Policy with your guardian ,and ensure that you have obtained the consent of your guardian. If you are the guardian , please contact us in time when you have any questions about the use of our services or the user information provided to us by the minor under your custody. We will protect the confidentiality and security of child's personal information in accordance with relevant laws and regulations and this Policy.If a child's personal data is collected with prior parental consent, we will only use or disclose the data as permitted by law, with the explicit consent of the child's parents or guardians, or when necessary for the protection of the child. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible.
In principle, personal information collected and generated by us in the People's Republic of China will be stored in the People's Republic of China.The security of your personal data is important to us. We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. The data storage period may vary with scenario, product, and service. Xinle cannot be held responsible for lapses in security caused by third party accessing 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.
To ensure a positive user experience, you may receive content or web links from third parties other than Xinle and its partners ("third parties"). Xinle does not have the right to control such third parties, but you can choose whether to use the links, view the content and/or access the products or services provided by third parties.
Xinle cannot control the privacy practices and data protection policies of third parties that are not subject to this Policy. When you submit personal information to such a third party, please read and refer to the privacy protection policy of the third party.