We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws. We are equally committed to ensuring that all our employees and agents uphold these obligations.
TRANSPARENCY/NOTICE: WHAT INFORMATION IS COLLECTED AND HOW WE CAN USE IT
The types of personal information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Some of the ways that we may collect personal information include:
· You may provide personal information directly to us through interacting with the products and services, and requesting services or information.
· As you navigate the services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of processing.
· Information You Provide Directly to Us. When you use the services or engage in certain activities, such as registering for an account, responding to surveys, requesting services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
· Communications with Us. We may collect personal information from you such as email address, or phone number when you choose to request information about our services, or register for our newsletter that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
· Automatic Data Collection. We may collect certain information automatically through our websites, products, services or other methods of analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and other actions taken through use of the services such as preferences.
· Specific Information Collected Through Our Products and Services. We may collect the following types of information (which may or may not be personal information):
· To Provide Products, Services, or Information Requested. HUAMI may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
o Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device;
o Communicating with you about your device, service or any general queries or other requests and comments, such as updates, customer inquiry support, information about our events, notices;
o Providing access to certain areas, functionalities, and features of our products and services;
o Allowing you to post comments in public forums;
o Conducting promotional activities, such as sweepstakes and Facebook events;
o Analyzing and developing statistical information on the use of our products and services to better improve our products and services;
o Optimizing the performance of your device;
o Storing and maintaining information about you for our business operations or legal obligations; or
o Providing local services without communicating with our servers.
· Administrative Purposes. We may use Personal Information about you for administrative purposes, including to:
o Measure interest in our services;
o Develop new products and services;
o Ensure internal quality control;
o Verify your identity;
o Communicate about accounts and activities on our services and systems, and, in our discretion, changes to any of our policies;
o Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
o Prevent potentially prohibited or illegal activities; or
o Enforce our Terms.
· Marketing Our Products and Services. We may use personal information to provide you with materials about offers, products, and services that may be of interest, including new content or services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to you;
o To provide Services to you and our sponsors;
o For other purposes disclosed at the time that Individuals provide Personal Information; or
o Otherwise with your consent.
· Research and Development. We may use personal information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products and services and we may share these statistics with the public or third parties in order to present the preference and trend analysis.
· Sharing Content with Friends or Colleagues. Our services may offer various tools and functionalities. For example, we allow you to provide information about or to your friends through our products and services. Our products and services may allow you to forward or share certain content with a friend or colleague.
· Specific Ways Personal Information is Used in Products and Services. Here are more details on how we use your information (which may include personal information):
o Setting up your account for Mi Fit. Personal information collected when creating Mi Fit account through our Mi Fit app, is used for creating the Mi Fit account and profile page for the user.
o Calculate exercise results. Personal body information are used to accurately calculate the exercise result information, such as BMI, muscle mass, body fat percentage, moisture content, protein, basal metabolism, visceral fat level, bone mass content, body shape, body age, calories burned.
o Physical analysis. Based on the personal data you provided and the data recorded by the device，we will provide you an analysis related to your physical condition for your reference. For example, according to your personal data and body composition, we can provide you a suggested ideal body weight interval value for your reference, present to you your current/whole-day pressure value and/or pressure tendency.
o Providing Mi Fit services. When you connect certain device with Mi Fit, the information collected through the device will be shown to user.
o To display caller information. When you receive a call, text messages, caller information will display on the device (certain type of device may not support this feature).
o To display music information. When you use music control function, the music information (name of song, name of album, singer, the playback of song, the status of song) will be displayed on the device (certain type of device may not support this feature).
o To determine whether the phone is supported. Phone Info will be used to determine if your device can use Mi Fit.
o Providing universal time function. You can add clocks around the world in Mi Fit according to your needs. We will calculate the local time corresponding to your selected area based on the time of your mobile phone and display it on Mi Fit and some other devices that support the universal time function.
o Providing female health function. You can record certain information related to menstrual period on some devices that support this function or in Mi Fit; If you turn on the physiological period intelligent prediction mode, we will predict your menstrual period and remind you based on the information you fill in. We also can recommend suitable training courses to you based on your physical condition during menstruation.
o Providing network related services. We use network types, network signals, etc. to prompts the user to download updates in different network environments.
o Providing location based services. In the course of using Mi Fit services, location information used to record the position in motion. For example, when you use the running track information recorded by the Mi Fit running function, using location optimization weather function or request map information, your location information may be sent back to Mi Fit so that Mi Fit will provide you with the right content.
o Providing off-wrist lock function. Your Mi band unlock password will be used to the off-wrist lock function. If you release this function, Mi band will be locked when the device detects that it is not be worn. If the wrong password is entered on the device more than a certain number of times, the user will be prompted to change the Mi band unlock password on Mi fit or restore the factory Settings on Mi band. For the avoidance of doubt, the foregoing information is only stored on the device and will not be sent to the server.
o Optimize service. Log information is used to improve the quality of service.
o Providing management devices. This information provides the ability to manage the bundled devices.
o Improve software stability. Collect crash logs for analyzing software quality to provide better service.
o Improve device stability. We may use the information to improve the bundled devices.
· Anonymous and Aggregated Information Use. We may use personal information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the mobile phone or device from which you access Mi Fit, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including presenting your activity rank among friend. Anonymized or aggregated information is not personal information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
· Providing location based services. In the course of using our services, location information may also be used by us or Third Party Service Providers to serve you the correct version of the service and provide accurate details about that location for the best possible user experience, e.g. weather details, location access (as part of the Android platform). You may turn this off at any time by going into the device settings or discontinue use of that application.
· Improving user experience. Some opt-in features allow us or our Third Party Service Providers to analyze data about how users use the Huami products and services, so as to improve the user experience, such as sending crash reports.
· Sending notices. From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies.
We may use your email address, Mi Account ID to provide marketing materials to you relating to goods and services of HUAMI and our business partners which offer network, mobile applications and cloud products and services. We will only so use your personal data after we obtain your prior explicit consent and involve a clear affirmative action or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication or sending email to firstname.lastname@example.org. We will not transfer your personal data to our business partners for use by our business partners in direct marketing.
· What information is collected and how we can use them: Technologies such as cookies, tags, and scripts are used by HUAMI and our Third Party Service Providers. These Technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
· Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the site may not work properly.
· Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
· Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
· Advertising: We partner with our Third Party Service Providers to display advertising and manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to gather information about your activities on other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out through the third party sites as described below.
· Mobile Analytics: Within some of our mobile applications, we use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where crashes occur within the application. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
THIRD PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SOFTWARE DEVELOPMENT KITS
Our site may contain links to other websites and other websites may reference or link to our site, products or other services. These other domains and websites are not controlled by us, and we does not endorse or make any representations about third-party websites or social media platforms. We may use third party APIs and/or software development kits (“SDKs”) as part of the functionality of our products and services. APIs and SDKs may allow third parties (including advertisers) to collect your personal information to provide services and content that is more relevant to you.
We encourage you to read the privacy policies of each and every website and application with which you interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Our services may include publicly accessible blogs, community forums, or private messaging features. The site and our other services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our site or other services. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.
We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.
Our Third Party Service Providers include, without limitation, our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers. Such Third Party Service Providers will be processing your personal information on HUAMI’s behalf or for one or more of the purposes listed herein.
· We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust personal information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) customer service activities; and (iv) in connection with the provision of the products and services We have executed appropriate contracts with the service providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
· Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide personal information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with us. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them.
· Displaying to Other Users. The content you post may be displayed through the products and services or on social media. Other users may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
· Advertising – Interest-Based Advertising and Third Party Marketing. Our advertising partners may deliver targeted advertisements to you when you visit non-HUAMI related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. If you prefer that we do not share your personal information with third party advertising partners, you may opt out of such sharing at no cost by following the instructions below.
· Disclosures to Protect Us or Others as Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
· Sharing with other companies in the Mi Ecosystem. HUAMI may disclose your personal data to Xiaomi or other Mi Ecosystem companies so as to provide you with and improve the exciting products and services (both hardware and software) from the Mi Ecosystem. The Mi Ecosystem companies are independent entities, invested and incubated by Xiaomi, and are experts in their fields. Some of these products and services will still be under Xiaomi / Mijia / Mitu brands, while others may use our own brand. HUAMI will take appropriate organizational and technical measures to ensure the security of personal data during the process of sharing of information, including but not limited to the encryption of your personal data.
We are committed to ensuring that your personal information is secure, and we will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable administrative, technical and physical controls and procedures to safeguard and secure the information we collect from your using of HUAMI products and services and on HUAMI websites. We will use all reasonable efforts to safeguard your personal information.
For example, when you access your Mi Account, you can choose to use our two-step verification process for better security. When you send or receive data from your HUAMI device to our servers, we make sure they are encrypted using Secure Sockets Layer ("SSL") and other algorithms.
All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.
By using our products and services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the site or through the product or service and/or by sending an e-mail to you. You may have a legal right to receive this notice in writing.
· You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you. Whenever you log in as a Mi Account user on HUAMI websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.
· HUAMI cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.
· Your assistance will help us protect the privacy of your personal information.
You have the right to opt out of certain uses and disclosures of your personal information. Where you have consented to HUAMI’s processing of your personal information or sensitive personal information, you may withdraw that consent at any time and opt-out to further processing by contacting HUAMI. In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services. Even if you opt-out, we may still collect and use non-personal information regarding your activities on our sites and/or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
HUAMI may occasionally send you push notifications through our mobile applications with version updates and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. HUAMI may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising
As noted herein, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at advertising, or online choices and aboutads choices.
Our applications may need access to certain features on your device such as Wi-Fi network status. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at email@example.com
HUAMI recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways HUAMI makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:
· Log in and out of the Account;
· Toggle on/off for other services and functionalities which deal with sensitive or personal information.
If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time through your device or privacy settings as described above. If you have any questions, please email us at firstname.lastname@example.org.
If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by Huami even if the further processing is incompatible with original purposes.
· You have the right to request access to and/or correction of any other personal information that you have provided that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall respond to your request within a reasonable period of time, but not longer than any timeframe set out under your applicable data protection laws.
· A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
· If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please email us as soon as possible at the email address below. Email: email@example.com
· For details relating to the personal information in your Mi Account, you may also access and change them at http://account.mi.com or by logging into your account on your device.
· Although HUAMI makes good faith efforts to provide individuals with access to their personal information, there may be circumstances in which HUAMI is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If HUAMI determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, HUAMI will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
If you have previously provided us consent to use your personal information, you may withdraw your consent by submitting a request. This may be done by sending an e-mail to firstname.lastname@example.org. We will process your request within a reasonable time from when the request was made, subject to applicable law.
To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by HUAMI for this transfer of your personal information.
Our products and services are not directed to children under 16 (and in certain jurisdictions under the age of 13) years of age. If you are under the age of 16 (and in certain jurisdictions under the age of 13), you must have your parent’s permission to access the products and services. HUAMI urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online.
HUAMI does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided HUAMI with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable HUAMI services. If we learn that we have collected any personal information from children under 16 (and in certain jurisdictions under the age of 13) and we do not obtain permission from a parent, we will promptly take steps to delete such information and terminate the minor’s account.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. HUAMI does not share personal information with third parties for their own marketing purposes.
If you are a European Union user under GDPR, HUAMI will provide a systematic approach to managing personal information through our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) HUAMI set up a Data Protection Officer (DPO) in charge the data protection, and the contact of the DPO is email@example.com, (2) HUAMI designated a representative in Europe, a professional attorney with data protection experience, and the contact of representative is firstname.lastname@example.org and (3) a procedure for conducting data protection impact assessments.
Anhui Huami Information Technology Co., Ltd.
Building H8, No. 2800 Chuangxin Road, Heifei, China (230088)