360 Robot Vacuum Cleaner WEBSITE PRIVACY POLICY
1、Who we are
- Shenzhen Qihoo Jian An Intelligent Technology Co., Ltd. (“We”or “us”) respects your privacy and values the trust you place in us when you share your personal data with us. This Privacy Policy sets out how we, as data controller, collect and use your personal data, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal data.
This Privacy Policy covers our use of your personal data arising from use of the 360 Robot Vacuum Cleaner (the “product”), 360 Robot Vacuum Cleaner APP and our official website (smart.360.com, the “Website”, hereinafter the product, the product App and the Website shall be collectively referred to be as “360 Service”).
We use the highest standards of data encryption to make sure your data stays private and secure.
2、How we use or process your Personal Data
We will collect and use your personal data to allow your access to and use of 360 Service in accordance with the purposes set out in more detail in this section. For user who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we use or process your personal data.
| NO. |
What we collect |
How we use it |
- 1
|
Registration Data and Log-in Data: your username, password, mobile phone number, email, user ID and the account settings.
Legal Basis (EEA):Necessary to perform our contract with you to provide 360 Service |
to register an account for you and enable you to log in the account;
to enable network-enabled features of the 360 Service and to provide our services; to communicate with you;
to enforce our terms, conditions and policies;
to better understand how you access and use 360 Service; and to administer 360 Service, including troubleshooting, test, security, fraud detection, and account management. |
- 2
|
Date collected when you use third party social media account to log in the APP, including: Facebook/Google/Apple OpenID, Token, Username and avatar.
Legal Basis (EEA):Necessary to perform our contract with you to provide 360 Service. |
to facilitate your third party social media account to login to the APP via social media account; and to insure account security. |
- 3
|
Data collected when you connect 360 Robot Vacuum Cleaner to the product APP: IP address; Wi-Fi account name and password; cleaning maps information, SN of 360 Robot Vacuum Cleaner.
Legal Basis (EEA): Necessary to perform our contract with you to provide 360 Service |
to connect the product and the product APP for the purpose of accessing and using 360 Service; and to push the notices to you about local weather. |
- 4
|
Data collected when you access and use 360 Service: the cleaning areas information (the cleaning map; the cleaning history, such as date, times and areas); the using history information of features of 360 Service (the charging information, regular cleaning information, cleaning mode setting, fault alarm information electricity information, voice commands information and the other setting information).
Legal Basis(EEA): Necessary to perform our contract with you to provide 360 Service |
to provide cleaning service;
to identify issues with 360 Robot Vacuum Cleaner;
to enforce our terms, conditions and policies;
to improve our service; and to better user's experience. |
- 5
|
Data when you share the products with your family, friends or other members, including QR Code of the product; the User ID or mobile phone of the third person who is shared with the product.
Legal Basis(EEA): Necessary to perform our contract with you to provide 360 Service |
to achieve the purpose of device sharing among the family, friends or other members; and to better user's experience. |
- 6
|
Data about the way you use 360 Service: 360 Robot Vacuum Cleaner SN, model and version number; IP address of your mobile device, automatically generated unique device identifiers, your mobile device information (device model, operating system information, screen resolution, network/internet status, CPU SN); the features you use in the product APP; error and crash log; the cleaning log of 360 Robot Vacuum Cleaner.
Legal Basis (EEA): Necessary to perform our contract with you to provide 360 Service and for legitimate business interest |
to identify and solve the issues with 360 Service;
to develop new and improve existing services;
to better understand how you access and use 360 Service;
to do the anti-fraud screening obligations;
to improve our products;
to do statistical analysis and research. |
- 7
|
Data when you communicate with us whether in person, or via email, over the phone, through social media or via any other medium, including: your contact details (this may include your social media account if that's the way you communicate with us); the details of your communications with us; the details of our messages to you.
Legal Basis (EEA): Necessary to perform our contract with you to provide 360 Service |
to answer your questions;
to show related data to users;
to improve our services;
to personalize our services;
to improve our products. |
3、Why we collect your personal data
We will collect and use your personal information as described in this Policy, including your sensitive information, your mobile phone number, gender, birthday, profile picture, nickname; The purposes and purposes for which this sensitive information is collected and used are detailed in the function description section below. Once the sensitive personal information is leaked, illegally provided or abused, it may endanger personal and property safety, and easily lead to personal reputation, physical and mental health damage or discriminatory treatment. Therefore, we will adopt compliance technology to encrypt the transmission and storage of sensitive information that you explicitly consent to and proactively provide to protect the security of your personal information. At the same time, according to your IP address, we will push advertisements and messaging services to you in the same language as the location; We will provide you with products or services in the process, after your authorization, We collect your unique device identifier (Android for Android devices) ID, OAID, GAID, iOS device is IDFV, OpenUDID), advertising identifier (iOS device is IDFA, CAID), MAC address, device status information, obtain the application list in the mobile phone, device model, system version number, device serial number, operating system version number, system ID number, Internet access type The version number of this product, the time and frequency of clicking a button, the option values of some key configurations, and the software crash log information, which, after being desensitized by the MD5 algorithm, is used to count the number of users of our product, the advertising effect, the usage status of the product, the causes of crash, the reduction of crashes, the improvement of our products, and the provision of customer support.
4、Who do we share your personal data with
- We will not transfer your personal data to any other third parties except as specified below, or in circumstances where you consent to such transfer. We may share your information with certain service providers (specified in below table), who supply services to support, improve or promote other services or features through 360 Service. Our service providers will be required to meet our standards and the requirements of laws or regulation, and to provide the same or equal protection of users’ personal data as stated in this Privacy Policy on processing data and security. The data we provide them, including your personal data, will only be provided in connection with the performance of their function.
| Identity of the recipient and contact information |
Purpose of use of personal data by the recipient |
Date of transfer |
Alibaba.com (Europe) Limited
https://www.alibabacloud.com/help/faq-detail/42425.htm?spm=a3c0i.12303690.9135018350.91.24a463e03ELaXN |
Providing database for the storage of the cleaning maps information |
from time to time |
Alibaba Cloud US LLC
https://www.alibabacloud.com/help/faq-detail/42425.htm?spm=a3c0i.12303690.9135018350.91.24a463e03ELaXN |
Alibaba Cloud (Singapore) Private Limited
https://www.alibabacloud.com/help/faq-detail/42425.htm?spm=a3c0i.12303690.9135018350.91.24a463e03ELaXN |
Your personal data also may be transferred to other third-party organizations in certain scenarios:
- If we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any government, public or regulatory authority for the purpose of compliance with a legal obligation or processes, such as a court order, subpoena or other legal process, or enforcing our terms, or protecting our users.
- If, to the extent permitted by laws or regulations, certain personal data may be transferred to our affiliated companies in order to protect the interests, property or safety of us.
- If we're discussing selling or transferring part or all of our business, the data may be transferred to prospective purchasers under suitable terms as to confidentiality.
- If we are reorganized or sold, data may be transferred to a buyer who can continue to provide services to you.
- 360 Service allows you to share the access to your product by permitting other people to connect to your product. These permitted users are able to access the product and collect the data from the product until you withdraw your permission. We encourage you to exercise discretion and caution with respect to permitting others to access your product because we do not control their actions and cannot stop them from sharing the data obtained from your product with someone else.
- We will make and enter into a strict data protection protocol by and between any company, organization and individual with which we share your personal data for them to process your personal data in accordance with our specifications, this Privacy Policy, any other relevant confidentiality and security measures, and the laws or regulations.
5、Where your personal data will be stored
- We operate the business all around the world. As for the users outside the China, your cleaning maps information data that we collect from you will be transferred to, stored at or processed in the database located in:
- Germany if you are EEA user;
- United States of America if you are a user in the north America or south America; and
- Australia if you are a user in other countries.
- Part of your other App information may be stored at China. Those countries may not have equivalent data protection laws to those applicable in the European Union. We do, however, ensure an adequate data protection level by agreements with our database providers and by adopting other necessary arrangements, both technical and organizational. Wherever any error or breakdown issues regarding 360 Service happens, we will give you a notice to request your approval to transfer some log data of 360 Service to China for the purpose of solving the issues. It is in your sole discretions to decide whether to approve or not. Please feel free to contact us for further details.
6、Your rights
- You have certain rights in relation to your personal data. We've listed the rights you have over your personal data and how you can use them below.
- The right to access and correction. You can access and correct your device adding information, device sharing information, voice commands information via the product App. You can inquire and correct your account information and other information provided by you, including your user name, password with your account information stored in 360 user center at http://i.360.cn/profile.
- The right to erase your personal data. You are entitled to ask us to delete your personal data if:
1. We have collected your personal data without your explicit consent;
2. We handle your personal data in violation of laws and regulations;
3. We use and handle your personal data against the agreement reached by us and you;
4. You have cancelled your account or decided not to use our 360 Service anymore;
5. We have stopped providing services to you; and
6. You believe that it is no longer necessary for us to have your personal data.
- You can contact us by the contact information as stated in Section 12 hereof to ask us to delete your personal data, and we will make a reply within 15 working days.
- Your right to restrict us to process your personal data. You can ask us to restrict how we use your personal data via the contact information as stated in Section 12 hereof, and we will make a reply within 15 working days.
- Portability. You have the right to receive a copy of certain personal data we collect from you. You have the right to receive this data in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal data to another party. If you wish for us to transfer the personal data to a third party, please ensure you detail that party. Please be noted that we can only do so where it is technically feasible. We may not provide you with certain personal data if providing it would interfere with any third party rights.
- Objection. You may object to our use of your personal data if we use your information on the basis of our legitimate interests. If you object to such processing, please contact us via the contact information as stated in Section 12 hereof.
- Canceling your account. You can have your account cancelled through the account cancellation of the 360 user center at any time. Please take note that if you have your account cancelled, your account will be not used and relevant account data will be deleted, and you cannot log in your account to enjoy our services. After you have your account cancelled, except that we save relevant data as required by laws and regulations, we will stop providing relevant products (or services) to you and will delete or anonymize your personal data within reasonable days.
- Withdrawing your consent or authorization. You might withdraw your consent to collect and use your personal data by closing any equipment function. It should be understood that some basic personal data is requisite for realizing a business function and that, after you withdraw your consent or authorization, we will not provide you services corresponding to withdraw consent or authorization and not handle your personal data. But your decision to withdraw your consent will not affect previous handling of your personal data based on your authorization.
7、Cookies
- We use cookies that identify your browser or device. A cookie is a small text file that is stored on the user’s computer or mobile device. We use cookies to record information about your activities on our Website and to remember you when you return to the Website. You may set your browser setting to reject cookies and you may still use our Website.
8、How we protect your personal data
- We are committed to keeping your personal data safe. We have taken reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.
- We are the first large-scale internet company which appoints the Chief Privacy Officer in China. CPO is responsible for various affairs related to the users’ personal data that our software and hardware products and services may involve, including formulating privacy policies for various products and services, reviewing the terms of use for the products and services, and supervising implementation of the working principles and data processing mechanism of the products and services. In addition, we have established a department in charge of personal data protection and act under supervision of the public.
- We transfer and store personal data using encryption to ensure the privacy of such data. 360 Service uses HTTPs between our APP and server with 2-way authentication interaction to protect your personal data. All the video stream uses private encryption protocol for anti-hacking and anti-peeping to ensure the security of data transmission.
- If our application adopts WebView technology, we conduct URL verification on all file agreements used in the WebView and restrict the access to the personal data to avoid the malicious misuse of any private documents and sensitive data of our products without special permission.
- We have implemented an access control mechanism in our server end. We require our employees who may have access to your personal data to obey the principle of data minimization and examine the access list and access records on a regular basis.
- Our server systems used to store your personal data are equipped with strengthened safeguards. We conduct account audit and monitoring on the operation of our servers. Where any security problem of the server systems is reported, we will immediately complete security upgrades for the server systems to ensure the security of our server systems and applications.
- We conduct regular training on the relevant laws and regulations related to personal data protection to strengthen our employees’ awareness of privacy protection.
- If any destruction of our physical, technical or management safeguard measures occurs, we will launch our emergency plan in a timely manner to prevent the spreading effect of the security incident and will report the same to the competent authority in accordance with the relevant laws and regulations. We will also notify you, in a timely manner, of the security incident, potential impacts and the measures we have taken or will take to deal with the incident, in a reasonable and effective way such as pushing notifications and publishing announcements.
- We may from time to time send you service-related notification or announcements when we consider it necessary to do so. We may also send you some advertisement or promotional materials via email. If you are not desirous to receive such promotion, please click the “cancelling the subscription” in the email, and we will not further to send the promotion.
9、How long we keep your personal data
- Except otherwise stipulated herein, we will keep your personal data as long as it is reasonably necessary.
We will routinely refresh our information to ensure we keep it up-to-date. We will store data produced by 360 Robot Vacuum Cleaner such as cleaning maps information and cleaning history for two weeks. If we are required to retain your information beyond the retention periods, for example to comply with applicable laws, we will store it separately from other types of personal data.
10、Protecting minors’ personal data
- If you are a minor, your guardian's consent or authorization will be needed for you to use our products or services. It is recommended that your parents or guardian read these Privacy Policy for you and it is suggested that you submit your personal data with the consent and guidance from your parents or guardian. If you are a minor's guardian, you can contact us by the contact information as stated in Section 12 hereof when you have any doubt about the personal data of the minor under your custody.
11、Changes to the Privacy Policy
- This Privacy Policy will be changed from time to time. If we change anything important about this policy (the personal data we collect, how we use it or why), we will highlight those changes at the top of the policy. Those changes will apply from the effective date specified in the notice We encourage you to check the Privacy Policy regularly for the latest changes. Your continued use of the 360 Services will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal data from you or when we use or disclose your personal data for new purposes. You can email the Data Protection Department for previous versions of the Privacy Policy and you can get in touch at the following email address: zh-service@360.cn.
12、How to contact us
- If you have any questions, advice, suggestion complaint about this Privacy Policy or any questions relating to the collection, use, or disclosure of your personal data, please feel free to contact our Data Protection Department at: zh-service@360.cn. Generally speaking, we will reply to you within fifteen (15) working days. If you are not satisfied with the response, you can hand over the complaint to the relevant regulatory authority in your jurisdiction.