AnyLink Privacy Policy 

Effective date: 07/01, 2023

Version No.:1.0

1. Introduction

Thanks for using AnyLink Home App (“APP”). The APP is operated by Jiangsu Ziqing Information Technology Ltd. registered office in Suite 1106, 401 North Xingyuan Road, Wuxi, Jiangsu (hereinafter, “we”, “us” and “our”) for you to better use our AnyLink IoT Gateway products, and/or connected third party's equipment (“Product”). The third party's equipment may include, but not limited to, heating and cooling equipment, heat pumps, refrigerators, freezers, etc. Jiangsu Ziqing Information Technology Co., Ltd is the data controller of the personal data collected while proving you services.

We are fully aware of the importance of personal data security and your rights. This privacy policy is drafted in accordance with data protection and privacy protection regulations, and other applicable laws and regulations in China. This policy describes the purposes, methods, collection scope and information security protection measures of our collecting, using, storing, entrusted handling, sharing, transferring and public disclosure of your personal data in the process of the provision of AnyLink Home mobile app, as well as the methods we provide to enable your control over your personal data, such as accessing, collecting, and deleting your personal data. Please read this policy together with our End User Agreement.

This policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, changes in applicable laws etc. We encourage you to read this policy carefully, and to regularly check http://www.anylink.io/legal (our web page) to review any changes we might make in accordance with the terms of this policy.

This policy will help you to understand the following:

1. Introduction

2. How Do We Collect and Process Data

3. How Do We Collect and Process Minors' information

4. Information Shared with Third Parties

5. How and Why We Process Your Information and Our Legal Basis for Processing

6. How Do We Store Your Data

7. How to Exercise Your Rights?

8. Cookies and Similar Technologies

9. Changes to our privacy policy

10. How to Contact Us

 

2. How Do We Collect and Process Data

We collect and process the following categories of personal data about you in order to provide you with services.

2.1 Information You provide

Your Account Information. You agree to provide your name, gender, mobile phone number, email, mailing address to create an account. If you don’t provide us with this information, you will not be able to create an account to use our Services. You can add other optional information to your account, such as a profile picture, and "about" information.

Device Installation Information. We collect information include installation address, installation time, and maintenance information when you apply to install the device. If you do not provide us with such information, we are not able to arrange technical professionals to install the device for you.

 

2.2 Automatically Collected Information

Device Information. We collect device information to provide you with continuous quality services, such as maintenances services etc. Information we automatically collect include your remote operation records, device model, device on-off status, operation mode, ambient temperature parameters, water temperature parameters, exhaust temperature parameters, intake temperature parameters, fan parameters, press parameters, various valve parameters, voltage and current parameters, various fault parameters, etc.

 

2.3 Information Third Parties Provide About You

Third-party Services. We may receive information about bad actors and abuse from security detection provider and app verification information from anti-abuse services to promote safety, security and integrity.

 

3. How Do We Collect and Process Minors' information

If you are a minor user, please read and agree to this policy carefully under the company and guidance of your legal guardian. You and your legal guardians shall take responsibilities in accordance with the laws, regulations, and this policy. Once a minor uses our App, we assume that he or she has the consent or guidance of a legal guardian. Our products and/or services are not provided to children (the definition of children is subject to your jurisdiction). If we accidentally collect personal information from a child (the definition of children is subject to your jurisdiction), we will delete such information as soon as possible.

We protect minors' personal information in accordance with the applicable laws and regulations, and will only collect, use, store, share, transfer or disclose minors' personal information permitted by law, with the consent of legal guardian, or when necessary for protecting the minor. If we notice that a minor's personal information has been collected without the prior and verifiable consent of the legal guardian, we will endeavor best efforts to delete the relevant information as soon as possible.

If you have any question about our practices or measures on protecting minors' personal information, you may contact us through the contact information specified in section 10 of this policy.

4. Information Shared with Third Parties

Respecting users' privacy is one of our fundamental principles. We will not share your personal data with any company, organization or individual, except for the following circumstances:

(1) We may share your personal data in accordance with laws and regulations or mandatory requests from competent government authorities.

(2) Share with authorized partners:

To provide you with better and quality products and/or services, certain services will be provided by our partners and, as a result, we may share some of your personal data with our partners. We will only share your personal data where it is legal, justified, necessary, specific and explicit purpose, and only where it is necessary to provide services to you.

Each partner may have its own separate privacy policy/personal data protection policy and user agreement. We recommend that you carefully read and comply with the third party's user agreement and privacy policy/personal data protection policy. If you refuse to allow our partners to collect the personal data necessary for the provision of the service, you may be unable to use those services provided by our technology partner by using products and/or services.    

5. How and Why We Process Your Information and Our Legal Basis for Processing 

Under applicable data protection laws and regulations in China, companies must have a legal basis to process information. We rely on your consent to collect and process your personal data and you may refer to our purposes and means of processing in section 2 of this policy. We may also need to process your personal data in order to comply with legal obligations.

6. How Do We Store Your Data

6.1. Retention of Your Personal Data

We take every reasonable step to ensure that your personal data are only processed for the minimum period necessary for the purposes set out in this policy. If our products and/or services were ceased due to business strategy or other reasons, unless otherwise stipulated by laws and regulations, we will take reasonable effort to notify you such circumstance, stop collecting your personal information, and delete or anonymize collected personal information.

6.2. Security Measures Taken to Safeguard Your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. The technical and organizational security measures taken by us include the following:

l We may adopt the cryptographic technology such as transport layer security protocol and deploy Https and other ways to prevent the transmission links from being eavesdropped, intercepted, and to establish a safe and private data environment and ensure the confidentiality and completeness of data. We may also take additional safety measures to protect your information such as encrypted storage.

l We may have implemented a strict data authorization control mechanism, adopted multiple identity authentication technology, and monitored the processing of your personal information to prevent illegal access and unauthorized use of data. We may also monitor the entire lifecycle of data to protect your personal information from unauthorized access, public disclosure, use, modification, and intentional or accidental damage or loss, etc.

However, because the internet is an open system, the transmission of information via the internet is never completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk, and you are responsible for ensuring that any personal data that you send to us are sent securely.

6.3. Transferring Outside China

Your personal data will be stored in a data center located in China; however, our technical specialists based in other regions, including US and European union, will access and process your personal data from time to time to provide technical solutions and troubleshoot operation errors (if any). By agreeing to this policy and using our products, you allow us to process data in such manner. Your personal data will not be transferred to any other parties outside of China.

7. How to Exercise Your Rights?

We recognize and protect your lawful rights under applicable data privacy regulations, and you may exercise your rights at any time. Your rights include but not limited to:

7.1. The Right Not to Provide Your Personal Data to Us

You have the right not to provide your personal data to us (however, please note that we will be unable to provide you with the full benefit of our products and/or services if you do not provide us with your personal data – e.g., we might not be able to process your requests without the necessary details).

7.2. The Right to Withdraw Your Consent

Where we process your relevant personal data on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal data in reliance upon any other available legal bases).

7.3. The Right to Access

You have the right to contact us to access your personal data.

7.4. The Right to Rectification

If you find that the personal data you have provided or processed by us is incorrect, you have the right to correct the information through settings in the App. If you are unable to correct the information by yourself, you can contact with us at any time in the manner described in this policy, and we will respond to your request for correction as promptly as possible.

7.5. The Right to Delete

Unless stipulated by laws and regulations, you shall have the right to delete part of personal information at any time at your discretion by using relevant function in the App, or contact us to delete your information. You may make a request to us to delete personal information under the following circumstances:

(1) Our processing of the personal information violates the laws or regulations.

(2) We collect or use your personal information without your prior consent.

(3) Our processing of the personal information violates the agreement with you.

(4) You stop using our products or services or you log out of your account.

(5) We no longer provide you with products or services.

(6) Other circumstances stipulated by the laws and regulations.

You hereby agree that once the deletion request is responded, your personal information will be deleted and any information you have provided and the record of actions you have taken will not be retrievable.

7.6. Cancellation of Account

Unless otherwise stipulated by laws and regulations, or stipulated in this policy, you may cancel your account by entering using the relevant function to do so.

To guarantee the safety of your account and assets, please, prior to closing your account, check and make sure that the account has met the following requirements: the account is registered by yourself, there is no complaint in the account. Your application for account closure shall be deemed as your voluntary waiver of all the assets and interests in the account (including the services you have subscribed to but not used up), after-sale service that may be generated from historical transactions and other rights and interests.

Please understand that unless we have retained or stored your personal data in accordance with the laws and regulations or the requirements of regulatory authorities, we will promptly delete your personal information or anonymize it after your account cancellation. Please be aware that we may not delete such information from our backup system immediately but will delete it when the backup system is updated within a reasonable time frame.

It is irreversible for you to close your account. Once you close your account, we will no longer collect your personal information, nor will we provide you with all products and/or services; the content and information under the account will be deleted or anonymized, unless otherwise stipulated by the laws and regulations or stipulated by regulatory authorities. Therefore, we advise that you should use caution in choosing to close your account.

8. Cookies and Similar Technologies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

8.1 How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

· Keeping you signed in

· Understanding how you use our website

· Add any uses your company has for cookies

8.2 What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

· Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

· Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

8.3 How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, if you choose to disable cookies, some of our features may not function properly as a result.

9. Changes to our privacy policy

We will keep this privacy policy under regular review and places any updates within the App. Our updates form part of this policy. With respect to material changes, we will also provide more conspicuous notices, such as conspicuous position notices, pop-up boxes, etc. In such cases, if you choose to continue to use our service, it means that you agree to be bound by the amended policy. Material changes in this policy include but are not limited to:

(1) Our service model has changed substantially. For example, the purpose of processing personal information, type of personal information processed and method of using personal information, etc.

(2) We have material changes in the ownership structure and organizational structure. For example, change in ownership due to business adjustment, bankruptcy, merger and acquisition, etc.

(3) Your rights to participate in the processing of personal information and the method of exercising them have changed substantially.

(4) When there is any change in the department responsible for personal information security, contact information or the channels of making complaints.

(5) When the personal information security impact assessment report indicates a high risk.

10. How to Contact Us

You also have a right to file a complaint with a supervisory authority, even though we encourage you to first contact us with any questions or concerns.

If you have any questions about the privacy policy, the data we hold of you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us:

· Email us at: legal@anylink.io

· Write to us at: Suite 1106, 401 North Xingyuan Road, Wuxi, Jiangsu Province.