Privacy Policy
Last Updated: December 16, 2022
Effective Date: December 16, 2022
This policy applies to SmartBT products and services, as well as certain features/services integrated into third-party products or software (collectively referred to as "our products and/or services"). This service is provided by Shenzhen RealTech Co., Ltd. The company's basic information is as follows:
Registered Address: 3rd Floor, C Block, 2nd-Phase of Huafeng Robot Industrial Park, Bao'An, ShenZhen - 518126, China.
If you have any questions, comments, or suggestions regarding this policy or your personal information, please contact us by sending an email to info@smartbt.store.
Shenzhen RealTech Co., Ltd. (referred to as "SmartBT" or "we") places great importance on user personal information. We understand the significance of personal information to you and are committed to maintaining your trust in us. We adhere to principles such as the consistency of rights and responsibilities, clear purposes, choice and consent, minimum necessity, security assurance, subject participation, openness, and transparency in protecting your personal information. Additionally, SmartBT commits to implementing appropriate security measures to protect your personal information in accordance with mature industry standards.
Before using or registering for SmartBT products and services, please read and thoroughly understand this "Privacy Policy." After confirming your full understanding and agreement, you may use the relevant products and services. While it is not mandatory for you to accept this policy or similar documents, please be aware that choosing not to accept may result in us being unable to provide you with complete services or respond to or resolve issues you encounter in certain specific scenarios. You can also choose to discontinue using our products or services. When you choose to continue signing this policy or using our products or services again, it will be considered that you have accepted and acknowledged this policy or similar documents based on the necessity of providing the service.
The purpose of formulating this policy is to help you understand the following:
- How we collect and use your personal information.
- How we entrust the processing and disclosure of your personal information.
- Cookie policy.
- How we protect your personal information.
- Your rights.
- How your personal information is transferred globally.
- Updates to this privacy policy.
- Contact us.
I. How We Collect and Use Your Personal Information
1. Instances of Collecting Your Personal Information
1.1. Account Creation, Purchase, and Product/Service Registration
If you submit applications online to create an account, make purchases, or register for our products or services, including fulfilling your purchase orders, delivering products or services, enabling or verifying products, making changes at your request, providing technical support, or authorizing updates, we may require you to provide personal data such as your name, email address, phone number, shipping address, product information, purchase date, and payment method. This information is necessary for processing your orders, downloading products, and providing services.
1.2. Service Upgrades
SmartBT may collect information about your terminal product's system and application for timely notifications about available system and application updates. The information collected for this purpose includes device name, system and application versions, operating system and browser versions, region and language settings, etc. The processing of this information by SmartBT is limited to notifying you about available application updates.
1.3. Troubleshooting
In the event of device or application abnormalities, if you choose to send relevant information to SmartBT for troubleshooting analysis by SmartBT or its partners, SmartBT may collect information such as device model, application name and version, device identification number, error logs, etc.
1.4. Collection of Personal Information for Specific Features You Use:
(1) When you bind your device for SmartBT product and service usage, we will collect the product's serial number and verification code. This information constitutes unique basic product information required for binding and providing further services.
(2) When you install software and use products and services, for security of your account usage, we will read your phone's status permission to receive and record the International Mobile Equipment Identity (IMEI) of the device. Please note that this information identifies the bound terminal device and is collected for the secure and normal operation of services. You can choose not to grant this permission, but this might result in the inability to identify bound terminal devices.
(3) When you use the app to scan QR codes or take photos, we will access your device's camera permission. After enabling the camera permission, you can use this function for QR code recognition, taking photos, and face recognition with your authorized consent in specific scenarios. Please be aware that we only obtain this permission upon your active authorization and present the camera interface to you.
(4) When you select photos from your phone's gallery containing recognizable QR codes, we need to access your photo library/storage permission to identify the device type and device serial number for adding. You can also use this permission to save photos or videos taken by the device's camera to your phone's gallery and share images or videos to social platforms like WhatsApp.
(5) When you use functions that require image collection, we need to access your camera and photo library/storage permissions for image information collection and storage. You can disable camera and photo library/storage permissions through system settings, but this will render you unable to use this function. Please note that we only obtain this permission upon your active authorization and present the camera interface to you.
(6) When you use Wi-Fi-related functions, we will access your location permission to obtain Wi-Fi lists and the current Wi-Fi name (SSID) your phone is connected to. This facilitates automatic population during device network configuration and ensures successful reconnection after changing router settings. You can choose not to grant this permission and manually enter the Wi-Fi name (SSID) or connect to Wi-Fi for related functions.
(7) When you use the monitoring video preview function, we will collect a screenshot of the current video frame to help you identify the monitoring location. Additionally, when you use the "Panorama Photo" function, we collect panoramic screenshots of video frames for the purpose of providing this feature to you; these screenshots will be continuously saved during your device's use. It's important to note that, unless you use additional value-added services based on video analysis and provide corresponding authorization, we will not view your video content or the aforementioned video screenshots.
(8) When you use functions like remote intercom, you need to grant microphone permission. We will collect and store audio content you submit to provide this feature. You can disable microphone permission through system settings, but this will render you unable to use this function.
(9) When you use analysis or comparison functions based on user benchmark information (including face/human recognition, license plate/vehicle recognition, sound recognition, text recognition, fingerprint unlocking), you need to pre-enter benchmark information like face images, fingerprints, sounds, etc. Refusal to provide these details will prevent you from using the relevant functions.
(10) When you enable message notification, we will collect screenshots of videos captured by your camera and use them as content for reminder messages. You can disable this feature through your account settings.
(11) When you use device or video sharing functions, you may need to provide information about relevant individuals, such as nicknames, relationships, and contact details. Refusal to provide this information will prevent you from using the related functions. It's important to note that sharing or similar functions will publicly expose the corresponding personal information within your designated scope. Please carefully decide whether to use these functions and take responsibility for any consequences.
(12) When you use value-added services, we will collect your personal information directly related to the service's purpose. The specific service purpose and information content will be provided to you through service descriptions or usage rules. This type of information is necessary for providing various value-added services; refusal to provide it may affect your ability to use related services.
(13) To ensure the smooth addition of security devices and routers and enable smooth camera preview within the app, as well as facilitate the discovery of security devices and routers on the local network, we need to access your local network permission. Denying this permission will affect your ability to use related functions properly. For example, you won't be able to accurately view the status during the device addition process or automatically discover security devices and routers on the local network.
(14) When you use the portrait/landscape switch function, we will access gyroscope, acceleration, and gravity sensor information to identify your device's orientation. Please understand that individual device sensor data doesn't involve any personal location information and can't be combined with other information to identify a specific individual.
1.5. Security and Operation Maintenance Services
To comply with legal regulations like the "Cybersecurity Law" and fulfill the basic requirements of providing services, ensuring the security of your account and system operation, we may collect information generated during your usage of our products and/or services, including:
(1) When you use relevant services, we will receive and record specific permissions granted by you during software installation and usage. This information includes hardware models of your phone or computer, operating system version numbers, browser types, IMEI, Media Access Control (MAC) addresses of network devices, IP addresses, software version numbers, network access methods and types, operation logs, etc. Please understand that these are basic information required for providing services and ensuring the normal operation of products.
(2) When you manage devices bound to your account, we will automatically receive and record information about related devices, including type, model, firmware version, MAC address, system version number, and system settings. We rely on this information to provide you with services and ensure the secure operation of devices. For example, when the system settings allow for automatic device upgrades (enabled by default for certain devices), we will automatically install and run upgrades when they are available to ensure compatibility between your devices and software.
(3) To better understand software and related service operations, ensuring operational safety, we may record network log information, usage frequency, crash data, error or exceptional service data, abnormal device system operation status, overall installation and usage, performance data, and other relevant information.
2. How We Use Your Personal Information
2.1. We will use your personal information according to the following rules:
(1) We will use it as specified in this policy to fulfill the relevant functions of products and/or services.
(2) We may integrate your personal information and/or other information acquired through lawful means related to your service or product usage behavior (referred to as "other information") to prevent, detect, investigate fraud, infringement, safety threats, illegal or agreement-violating behavior towards us or our affiliated companies.
(3) When you access third-party services through our products and/or services, we will share personal information within the scope of your authorization with the third-party service providers.
(4) Other uses permitted by your consent.
2.2. Please note that all personal information provided or authorized by you during the use of our products and/or services will be continuously authorized for use during your usage of our products and/or services unless you delete, refuse collection through account settings, or system settings. Upon account cancellation, we will cease use and delete your personal information, except as otherwise stipulated by laws and regulations.
2.3. We will generate statistics regarding product and/or service usage and may share this aggregated information with the public or third parties to showcase overall usage trends, create market satisfaction surveys, service improvement plans, and other research outcomes. However, this statistical information will not include any personally identifiable information.
2.4. When displaying your personal information, we will use methods such as content replacement and anonymous processing to desensitize your information and protect its security.
2.5. When we use your personal information for purposes not mentioned in this policy or when information collected for specific purposes is used for other purposes, we will seek your prior consent through active opt-in forms.
2.6. We specifically note that information that cannot identify your personal identity either alone or when combined with other information is not considered your personal information in the legal sense. When your information can identify your personal identity either alone or when combined with other information, these combined pieces of information will be treated as your personal information and will be processed and protected under this policy.
3. Exceptions for Obtaining Consent
According to relevant laws and regulations, collecting your personal information in the following situations does not require obtaining your consent:
(1) In situations relevant to national security and defense;
(2) In situations relevant to public safety, public health, major public interests;
(3) In situations relevant to criminal investigation, prosecution, trial, and enforcement of judgments, administrative law enforcement;
(4) When it's difficult to obtain your consent but necessary to protect your or other individuals' life, property, etc.;
(5) Personal information disclosed by you to the public;
(6) Collecting personal information from legally publicized information, such as lawful news reports, government information disclosure, and other channels;
(7) When necessary for signing and fulfilling relevant agreements or other written documents with you;
(8) When necessary for the security and stable operation of the provided products and services, such as discovering and addressing product and service faults;
(9) Necessary for academic research institutions to conduct statistics or academic research for public interests and providing research or descriptive results to the public, with the results de-identified;
(10) Other situations stipulated by laws and regulations.
II. How we entrust the processing and disclosure of your personal information
Certain modules or functions of our products and services are provided by external vendors. For the companies, organizations, and individuals to whom we delegate the processing of personal information, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our requirements, this Privacy Policy, and any other relevant protection and security measures. Please refer to the appendix for specific external vendors.
SmartBT will only disclose your personal information under the following circumstances:
1. For the purpose of providing services, it is necessary to share your personal information with third parties, including customers.
2. After obtaining your explicit consent.
3. Based on legal requirements for public disclosure: SmartBT may publicly disclose your information when required by law, legal proceedings, litigation, or government authorities.
III. Cookie Policy
To ensure the normal operation of our website, we sometimes place small data files on your computer or mobile device. These files are known as cookies. A cookie is a simple text file that a website's server stores on your computer or mobile device, and only that server can retrieve or read the contents of the cookie. Each cookie is unique to your browser. It contains some anonymous information, such as a unique identifier, the website name, and some numbers and characters. It allows the website to remember things like your preferences or the contents of your shopping cart.
Most large websites or internet service providers enable the website to remember your actions during your visit (using session cookies) or for your next visit (using persistent cookies) in order to improve the user experience. Cookies help the website remember your settings, such as language, font size, and other preferences you use while browsing the website on your computer or mobile device, so you don't have to enter these settings again when you return to the website. Without using cookies, if you move to a new page on the same website, you would be treated as a new visitor and your identity would not be recognized. For example, if you enter details and then move to another page, that page would not be able to identify you or keep you logged in.
Our cookies are not used to identify your personal identity but are used to make the operation of the app better and more convenient during your visit. If necessary, you can control or delete cookies.
SmartBT will not use the personal information collected by cookies for any purposes other than those described in this document, nor will it be used to collect any personal information for any other purposes.
IV. How We Protect Your Personal Information
1. We have implemented security measures that comply with industry standards to protect the personal information you provide, to prevent unauthorized access, public disclosure, use, alteration, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example:
- Our network services use transmission security protocols and encryption technologies to provide browsing services securely, ensuring the security of user data during transmission and storage.
- We manage and standardize the storage and use of user information through a data classification and grading system, data security management specifications, and data security development specifications.
- We establish strict data usage and access systems, use strict data access control and multi-factor authentication technologies to protect information security, and prevent unauthorized access and use of data.
- We conduct specialized data and technical security audits and implement multiple measures such as log audits and behavior audits.
- We provide security and privacy protection training courses to enhance employees' awareness of the importance of information security.
2. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will retain your personal information only for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.
3. We will regularly update and publicly disclose information about security risks and assessments of the impact of personal information security. You can obtain this information by sending an email to [info@smartbt.store].
4. The internet environment is not 100% secure, but we will do our best to ensure or guarantee the security of any information you send to us.
5. In the event of a personal information security incident, we will promptly inform you in accordance with legal and regulatory requirements: the basic situation and possible impact of the security incident, the measures we have taken or will take, advice on how to prevent and reduce risks, and remedies for you. We will inform you of the relevant information through email, letters, phone calls, push notifications, etc. If it is difficult to inform each individual information subject, we will make reasonable and effective announcements. At the same time, we will also report the disposal of personal information security incidents to regulatory authorities as required.
V. Your Rights
We will retain your personal information for the period necessary to achieve the purposes stated in this policy, unless the law requires or allows us to retain this information for a longer period. We guarantee your rights to the following personal information:
1. Access to Your Personal Information
You have the right to access your personal information, except as otherwise provided by laws and regulations. If you wish to exercise your data access rights, you can access them yourself by logging in with your SmartBT ID on the SmartBT Business Cloud. If you are unable to access this personal information in the above manner, you can contact us at any time by sending an email to [info@smartbt.store].
2. Correction of Your Personal Information
If you find errors in the personal information we process about you, you have the right to request us to correct it. You can make correction requests through the methods listed in "1. Access to Your Personal Information."
3. Deletion of Your Personal Information
In the following circumstances, you can request us to delete your personal information:
- If our processing of personal information violates laws and regulations.
- If we collect and use your personal information without your consent.
- If our processing of personal information violates our agreement with you.
- If you no longer use our products and services or you have cancelled your account.
- If we no longer provide products or services to you.
If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and ask them to delete it in a timely manner. Unless otherwise provided by laws and regulations, or with your independent authorization, these entities will delete your personal information.
4. Changing the Scope of Authorization or Withdrawing Authorization
You can change the scope of authorization or withdraw your authorization for us to collect personal information by deleting information, disabling a service or feature, adjusting personal information settings in software, or managing application permissions. You can also withdraw all your authorization for us to collect your personal information by canceling your account.
Please understand that each business function requires some basic personal information to be completed. After you withdraw your consent or authorization, we will not be able to provide you with services corresponding to your withdrawn consent or authorization, nor will we process the relevant personal information. However, your decision to withdraw consent or authorization will not affect the processing of personal information that was conducted based on your authorization prior to the withdrawal.
5. Account Cancellation by Data Subjects
You can also apply for account cancellation through customer service or by sending an email to [info@smartbt.store].
For requests that require manual processing, we will complete the processing within 15 business days.
After your account is cancelled, you will no longer be able to log in or use our products and services with that account. We will actively delete your personal information, except as otherwise provided by laws and regulations.
6. Obtaining a Copy of Personal Information by Data Subjects
If you need to obtain a corresponding copy of your personal information, you can send an email to [info@smartbt.store] or contact us. To ensure security, we may require you to provide a written request or verify your identity in another way. We will respond to your request within 15 business days after receiving your feedback and verifying your identity. If technically feasible and compliant with relevant laws and regulations, we may directly transmit your personal information copy to a third party designated by you.
7. Responding to Your Requests
For your reasonable requests, we generally do not charge fees and will respond to your requests within the time limit prescribed by law (within 15 business days). However, for repeated requests beyond a reasonable limit, we may charge a certain cost depending on the situation. We may refuse requests that are groundless, excessive, require excessive technical measures (for example, require developing a new system or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are impractical (for example, involve information stored on backup tapes) as appropriate.
We will be unable to respond to your requests in the following circumstances:
- Related to SmartBT's fulfillment of legal and regulatory obligations.
- Directly related to national security and national defense security.
- Directly related to public security, public health, and significant public interests.
- Directly related to criminal investigation, prosecution, trial, or execution of judgments.
- Where SmartBT has sufficient evidence of your subjective malice or abuse of rights.
- To protect the significant legitimate rights and interests of the data subject or other individuals, organizations, but it is difficult to obtain the consent of the person.
- Where responding to your request would seriously damage your or other individuals' or organizations' legitimate rights and interests.
- Involving trade secrets.
VI. How Your Personal Information Is Transferred Globally
We collect and generate personal information while operating within the territory of the People's Republic of China, and store it within China, unless otherwise specified by laws and regulations.
VII. Updates to This Privacy Policy
1. SmartBT may periodically modify and update this policy. You can access the latest version of the terms of this agreement by visiting www.smartbt.store.
2. We will not restrict your rights under this policy without your explicit consent. For major changes, we will notify you through push notifications, pop-up windows, emails, etc.
3. Major changes referred to in this policy include but are not limited to:
- Major changes to our service model, such as changes in the purpose, type, and method of processing personal information.
- Major changes to our ownership structure, organizational structure, etc., such as changes in business adjustments, bankruptcy mergers and acquisitions, and restructuring that result in changes in ownership.
- Changes in the main objects of sharing, transferring, or publicly disclosing user information.
- Major changes in your rights and their exercise methods when using our services.
- Changes in the department responsible for personal information security, contact methods, and complaint channels.
- When the assessment report on the impact of user information security indicates a high risk.
VIII. Contact Us
If you have any questions, opinions, or suggestions regarding our policies, you can send an email to info@smartbt.store to contact us. In general, we will respond within fifteen business days.