2.1 DEVICE DATA
Your Smart Ring device collects measurement data to estimate a variety of metrics: PPG sensor data, accelerometer data, and skin temperature data.

We use the measurement data to calculate and generate data such as heart rate, heart rate variability, respiratory rate, calories burned, sleep phases, step counts, stress levels and activity intensities throughout the day.

2.2 USAGE DATA
When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, installing our Application or software, when you view or search for content, create or log into your account, pair your device with your account, or interact with our Services with third-party accounts. (like Apple ID).

We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, Smart Ring or mobile device information (including device and application identifiers), location (depending on the permissions you give us). granted) and cookies.

2.3 LOCATION DATA
If you access or use any of our location-based services, for example by enabling GPS-based activity tracking through your Application, we may process the approximate or precise location of your device while the service is active. This data may be obtained through your device’s service provider network ID, GPS and/or Wi-Fi data.

We do not process this location data without first obtaining your consent. You can disable this location processing at any time using your mobile device’s location permission settings. We may also derive your approximate location from your IP address.

2.4 DATA YOU PROVIDE
To create an account on our Services, you may provide us with data including: your username, year and month of birth, gender (female, male or you choose not to disclose), height, weight, email address, number cell phone number, password and country information. This is the data you must provide to create an account with us. You may also choose to provide other types of information, such as a profile photo. If you get in touch us or participate in a survey, contest or promotion, we will collect the data you submit, such as your name, contact information and message.

2.5 THIRD PARTY DATA
When you choose to access our Services through a WeChat, QQ (including Tim), Google, Facebook or Apple account, we collect your account name and profile photo.

3. HOW WE USE YOUR DATA
We use the data we collect for the following purposes.

3.1 To provide and maintain our services
We process personal data to provide our Services. For example, to provide daily information about heart rate variability, sleep and activity.

3.2 To improve and develop our products and services
We process data relating to your use of the Smart Ring device and app to improve our services and develop new features. When possible, we will do this using only pseudonymized, aggregated, or non-personally identifiable data.

3.3 To provide customer service
We process personal data to provide customer service and manage our customer communications. If you contact our customer support with questions about your app data, we may use the data you provide to answer your questions and resolve any issues you may have.

3.4 To comply with legal obligations
In certain cases, we must process certain data when required by applicable laws and regulations. Such legal obligations relate, for example, to accounting and tax requirements, legal claims or other legal purposes.

4. LEGAL BASIS FOR DATA PROCESSING
Our legal basis for processing your data depends on the specific purposes of the processing, including:

4.1 Contract
When processing personal data to provide services, we process it on the basis of a user agreement, which is formed when you create your account and accept our terms and conditions.

4.2 Consent

We process your health-related data only with your consent. Please note that some of the personal data we process, including any data relating to your health, is considered special or sensitive personal data. In accordance with applicable law, this data is only processed if you have given your consent to the processing.

4.3 Legitimate Interest
We process your data based on our legitimate interests when we process it to market our products and services, provide our customer service and improve our products and services. When choosing to use your data based on our legitimate interests, we carefully consider our interests against your right to privacy, in accordance with applicable law.

4.4 Legal obligation
We must process certain information to comply with legal obligations which may vary by country.

5. OUR CHILDREN POLICY
Persons under the age of 18 or any higher minimum age in the jurisdiction where that person resides are not permitted to create Smart Ring accounts. If we become aware that we have collected personal data from a child under the relevant minimum age, we will take steps to delete the data as quickly as possible. Parents who believe their child has submitted personal data to us and would like it deleted may contact us (see “How to Contact Us” below).

6. HOW DATA IS SHARED AND DISCLOSED
We do not sell our users’ personal data. We do not share your data except in the limited circumstances described below.

6.1 FOR EXTERNAL PROCESSING
We share your data with certain trusted partners, including our affiliates, service providers and other partners, so that we can provide our services and operate our business. We require our partners to process your data based on our instructions and in accordance with this policy and any other appropriate confidentiality and security measures. We also require these partners to protect your data to at least the same standards as us.

We use external processing services, such as:

We reserve the right to disclose personal data to protect our legal rights and property; and to comply with valid legal requirements.

We may preserve or disclose data about you to comply with a law, regulation, legal process or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activities, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

We may share non-personal data that is aggregated so that it cannot reasonably be used to identify an individual with or without combining additional information. We may disclose this data publicly and to third parties, for example in public exercise and activity reports, to partners under agreement with us, or as part of the community referral data we provide to users of our subscription services.

If we are involved in a merger, acquisition or sale of assets, we will continue to take steps to protect the confidentiality of personal data and provide notice to affected users before transferring any personal data to a new entity.

7. HOW WE STORE AND TRANSFER DATA
We process and back up personal data through a global operation and control infrastructure. We currently use cloud services deployed in the UK to process personal data of users in the US, UK and EEA.

We rely on multiple legal bases to legally transfer personal data around the world. These include your consent and model contractual clauses approved by the European Commission, which require certain privacy and security protections. You can obtain copies of the model contractual clauses by contacting us. We are subject to oversight by the U.S. Federal Trade Commission and remain responsible for the personal data we transfer to third parties who process it on our behalf as described in the “HOW DATA IS SHARED AND DISCLOSED” section.

In cases where personal data is processed outside the jurisdiction in which it was collected, we always ensure that your data is protected with appropriate safeguards, in accordance with applicable privacy and data protection laws. Note that the Countries where we operate may have privacy and data protection laws that are different and potentially less protective than the laws in your country. You agree to this risk by creating a Smart Ring account and clicking “I Agree” to transfer data.

If you have any complaints about our international data transfer, please contact us by the means described in the “HOW TO CONTACT US” section. You may make a complaint to the competent regulatory authority in your jurisdiction.

8. HOW WE STORE YOUR DATA
We use technical and organizational safeguards to keep your data safe and secure. Where appropriate, these safeguards include measures such as the anonymization or pseudonymization of personal data, strict access control and the use of encryption to protect the data we process. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers. However, no method of transmitting or storing data is completely secure. If you have any security concerns, please contact us using the methods described in the “HOW TO CONTACT US” section.

We also ensure that our staff receive appropriate training to ensure that personal data is only processed in accordance with our internal policies, consistent with our obligations under applicable law. We also limit access to your sensitive personal data to personnel who have specifically been granted such access.

We regularly test our services, systems and other assets for potential security vulnerabilities. We also regularly update the Smart Ring app and Smart Ring device firmware. We recommend that you always have the latest app and firmware versions installed to maximize the protection of your data.

9. DATA RETENTION
The retention period for your data generally depends on the lifecycle length of your Smart Ring account. Your data will be deleted when it is no longer necessary for the purpose for which it was originally collected, unless we have a legal obligation to retain the data for a longer period. For example, your measurement data regarding sleep, stress and  Activity is only stored while your Smart Ring account is active.

We also have legal obligations to retain certain personal data for a specific period, such as for tax purposes. These required retention periods may include, for example, accounting and tax requirements, legal claims or any other legal purposes. Please note that mandatory retention periods for personal data vary depending on relevant laws.

If you wish, you can request deletion of your Smart Ring account by contacting data_protect@ringconn.com.

10. WHAT ARE YOUR RIGHTS

10.1 YOUR RIGHTS UNDER APPLICABLE LAW
You have rights and choices regarding your data in accordance with applicable laws. Some of these rights apply generally, while others only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Please note that if you exercise some of your rights below, for example, by withdrawing your consent to our Privacy Policy, we may not be able to provide you with our Services.

You can choose to exercise the following rights over your data:
(1)Right of confirmation and access. You can ask us to confirm whether your data has been processed, or request access to your data and receive a copy of the personal data we have collected and stored about you.
(2)Right of rectification. You can update, rectify or change your data in the App account settings. You can request that we update, rectify or change your data when that data is not accurate.
(3)Right to erasure. You have the right, as provided by applicable laws, to request that we erase, destroy or anonymize your data. You may request that we cease providing personal data to third parties under certain circumstances in accordance with applicable laws.
(4)Right of portability. You have the right to data portability in circumstances where we rely on contractual necessity and consent as the legal basis. This means that you have the right to receive your data in a structured, commonly used and machine-readable format and to share it with third parties.
(5)Right to withdraw consent. You may withdraw consent to the processing of personal data based on your consent, unless such withdrawal is restricted by law or contract. However, withdrawal does not affect the legitimacy and effectiveness of the way we process your data based on your consent before the withdrawal was made.
The. You may withdraw your consent in your Application’s account settings;
B. If you wish to unsubscribe from electronic communications, please see your notification settings in your app’s account settings to control our marketing communications to you.
(6)Right to object or restrict processing. You have the right to object to or restrict the processing of your data in certain circumstances based on legitimate interests or public interests based on applicable laws. For example, in accordance with applicable laws, you may require us to stop or not start processing your data for direct marketing purposes. You can object to decisions being made based solely on automated processing relating to your profile, under certain circumstances, in accordance with applicable laws.

When submitting an objection or restriction request, you must explain which specific processing activity you are objecting to or should be restricted and why the processing should be stopped. We will stop specific processing if we do not have compelling legitimate reasons to continue such processing or if we do not need it for legal claims.

10.2 HOW TO EXERCISE YOUR RIGHTS
You may exercise these rights by logging into your account and using your account settings or by contacting us as specified in the “How to Contact Us” section in writing or by other means permitted by applicable law.

We will ensure that you can exercise your rights in accordance with applicable laws. Depending on applicable laws, there may be situations in which we may deny your requests, for example, when the refusal is complied with by a court order or when the exercise of your rights adversely affects the rights and freedoms of others.

When you need to exercise your rights, we may ask you to authenticate your identification, for example, through your Smart Ring account.
Normally, you do not need to pay us when you exercise your rights under applicable laws; however, we reserve the right to charge a reasonable fee for processing any data access, correction request, or other scenarios where charging the fee is permitted by applicable law.

We will respond to your requests within the deadlines set out in applicable laws in the country/regions in which you reside.
If you have any questions about this Privacy Policy or about exercising your rights, you can send your request in writing to the email address we provide below under “How to contact us”.

If you consider that the processing of your personal data by us does not comply with this Privacy Policy or with applicable laws, you have the right to lodge a complaint with the competent regulatory authority in your jurisdiction.

11. POLICY FOR EUROPEAN USERS
If you live in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, please review these additional privacy policy terms in accordance with the European Union General Data Protection Regulation (“GDPR”).

11.1 YOUR DATA CONTROLLER
Based on United States law and considering that the company is based in the United States, the data controller would be the company itself, as established by US privacy laws such as the California Consumer Privacy Protection Act (CCPA) or the Children’s Online Privacy Protection Act (COPPA), depending on the context and type of data involved. Therefore, the company would be responsible for controlling and protecting user data as required by applicable federal and state laws, in addition to any industry-specific regulations.

11.2 HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that the data we collect is health data or another special category of personal data subject to the GDPR, we request your explicit consent to the processing of the data. We obtain this consent separately when you perform actions that lead to obtaining data, for example, when you pair your device with your account. You may use your account settings on the Application and the settings on your mobile device to withdraw your consent at any time, including by unpairing your device or deleting your data or account.

11.3 HOW TO EXERCISE YOUR LEGAL RIGHTS 

charge a reasonable fee for processing any data access, correction request, or other scenarios where charging the fee is permitted by applicable law.

We will respond to your requests within the deadlines set out in applicable laws in the country/regions in which you reside.
If you have any questions about this Privacy Policy or about exercising your rights, you can send your request in writing to the email address we provide below under “How to contact us”.

If you consider that the processing of your personal data by us does not comply with this Privacy Policy or with applicable laws, you have the right to lodge a complaint with the competent regulatory authority in your jurisdiction.

11. POLICY FOR EUROPEAN USERS
If you live in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, please review these additional privacy policy terms in accordance with the European Union General Data Protection Regulation (“GDPR”).

11.1 YOUR DATA CONTROLLER
Based on United States law and considering that the company is based in the United States, the data controller would be the company itself, as established by US privacy laws such as the California Consumer Privacy Protection Act (CCPA) or the Children’s Online Privacy Protection Act (COPPA), depending on the context and type of data involved. Therefore, the company would be responsible for controlling and protecting user data as required by applicable federal and state laws, in addition to any industry-specific regulations.

11.2 HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that the data we collect is health data or another special category of personal data subject to the GDPR, we request your explicit consent to the processing of the data. We obtain this consent separately when you perform actions that lead to obtaining data, for example, when you pair your device with your account. You may use your account settings on the Application and the settings on your mobile device to withdraw your consent at any time, including by unpairing your device or deleting your data or account.

11.3 HOW TO EXERCISE YOUR LEGAL RIGHTS

You have the right to request the erasure of your personal information, subject to certain exceptions, such as where we have a legal obligation to retain the data in question. After we receive and validate your request, we will delete your personal information, as well as instruct our service providers to delete your personal information, unless an exception applies.
(3)How to exercise your privacy rights under CCPA

If you reside in California, you may request disclosure, access, and/or deletion of your personal data as described above by sending us a verifiable consumer request:
By sending an email to data_protect@ringconn.com, including the following information along with your request: your full name, company name (if applicable), address, email address and telephone number. We may ask you to provide additional information if necessary to confirm your identity. This is for security reasons and is required by law in some cases.
Only you, or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a verifiable consumer request relating to your personal information.
You have the right to make a free request up to twice every 12 months. We will respond to all validated requests within 45 days of receiving your request, unless we request an extension. If we reasonably require an extension to respond to your request, we will notify you of such extension within the initial 45-day period.

12.3 NON-DISCRIMINATION
We do not discriminate against users who request to exercise their privacy rights under the CCPA. Unless an exception applies, this includes our promise not to:
a.Deny you goods or services;
B. Charging different prices or fees for goods or services, including granting discounts or other benefits, or imposing penalties;
w. Provide you with a different level or quality of goods or services; or
d.Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13. UPDATE THIS PRIVACY POLICY
We will notify you before we make material changes to this policy and will give you the opportunity to review the revised policy before deciding whether you want to continue using the Services. You can review previous versions of the policy on our website (https://www.smartalliance.tech).

14. SEPARABILITY
If any part of this Privacy Policy is held by any court or other competent authority to be invalid, illegal or unenforceable, that part will be severed from the rest of the provisions of this Privacy Policy, which will continue to be valid and enforceable to the fullest extent. measure permitted by law.

15. DOUBLE TONGUE
This Privacy Policy is written in English and in the language of your country of residence (if applicable) and both versions are equally authentic. In case of any discrepancy between these two versions, the English version will prevail.

16. COOKIE POLICY
This section of the Cookies Policy explains how we use cookies and other similar technologies to store information on our website (the “Site”) and improve your experience while you navigate through the Site. This Policy also describes the types of cookies and other tracking technologies used by us on your device (such as PC, tablet or mobile phone).
For more information about how we use the personal information we collect about you when you use our Online Services, please see our Privacy Policy.

16.1 What are Cookies and Other Technologies we use?
Sometimes the Site may use “cookies” or other technologies (such as browser cookies, flash cookies and web beacons).
Cookies. Cookies are small pieces of text files that may be stored and accessed on your device when you visit our Online Services, to the extent you agree. They help the website remember information about your visit, which can make it easier for you to visit the website again and more useful to you. Some or all of the cookies or other technologies described below may be stored on your browser, application or device.

Other technologies. Other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to allow us to collect information about how you use our Site. To see how our Site is performing, we sometimes use conversion beacons, tags, scripts and pixels, which trigger a small line of code to tell us when you clicked a specific button or accessed a specific page. We also use these technologies tracking to analyze usage patterns of our Services. The use of these technologies allows us to record that a specific device, browser or application visited a specific web page. The information provided below about cookies also applies to these other tracking technologies.

16.2 What are first-party and third-party cookies?
Whether a cookie is first-party or third-party depends on where it comes from.
First-party cookies are set by us on our behalf on the Site and in our Services. We and our service providers may use cookies and other technologies to store information in your browser or on your cell phone, tablet, computer or other devices that allow us to store and receive certain information whenever you use or interact with our Platform. . These cookies and other technologies help us identify and learn more about our users and their likely interests, and to deliver and personalize marketing or advertising. We also use cookies and other tracking technologies to control access to certain content on our Site, protect the Site, and process any requests you make to us.

Third-party cookies are set by third parties on our Online Services. Approved third parties may also set cookies when you interact with our Services. Third parties may include search engines, measurement and analytics service providers, social media networks, and advertising companies. Third parties may use cookies in the process of delivering content, including advertisements relevant to your interests, to measure the effectiveness of their advertisements and to perform services on our behalf.

Please note that we have no control over or responsibility for third-party cookies unless third-party cookies are placed at our request or under our authorization (in which case we will ensure that appropriate safeguards are in place with the third party to ensure the fair use of cookies) .

16.3 What are the purposes for using Cookies?
We use cookies and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services for additional purposes, including:
a.to make the Site and our Services function properly;

b.reports, which allow us to measure and analyze the performance of our Services;
c.conduct research and diagnostics to improve our content, products and services;
d.to facilitate login to the Site and application (such as remembering your user ID);
e.recognize you when you return to the Site and our Services and remember the information you have already provided and your preference for using our Site and Services;
f.to track your interaction with the Site and our Services;
g.to improve your security when using the Site and our Services;
H. contact you to provide online or offline customer service using information voluntarily provided by you;
i.to ensure that the Site and our Services comply with local laws and regulations (if any).

We use cookies and other technologies to collect the following information:
Data generated during your interaction with the Site, which may include, but is not limited to: personal data about you that you voluntarily choose to provide to us and information automatically collected about your interactions with the Site.

Information voluntarily provided by you may include, but is not limited to: email address or other contact information, the registered account, the role information selected when registering for an account, information submitted by users when using the tool search engine on the Site and other information voluntarily provided by you. information sent.

Information collected automatically may include, but is not limited to, IP address, browser type, browser language, domain name, data about actions taken to enter and leave the page, browsing behavior, dwell time and what content was clicked, the order in which content was clicked, which videos were played, view counts and associated performance data, request times to the site, response speed data.

We may provide access to some information collected through cookies to third parties for advice on how we can improve your user experience on our Online Services. In any case, we will only share your personal information with third parties in accordance with our Privacy Policy.

16.4 How to manage Cookies in your browsers?
We may use session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Please note that if you delete or choose not to accept cookies served by us or all sources, you may not be able to use certain features of the Site to their full potential.

You can use the browser with which you are viewing this Site to enable, disable or delete cookies. If you do not want cookies to be placed on your device, you can adjust your Internet browser setting to reject all or some cookies. To do this, follow the instructions provided by your browser (usually located under “Help”, “Tools” or “Edit”).

If you wish to remove previously stored cookies, you can delete them manually at any time via your browser settings. However, this will not prevent the Platform from placing further cookies on your device unless and until you adjust your Internet browser settings as described above.