Trudian Cloud Privacy Policy

Last updated on:

Effective Date:

Guangdong Trudian Technology Co.,Ltd. and its affiliates (collectively, "we" or "Trudian") are dedicated to protecting your privacy.

The Trudian Cloud Privacy Policy ( "The Policy") applies to all products and/or services offered on the Trudian Cloud platform, including the Trudian Cloud application (mobile client). When you use our services, we collect and process information about you,Therefore, please read this policy carefully and make sure you understand our rules for collecting and processing your personal information (including how such information is collected, used, stored, and shared) and the ways in which we provide you with access to, update, delete, and protect that information.

When you agree to this privacy policy, or start and continue to use our products or services in an appropriate manner, and do not contact us by appropriate means to express contrary opinions, we will consider that you fully understand and agree to this policy. During the reading process, if you have any questions, comments, suggestions or complaints, especially if you believe that our personal information processing practices have harmed your legitimate rights and interests, you can complain/suggest our services through the appropriate regulatory channels or contact us through the following contacts:

E-mail:trudian@aliyun.com

If you are a minor under the age of 18, please obtain prior consent from your parent or legal guardian before using our products or services in accordance with relevant laws and regulations. At the same time, if you are a child under 14 years of age, please make sure you read the Trudian Children's Privacy Statement and make sure you clarify with your guardian or parent the information related to the protection of children's privacy.

This policy explains to you, among other things:

1. what personal information do we collect

2. the purposes for which personal information is processed and the definition of the legal basis

3. who we share your personal information with

4. the transfer of the collected information

5. the rights related to personal information

6. information security measures

7. Information retention period

8. Protection of personal information of children

9. Statement on policy changes

10. Contact us

Definition

For the purposes of this policy

Affiliated company: directly or indirectly controlled by the Trudian; or directly or indirectly controlling the Trudian; or jointly controlling the same company with the Trudian; or directly or indirectly controlled by the same company with the Trudian, including but not limited to parent company, subsidiary; subsidiary controlled by the same parent company with the Trudian, etc.

User Administrator: refers to the individual who is designated by the enterprise user and has the right to operate the enterprise user management backend system; the enterprise user administrator can be one or more people. The creator of the enterprise account will be the administrator of the enterprise account by default.

Personal User/End User: "Personal User" or "End User" refers to the individual who is authorized by the Enterprise User to use the Contact Software and Services, hereinafter referred to as "you" or "End User". "End User". When an Enterprise User or Enterprise User Administrator invites you to access their Enterprise Account as an End User, you will receive an invitation by email, QR code, link and choose whether to join or not.

Personal Information: Information recorded electronically or otherwise that can be used alone or in combination with other information to identify an individual or reflect the activities of a particular individual.

Sensitive Personal Information: This includes personal biometric information, communication records and content, health information, transaction information, precise location information, etc. When we provide you with specific products or services that involve the collection of sensitive personal information, we will obtain your consent through prominent and clear notice before collecting sensitive personal information about you.Face data is collected because the access control device face recognition function must have an original photo of the user for comparison, so the face must be collected through the APP. Face collection is completely for the user to initiate the process. If the user needs to use the face recognition function, the user takes the initiative to collect a face in the APP. The user can also actively delete it later. So we will collect the face data of the user who needs to open the door by face recognition of the access control device. Face data use: face data is collected through APP, sent down to the access control equipment, encrypted storage. When the user who has collected the face is recognized by the access control device after the access control device checks successfully triggers the door to open. Data will not be shared, data encrypted storage in the access control equipment. If the user does not actively delete the face data, the data will always be stored in the access control device encrypted.

Anonymization: The process of technically processing personal information in such a way that the subject of the personal information cannot be identified and the processed information cannot be recovered. The information obtained after anonymization of personal information is not personal information.

De-identified processing: is the process by which personal information is processed in such a way that it cannot be identified with a specific natural person without the help of additional information.

Smart device: is a non-standard computing device produced or manufactured by a hardware manufacturer that has a human-machine interface and can transmit information via a wireless network.

Application: It is a mobile application (i.e. mobile client) developed by the Trudian that can help end-users to control the smart device remotely and transmit the records back to the Trudian Cloud platform.

Ⅰ、That personal information do we collect

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

1、 Information you voluntarily provide to us

Account Registration Information: When you register for an account with us, we collect your account name and contact information, including your email address, phone number, username, and login credentials. During your interaction with our products, we may further collect nickname, country code, language preference or time zone information from your account.

When you choose to authorize the use of third party account login, we will obtain your shared account information (default system avatar, nickname, region information) from the third party to bind with your Trudian account for quick login, and we will use your personal information in accordance with the agreement with the third party and the terms of the third party's published privacy policy regarding the sharing of personal information and in compliance with relevant regulations.

User Feedback: When you use our service and submit feedback and suggestions to us in relation to the service, we will collect your completed email address, cell phone number and feedback content (added pictures or videos), as well as logs of submitted issues, all of which will be used to give us the opportunity to deal with your application issues and smart device related failures in a timely manner.

At the same time, depending on the application products and services, Trudian may collect personal information that is appropriate and necessary to provide the products and services to you.

Based on the information collected by the additional functions provided

In an effort to provide you with more convenient and better products and/or services, and in an effort to enhance your experience, we collect and use your personal information in connection with the following additional services we provide to you. If you do not provide this information, it will not affect your ability to use the basic services of the Trudian Intelligence application, but you will not be able to access the user experience that these additional services provide to you. These additional services include:

Additional services based on location information:

When you enable the location function of your mobile device through system authorization and use the services provided based on location, we will collect and use your location information so that you can use the Trudian Cloud application to network with your smart device.

Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Location Information] permission

Additional services for accessing and uploading images based on photo albums (photo galleries):

You can use this feature to upload your photos/pictures with album permission to provide proof of reporting a problem with your device. When you report a problem with your device we will use the photos/pictures you upload to locate your problem.

Go to [My] - [Settings] - [Privacy Settings] - turn off/on [Photo Album] permission

Additional camera/camera based services:

You can use this feature for face recording with camera/camera permission turned on. Please know that even if you have agreed to turn on the camera/camera, we will only turn on the camera/camera when you tap to record your face.

Go to [My]-[Settings]-[Privacy Settings]-turn off/on [Camera/camera]

Additional services related to microphone-based speech technology:

You can use the microphone for visual intercom with the microphone permission enabled. Please know that even if you have agreed to turn on the microphone permission, we will only turn on the microphone when you actively click to accept the call.

Go to [My]-[Settings]-[Privacy Settings]-Turn off/on [Microphone] permission

Additional services based on storage permissions (for Android):

We are requesting this permission from you in order to ensure the stable operation of the client. After you enable our permission to read/write your device storage, we will read or write necessary information such as pictures, files, and crash log information from your device storage for the purpose of providing you with the function of information distribution or recording crash log information locally.

Go to [My] - [Settings] - [Privacy Settings]-Turn off/on [Storage] permission.

Additional features based on message notification permissions:

We are requesting this permission in order to send you notifications about products or services, especially if you have purchased a service that requires alerts to be sent to you so that you can catch the real-time status.

Go to [My] - [Settings] - [Privacy Settings]-Turn off/on [Message] permission.

"Hover Window" based add-on (Android):

We request this permission from you to receive call information when your access control device calls the mobile app.

Additional services related to Bluetooth-based technology:

You can make Bluetooth functions, including device control, device status acquisition, device discovery, device networking, in which we will communicate with end devices via Bluetooth, after you have enabled Bluetooth permission. Please know that even if you have agreed to enable Bluetooth permission, we will only use Bluetooth for communication in these scenarios: displaying device status in the home page and device panel; device control in the home page and device panel.

Additional services related to Face ID (Face ID) based technology (iOS only):

You can enable the Face ID feature for secure and convenient password-free login via Face ID verification provided by iOS, eliminating the need to repeatedly enter your account password. iOS does not provide Face ID data to us, and we do not and cannot collect and store your Face ID data. You can also turn this feature on/off at any time.

Additional features based on fingerprint permission (Android only): We request this permission from you in order to allow you to log in to the App password-free with your fingerprint ID, and we do not save and upload your fingerprint information.

Additional features based on binding to the Notification Listener Service permission (Android only)

We request this permission from you for the purpose of synchronizing App messages to your mobile smart device by listening to App notification bar messages after the smart device is connected to the App for display to you.

You understand and agree that the above additional services require you to enable access to your location information (geolocation), camera (camera), photo album (photo gallery), microphone (voice), internal and external storage, "hover window", Bluetooth, Face ID, fingerprint in your device to enable the collection and Use. You can check the status of each of these permissions in your device settings and turn them on or off at your discretion.

Please note that by turning on any of the permissions, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, and by turning off any of the permissions, you cancel your authorization, and we will no longer collect and use the relevant personal information based on the corresponding permissions, nor will we be able to provide you with the services corresponding to the permissions. However, your decision to turn off the permission will not affect the collection and use of information based on your authorization.

2、The information we collect automatically

Mobile Device Information: When you interact with our products, we automatically collect mobile device information, including mobile device model, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files and mobile network information, in order to protect your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience and protect the security of your account, application version number, push notification identifiers, log files, and mobile network information. At the same time, we may collect your software version number. We may collect information about the mobile applications and other software you use, as well as application installation lists of applications (for the purpose of application performance monitoring), as necessary to ensure the security of the operating environment or to provide the Services.

Log information: When you use our application, in order to improve your user experience, we collect log information about your use of the service, including the way, type and status of access to the network, network quality data, operation logs (such as function operations during the use of the contact service, etc.), service log information (such as the URL information you view in the contact, service failure information, etc.), so that we can accurately identify problems and help you solve problems during the use of the service.

Please note that mobile device information and service log information alone is information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be treated as personal information during the period of combined use, and we will anonymize and de-identify such information unless we obtain your authorization or unless otherwise required by law or regulation.

3、 Smart device related information

When you use a smart device, we collect information inherent in the smart device itself as well as information generated by you in the course of using the smart device.

Basic Smart Device Information: When you use a smart device connected to our products or services, we collect basic information about the smart device, including the smart device's name, device ID, online status, activation time, firmware version and upgrade information.

Information collected during the process of connecting smart devices: Based on the type of smart device you need to connect, whether it is via Wi-Fi connection, via Wi-Fi connection after establishing a local connection via Bluetooth, or via Bluetooth connection, we will collect the Mac address of the smart device.

Information reported by smart devices: Depending on the different smart devices you choose to connect to our products or services, we may collect information reported by your smart device. To help you better understand the use of our services, the following smart devices are used as examples, and their reported information applies only when you use that type of service:

For example: When you voluntarily use a smart access device and connect to a Trudian platform:You are connected to a camera-enabled doorway, access control to monitor the security of your home or view the content of the surveillance through the contact service ,after you add and use the device, when someone opens the door, the camera of the device will capture the surveillance screen (in picture format) in order to keep the proof of opening the door to protect your safety.

Ⅱ、The purposes for which personal information is processed and the definition of the legal basis

The purposes for which we process your information are as follows:

provides services to you: we process your account information, mobile device information, usage information, location information and smart device-related information to provide the products and services you request. The legal basis for such processing is the performance of our contract with you in accordance with our User Agreement.

to improve our services: We process your mobile device information, usage information, location information and smart device-related information to ensure the functionality and security of our products, to develop and improve our products and services, to analyze the efficiency of our operations, and to prevent and track fraud or misuse. The legal basis for such processing is the performance of our contract with you in accordance with our User Agreement.

Non-Marketing Communications: We process your personal information for the purpose of sending you important information related to services, changes to terms/conditions and policies, and/or other administrative information. At the same time, we may also send you notifications related to your purchase of services. You can manage whether you request to receive such communications in your device settings, and when you choose to turn off push notifications, we will not continue to send you such information. The legal basis for such processing is the performance of our contract with you under our User Agreement.

Compliance: We will only process your personal information if we are required by law to disclose the information, or when we believe it is necessary or appropriate to:

(a) To comply with applicable laws and regulations, legal process or requests from public agencies and governmental authorities;

(b)To honor our Terms of Use and other agreements, policies or standards, including investigating any potential use violations;

(c) To protect the rights, privacy, safety or property of us and/or other users, including you;

(d) As well as to seek available detection, prevention, remedial measures or to limit the damages we may be required to provide or to resolve security, fraud or technical issues.

We also use the collection of your personal information in other ways, and we will provide specific notice at the time of collection and obtain your consent as required by applicable law. If there are any changes in the purposes for which your personal information is processed, we will notify you of such changes via email and/or prominent notice on our website and inform you of your choices regarding your personal information.

Ⅲ、Who we share your personal information with

Trudian will only share your personal information in a way that you are aware of. We may share your personal information with the following participants:

Discloses your personal information to third party service providers who provide certain business-related services to us, including website hosting, data analytics, payment and credit card processing, infrastructure provisioning, IT services, customer support services, email delivery services, and other similar services, so that they can ensure that they can provide services to us.

Discloses your personal information to customers and other business partners who directly or indirectly provide you with smart devices and/or networks and systems that you use to access and use our websites and services.

Discloses your personal information to affiliates or other third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock (including, but not limited to, the foregoing in connection with any bankruptcy or similar proceeding). In such cases, you will receive explicit notice via email and/or our website of changes in ownership, new incompatible uses of personal information, and choices regarding personal information.

We will reasonably and lawfully share your personal information when it is necessary or appropriate for us to:

(a) To comply with applicable laws, regulations, legal process, policies and/or standards, or the requirements of appropriate public agencies and governmental authorities;

(b)Fulfilling our terms of use and other agreements, policies and standards, including investigating any potential violations;

(c) To protect our operations, business and systems;

(dTo protect the rights, privacy, security or property of us and/or other users, including you;

(e)Risk management, detection and identification of illegal, fraudulent, deceptive or malicious activity.

(f) Disclosure of your personal information to subsidiaries or affiliates of the Company for the purpose of conducting regular business activities.

We will disclose your personal information to third parties other than those listed above only with your consent.

Ⅳ、The transfer of the collected information

Trudian operates on a global basis, so the personal information we collect pursuant to this policy may be transferred, stored and processed between different countries or regions. The laws and regulations applicable in the country or region where we operate may differ from the laws applicable in the country/region where you reside, but we will strictly comply with the laws, regulations and requirements related to the protection of personal information. Therefore, within the framework of personal information protection, in order to facilitate our operations, we may transfer personal information to the countries or regions where we conduct business. Our privacy and security practices are designed to provide global protection for your personal information, regardless of where your information is stored.

In particular, personal information collected and generated in the course of our operations within the People's Republic of China will be stored and processed in data centers in mainland China, except where cross-border transfers are permitted under the provisions of applicable law.

If you would like to learn more about our security measures, you can contact us directly through this policy.

Ⅴ、The rights related to personal information

We respect your rights and we also hold your personal information.

You do not have to pay any fees to implement your personal rights. According to the requirements of local information protection law, we will check and process your request within 15 working days if your account is served in mainland China, or within 30 days if your account is served outside mainland China.

If you decide to send us a request via email, please indicate what information you would like to change, whether you would like your personal information removed from our database, or what restrictions you would like us to place on the use of your personal information. Please note that for security reasons, we will ask you to verify your identity before we can process your request further.

You may exercise your rights with respect to your personal information through the following indicated routes:

Right to correct personal information: If you ask us to correct inaccurate or incomplete personal information relating to you, you may correct the information in 2 ways:

1)Modify "registered account" (email): [My] - [Settings] - [Account and Security] - [Email];

2)Modify "Region": [My] - [Settings] - [Account and Security] - [Region];

Personal information deletion right: If you request to delete your personal information, you can go through [My] - upper right corner [Settings] - [Account and Security] - [Account Cancellation], according to the prompt display, you can cancel your account and further delete your personal information;

Personal information restriction processing rights: request to temporarily or permanently restrict us from processing some or all of your personal information, please delete your account through [My] - [Settings] - [Account & Security] in the application or [My] - [FAQ & Feedback] to us or by trudian@aliyun.com submitting your application.

Right to revoke the processing of personal information: When we choose to object to or refuse our use of your personal information based on your consent or our legitimate interests, please refer to the following "revocation of consent" process to revoke your decision to consent to the processing:

1) as mentioned above, you can change the device permissions through the application's [My] - [Settings] - [Privacy Settings] and then in the device system settings to obtain the permission settings to revoke your consent, including location, camera/camera, photo album (photo gallery/video gallery), microphone, Bluetooth settings, message notification push and other related functions;;

2) in the non-marketing communications you agree to,go to [My] - [Message Center] - [Settings] to close your choice;

3) Unbundling smart devices through the Trudian Cloud platform, your information of using smart devices will not be collected;

When you withdraw your consent or authorization, it causes us to be unable to continue to provide you with the services corresponding to the part of withdrawal of authorization. However, your withdrawal of consent or authorization does not affect the withdrawal of the personal information processing previously carried out based on your consent.

If you still have further questions, please contact us through [My] - [FAQ & Feedback] in our application, or please send an email to trudian@aliyun.com

Ⅵ、Information security measures

We maintain commercially reasonable physical, administrative and technical safeguards to maintain the integrity and security of your personal information. Contact provides a variety of security safeguards to effectively ensure the security of user and device information.

In terms of device access, we use proprietary algorithms for contact points to guarantee data isolation, access authentication and authorization requests.

We support communication using secure algorithms and transport encryption protocols as well as commercial grade information encrypted transmission based on dynamic keys for data communication.

We use strict data filtering and validation as well as a complete data review process for data processing.

In terms of data storage, all confidential information of users will be securely encrypted for storage.

In addition to the above-mentioned security at the technical level, at the institutional and control level, Trudian also has a series of security safeguards in place, including assigning duties and responsibilities, holding training courses on security and privacy protection, strengthening employees' awareness of data protection, controlling access rights and other measures to prevent data loss, illegal use, receiving unauthorized access or leakage, tampering or destruction.

Please send an email to trudian@aliyun.com,If for any reason you believe that your interactions with us are no longer secure (for example, you believe that the security of your contact account has been compromised), Please Let us know immediately and send your email to trudian@aliyun.com .

If a security incident occurs that affects your personal information security, we will be the first to notify you through your reserved email address, phone number, message center push and other ways, and inform you of the recommendations to reduce or prevent the relevant risks and other information. If necessary, we will take timely remedial measures in accordance with our internal security incident contingency plan, and report to the relevant authorities in accordance with regulations.

Ⅶ、Information retention period

We will process your personal information for the shortest period of time necessary to achieve the purposes described in this policy or as required by law or regulation, unless a longer retention period is required by specific legal requirements. We will determine the appropriate retention period based on the volume, nature and sensitivity of the personal information, and at the end of the retention period, we will destroy your personal information.

1) in accordance with the User Agreement and this Policy in order to meet the products and services requested by you;

2) When you explicitly request the deletion of your personal information, we set this as a task and no longer retain your personal information.

We will stop retaining and do deletion of your personal information when we confirm that the purpose of collection and processing of personal information is completed on the basis of 1), or after we confirm your request for deletion or cancellation according to 2), or after we terminate the operation of the corresponding product or service. In general, we will not retain your personal information once the specified retention period has been reached. If we are unable to destroy the information for technical reasons, resulting in the retention of personal information beyond the storage period, we will take appropriate measures to prevent further use of your personal information, including anonymization.

Ⅷ、Protection of personal information of children

Trudian takes the protection of children's personal information very seriously. If you are under the age of 14 (or the age specified in your country/region), it is important that you read the Trudian Children's Privacy Statement and obtain prior written consent from your parent or legal guardian before you use our Services. Trudian protects the personal information of children in accordance with the relevant laws and regulations of each region, country or territory. Please note that if we discover that we have collected personal information from children without the prior consent of a verifiable parent or legal guardian, we will attempt to delete the relevant personal information as soon as possible.

Ⅸ、Statement on policy changes

We will update this policy at least annually in response to changes in information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or post a notice within the Application before the changes take effect. We encourage you to periodically visit the Application for the latest information on privacy practices.

Ⅹ、Contact us

If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us at [My] - [FAQ & Feedback] in the Trudian Application or as provided below, and specify "Privacy Policy". We have a dedicated privacy and security team to address your questions regarding your rights and inquiries regarding personal information. If your question itself involves a more significant matter, we may ask you to provide additional information to confirm the nature and impact of the matter. If you are not satisfied with the response you receive, you may refer the complaint to the appropriate regulatory agency. When you consult us, we will provide information on the relevant complaint channels that may be used in accordance with your actual situation and will complete verification and processing of your request within 15 working days.

Contact information and contact address:

Guangdong Trudian Technology Co.,Ltd

Address for correspondence: Farbell Technology Park, Yixian Road, Nanlang Street, Cuiheng New District, Zhongshan City, Guangdong Province

E-mail:trudian@aliyun.com

Contact number: