Privacy policy

Last updated on December 9th, 2022

Wonderlabs. Inc (hereinafter referred to as "we" or "us") respect and protect the personal information of all users. We will collect and use the information generated during your use of our products or services (including smart home products, accessories, computer applications, App, toolkits, websites, information storage platforms and related services) or provided by you on your own initiative in a lawful, proper and necessary way.
Please take a moment to read this Privacy Policy carefully before using our products or services, so that you can fully understand how we will collect, use, save, share and transfer your personal information, as well as the ways we provide you to access, update, delete and protect this information, and fully understand and agree to the content herein. You have the right to refuse this Policy, but if you do so, we will not be able to provide you with our products and/or services. When you choose to (re)use our products and/or services, you will be deemed to have accepted and acknowledged this Policy as it is an essential prerequisite for the rendering of our products and/or services.
Your agreement to the Policy indicates that you understand that we will collect certain personal information from you in specific service scenarios, but it does not mean that we will collect and process all of the personal information covered herein once you agree to this Policy and use our products and/or services. When it comes to additional business functions that require the processing of your non-essential personal information, we will ask for your consent separately.

1. INFORMATION WE COLLECT

1.1 Sources of personal information

1.1.1 Information you provide to us This includes information you provide when you register and set up new products, download software, post on online platforms like forums or communities, respond to a survey, or enter a interactive.

1.1.2 Information from the use of products and services
When you use products and services, some data may be sent to us such as your hardware model, firmware and operating system version, unique device identifiers and IP address/location information. Other times, subject to applicable law and your consent where it’s required, we may collect data based on your activities including your settings and configurations, usage data, and crash or error data. We also collect information about you through cookies and similar tracking technologies.

1.1.3information we received from the third parties
We also obtain information about you from other sources. For example, we collect information from publicly available sources, when you interact with us on social media, when you purchase one of our products or services through a third-party service, and when you submit a review for one of products or services. This information includes information about your purchase of a device or service, information from reviews you post, username for third-party services, social media profile information.

1.2The content of personal information
The data we received depends on the products, features and services you use, events in which you may participate, and other interactions you may have with us. This data can include the following:
1.2.1 Registration, account log-in and verification data, including:
● Name and contact information: your name, nickname, email address, postal address, phone number, etc.
● Credentials: passwords, hints, and information used for authentication and account access.
● SwitchBot Accounts: Some products utilize a SwitchBot account to optimize your experience. For example, it may enable improved personalization and allow you to save and recall settings, configurations, and history. When you create a personal SwitchBot account, We will collect the unique identifier or MAC address of the device and bind it to your App account. Upon your informed consent, we will collect your location (WiFi SSID) or bluetooth information of your device to connect the device to the internet, and will not upload or keep any of such data. When you sign into your account, we may collect information about your session, including a record of your sign-in, date and time, the product you signed into, the number assigned to your account, and a unique identifier assigned to your device, your IP address, and your operating system and browser version, etc.
● Demographic data: data like your age, gender, country, and preferred language.
● If you use other login methods, you will permit us to access your email address registered for your third-party account, for the purpose of binding it to your SwitchBot account. For personal information that we need but the third-party cannot provide, we will inform you and ask you to provide it through system prompts, etc.

1.2.2 Purchase information
Data needed to process your order if you make purchases through our platform, like your shipping address, products ordered, amount, and contact information. We do not collect payment information (i.e., credit or payment card number), because consume transactions are done through secure third party companies.

1.2.3 Usage data:
Data about how you and your device interact with us and our products, including:
● Product use data: the features you use, actions you take, and activities you perform. When your device is connected to our services, our services will collect various device event data through the App, such as when the device is used, whether it is turned on or off, and when it is capturing video, motion, battery life or other data. For cameras, our services will collect video and images from your cameras in accordance with your camera storage settings, which may include images or videos of individuals. For robot vacuum cleaner, our services will collect information about the robot's movement throughout the environment to create a location "map" of the robot’s domain and the existence and type of obstacles encountered. We will store the name you give your device and the name of the area location. When you set the device scene, we may collect the scene name, condition, action, and valid period you set.
● Error reports and performance data：the type or severity of the problem, details of the software or hardware related to an error, the contents of files you were using when an error occurred.
● Maintenance information: To provide you with product and service consultation, technical support, after-sales service and other service information through telephone, network, etc. For example, in order to contact you as soon as possible and help you solve problems or record solutions and results of related problems, we may collect and store your communication/call records and related information according to this Policy, such as account information, country, email address, order information, payment information, purchase channel, bound product information, phone number, call records and the information you provide to us as evidence.

1.2.4 Support data：
Information about your hardware, software, your communications with us, data about the machine and the application you were using, and system, registry, and configuration data, used to support the functions and services of the product, etc. including:
Device data: data about your device you use to connect to our services, including the hardware model, operating systems, device identifiers, and regional and language settings.

● Interests and favorites: your preferences, programmed activities, and the services you use contacts and relationships. If you use products that support multi-user, community, and sharing features, we may collect data about your contacts and relationships.
● Location data – Some products use location data for purposes like time/date and language preferences. Data we may collect about your location can be either precise or imprecise. Precise location data can be your home or work address information or Global Position System data, which we may collect when you enable location-based products or features. Imprecise location data may include a location derived from your Wi-Fi or IP address or data that indicates where you are located with less precision, like a city or region.
● Content: We may collect information about the content of your files and communications when necessary to provide you with the products you use. We also may collect the content of messages you send to us, like feedback and product reviews you write, or questions and information you provide for customer support.

1.3 Product tester data
When you sign up to become a SwitchBot product/service tester, we may collect information about you. We use this data to invite you to become a tester, and we use your feedback to develop and improve our products and services.

2. COOKIES, BEACONS AND SIMILIAR TECHNOLOGIES
We, as well as certain third parties that provide content, advertising, or other functionality in our services, use cookies, pixels, beacons, and other technologies in certain areas of our services.

2.1 Cookies
Cookies are small files that store information on your computer, mobile phone, or other device. They enable the entity that put the cookie on your device to recognize you across different websites, services, devices, and browsing sessions. Cookies serve many useful purposes. For example:、

● Cookies can remember your sign-in credentials so you don’t have to enter those credentials each time you sign in to a service.
● Cookies help us and third parties understand which parts of our services are the most popular because they help us to see which pages and features visitors are accessing and how much time they’re spending on the pages. Studying this information helps us to adapt the services and provide you with a better experience.
● Cookies help us and third parties understand which ads you’ve seen so you don’t get the same ad each time you access a service.
You can choose to accept or reject cookies, configure your browser to accept all cookies or reject all cookies, and you can choose to accept some cookies. Note that some services are designed to work using cookies, so disabling cookies may affect your ability to use those services or certain parts of them. For cookie selection or other questions, you can also contact us through “contact” at the bottom of this page.

2.2 Other local storage
We, along with certain third parties, may use other kinds of local storage technologies, such as Local Shared Objects (also referred to as Flash cookies) and HTML5 local storage, in connection with our services. These technologies are similar to the cookies discussed above. They’re stored on your devices and can be used to store certain information about your activities and preferences.

2.3 Beacons
We, along with certain third parties, may use technologies called beacons or pixels that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you’ve viewed particular content or a particular email message, and determine the time and date on which you viewed the beacon and the IP address of your device. We and certain third parties use beacons for a variety of purposes, including to analyze the use of our services and, along with cookies, to provide content and ads that are more relevant to you.

In addition, you also consent to us and the aforementioned third parties having access to such cookies, local storage technologies, beacons and information.

3. HOW WE USE INFORMATION

In order to provide you with the corresponding functions of our products and/or services, we undertake to follow the principle of data minimization when collecting and using your personal information, and not to use your personal information for purposes other than the Terms of Service and this Policy.

We use the data we collect to operate our business and provide, improve, and personalize our products and services, and to send communications, including promotions, account information, security updates, and product information. We may analyze this data, including your personal information, to give you a more seamless, consistent, and personalized experience. We will always do so subject to applicable law and your consent where it’s required.

We use data to provide and improve our products and to perform essential operations. This includes operating and using the products, maintaining and improving their performance, and using data to research, develop new features, and provide customer support. Example uses include:

●Process and fulfill your purchases.
●Providing the product or service: We use data to ensure our products operate as intended and expected. Our products may have personalized features and recommendations that enhance your productivity and enjoyment, and tailor your experiences based on your activities, interests, and location.
● Customer support: We use data to diagnose product problems, repair customers' devices, and provide other customer care and support services.
● Product activation and registration: We use device and application version, location, and unique device, network and identifiers and other data to activate and register products.
● Product improvement: We use data to improve our products, add new features or capabilities, report errors, improve security, determine what new features to prioritize, and improve efficiency.
● Security, safety and dispute resolution: We use data to protect the security and safety of our products and our users, to detect and prevent fraud, and to resolve disputes and enforce our agreements. For example, we may use data to determine which products need security patches or analyze patterns in data that allow us to develop new security features.
● Business operations: We may use pseudonymous and aggregated data to create statistics and analysis. For example, financial and product reports are created to analyze performance in a given sector or region.
● Marketing communications: We may send you information about our products and services by email or telephone, including information about new product features, releases, promotions, and announcements. You can opt out at any time by clicking the ‘unsubscribe’ link in the marketing emails. Subject to applicable law and your consent where it’s required, we may also use cookies or tracking technology to determine the effectiveness of our communications – for example, to determine, in the aggregate, how many people open our emails. We may also send emails to remind you about items left in your online shopping cart, update you or inquire about a service or repair request, or to tell you that you need to take action to keep your account active.
● Support communications: We may contact you by email or other means to inform you when a subscription is ending or to let you know when security updates are available.
●Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of you and others.

4. SHARING AND DISCLOSING INFORMATION
We do not sell your personal data. We will share and disclose your personal information in the following ways:
● We may share your personal data with your consent, or to complete a transaction, or provide a product or service you requested or authorized. For example, we share your content with third parties when you tell us to do so, like when you send data to a friend or link accounts with another Service.
● We also share personal data among our controlled affiliates, our subsidiaries, and our holding company for the purposes described in this policy and when required by law. These companies will use your personal information in the same manner as we do under this Policy.
● We may share personal data with vendors or agents working on our behalf for the purposes described in this statement only to perform their work. For example, companies hired to provide customer service support, assist in protecting and securing our systems and services, data storage or services, website operation services or companies provide certain functions or modules may need to access personal data to provide those functions. We will share your personal information with third parties in accordance with the data minimization principle. We will reach an agreement with them on the purpose and period of sharing, processing methods, types of personal information and protection measures, and evaluate and monitor their actions to protect your personal information when necessary. These companies must abide by our data protection and security requirements and are not allowed to use personal data they receive from us for any other purpose.
● We may also disclose personal data to another company if we plan to merge with or be acquired by that business. This may include any organization involved in a merger, transfer, or sale of our assets or business.
● If you post information in public areas in our products and services, like communities, forums, or blogs, it will be available to the public and we may reuse and republish it at our discretion and in line with our terms of use.
● If you choose to integrate third-party applications or services with our products or services, such as Amazon Alexa and Google Assistant, we will allow third parties to collect the information needed for integration from your products and applications and, with your consent, these third parties will collect specific types of data based on the nature of the service. Please review their privacy policy for details about the information they will receive and how they process them.
● When law enforcement authorities, regulatory agencies and other parties collect information for legal reasons, we will disclose the information to them if we believe the disclosure is consistent with the requirements of any applicable law or legal process.
● We allow others to provide analytics services for us across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the services and other websites and applications, including your IP address, web browser, and other information. We use third-party analytics tool -- Google Analytics to assist us with analyzing and improving our service. Google provides some additional privacy options to protect business's data. We've read and accept updated terms and contractual protections Google made to analytics tool we've used. To select or prevent Google Analytics from using your information for analytics, you may go to https://tools.google.com/dlpage/gaoptout or install the Google Analytics Opt-out Browser Add-on. 
● Our services may contain links to third-party websites of our network of partners, advertisers, retailers and affiliates, as well as links to websites of third-party organizations within this Privacy Policy. If you follow a link to any of these third-party sites, please be aware that these sites have their own terms of use and privacy policies, and we are not responsible or liable for their services or practices, please review their terms of use and privacy policies before submitting any information to these sites.

5. CONTROLLING AND ACCESSING INFORMATION
You have the right to request access to, or copies of your information, and direct us to modify, update, delete, restrict or deactivate certain information pertaining to you. You can also request that we remove your personal information from the blog, community forums, or other public areas within our control, you can contact us directly through “contact” at the bottom of this page. If we cannot remove certain personal information, we will let you know why.
You also have the right to withdraw your consent in the event that we process your relevant personal data in accordance with your consent. If you need to delete your account, please click "Profile – Account and Security - Delete Account" in the App. Unless otherwise stipulated by laws and regulations, after you delete your account, we will stop providing you with our products and/or services. And delete your personal information at your request.
You may unsubscribe from our marketing emails by following the instructions in the email you received, and we will respond to requests within 30 days of receipt.
For all kinds of personal information requested by us, you can choose to object to the processing when it is used for a specific purpose.

6 For the privacy rights of California residents
Pursuant to the California Consumer Privacy Act (CCPA), California residents have certain rights regarding our collection, use and sharing of their personal information. We will not sell your personal information, nor will we sell your personal information in the future without providing you with notice and an opportunity to opt-out.

6.1 Personal information we collect
To learn more about the categories of personal information we have collected in the past 12 months and how we have used it, please see sections 1, 2 and 3 above.

6.2 Disclosure of personal information We disclose your personal information with service providers for business purposes in a manner that does not constitute a "sale". To learn more about how we disclose data to third parties, please see section 4 above. All non-essential cookies (including third parties) require the California consumer's prior opt-in consent, and are loaded according to the consumer's instructions and preferences.
As a California resident, you may exercise the right to know, after verifying your identity, any or all of the following information about your personal information that we have collected and disclosed within the past 12 months:
The personal information we have collected about you;
The categories of personal information we have collected about you;
The categories of sources of the personal information;
The categories of personal information that we have disclosed to third parties for a business purpose;
The categories of recipients to whom your information was disclosed;
The business or commercial purposes for collecting the personal information;
You have the right to request deletion of personal information we have collected from you, you also have the right not to be discriminated against in exercising these rights. However, please note that exercising these rights may limit our ability to process personal information. For example, if you submit a deletion request, we may no longer be able to provide our products and services to you.

6.3 To submit your California consumer rights requests You may submit a request to exercise your California consumer rights by submitting a request through the contact at the bottom of this page. Before we can process your request, we need to verify your identity, which may require you to provide additional personal information, or to log into your account. In some cases, we may deny or limit your request, particularly if we are unable to verify your identity or locate your information in our systems or where permitted by law.

6.4 Do not sell personal information We will not sell your personal information or disclose it to third parties for direct marketing purposes unless you first expressly consent to the disclosure.

7 CHILDREN
We do not knowingly collect or maintain information about persons under 18 (Or the age required by local law) years of age. If We learn that information about children has been collected on or through the Sites, We will take appropriate steps to delete this information. If you are the parent or legal guardian of a child who has registered for an account or service on our sites, please contact us using the contact information below to have that child’s account or service terminated and personal information deleted.

8. DATA SECURITY
Our data management measures comply with ISO/IEC 27001 information security management system standards. We are committed to the protection of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized or accidental access, public disclosure, use, modification, damage or loss of your personal information. We will take all reasonably practicable measures, including administrative management, technical support and physical defense measures, to protect your personal information, and will retain your personal information only within the period of time stipulated by laws and regulations.

We provide online services that use web encryption technology, AWS provides us secure and reliable data storage services that no one can access without your permission.

9. HOW WE STORE AND PROCESS INFORMATION

9.1We will retain your personal data for as long as
● you use our products or services
● your account is active
● needed to provide you services
● we are legally required to
● to resolve disputes, and
● to enforce our agreements
Personal data that is no longer required to be retained will be deleted at regular intervals.

9.2 SwitchBot Cam
SwitchBot Cam is a wireless camera and software application. The Privacy Policy applies to the product, but there are a few distinctions as noted below.

9.2.1 Activation and Registration
To activate and register your products, you provide information to us to create an account, including your name, email address, password, payment information (if you subscribe to premium services), camera name, and camera settings.

We also provide activation and registration through third party open authorization services such as Google, Amazon or Apple.

9.2.2 Video and Audio Recordings
When you use SwitchBot cam products and services, our servers automatically receive, record, and process data necessary to provide the service as well as information from the devices you use to view or listen to the data, including:

● Video and audio recordings
● Device-specific information like hardware model, operating system version, and device identifiers
● Service event logging information Time and date of service use
● On/off, and other interaction with the product
● Crashes, system activity, and hardware settings
● Geo-location information (when location services are enabled)

9.2.3 SwitchBot security and storage

We have implemented SwitchBot products so that no SwitchBot employee, contractor, vendor, affiliate, or governmental entity can access unencrypted footage. Every SwitchBot camera has a unique private key and digital certificate, which is used to encrypt communications in transit.

Data collected is stored directly within the application, on your Device, and on servers in the U.S. or other countries where we or our affiliates, subsidiaries or service providers have facilities. We will retain collected information for as long as needed to provide the service and in accordance with the Privacy Policy.

10. International transfer of personal data
Personal information collected by us may be stored and processed at our company or affiliate, or service provider maintenance facilities in the United States or any other country, or transmitted to third parties mentioned in Section 4 above for processing. where the legal and data protection compliance requirements may differ from those applicable to your country/region. We are committed to complying with all applicable legal requirements related to the processing and transfer of personal information.

11. Update
We may update this Policy from time to time, If we make any changes to this Policy, we will revise the date at the top of the Policy. Your continued use of our products and/or services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy.

In the event that our specific products or services are discontinued, we will notify you in advance through notifications, announcements, emails, etc., and process your personal information in accordance with this Policy or relevant documents. If we cease operations permanently, this Policy will become invalid and we will process all your personal information in accordance with applicable regulations.

12.Contact
If you have any questions, comments, or requests regarding your data, this Privacy Policy, or data management, please submit a request at https://support.switch-bot.com or email support@switch-bot.com, we will contact you within 7 working days. If you are not satisfied with our response, especially if our information processing has harmed your legitimate rights and interests, you can file a complaint to the local competent authorities.