Our Privacy Policy will be published and effective on February 9, 2022. Beginning on that date, this Privacy Agreement provides privacy details about how we manage the personal information you disclose while using the "Pawaii" App and all devices and services connected to the "Pawaii" App.

Please take some time to familiarize yourself with our Privacy Policy and contact us if you have any questions. The contact email is support@pawaii.com.

Hechong Technology (Qingdao) Co., Ltd. and Pawaii (hereinafter collectively referred to as "we" or "Pawaii") are committed to protecting your personal privacy.

This privacy policy (hereinafter referred to as "this policy") describes how we process personal data and protect information privacy when you use the following services, products and related mobile applications (collectively referred to as "products").

 

Pawaii Mobile App

In this policy, "personal data" refers to information that can be used alone or in combination with other information to identify individuals. "Smart devices" refer to non-standard computing devices produced or manufactured by hardware manufacturers that have human-machine interfaces and can transmit data through wireless networks, including smart pet appliances, smart wearable devices, smart air purification devices, etc. "Application" means a mobile application developed by Pawaii that enables end users to remotely control smart devices and connect to the Pawaii platform.

 

What personal data we collect

In order to provide our services to you, we will ask you to provide the personal data necessary for such services. If you do not provide personal data, we may not be able to provide you with our products or services.

 

Categories of Information Collected

We will only collect necessary information for the detailed, clear and lawful purposes, and we may collect the following types of information (whether it is personal information or not):

1. Information you provide to us or upload: "Pawaii" App account information (such as your security-related information, name, hereinafter referred to as "Pawaii Account"), data or data synchronized by devices that you may access to the Pawaii platform, The account and related setting information created by the Pawaii platform, as well as the equipment you add or the messages and feedback you send.

2. Information about handheld terminals or SIM cards: We may collect information about handheld terminals running Pawaii, such as SDK/API/JS code versions, browsers, Internet service providers, application identifiers, application versions, application distribution channels, independent Device identifier, iOS advertising identifier (IDFA), Android advertiser identifier, network card (MAC) address, DID, firmware version, International Mobile Equipment Identity (IMEI), device model, terminal manufacturer, terminal device operating system version , session start/stop time, language location, time zone, and network status (WiFi, etc.), etc.

3. Location information (applicable to specific services/functions only): Various information related to your location, such as area and country codes, city codes, mobile network codes, mobile device country codes, cell identification codes, area names, latitude and longitude information, Time zone settings and language settings.

4. Login Information: Information related to your use of certain features, mobile applications and websites, such as cookies and other anonymous identifier technologies, IP addresses, network request information, temporary message history, standard system logs and system crash information, etc.

5. Data recorded by the device: When you use the "Pawaii" App to synchronize the data of related devices, we will record your pet's information, including name, type, breed, birthday, weight, etc.

6. Other information: Environmental Characteristic Value (ECV) (the value generated by Pawaii account, mobile phone ID, connected Wi-Fi account and location information)

7. Account Credentials: Information about your account credentials, such as passwords, associated email addresses, etc.

8. Storage permission: Some of our businesses will generate certain pictures or videos in the App, which need to be saved to the mobile phone; at the same time, some businesses need to call the existing videos or pictures in your mobile phone, and we will apply for storage permission from your mobile phone .

 

Information You Voluntarily Provide to Us

Account or Profile Data: When you register for an account with us, we may collect your name and contact details such as your email address, phone number, username and login credentials.

During your interaction with our products, we may further collect your nickname, avatar, country code, language preference or time zone information in your account.

 

Information We Collect Automatically

[Required]

[Required] Basic account information: mobile phone number and email address; password.

[Required] Mobile device related information: When you interact with our products, we will automatically collect device information, such as location permissions: Android 6.0 or above is required to obtain device WiFI information (including nearby WiFI list) location permissions when configuring the network. ; Phone model information, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

[Required] Basic information about smart devices: When you use smart devices connected to our products or services, we may collect basic information about smart devices, such as device name, device MAC address, device ID, online status, Activation time, firmware version and upgrade information, etc.

[Required] Log information and basic usage data: When you use our application, system and exception logs may be uploaded. During your interactions with our Site and Services, we automatically collect Usage Data related to visits, clicks, downloads, sent/received messages and other use of our Site and Services.

 

[Consent information with special authorization]

Other account information: your user nickname, avatar, SDK account information accessed by a third party, etc.

SDK access instructions for third-party account login:

Google

Function: It is used to help users log in to Pawaii Smart App with Google.

Types of personal information collected: general device information, mac address, ip address.

 

Third-party SDK access instructions:

For device binding function

broadlink

Function: User Pawaii App adds smart devices, including smart pet appliances, smart wearable devices, smart air purification equipment, etc.

Type of Personal Information Collected: Install List.

 

For push notification functionality

Xiaomi

Function: Used for Pawaii Smart App to push messages to Xiaomi mobile phone users

Types of personal information collected: general information such as user id, IMEI, device model, device serial number, etc.

 

Huawei

Function: used for Pawaii Smart App to push messages to Huawei mobile phone users

Types of personal information collected: general information such as user id, IMEI, device model, device serial number, etc.

 

OPPO

Function: Used for Pawaii Smart App to push messages to OPPO mobile phone users

Types of personal information collected: general information such as user id, IMEI, device model, device serial number, and installation list

 

VIVO

Function: Used for Pawaii Smart App to push messages to VIVO mobile phone users

Types of personal information collected: general information such as user id, IMEI, device model, device serial number, etc.

 

AliCloud

Function: Used for Pawaii Smart App to push messages to mobile phone users

Types of personal information collected: general information such as user id, IMEI, device model, device serial number, clipboard and installation list, etc.

 

In addition, the Pawaii application will allow self-starting when booting up to push user subscription messages and device messages in a more timely manner.

[Specially authorized consent information] Additional services based on cameras/cameras: You can use this function to scan codes after enabling camera/camera permissions to add your purchased devices, join family and other functions. Please know that even if you have agreed to turn on the camera/camera permission, we will only obtain information when you actively use the camera/camera by scanning codes, shooting, etc.

[Specially authorized consent information] Additional services based on album (picture library/video library) picture/video access and upload: You can use this function to upload your photos/pictures/videos after enabling the album permission to change your profile picture , Reporting equipment use problems and providing proofs and other functions. When you use functions such as avatars, we will not identify this information; but when you report device usage problems, we will use the photos/pictures you upload to locate your problem.

[Specifically authorized consent information] Smart device location information: When you use our specific products or services, we may collect real-time precise or non-precise geographic location information about you.

[Specially authorized consent information] Family information: family name, family location (set manually by you).

[Specifically authorized consent information] Information reported by smart devices: Depending on the smart devices you choose to connect with our products or services, we may collect information reported by your smart devices.

 

We do not collect data about your personal racial or ethnic origin, political opinions, religion, philosophical beliefs, trade union membership, personal genetic data or data relating to your health, sex life or sexual orientation. We will not collect the data of users under the age of 16 without the permission of the child's guardian. If you are a child under the age of 16, please use our products and services only after obtaining the permission of your parents or your guardian.

 

Purposes and legal basis for processing personal data

We process your information for the following purposes:

1. To provide services to you: We process your account and profile data, device information, usage data, location information, and smart device-related information to provide products and services that you request or purchase. The legal basis for such processing is the performance of our contract with you in accordance with our Terms of Use.

2. Non-Marketing Communications: We process your personal data for the purpose of sending you important information about the Services, changes to terms/conditions and policies and/or other administrative information. Due to the importance of such information, you may not be able to opt-out of receiving such emails. The legal basis for such processing is the performance of our contract with you in accordance with our Terms of Use.

3. Marketing communications: We may process your personal data to provide you with marketing and promotional materials in relation to our products and services. In the above cases, each email we send to you will contain instructions allowing you to opt out of receiving such emails. The legal basis for such processing is based on your consent.

 

Compliance:

We process your personal data as we deem necessary or appropriate.

1. comply with applicable laws and regulations;

2. comply with legal process;

3. To respond to requests from public bodies and government authorities;

4. enforce our terms and conditions;

5. protect our operations, business and systems;

6. protect the rights, privacy, safety or property of us and/or other users, including you;

7. seek available remedies or limit damages we may be required to provide.

 

Who do we share your personal data with?

Pawaii only shares your personal data in ways you know. We may share your personal data with the following parties: Disclosure of your personal data to third party (e.g. Google, Apple, etc.) service providers who provide us with certain business-related services, such as website hosting, data analysis, infrastructure supply, IT services, customer support services, email delivery services and other similar services to ensure that they can provide services to us.

Disclose your personal data to customers and other business partners who directly or indirectly provide you with smart devices and/or the networks and systems you use to access and use our website and services.

Affiliates or Other third parties (such as Google, Apple, etc.) disclose your personal data. In such event, you will receive clear notice of the change of ownership, new incompatible use of personal data, and choices regarding personal data via email and/or our website.

As we deem necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public bodies and government authorities, including those outside your country of residence and Governmental authorities; (d) enforce our terms and conditions; (e) protect our operations, business, and systems; (f) protect the rights, privacy, safety, or property of us and/or other users, including you; and (g) seek available remedies or limit damages we may be required to provide. Disclosing your personal data to subsidiaries or affiliates of the company for regular business activities. Except for the third parties mentioned above (such as Google, Apple, etc.), we only disclose your personal data to other third parties with your consent.

 

INTERNATIONAL TRANSFERS OF COLLECTED INFORMATION

To facilitate our operations, we may transfer, store and process your personal data in jurisdictions other than where you reside. These countries may have different data protection laws. In such cases, we will ensure that your information is adequately protected through one or more of the following: Agreements in accordance with the "EU Standard Contractual Clauses" approved under Article 46 of the GDPR. For more information visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third- countries_en. If you want to know more about our security measures, you can contact us directly through this policy.

If your place of use is in the EU, all your user data will be kept in the EU firstly, but in order to improve the experience of the products you use, our company will transfer the data uploaded with your consent to the white list countries and regions identified by the EU ( United States, Canada, Switzerland, New Zealand) or servers in mainland China, Japan, and Russia. There is a certain risk of data privacy protection when data is transmitted out of countries and regions outside the EU. In this regard, you understand and agree to the data transmission across the EU.

 

Rights Relating to Personal Data

You may exercise any of the following rights:

Manually delete data through our product (Pawaii APP);

You don't need to pay anything and we will respond within 30 days. If you decide to send us a request by email, please explain what information you would like changed, whether you would like your personal data to be deleted from our databases, or what restrictions you would like us to be placed on using your personal data. Please note that for security reasons, we may ask you to verify your identity before further processing your request.

you can:

1. Request access to your personal data processed by us, and you have the right to know the data collected, including the data uploaded to the cloud with your consent;

2. require us to correct inaccurate or incomplete personal data relating to you;

3. Request to delete your personal data; and destroy cloud-backed data;

4. require us to process your data based on your consent or a contract with you, and to transfer personal data to you when we process your data automatically;

5. choose to object to or object to our use of your personal data when we use it based on your consent or our legitimate interests;

6. You can cancel your account, and your cloud backup data will be deleted within 7 working days after canceling your account. You have the right to manually destroy the account and all data under the account at any time. If you have special requirements, you can send us an email to let us know.

 

Pawaii App can be deleted manually in the App. The account deletion path is: Me-Settings-Delete Account.

 

Security measures

We employ commercially reasonable physical, managerial and technical safeguards to maintain the integrity and security of your personal data. Pawaii provides a variety of security strategies to effectively ensure the data security of users and devices. In terms of device access, we use Pawaii's proprietary algorithm to ensure data isolation, access authentication and authorization applications. In terms of data communication, it supports communication using security algorithms and transmission encryption protocols, as well as commercial-grade information encryption transmission based on dynamic keys. In terms of data processing, strict data filtering and verification and a complete data review process are adopted. In terms of data storage, all confidential information of users will be safely encrypted for storage. If for any reason you believe that your interactions with us are no longer secure (for example, you believe the security of your Pawaii account has been compromised), please let us know immediately by emailing support@pawaii.com.

We will improve data security measures from time to time, including but not limited to data encryption, physical measures, data authentication and other means, and we will choose to notify you according to the needs of the situation.

We have a Data Protection Officer (DPO) who can be contacted at support@pawaii.com.

In the event of your data leakage, we will report the leakage of personal data to the EU or your country’s regulatory agency within 72 hours, take corresponding remedial measures as soon as possible, and report the remedial measures to you and the EU regulatory agency. If we fail to report to the regulator within 72 hours, our follow-up report will explain the reason for the delay.

 

Data retention period

We will process your personal data for the shortest period necessary to fulfill the purposes described in this policy, unless a longer retention period is required by specific legal requirements. We will determine an appropriate retention period based on the volume, nature and sensitivity of the personal data, and we will destroy your personal data after the retention period ends. If we are unable to destroy the data for technical reasons, we will take appropriate measures to prevent further use of your personal data.

 

Statement Regarding Policy Changes

We conduct periodic reviews of our Privacy Policy and may update this Privacy Policy to reflect changes in our information practices. If we make major changes to this Privacy Policy, we will notify you by email (sent to the email address specified in your account) or by publishing it on Pawaii App or via mobile devices, so that you can understand the information we collect and how we use it . Such privacy policy changes will apply from the effective date stated in the notice or website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Products and Services on the website, mobile phone and/or any other device will be deemed acceptance of the updated Privacy Policy. When we collect more personal information from you or we want to use or disclose your personal information for new purposes, we will ask for your consent again.