Our
Privacy Policy took effect on March 10, 2023. From now on, this Privacy Policy
provides privacy details on how we manage your personal information for Handy
Heat Pump products and services. Please take a moment to familiarize yourself
with our Privacy Policy and let us know if you have any questions.
We
commit to you that:
Guangzhou
LinkedGo Technology Co., Ltd. (hereinafter referred to as "LinkedGo”,
we", "our" or "us") considers your privacy as very
important. Handy Heat Pump is a smart device control and management platform
provided by us.
Your
privacy is quite significant for us. The Privacy Policy is a statement and
commitment covering the privacy of Handy Heat Pump APP and constitutes an
integral part of our Privacy Policy. In the event of any inconsistencies
between our Privacy Policy and other specific agreements involving Handy Heat
Pump, the terms of the Privacy Policy shall prevail. Matters not explicitly
specified in the Privacy Policy shall be governed by our Privacy Policy.
The
Privacy Policy is designed to fully consider your needs. Please make sure that
you have a comprehensive understanding of our personal information collection
and usage practices, while ensuring that ultimately, you have control of your
personal information provided to us. The Privacy Policy explains how we
collects, uses, discloses, processes, and protects any information that you
give us when you use Handy Heat Pump APP. Under the Privacy Policy,
"personal information" means information that can be used to identify
an individual, either from that information alone or from that information
combined with other information. We only use such information in strict
accordance with the Privacy Policy.
Ultimately,
we want to provide users with the best experience. Should you have any
questions with our data handling practices as summarized in the Privacy Policy,
please send email to support@go-heating.com, so that we can reply to your
specific concerns. We are happy to receive any of your feedback.
I. What
information is collected by us and how do we use it?
(I)
Personal information needs you to authorize us to collect and use it
We
collect personal information to provide you with products and/or services and
to ensure that we comply with applicable laws, regulations, and other
regulatory documents. You have the right to choose whether to provide this
information. However, in most cases, if you do not provide this information, we
may not be able to provide you with corresponding services or respond to your
queries. These functions may include:
(1)
Smart device connection:
In
order to provide you with Handy Heat Pump account services and allow you to
securely connect to and manage smart devices, we may collect your Wi-Fi
information, location information, account login information, information
associated with your mobile phone and smart devices, and information associated
with your Handy Heat Pump account and smart devices. The information will be
used to provide you with a variety of functions, including pairing and connecting
with smart devices, discovering nearby devices, and device management. Examples
of the aforesaid information are as follows:
l Account
login information: Handy Heat Pump account, nickname, and profile picture
information.
l Mobile phone-related
information: Hardware-based identifier (MAC address, Android ID), mobile phone
model, operating system version, operating system language, country or region,
version of APP store, screen size and resolution, CPU, and display
device-related information.
l Information
to be collected while connecting to smart devices: Depending on the type of
smart device you need to connect to, we may collect the following information:
l Smart
devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, Wi-Fi MAC address,
and Wi-Fi password), device MAC address, and device ID.
l Smart
devices connected via Wi-Fi after local connection is built via Bluetooth:
Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, and Wi-Fi password), device
MAC address, and Bluetooth MAC Address.
l Smart
devices connected via Bluetooth: Bluetooth MAC address on the device and device
ID.
l Smart
devices connected via 4G and NB-IOT: IMEI and ICCID of the device.
l Smart
devices connected via LORA: UUID and MAC on the device.
(2) Use
smart devices for home management
We may
collect information related to room settings that you provide to smart devices
for smart home management. This will allow you to enjoy greater convenience
when using smart devices (for example, being able to quickly recognize that a
device is in the bedroom rather than the living room when using multiple smart
devices).
(3)
Device sharing
We
support you to share smart devices with others through your Handy Heat Pump
account. Sharing smart devices with others also allows them to control them. To
enjoy this function, we may collect your account ID, ID provided by you that is
associated with the account to which you share access, and shared device
information (including device ID, device name, device authentication key, and
device sharing status). Through this information, we enable you to share device
controls and usage with other users' Handy Heat Pump accounts, as well as
display device sharing status on My Devices of the Handy Heat Pump APP.
(4)
Update of APP and smart devices:
To
ensure that you can continue to receive the latest Handy Heat Pump service, we
may use your Handy Heat Pump APP version information and your mobile phone
model to provide you with Handy Heat Pump APP updates. We may also collect a
list of your connected smart devices and related version information to provide
you with smart device updates so that you can use the latest version of the
service (including firmware versions).
(II)
Circumstances in which you may need to authorize us to collect and use your
personal information
To make
you better control and manage the smart devices provided by Handy Heat Pump, we
may collect and use your personal information in the following additional
functions. If you do not provide this personal information, you can still use Handy
Heat Pump's basic services, but you may not be able to use these valuable
additional functions. These additional functions include:
(1)
User feedback:
We may
collect your feedback on issues you report to us, feedback logs, and any phone
numbers or email addresses you provide us. The information is used to help us
better understand any problems you encounter and allow us to contact you.
(III)
Your personal information we obtained from third-party sources
Under
certain conditions permitted by law, we may collect your personal information
from third-party sources. For example, when using the Smart Scenario function
(smart device connection), if you provide authorization, we can get the device
status of the smart device from the area where the smart device is to determine
whether to activate the Smart Scenario (for example, if you configure a rule to
turn on the light when someone walks by the sensor). You can Add or Delete
smart connection rules on the “Smart” page. You also can select to Enable and
Disable smart connection on the Smart Device page.
(IV)
Non-personal information
We may
also collect other types of information which are not directly or indirectly
linked to an individual and which may not be defined as personal information
according to applicable local laws. Such information may include statistical
data generated when you use a specific service, for example, clicking, page
redirecting, and browsing time; We collect such information to improve the
services we provide to you.
II. Sharing your personal information with third party
service providers
We do
not sell any personal information to third parties. To help us provide you with
products and services described in the Privacy Policy, we may, where necessary,
share your personal information with our third party service providers and
business partners. We will conduct due diligence and have contracts in place to
ensure that third-party service providers comply with the applicable privacy
laws in your jurisdiction. Location-based service providers: Our certain
location-based services are provided by third party providers, including Baidu.
In order to provide you with location-based services, we may provide these
service providers with information such as your device identifier. If we share
your personal information with third parties, we will use encryption technology
or other means to protect your information security. We reasonably examine the
data security practices of companies and organizations that share personal
information with us and/or sign strict data processing agreements with us. In
addition, we require third parties to take appropriate measures to protect your
information and strictly comply with applicable laws, regulations, and
regulatory requirements.
III.
Retention Policy
We
retain personal information for the period necessary for the purpose of the
information collection described in the Privacy Policy, or we retain personal
information to comply with applicable legal requirements. We will cease to
retain and delete or anonymize your personal information once the purpose of
collection is fulfilled, or after we confirm your request for erasure or
cancellation, or after we terminate the operation of the corresponding product
or service. We will continue to retain relevant information in accordance with
applicable law, even if further information processing is not related to the original
collection purpose, provided that doing so is in the public interest or for
scientific or historical research or statistical purposes.
Vi.
Your Rights
(I)
Controlling settings
We
recognize that privacy concerns differ from person to person. Therefore, we
provide examples of ways Handy Heat Pump makes available to you to restrict the
collection, use, disclosure, or processing of your personal information and
control your privacy settings: enable or disable location access, camera,
microphone, and read/write access on the mobile phone;
l Modify
personal information, such as nicknames or profile pictures. To do so, open the
Handy Heat Pump APP and go to My > Settings > Personal Data;
l Enable
or disable smart device connection;
l Log in
or log out Handy Heat Pump account.
If you
have previously consented to us using your personal information for the
aforesaid purposes, you may change your mind by withdrawing authorization at
any time.
(II)
Your rights to your personal information
Depending
on applicable laws and regulations, you may have the right to access, rectify,
and/or erasure in relation to personal information that we hold about you
(hereinafter referred to as the “request”).
You may
also access and update the details relating to the personal information in Handy
Heat Pump by signing in to your account on your device. For additional
information, please send us an email to support@go-heating.com. Most laws
require a data subject to meet certain requirements when making a request. The
Privacy Policy requires that any request you make meets the following
conditions:
l Your
request shall be submitted through our specified request channel in writing
(unless the local law explicitly recognizes the oral request) to protect your
personal information security;
l You
provide sufficient information to enable us to verify your identity and ensure
that you are the data subject or legally authorized to act on the data
subject's behalf.
l Once we
obtain sufficient information to confirm that your request can be processed, we
shall proceed to respond to your request within any timeframe set out under
your applicable data protection laws. In detail:
l Based
on the requirements of applicable laws, a copy of your personal information
collected and processed by us will be provided to you upon your request free of
charge. For any extra requests for relevant information, we may charge a
reasonable fee based on actual administrative costs according to and if
permitted by the applicable laws.
l If you
think that any information we are holding on you is incorrect or incomplete,
you are entitled to have your personal information corrected or completed based
on the purpose of use.
l Based
on the requirements of applicable laws, you have the right to request the
deletion or removal of your personal information. We shall consider the grounds
regarding your erasure request and take reasonable steps, including technical
measures, if corresponding rules are fulfilled. After you delete or we assist
you to delete your information, we may not be able to immediately delete the
corresponding information from the backup system due to applicable laws and
security techniques. In this case, we will ensure that your personal
information remains secure and prevent any further processing of the backup
before it is removed or anonymized. For example, the E-Commerce Law of the People's
Republic of China requires that your goods and services information and
transaction information is retained for no less than three (3) years from the
closing date of the transaction.
l We have
the right to refuse to process requests deemed frivolous or vexatious,
compromising the privacy of others, highly unrealistic, requiring
disproportionate technical effort, no need of approval under local laws, and
involving information already in the public domain or provided under conditions
of confidentiality. We may also deny a request to delete or access data if we
believe that some aspect of the request could prevent us from lawfully using
the data for the aforesaid anti-fraud and security purposes.
(III)
Withdrawal of letter of consent
l You may
withdraw your consent by submitting a request, including collecting, using,
and/or disclosing your personal information in our possession or control. You
can go to My > Privacy Settings > Withdraw Consent to Privacy Policy. We
will process your request within a reasonable time from when the request was
made, and thereafter not collect, use and/or disclose your personal information
as per your request.
l Please
note that your withdrawal of consent may result in certain legal consequences.
Depending on the extent to which you authorize us to process your personal
information, please note that you may not be able to continue receiving the
full benefit of our products or services. The withdrawal of your consent or
authorization will not affect the validity of our processing of personal
information on the basis of the consent up until the point of withdrawal.
(IV)
Cancelling a service or account
If you
wish to cancel an Handy Heat Pump account, please note that the cancellation will
prevent you from using the full range of our products and services.
V. How
your personal information is transferred globally
We
process and backs up personal information through a global operating and
control infrastructure. Currently, we have data centers in China and Germany.
For the purposes described in the Privacy Policy, your information may be
transferred to these data centers in accordance with applicable law.
We may
also transfer your personal information to third-party service providers and
business partners and your data may therefore also be transmitted to other
countries or regions. The jurisdiction in which these global facilities are
located may or may not protect personal information to the same standards as in
your jurisdiction. There are different risks under different data protection
laws. However, this does not change our commitment to comply with the Privacy
Policy and to protect your personal information.
In
particular
l The
personal information that we collect and generate in operations within the
territory of Mainland China is stored in data centers located in Mainland
China, except for cross-border transmissions as permitted by applicable law.
l The
personal information we collect and generate in our operations in Germany is
processed and stored in data centers located in Germany, except for
cross-border transmissions as permitted by German law.
If we
need to transfer personal information outside of your jurisdiction, whether to
our affiliates or third-party service providers, we will comply with related
applicable laws. We ensure that all such transfers meet the requirements of
applicable local data protection laws by implementing uniform safeguards.
If you
use our products or services in the area of the European Economic Area (EEA),
XXX will act as the data controller and will be responsible for the data
processing. Contact details can be found in the "Contact us" section.
If we
share personal data originating by you in the EEA to our affiliates or a third
party service provider outside the EEA, we will do so on the basis of EU
standard contractual clauses or any other safeguards provided for in the GDPR.
V.
Third Party Websites and Services
Our
Privacy Policy does not apply to products or services offered by a third party.
Depending on the product or service you use, Handy Heat Pump products or
services may incorporate a third parties' products or services, such as
location-based services. Some of these will be provided in the form of links to
third parties' websites, and some will be accessed in the form of SDKs, APIs,
etc. Your information may also be collected by a third party when you use these
products or services. For this reason, we strongly suggest that you take the
time to read the third party's privacy policy just like you read ours. We are
not responsible for and cannot control how third parties use personal
information which they collect from you. Our Privacy Policy does not apply to
other sites linked from our services.
The
following are the examples of when third party terms and privacy policies may
apply when you use the specific products or services listed above:
Privacy
policies of location-based service providers:
l Baidu
Map Open Platform Product and Services Privacy Policy
Notification
push:
VII.
Contact Us
If you
have any doubts or feedback about this Privacy Policy or any questions relating
to our collection, use, or disclosure of your personal information, please
contact us by sending an email to support@go-heating.com. Our professional
response team can handle any questions you may have about your claims or about
your personal information. If your question itself involves a significant
issue, we may ask you for more information. If you are not satisfied with the
response you received from us, you can hand over the complaint to the relevant
data protection regulatory authority in your jurisdiction. Upon request, we
will provide you with information on how to file a complaint based on your
actual situation.
Address:
l No.3,
Tianyuan Road, Dagang Town, Nansha District, Guangzhou City, Guangdong
Province, China, Postcode: 511470