NOTO Labs, its affiliates, and subsidiaries (“we”, “us”, “our”, and “NOTO Labs”) are committed to protecting your privacy. This Mobile Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related Applications (the “App”) (collectively, the “Products”):
- NOTO Labs Mobile Application
Before you use our Products, please carefully read through this Policy and understand our purposes and practices for collection, and processing of your Personal Data, including how we use, store, share, and transfer Personal Data. In the Policy, you will also find ways to execute your rights of access, update, delete, or protect your Personal Data
When you accept this Policy when you register with your Personal Data, or if you start to use our Products and do not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any questions regarding this Policy, please do not hesitate to contact us via: info@iotstadium.com
You are not obliged to provide to us with your Personal Data (as defined below). However, we may be unable to provide you with certain products and /or Services if you decline to provide such data.
Definitions
In this Policy, Personal Data means information generated, collected, recorded, and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone or from that information and other information we have access to about that individual.
- Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collect personal sensitive data about you.
- Devices refer to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network.
What Personal Data Do We Collect
In order to provide the Services to you, we will ask you to provide the necessary Personal Data that is required to provide those Products. If you do not provide your Personal Data, we may not be able to provide you with the Products.
1. Information You Voluntarily Provide Us
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- Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, username, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference, or time zone information into your account.
If you authorize login to the Products with a third-party account, we will obtain from such third party your account information (such as portrait, nickname, region, gender, etc.) which may be bound with your NOTO Labs account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies, or documentation agreed with such third parties regarding sharing personal information, in processing your Personal Data.
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- Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number, and feedback content to address your problems and solve device failures on a timely basis.
- Information based on additional functions: In order to offer you the Services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, that if you do not provide such information, you may continue to use the basic Services of the App and connected Devices, but certain features based on these additional functions, they may not be available. These additional functions may include:
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- Additional functions based on location information:
When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Devices. Also, we may collect information about your a) real-time and precise location, for instance, when youchoose to use the automation scenarios for controlling your Device, or b) nonprecise geolocation when you use certain Devices or Services. Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details. You may disable the collection and use of your location information by managing the device level settings, upon which we will cease to collect and use your location information. - Additional services based on camera:
You may use the camera to scan the code by turning on the camera permission to pair with a Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc. - Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):
You can use this function to upload your photos/pictures/videos after turning on the photo album permission, to realize functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem. - Additional services related to microphone-based service:
You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognize your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App. - Additional services based on storage permissions:
The purpose is to ensure the stable operation of the App by utilizing the storage permission. After you give or indicate permission to read/write your mobile device’s storage, we will access pictures, files, crash log information, and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.
- Additional functions based on location information:
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Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect previous collection and use of information based on your authorization.
2. Information We Collect Automatically
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- Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version mobile hardware serial number (a unique mobile identifier, which is a string representing the device manufacturer coded in the mobile device), Android ID, application version number, push notification identifier, log files, and mobile network information.
- Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
- Log Information: When you use our app, the system and exception log may be uploaded.
Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.
3. Device-Related Information
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- Basic Information of Devices: When you connect your Devices with our Products, we may collect basic information about your Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
Purposes and Legal Basis for Processing Personal Data
The purposes for which we may process information about you are as follows:
- Provide You Services: We process your account and profile data, device information, usage data, location information, and Device related information to provide you with the Products and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
- Improve Our Services: We process your device information, usage data, location information, and Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
- Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, policies, and/or other administrative information. Because this information may be important, you may not opt out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
- Personalization: We may process your account and profile data, usage data, and device information to personalize product design and to provide you with services tailored for you. The legal basis for this processing is your consent.
- Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate:
a. to comply with applicable laws and regulations;
b. to comply with legal process;
c. to respond to requests from public and government authorities
d. to enforce our terms and conditions;
e. to protect our operations, business, and systems;
f. to protect our rights, privacy, safety, or property, and/or that of other users, including you;
g. to allow us to pursue available remedies or limit the damages that we may sustain.
If there is any change in the purposes for processing your personal data, we will inform such change you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.
Who do We Share Personal Data with?
At NOTO Labs, we do not share your Personal Data in any way.
- Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:
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- For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notifications, and other related functions;
- You may opt-out the non-marketing communication through Settings;
- You may opt out of the data analysis features through Settings;
- You may opt out of the Personalization feature through Settings;
- Unbind the Device through the app, and the information related to the Device will not be collected;
When you withdraw your consent or authorization, we may not be able to continue to provide you with the products or services correspondingly. However, your withdrawal of your consent or authorization will no
- Security Measures
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. NOTO Labs provides various security strategies to effectively ensure the data security of users and devices. As for device access, NOTO Labs proprietary algorithms are employed to ensure data isolation, access authentication, and applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial-level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing info@iotstadium.com. - Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destroy your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data. - Children's Privacy
Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information. - Change to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by utilizing a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us at info@iotstadium.com
