As a player focusing on the application of big data and AI technology, Ecovacs Robotics Co., Ltd. (hereinafter “we”) fully understand the importance to protect users’ privacy in the big data era and are committed to safeguard the privacy of our customers. We hereby remind the Commissioned Party (hereinafter “you”) that we may collect some of your information in order to communicate with you effectively and ensure that the information you provide satisfies the requirements for product test when you participate in our New Product Testing Program (the “Program”). We collect such data necessary solely for the purposes of our product test. We ensure you that such data will not be used for any purposes other than those disclosed to you in this Statement.

To fully safeguard your right to be informed, we will use this Statement to fully disclose and keep you informed of the categories, purposes, storage and protection of your personal data, as well as how we entrust and share your personal data, and how we safeguard your rights and interests when we carry out the Program. Please read this Statement carefully before joining the Program. In particular, those terms in bold require your special attention and meticulous reading. If you have any questions regarding the Program or our privacy policy, please feel free to contact data-privacy@ecovacs.com, We will promptly respond to your requests and provide our feedback upon receipt of your questions and concerns.

1. The Program

In general, the Program has three stages: recruitment, user screening and communicating and Program.

At the recruitment stage, we will usually issue an announcement to inform you of the specific information of the Program and the requested information from you to perform the product test (the categories of relevant information are set out below). If you intend to participate in our Program, please provide us with some of your information in accordance with the announcement. Once you click to submit your information, you will be deemed as giving consent to join our Program, and agreeing that we may contact you for the future product tests.

At the user screening and communicating stage, we will review your submission in accordance with specific requirements of a specific product test after receiving the information you have submitted. If the requirements are satisfied, we will contact you according to the contact details you have provided and communicate in detail with you regarding the specific procedures and arrangements of Program. During such communication, you may be requested to provide some further information (the categories of relevant information are set out below). You may opt to participate in our Program based on your own circumstance and intent. If you opt in, we will, upon your consent and subject to specific conditions of a product test, courier the product to your home or residence.

At the Program stage, we will have the product couriered to you and tested at your home or residence under our instructions based on our previous communication. During such test, the tested product may collect certain data of your home environment due to the R&D needs for product functions (the categories of relevant data are set out below).

2. Categories and usage of your personal data that we may collect

We may collect certain data from you at the recruitment, review and communication, and Program stages respectively:
 

Categories of data	Purposes/scenarios for data use
Name, ID number, telephone number, email address	Such data will be used for purpose of executing of testing agreement and contacting you during the testing.
Home address*	If you acknowledge and agree to participate in our Program, you will need to provide us with your home address so that we can conducting the testing in your address.
The layout of your home*	Such data will be used to verify the effectiveness of functions of new products, identify technical deficiencies and contribute to technical improvements

* Note: In principle, your personal data will not be proactively collected in such scenario. However, due to the objective function needs and in certain occasional situations, we may not entirely rule out the possibility of collecting your personal data. To protect your privacy and avoid processing your personal data by accident, we will use technical methods commonly adopted in the industry to anonymize your data upon receipt, and ensure that it is difficult to identify or relate to any specific individuals from the anonymized data.

We covenant to you that such data will be used solely in our Program to perform the product test.  Without your explicit consent, such data will not be used to recognize the identity of you or any other individuals, or for any other purposes.

In addition to the above data, we have also set up some other information requests, which may help us better understand your attitude toward smart home appliances and your habits (the “Optional Questions”). These data will help us evaluate your purchase intention for smart home appliances and your habits, as well as the consumption trend and development prospect of our products and the industry in which we operate. This would better help us insight into consumer demand, understand the development trend of the industry, so as to help us make business decisions. If you voluntarily reply to those optional questions, it may help improve your chances of being selected as a member of the Program.

We would like to remind you that, minors under the age of 18 is not included as the user of the Program. In case we occasionally collected data related to minors, such data will be deleted immediately. If you find that we have collected data of minors, please feel free to contact data-privacy@ecovacs.com, Upon recipient, we will delete the relevant data in time after we have reviewed and confirmed the collection.
 
3. How we store and protect your personal data
 
Since our product R&D team is based in the People’s Republic of China (P.R.C), your personal data we may have collected in our Program will be transferred and stored in P.R.C.

You understand and agree that when you click to submit the information, you will be deemed to have fully understood and agree that your personal data will be transferred outside your jurisdiction and stored in China. If you refuse such transfer, you should immediately stop submitting relevant information.

We will take necessary and reasonable data security protection measures when transferring your personal information outside your jurisdiction on the premise of providing appropriate safeguards in accordance with the data security requirements in your jurisdiction. You may contact us through the contact channel disclosed in this Statement to know more about the protection measures related to the international transfer of your personal information. Further, we will only store your personal data during the period required for the purpose provided in this Statement or required or permitted by applicable laws and regulations.
 
In order to ensure the sustainability and efficiency of the Program and facilitate our good and continuous communications with the candidates, we have built a special user database for the Program. If you agree to participate in the Program, we will incorporate into the database the data you may have submitted at the recruitment stage. We will store the data submitted by you for one (1) year after the end of the specific recruitment you applied for. During such period, if relevant data you provide satisfies the requirements of our product test, we will contact you and retain the relevant data you provide at the review and communication stage as well. After the one (1) year period expires, we will promptly delete all the data collected from you during recruitment process.

If you satisfy the specific requirements for product test and participate in the Program after you opt in the Program, we may keep the data collected from the Program for a certain period for the purpose of product R&D after completion of the specific product test to help us improve the corresponding technologies and functions. We will retain the data collected from the test for one (1) year after the completion of such test and delete such data upon the expiration of the period.

For your replies to Optional Questions submitted during recruitment process, we will only retain your data for the shortest time necessary for the purposes disclosed in this Statement.  In addition, if we stop the provision of services or business operation, we will promptly cease to continuously collect data related to you and may give notice to you individually or by publishing notifications. We will also delete or anonymize your personal data possessed by us without delay.
  We undertake to maintain data security to the level as specified by the Law. In order to keep your data safe, we commit to apply various security technologies and associated management systems to protect your data from being disclosed, destroyed or lost. We have established our personal data protection department. We have also developed relevant internal policy to strictly control data access procedures and approval mechanisms. We seek to only give employees who may access to your data the least authority and limited data access sufficient for fulfilling their duties.

Please understand that due to the limitation of technologies or potential malicious attacks, personal data security incidents may unfortunately occur due to factors beyond our control. If an incident occurs, we will, in accordance with laws and regulations, immediately notify you of: general facts and potential influences of the incident, measures we have adopted or will adopt, advice for you to protect your data and reduce risks, our remedial measures for you, etc. We will inform you by email, letter, telephone or by pushing notifications. If we cannot contact you individually, we will publish notifications in a reasonable and effective manner. We will also report the result of personal data security incident to regulatory departments if required.

4. How we entrust, share, transfer and disclose your personal data

In order to assist us in collecting data, at the recruitment and Program stages, we will entrust the third party to collect the relevant data mentioned in Part 2 of this Statement.

We will strictly regulate the data processing activities of the third party, and require them to collect and process data within the scope of your authorization, and ensure that their data processing activities are at least in accordance with this Statement. After completing the data collection at the recruitment stage, we will require the third party to delete the relevant data in time.

5. How we safeguard your rights and interests regarding your personal data

If you need to access, rectify, delete, or restrict or object our processing of any data you have provided, or you want to raise any other requests, please contact data-privacy@ecovacs.com. We will contact you within 10 days upon the receipt of your message, and promptly respond to your request.

We fully respect your right to choose. After participating in the Program, you may choose to withdraw your consent to our processing of your personal data or opt out from the Program through data-privacy@ecovacs.com. Upon receipt of your request to withdraw consent or to opt out, we will promptly contact you and delete all the data you have provided to us during your participation in the Program after we have checked and confirmed your intent to do so.
 
6. Additional Statement and Commitment Regarding the Camera
As this product comes with a camera and audio recording device, we hereby make the following statement and commitment:
(1) The camera and audio recording device will only function when the user activates them, and will not activate without the user's knowledge or consent.
(2) Once the user activates the camera or audio recording device, the 2D/3D maps generated by the device and correct errors will be displayed on both the device and app.
(3) Even when the user activates the camera or audio recording device, without your explicit request or unless otherwise expressly stated above in this Statement, information captured by the camera and audio will not be transmitted to us or any third party, and will not be transferred to any country outside of the test country.
(4) Photos/videos taken upon your request are in high resolution. They possibly involve the collection and processing of your personal data and might enable identification of individuals in the work environment, depending upon what is revealed in such photos/videos. To avoid this, you can turn the camera off anytime via your app and you can delete any photos/videos taken anytime via the app.