GENERAL
Hubei Xingji Meizu Network Technology Co., Ltd. and its global affiliates (also referred to as “we”, “us”, or “our”) take your privacy seriously where we deal with your personal data. Personal data refers to any type of information that identifies you personally such as your name, contact details, payment details, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly (“Personal Information”).
This Privacy Policy describes our practices in connection with Personal Information that we collect from you in person and through your use of our products and services, including smart glasses (hereinafter referred to as “Glasses”), mobile apps and websites. We will be responsible as a data controller for all the Personal Information we collect through your use of our products and services mentioned in this Privacy Policy, including Glasses, mobile apps and websites.
Please note that this product/service may adapt, connect, and manage different types of glasses and implement priority adaptation to different hardware, systems, and models. Due to the specificity of the product/service, this policy will integrate different products/services. When you use a specific product/service, not all terms of this policy apply to that specific product/service. In cases where a specific term is referred to, that term applies only to that specific product/service.
Where there are local variations or additions concerning how we use your Personal Information collected from your home country, these are set out clearly in the 【13. Country Specific Schedules】 section of this Privacy Policy. Please treat these schedules as a part of this Privacy Policy.
QUICK GUIDE TO CONTENTS
1 HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
2 HOW WE SHARE YOUR PERSONAL INFORMATION
3 WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST?
4 DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
5 DO WE TRANSFER YOUR PERSONAL INFORMATION?
6 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
7 SECURITY
8 SENSITIVE PERSONAL INFORMATION
9 YOUR PRIVACY RIGHTS
10 CHILDREN
11 UPDATES TO THIS PRIVACY POLICY
12 CONTACTING US
13 CONFLICT
14 COUNTRY SPECIFIC SCHEDULES
1.HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
We receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our Glasses, mobile apps and websites.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either “performance carry out a contract with you”; “where we have a legal obligation”; “ where you have given us your consent”; or “where it is necessary for our legitimate interest” (this means that we have a business or commercial interest in using your Personal Information).
The tables below set out clearly how we collect and use your Personal Information.
1.1 Personal Information that you provide to us
Information you give us | How we use your information | Legal basis or justification for processing |
Interpreter You give us Personal Information about you when you use the interpreter function. This is generally information including user configuration data (including subtitle content and font size, translation language type). The processing of personal information during this process is completed on the mobile device and is not transmitted or stored on our servers. | To convert the corresponding language translation according to the user's set configuration and display AR subtitles on the glasses. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Smart reminder You give us Personal Information about you when you modify the notification switch settings in the smart reminder. This is generally information including your notification switch setting information. We only process your Personal Information locally. | To record the settings for displaying, announcing, and automatically turning on the screen for phone notifications on the Glasses. | Performance of a contract with you. |
Voice assistant You give us following Personal Information about you when you use the Voice assistant function: 1. Information that you enter or record; 2. Your home address and work address; 3. Your city information and precise location information;4. The date and day of the week you inquire about. | - To provide voice interaction services. - To display multiple related navigation options on the Glasses based on the results of the voice assistant interaction, to help you view planned routes. - To display weather information for your location on the Glasses, based on the results of the voice assistant interaction. To display the date, day of the week and time information you inquire about on the Glasses. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
AR Navigation You give us Personal Information about you when you use the frequently used addresses feature. This is generally information including your home and work addresses, which are provided actively by you. | To facilitate convenient navigation to your home and work addresses, as well as for route planning during navigation. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Fill out a user experience survey questionnaire You give us Personal Information about you when you choose to fill out a user experience survey questionnaire. This is generally information including your customized anonymous ID, the content of the questionnaire, which you have voluntarily agreed to provide. | · To understand the user's experience with the product and to further improve that experience, as well as to contact and communicate with you by our customer service with your consent. | Necessary for our legitimate interests. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Customer Service Support You give us Personal Information about you when you contact us through our customer service email or by other methods in relation to an order or support request you have made with us. This is generally information including your name, Flyme account number, and details of your enquiry or query. | To communicate with you regarding your access to our services and provide you with related customer service. | Performance of a contract with you. |
Responding to requests for exercising rights by the subject of personal information You give us Personal Information about you when you exercise your rights related to Personal Information, such as the right to access, copy or delete. This is generally information including your phone number, email address, Flyme account and details of your enquiry or query. | To response to your request, including to verify that this exercise request is from you. | Legal Obligation. |
Feedback submission feature You give us Personal Information about you when you use the feedback submission feature to provide feedback. This is generally information including your Glasses model, phone model, as well as the information about the issue you choose to submit (issue type, frequency of the issue, issue description), issue logs (which may include voice conversation records from your recent use of the voice assistant or translation feature), feedback images/videos, and the time of feedback. In this case, we may need to request permission to access external storage (Android system) / photo permissions (iOS system). | To resolve the issue and provide you with processing suggestions. | Performance of a contract with you. |
Exercise and Health (When you purchase and bind the ring) You give us Personal Information about you when you use the personal health information filling feature. This is generally information including your date of birth, gender, height, weight, family history of diabetes, high cholesterol status, which you have voluntarily agreed to provide. Please note that you can choose whether to provide personal health information, but not providing the necessary health information may prevent the corresponding functions from being able to perform assessments properly. THE RING’S FEATURES ARE NOT PROVIDED TO INDIVIDUALS UNDER 18 YEARS OF AGE, AND MINORS SHOULD NOT SUBMIT THEIR PERSONAL INFORMATION. | - The purpose of collecting your date of birth, gender, height, and weight is to conduct exercise vitality index analysis; - The purpose of collecting your date of birth, gender, height, weight, family history of diabetes, and high cholesterol status is to assess the risk of high blood sugar levels. (Note: This product is not a medical device, and the assessment results are for reference only and not to be used as a basis for diagnosis and treatment. If you feel unwell, it is advised to seek medical attention promptly). | Upon your explicit consent. We collect exercise and health-related data only after you have given your explicit consent to the “Ring Sensitive Personal Information Processing Rules”. |
1.2 Personal Information that we collect when you use our products and services
Information we collect | How we use your information | Legal basis or justification for processing |
Using our services with Flyme account When you use our services with a Flyme account, we collect and use your Flyme account ID and nickname and avatar. This information is collected through indirect means from our affiliated companies with your authorization. Please read the Flyme Account Privacy Policy carefully before registering or logging in to your Flyme account. To better protect your privacy and security, the local data generated from the use of smart devices and their accompanying apps, including Voice Assistant, Navigation, Translator, Smart Reminders, Teleprompter, Meeting Assistant, Speech-to-Text, Quick Notes, and Glasses Settings, will be associated with your Flyme account and displayed in isolation locally. Application data between different accounts will be independent and not visible to each other. | To help you use our services through your Flyme account. | Performance of a contract with you. |
Device connection We collect Personal Information about you when you use the device connection function. This is generally information including your device's Bluetooth Mac address, phone model, device serial number, AndroidID, customized anonymous ID, this information is collected through the system automatically after you turn on the permissions. In this case, we may request your consent to access your geographical location (for Android devices) and Bluetooth (both Android and iOS devices) to identify and connect devices via Bluetooth. We only process your Personal Information locally. | To enable the discovery, binding, and maintenance of the connection status between Glasses and other devices with our application. | Performance of a contract with you. |
Touchpad We collect Personal Information about you when you use the touchpad feature. This is generally information including your actions on the touchpad screenshots taken on the Glasses’ screen. This information is collected automatically through the system. You have the option to disable the transfer of glasses screenshots to this application, which will not affect your use of other features. In this case, we may request your permission to album access (for iOS systems) to save screenshots to the phone’s album. We only process your Personal Information locally. | To operate Glasses via the touchpad, for example when flipping pages on as the teleprompter function or to take screenshots on the Glasses’ screen and store them in the phone’s album. | Performance of a contract with you. |
Device display feature We collect Personal Information about you when you use the device display feature on the homepage. This is generally information including your connection status, battery level, device name, device model, Glasses volume and brightness and device binding information of your multiple devices (glasses, rings). These information is collected automatically through the system. | To display the status of the bound devices and to provide control functions. | Performance of a contract with you. |
Glass Settings We collect Personal Information about you when you use the glasses settings. This is generally information including your device-related information (Glasses name, model, firmware version, serial number), device setting options (including app list order, standby component layout, do-not-disturb mode selection, auto-brightness adjustment, auto-screen off settings, and audio control settings during screen off, wear detection settings, network configuration, auditory assistance mode, image stabilization, image adjustment), system language configuration information, and Glasses light sensor data. When you use the automatic brightness adjustment function, on specific glasses devices, we will also collect location information to obtain local sunrise and sunset times through location information and automatically adjust brightness according to your selection. Additionally, we will bind the device information (device name, model, firmware version, serial number), glasses setting data (notification settings, automatic screen off time settings, glasses desktop component card settings, Wi-Fi account password stored in device networking, voice assistant settings, automatic call volume adjustment settings, touchpad settings) with your logged-in Flyme account to synchronize your settings and provide a consistent experience. | To display the status of the bound device and to control related options on the device, and to achieve automatic brightness adjustment function. | Performance of a contract with you. |
Audio and Video We collect your Personal Information when you play audio and video content on your phone while it is connected to your Glasses. This is generally information including related information about the audio and video, including titles, lyrics, artist information, song duration, playback progress, playback status. This information is collected automatically through the system. The information processed during this process is transmitted in real-time from the phone to the glasses via Bluetooth. In this case, we may request your consent to use of Bluetooth permissions. We only process your Personal Information locally. | To play audio through the Glasses and to display related information about the audio and video content. | Performance of a contract with you. |
View weather information We collect Personal Information about you when you view the weather information. This is generally information including real-time temperature information, weather information, city information, and date information. This information is collected automatically by the system. In this case, we may need to use geolocation permissions (Android and iOS systems), the weather information processed in this process is synchronized by the phone's interconnection function to the Glasses side, and is only processed and cached locally on the Glasses side. | To display weather information. | Performance of a contract with you. |
View exercise information We collect Personal Information about you when you use your iOS or Android phone to view real-time exercise information. This information generally includes the real-time number of steps you take in the mobile app, which we collect with your authorization to enable health permissions (iOS system) or which we collect from the mobile sports health application indirectly with your authorization (Android system). The information processed during this process is synchronized to the Glasses from the phone’s interconnectivity features and is only processed and cached locally on the Glasses. | To show you the number of steps you have taken on your Glasses. | Performance of a contract with you. |
Interpreter We collect Personal Information about you when you use the simultaneous interpretation function under the Interpreter . This is generally information including voice data, transcription results and translation logs (including translation completion date and translated text). This information is collected automatically by the system (where the dialogue recording is transmitted from the Glasses to this application, and the transcription results and translation records are obtained by this application from the translation service provider). We collect Personal Information about you when you use the conversation translation function under the Interpreter. This is generally information including voice data, transcription results and translation logs (including translation completion date and translated text). This information is collected automatically by the system (where the dialogue recording is transmitted from the Glasses to this application, and the transcription results and translation records are obtained by this application from the translation service provider). We collect Personal Information about you when you use the phone call translation feature under the Interpreter. This is generally information including call recordings, transcription results, and translation logs (including translation completion date and translated text). This information is collected automatically by the system (where the call recording is transmitted from the Glasses to this application, and the transcription results and translation records are obtained by this application from the translation service provider). We collect Personal Information about you when you use the information extraction function under dialogue translation or call translation. This is generally information including your Flyme account, the text translated from audio, as well as the summary and to-do list text after information extraction. This information is collected automatically by the system for the purpose of summarizing the translation records based on large language model and generating to-do lists. The information extraction feature is optional, and if you refuse to provide this information, it will not affect your use of other features of Interpreter. The information extraction service in this feature is based on a third-party large language model. The large language model used in our product is Google’s Gemini 1.5 Pro. For specific information about this model, please refer to: https://console.cloud.google.com/vertex-ai/publishers/google/model-garden/gemini-1.5-pro-001?hl=zh-cn&_ga=2.144701235.789893142.1724657599-1089955347.1724657579. Please rest assured that the content you provide while using our product will not be used for model training. Within the scope allowed by laws and regulations, we cannot be responsible for third-party products and any content. In addition, when you actively turn on the location switch and use the location display function associated with translation records, we will collect your geographical location information to display the location where the translation record is generated. In this case, we may need to use location permissions (Android and iOS systems). You can refuse to provide this information, which will not affect your use of other functions of the Interpreter. | - To provide conversation translation, call translation, and simultaneous interpretation services; - To provide you with information extraction services so you can generate summaries and to-do lists from translation records. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Smart reminder We collect Personal Information about you when you use the smart reminder feature, which allows notifications from your phone to be displayed on your Glasses. This is generally information including your notification data. This information is collected automatically through the system after you have granted the necessary permissions. In this case, we may seek your authorization to enable notification permissions (for both Android and iOS systems) and to access the list of installed apps (for Android systems). Your notification data is used solely for display purposes on the Glasses, and we do not store your notification information. We collect Personal Information about you when you use the smart reminder schedule card feature. This information is collected automatically through the system after you grant permission. In this case, we may request authorization to open the read calendar permission (Android system and iOS system). Your schedule information is only used for display on the Glasses, and we will not store your schedule information. | - To display and alert you to phone notifications on your Glasses. - To remind you of the nearest schedule on the Glasses before the schedule starts. | Performance of a contract with you. |
Social communication —Manually answer and redial missed calls on the Glasses (the scenarios of making/receiving calls through voice assistants will be described in the voice assistant section) We collect Personal Information about you when you manually answer and redial missed calls on the Glasses. This is generally information including your call information (including contact name and phone number) and missed call records. This information is collected automatically through the system after you have granted the necessary permissions (contacts and call history permissions), and synchronized to the Glasses to display the information, so that you can manually answer and redial missed calls on the Glasses. If you do not enable the aforementioned permissions, it will not affect your use of the phone answering function, but without enabling the contact permission, the contact information (name and phone number) will not be displayed in the call information you receive on the Glasses. If you have not enabled the call history permission, you will not be able to provide missed call reminder and redial service. Personal Information processed during this process is handled locally on the phone and Glasses. We will not transmit or save it to our servers. | To identify and match contact information during the process of receiving system calls, or assist you in quickly calling back numbers from your recent call history. | Performance of a contract with you. |
Voice wake-up and voice recognition We collect Personal Information about you when you use voice wake-up and voice recognition features. This is generally information including your customized anonymous ID and recording data. | To distinguish between devices for voice recognition, to activate the Voice assistant feature, and to identify the user’s needs. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given) |
Voice assistant We collect Personal Information about you when you use voice commands to answer calls or make calls (including returning missed calls). This generally information including your contact data (such as contact names and phone numbers) and missed call records. This information is automatically collected through the system once you have granted the necessary permissions (for contacts and call history), and it is synchronized with the Glasses to display this information. This allows you to answer and make calls (including returning missed calls) using voice commands through the Glasses. If you are using a smartphone running Android 14 or above, when using the voice assistant to make a call, if it detects that two or more SIM cards are inserted into the phone simultaneously and no default card is set, this application will request the system’s permission to read the phone number and obtain the numbers corresponding to the different SIM cards. This information will then be displayed on the Glasses interface, allowing you to select the phone number to use for making calls. The SIM card phone numbers obtained in this process are only processed locally. If you do not grant the aforementioned permissions, it will not affect your ability to use the answering function, but you will not be able to make calls using the voice assistant. When you generate memos or to-do list items through the voice assistant, or when you add, delete, modify, or check memos or to-do list items in the Quick Notes feature through the voice assistant, we collect the memos or to-do list items you input. This information is collected through user-initiated methods and system automatic collection methods. | - To help you view incoming call information on your phone through your Glasses while wearing them, and allows you to answer, reject, and make phone calls. - To generate memos or to-do list items quickly and to quickly search and modify memos or to-do list items recorded by the voice assistant within the Quick Notes feature. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Generative AI services You can access and use the generative AI services provided by third-party large language model service providers through the Voice assistant, Meeting assistant, Interpreter and Speech-to-Text features. We collect Personal Information about you when you use these functions. This is generally information including voice data and the text information generated from voice transcription, which is collected automatically through the system. In this case, we need to share the voice transcription information you input with the third-party large language model service provider, and indirectly collect generated text information from them. The large language model used in our product is Google’s Gemini 1.5 Pro. For specific information about this model, please refer to: https://console.cloud.google.com/vertex-ai/publishers/google/model-garden/gemini-1.5-pro-001?hl=zh-cn&_ga=2.144701235.789893142.1724657599-1089955347.1724657579. Please rest assured that the content you provide while using our product will not be used for model training. Within the scope allowed by laws and regulations, we cannot be responsible for third-party products and any content. We will bind the conversation records during your use of the Voice assistant with your logged-in Flyme account to synchronize your conversation records and provide a consistent experience. | To use your input text and voice input converted to text content as input, and to output corresponding text content as a response through the third-party large language model. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Quick Notes We collect Personal Information about you when you use the Quick Notes feature. This is generally information including instructions and related records about memos or to-do items. This information is collected automatically by the system from the transcription records of your voice assistant after you request the recording memos or to-do items. The memos or to-do information displayed in Quick Notes is only displayed and processed locally on the Glasses and within this app end, and we do not save it to our servers. | - To facilitate you in quickly creating, querying, and modifying memos or to-do items through voice assistant. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
AR Navigation We collect Personal Information about you when you use AR navigation. This is generally information including customized anonymous ID, precise location information, rough location information, planned route information, departure and destination, city, province, country, and coordinate system, which is provided by the user and automatically collected by the system. In this case, we may need to use geolocation permissions (Android and iOS). | To facilitate positioning and route planning during navigation. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Meeting assistant We collect Personal Information about you when you use Meeting assistant function. This is generally information including audio recorded on the Glasses, Flyme account, the recording start time and duration and the target language. This information is collected automatically by the system and also provided actively by you. Additionally, we may collect your geographic location information to display the recording location. In this case, we may need to use geographic location permissions (for Android and iOS systems). You can refuse to provide this information, which will not affect your use of other functions of the Meeting assistant. We collect Personal Information about you when you use the information extraction function of the Meeting assistant. This is generally information including your Flyme account and the text transcribed from the audio. This information is collected automatically by the system. The information extraction service in this feature is based on a third-party large language model. The large language model used in our product is Google’s Gemini 1.5 Pro. For specific information about this model, please refer to: https://console.cloud.google.com/vertex-ai/publishers/google/model-garden/gemini-1.5-pro-001?hl=zh-cn&_ga=2.144701235.789893142.1724657599-1089955347.1724657579. Please rest assured that the content you provide while using our product will not be used for model training. You can directly set the to-do items as events on the calendar. In this case, we may need to use calendar permissions. The information extraction function is separately enabled. If you refuse to provide the necessary information for this function, it will not affect your use of other functions of the Meeting assistant. | - To provide Meeting Assistant services, including transcribing meeting or phone recordings into text for you to view the content and location information, and supporting the summarization of meeting records and/or the generation of to-do items through information extraction features. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Speech-to-Text We collect Personal Information about you when you use the Speech-to-Text feature. This is generally information including the audio data, transcription data and your Flyme account. This information is collected automatically by the system and provided by you actively. In addition, we may collect your geographical location information to display the recording location of the audio. In this case, we may need to use location permissions (Android and iOS systems). You can refuse to provide this information, which will not affect your use of other functions of voice transcription. We collect Personal Information about you when you use the information extraction function of the Speech-to-Text. This is generally information including your Flyme account and the text transcribed from the audio. This information is collected automatically by the system. The information extraction service in this feature is based on a third-party large language model. The large language model used in our product is Google’s Gemini 1.5 Pro. For specific information about this model, please refer to: https://console.cloud.google.com/vertex-ai/publishers/google/model-garden/gemini-1.5-pro-001?hl=zh-cn&_ga=2.144701235.789893142.1724657599-1089955347.1724657579. Please rest assured that the content you provide while using our product will not be used for model training. The information extraction function under Speech-to-Text is separately enabled, and if you refuse to provide this information, it will not affect your use of other functions of Speech-to-Text. | - To provide the Speech-to-Text service and to use the information extraction feature to generate content summaries from the records transcribed from speech. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Version compatibility When this application is connected to the Glasses, we collect your Glasses firmware version number, Glasses model, Glasses connection status, the current version number of the APP, and phone model. This information is obtained automatically by the system. The purpose of collecting this information is to determine whether the Glasses version is compatible with the phone APP version. If it is determined that they are not compatible, you will be prompted to update the software or firmware accordingly. Please be assured that the above information is collected and processed locally on the application client only, and we will not upload it to our servers.AI编辑 | - To check the compatibility status between the Glasses version and the phone app version, and prompt the user to update when versions are not compatible. | Performance of a contract with you. |
Software Update We collect Personal Information about you when you use the software update function. This is generally information including your phone brand, phone model, app name, app package name, and app version number. | To detect and update the application. | Performance of a contract with you. |
Firmware Update We collect Personal Information about you when you use the firmware update function. This is generally information including your Glasses’ serial number, model, system version, storage space, and battery level. If you have purchased a ring, we will also collect your ring’s SN address, battery level, version, model, upgrade status, and MAC address. These pieces of information are obtained automatically through the system or application, and the purpose of collecting this information is to detect and update the firmware. | To detect and update the firmware. | Performance of a contract with you. |
Teleprompter We collect Personal Information about you when you use Teleprompter. This is generally information including your teleprompter document information and configuration information (including teleprompter mode settings and notification switch information). This information is collected through a combination of your active provision and system automation after you have granted permissions. We only process your Personal Information locally. | To provide you with document import, to select teleprompter documents, and to synchronize the selected teleprompter documents to the Glasses for display. | Performance of a contract with you. If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
Record the activation status of the Glasses device We collect Personal Information about you when you first use the Glasses for a specific duration. This is generally information including your Glasses’ encrypted SN number, the version number of the Glasses’ operating system, model, activation time, phone brand, phone model, phone manufacturer, and phone operating system. This information is collected through the Glasses and mobile device and reported to the server through this application. For the purpose of risk control, we need to check your device activation status every time you restart your device. | To record the activation status of the Glasses and to calculate the number of activations. | Performance of a contract with you. |
Data Synchronization When you use our apps and smart devices (Glasses, ring), we synchronize the following information to your logged-in Flyme account, to provide a consistent experience. (1) Glasses device information: device name, model, firmware version, serial number; (2) Glasses settings data: auto screen-off time settings, glasses home screen widget card settings, app space desktop configuration, page layout of quick commands on the discovery page; (3) Navigation data: home and company addresses set within the navigation component, frequently used addresses, license plate number, commonly used modes of transportation; (4) Voice Assistant: the on/off status of various Voice Assistant functions, location information (used for obtaining location when using voice navigation and weather queries), address information (home and company addresses saved by the user through voice commands), conversation history between the user and the Voice Assistant; (5) Social communication, Smart Reminders: the on/off status of notification forwarding, information reminder switch status. | - To achieve cross-device synchronization of your settings and data, providing a consistent experience. | Performance of a contract with you. |
Ring Management (When you purchase and bind the ring) When you purchase a ring and bind it through this app, as well as use the ring management feature, we collect your ring device information (including ring name, ring model, battery level, ring firmware version, ring MAC address, ring Bluetooth name and address information), ring binding connection status, ring wearing status, and infrared light measurement information. This information is collected automatically by the system. | - To display the information of the bound ring device and to manage the ring device (including determining whether the user is wearing the ring). | |
Exercise and Health (When you purchase and bind the ring) We collect Personal Information about you when you use the ring’s health index feature. This is generally information including your health index information (health index, sleep, exercise, stress, heart rate, blood oxygen levels). This information is collected automatically by the ring with your authorization. The purpose of collecting this information is to provide you with health index services. We collect Personal Information about you when you use the ring’s heart rate monitoring feature. This is generally information including your cardiac health information (time of heart health data generation, heart rate, latest heart rate, average heart rate, minimum/maximum heart rate, heart rate variability, average heart rate variability, minimum/maximum heart rate variability). This information is collected automatically by the ring with your authorization. The purpose of collecting this information is to provide you with heart rate index services. We collect Personal Information about you when you use the ring’s blood oxygen level monitoring feature. This is generally information including your blood oxygen health information (time of blood oxygen data generation, blood oxygen concentration, latest blood oxygen value, average blood oxygen value, maximum blood oxygen value, minimum blood oxygen value, blood oxygen concentration percentage). This information is collected automatically by the ring with your authorization. The purpose of collecting this information is to provide you with blood oxygen level testing services. We collect Personal Information about you when you use the ring’s stress monitoring feature. This is generally information including your stress health information (time of stress data generation, stress status, latest stress value, minimum stress value, stress percentage). This information is collected automatically by the ring with your authorization. The purpose of collecting this information is to provide you with stress testing services. We collect Personal Information about you when you use the ring’s sleep monitoring feature. This is generally information including your sleep health information (time of sleep data generation, duration of nighttime/short naps, sleep structure percentage, status percentage, quality assessment score and detailed suggestions, time taken to fall asleep, average heart rate/blood oxygen/HRV). This information is collected automatically by the ring with your authorization. The purpose of collecting this information is to provide you with sleep monitoring services. We collect Personal Information about you when you use the ring’s body temperature monitoring feature. This is generally information including your body temperature health information (time of body temperature data generation, body temperature trend). This information is collected automatically by the ring with your authorization. The purpose of collecting this information is to provide you with body temperature testing services. We collect Personal Information about you when you use the ring’s blood sugar monitoring feature. This is generally information including your blood sugar health information (time of blood sugar data generation, normal/abnormal blood sugar, pre-meal/post-meal/fasting blood sugar, blood sugar risk assessment, results of blood sugar measurement) and personal health information (date of birth, gender, height, weight, family history of diabetes, high cholesterol status). Blood sugar health information is collected automatically by the ring with your authorization, and personal health information is collected through your active reporting. The purpose of collecting this information is to provide you with blood sugar risk assessment services. We collect Personal Information about you when you use the ring’s exercise vitality index analysis feature. This is generally information including your vitality index information (vitality index, exercise assessment, step count, time of step data generation, calories) and personal health information (date of birth, gender, height, weight). Vitality index information is collected automatically by the ring with your authorization, and personal health information is collected through your active reporting. The purpose of collecting this information is to provide you with exercise vitality index analysis services. | - To provide you with functions and services such as health index, heart rate monitoring, blood oxygen level testing, stress detection, sleep monitoring, body temperature measurement, blood sugar risk assessment, and exercise vitality index analysis. | Upon your explicit consent. We collect exercise and health-related data only after you have given your explicit consent to the “Ring Sensitive Personal Information Processing Rules”. |
Recording your action of clicking confirm, agree, decline or withdraw consent When you review and select to confirm, agree, decline, or withdraw consent to this policy within the interactive interface, we collect and use your device information (variable device ID, such as Android ID, IDFV) and log information (timestamp and corresponding system, application, and protocol version information), which is collected automatically by the system. | To comply with legal regulations and to confirm which version of this policy is valid for you in order to protect your legal rights and interests. | Performance of a contract with you. |
1.3 General Enquiries
Information we collect | How we use your information | Legal basis or justification for processing |
General Enquiries You give us Personal Information about you when you contact us or otherwise interact with us generally, including via email, telephone call or otherwise. This is generally information including your name, contact information, and details of your communication. | To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our products and services. | Performance of a contract with you. |
1.4 Automatically Collected Information
Information we collect | How we use your information | Legal basis or justification for processing |
Cookies (and Similar Technologies) When you access our websites, we might use third-party cookies and other similar technologiesto automatically collect information. For example, the information we collected via cookies might include the number of times you visit or the time you stay on a specific page. | To measure and analyze website usage, such as the number of page views and unique visitors, so as to enhance your experience using our services. | Necessary for our legitimate interest If, according to the requirements of the applicable country, such processing requires your consent, such processing will be based on your consent (if given). |
1.5 Internal Business Processes
Information we collect | How we use your information | Legal basis or justification for processing |
Aggregating and/or Anonymizing Personal Information Our aggregating and/or anonymizing of Personal Information may apply to the above Personal Information, including hardware, operating system, performance statistics, as well as usage data of devices and applications, that collect about you. | To aggregate and/or anonymize any Personal Information we collect so that it will no longer directly identify you or any other individual. To develop new products and services. To enhance, improve, or modify our current products and services. | Necessary for our legitimate interests. |
Audits (Internal and External) and Compliance Our audit and compliance process may apply to any of the above Personal Information we collect about you. | To verify that our internal processes function as intended. To verify that our internal processes are compliant with legal, regulatory or contractual requirements. | Necessary for our legitimate interests. |
Fraud and Security Our fraud and security monitoring process may apply to any of the above Personal Information we collect about you. | To carry out fraud and security monitoring within our business, for example, to detect and prevent cyberattacks or attempts to commit identity theft. | Necessary for our legitimate interests. |
Administration Our administrative processes may apply to any of the above Personal Information we collect about you. | To operate efficiently within our business model and corporate structure, in a way that effectively services our customers, including by using a range of centralised and localised business functions. | Necessary for our legitimate interests. |
Legal claims Our legal claims process may apply to any of the above Personal Information we collect about you. | To effectively defend or bring claims to protect our legal rights and interests, and to respond to investigations from regulators or law enforcement. | Necessary for our legitimate interests. In relevant circumstances we may also rely on legal obligation as a legal basis for this process. |
2.HOW WE SHARE YOUR PERSONAL INFORMATION
We share and disclose, or may share or disclose your Personal Information for the following purposes:
2.1 We share your Personal Information with our global affiliates for the purposes described in this Privacy Policy.
2.2 We share your Personal Information with third parties who perform services of automatic speech recognition and speech to text when you use Interpreter, Speech-to-Text and Meeting assistant. This Personal Information includes the audio recordings.
2.3 We share your Personal Information with third parties who perform services of translation when you use the interpreter feature. This Personal Information includes the speech transcription results.
2.4 We share your Personal Information with third parties who perform services of position and navigation when you use the AR navigation feature. This Personal Information includes the latitude and longitude data, national code and keywords searched by users.
2.5 We share your Personal Information with third parties who perform services of automatic speech recognition, semantic understanding, speech synthesis, and Generative AI when you use Voice assistant. This Personal Information includes the audio recordings and text information.
2.6 We share your Personal Information with third parties who perform services of weather data query when you view weather information through Glasses. This Personal Information includes geographic location information.
2.7 We share your Personal Information with third parties who perform services of data analytics services when you visit our website. This Personal Information includes the number of times you visit and the time you stay on a specific page.
2.8 We share your Personal Information with third parties who perform services on our behalf (and in some cases, our affiliates), to facilitate the services they provide to us. These can include consultants, providers of professional advisory services (lawyers and accountants), service providers involved in hosting, marketing technology, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, email delivery, credit card processing, auditing and other similar services.
2.9 We share your Personal Information if we have a duty to do so, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal or regulatory obligation, such as pursuant to court orders, enforcement action from regulators or law enforcement; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of us, our affiliates, you, other third parties, users of our products and services or the general public.
2.10 We may share your Personal Information in connection with sales or business transactions. Where we have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
2.11 We share your Personal Information to enforce our terms and conditions or any other contracts we have with you and to allow us to pursue available remedies or limit the damages that we may sustain in any action, such as pursuant to court orders and engaging debt collection agencies.
2.12 We entrust the cloud service provider with the storage of your Personal Information.
2.13 We do not sell your Personal Information, as "sale" is defined by California law.
3.WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST?
Please bear in mind that if you choose not to provide information requested by us, or if you withdraw your consent or object to our use of your Personal Information where we have made it clear that this information is necessary, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.
4.DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
No, we do not carry out automated decision making.
5.DO WE TRANSFER YOUR PERSONAL INFORMATION?
Please note that as a result of the global nature of our operations, your Personal Information you provide to us while interacting with us may be stored and processed in any country where we have facilities. Currently, we have our Internet Data Centers(“IDCs”) in the Singapore and Hong Kong. By using our products and services, you understand that your personal information may be transferred to these IDCs for the purposes described in this Privacy Policy and in accordance with applicable laws.
However, Personal Information that is explicitly stated in this Privacy Policy to be processed locally will not be transmitted and stored in these IDCs.
We may also transfer your Personal Information to third party service providers and business partners, so your Personal Information may be transferred to other countries or regions. The jurisdictions of these countries or regions may not provide the same standards of Personal Information protection as the jurisdiction where you are located, and there may be different risks under different data protection laws. In such cases, we will take measures to ensure that the data we collect is processed in accordance with this policy and applicable laws. These measures include the following:
If Personal Information of data subjects located in the European Union is transferred to a country or region without an equivalent level of data protection recognized by the EU, we will use various legal mechanisms, such as signing standard contractual clauses approved by the European Commission or seeking your consent for the cross-border transfer of personal data, or implementing data anonymization and other security measures before the cross-border data transfer. You can obtain a copy of the EU standard contractual clauses at here.
Please see the 【13. Country Specific Schedules】 of this Privacy Policy for information on how we protect your Personal Information when it is transferred from your country of residence to a location outside your country of residence.
6.HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.
The criteria we use to determine our retention periods include:
6.1 whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);
6.2 whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations); and
6.3 any guidelines issued by relevant legal and data protection authorities.
7.SECURITY
We have in place security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
8.SENSITIVE PERSONAL INFORMATION
We ask that you not send us, and you not disclose to us, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation or sex life, political opinions, religion or philosophical beliefs, health related information, criminal background or trade union membership) on or through our products and services or otherwise unless we expressly request this information.
When you bind and utilize the fitness and health functionalities of the ring via this application, we will gather your health-related data to facilitate the presentation of your health index and to offer assessment and analysis services. Prior to collecting such health data, we will secure your explicit consent in accordance with the “Ring Sensitive Personal Information Processing Rules”. Additionally, we ensure that the health data you provide will be stored in an encrypted format to maintain its security and confidentiality.
Please see the 【13. Country Specific Schedules】 of this Privacy Policy for Sensitive Personal Information specific to your country of residence.
9.YOUR PRIVACY RIGHTS
If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict, erasure or delete Personal Information), you may contact us at: 【dpo@xrglobal.xjmz.com】. We will respond to your request consistent with applicable law.
In your request, please make clear what actions you are requesting we carry out with regards to your Personal Information and the specific information that your request concerns, so that we can action your request more readily. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.
Please see the 【13. Country Specific Schedules】 of this Privacy Policy for information on specific data protection rights provided by your country of residence.
10.CHILDREN
Our products and services are not directed at children under the age of 18. We do not knowingly collect Personal Information from the children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at 【dpo@xrglobal.xjmz.com】. We will investigate any notification and if appropriate, delete the Personal Information from our systems.
Please see the 【13. Country Specific Schedules】 of this Privacy Policy for information regarding children’s Personal Information specific to your country of residence.
11.UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions on our products and services from time to time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our products and services.
12.CONTACTING US
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us by email at 【dpo@xrglobal.xjmz.com】.
We are located at the following address: B1345, Chuanggu Start-up Area, Taizihu Cultural and Digital Creative Industry Park, No.18 Shenlong Road, Wuhan Economic & Technological Development Zone, Hubei Province, PRC.
Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.
13.CONFLICT
In the event any inconsistency between the English version of this Privacy Policy and the official language translation version in your jurisdiction, the English version shall prevail.
14.COUNTRY SPECIFIC SCHEDULES
14.1 MALAYSIA
Scope and Applicability of this Schedule
In addition to our Privacy Policy, this Schedule describes our practices in Malaysia in connection with Personal Information that we collect from you in person and through your use of our products and services, including Glasses, mobile apps and websites. The Privacy Policy shall be construed as part and integral part of this Schedule, and the Privacy Policy and this Schedule shall be binding on you as user of our products and services, including Glasses, mobile apps and websites in Malaysia.
Personal Information and Sensitive Personal Information
For the purposes of Malaysia,
(a) “Personal Information” as referred in the Privacy Policy shall refer to and be construed as “personal data” as defined under the Personal Data Protection Act 2010 and refers to any type of data and information that identifies or relates directly or indirectly to you personally such as your name, contact details, payment details, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly, other personal data you submitted to us from time to time and all other personal data we again collect from you on any subsequent occasion.
(b) "Sensitive Personal Information" means any personal data consisting of information as to your physical or mental health or condition, your political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission by you of any offence or any other personal data of similar nature.
The above terms shall be construed accordingly in our Privacy Policy.
How We Use Your Personal Information
In Malaysia, we receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our Glasses, mobile apps and websites.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either
· to provide a requested service or carry out a contract with you;
· to take steps at your request with a view to entering into a contract;
· where we have a legal obligation;
· where you have given us your consent, whether explicitly or by your conduct of your sharing the Personal Information with us;
· where it is necessary for our legitimate interest;
· to protect your vital interests;
· for the administration of justice; or
· for the exercise of any functions conferred on any person by or under any law.
By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you:
· consent to us collecting, using, disclosing and/or processing your Personal Information for the Purposes as described in this Privacy Policy;
· consent to us collecting personal data about you from sources other than yourself and using, disclosing and/or processing the same, for one or more of the Purposes as described in this Privacy Policy;
· consent to us disclosing your Personal Information to third party as described in this Privacy Policy;
· consent to us transferring your Personal Information out of jurisdiction to third party as described in this Privacy Policy;
· represent and warrant that you have read and understood the terms and conditions of this Privacy Policy, and you agree, accept and consent to the terms and conditions of this Privacy Policy.
Please bear in mind that if you choose not to provide information requested by us, or if you object to our use of your Personal Information where we have made it clear that this information is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.
Your obligations
(a) It is solely your responsibility and obligation to ensure that the Personal Information you submitted or supplied to us is accurate, complete, not misleading. You are also responsible for updating your Personal Information as and when it becomes incorrect or out of date.
(b) In the event you may need to provide us with Personal Information relating to third parties or other persons (for example about your spouse or children), you confirm that you have (i) obtained their consent or otherwise entitled to provide their Personal Information to us and for us to process according to the Privacy Policy, and (ii) warrant that they have read our Privacy Policy and this Schedule and acknowledge and agree to the terms and conditions set out herein.
(c) Our products and services are not directed to children under the age of 18. We do not knowingly collect Personal Information from the children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at 【dpo@xrglobal.xjmz.com】. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you submit or disclose Personal Information of children under the age of 18 or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Information in accordance with the Privacy Policy .
Transfer Of Your Personal Information To Places Outside Malaysia
(a) We may transfer your Personal Information to places outside Malaysia (including Singapore) including if the transfer is to our facilities that are located outside Malaysia or if any of our service providers or strategic partners who are involved in providing part of our and/or service or data storage or data processing services for and on behalf of us is located outside Malaysia or has servers and/or related equipment outside Malaysia or if you use the products and/or services from a country other than Malaysia. You consent to us transferring your Personal Information to places outside Malaysia in these instances. We may also transfer your Personal Information to places outside Malaysia where permitted by law.
(b) By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree to the terms and conditions set out in this Privacy Policy and you consent to us to us collecting, using, disclosing and/or processing your Personal Information, and you hereby give us your consent to transfer your Personal Information to a place outside Malaysia, including Singapore.
Sensitive Personal Information
(a) We ask that you not send us, and you not disclose to us, any Sensitive Personal Information, and information related to sexual orientation or sex life, on or through our products and services or otherwise unless we expressly request this information.
(b) If you submit or share your Sensitive Personal Information to us (directly or indirectly), you give us your explicit consent to us processing the sensitive Personal Information.
Your Privacy Rights
(a) If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict, erasure or delete Personal Information), you may contact us at: 【dpo@xrglobal.xjmz.com】. We will respond to your request consistent with applicable law.
(b) In your request, please make clear what actions you are requesting we carry out with regards to your Personal Information and the specific information that your request concerns, so that we can action your request more readily. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.
(c) We may charge a reasonable fee for access. We will allow you to access to your Personal Information provided that you have made payment for the fee for access. This right of access is further subject to the legal restriction. We reserve our right to refuse to grant you the access in certain circumstances such as when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or if the access will compromise the Personal Information of others.
Updates To This Privacy Policy
We may change, amend, modify or update this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you or otherwise post updated versions on our products and services from time to time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our products and services. By you submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree that you have accepted and consented to the terms of this Privacy Policy including the amended, modified or updated version of this Privacy Policy.
Security
We have in place security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
However, transactions done via personal devices may not be secured and communications over those devices may be exposed to unauthorized third-party interception.
We cannot accept responsibility for any unauthorised access or loss of Personal Information.
While we cannot guarantee that loss, misuse or alteration of Personal Information will not occur, we make reasonable efforts to prevent such unfortunate occurrences.
Conflict
In the event of any inconsistency between the English version and the Bahasa Melayu version of this Privacy Policy and this Schedule, the English version shall prevail over the Bahasa Melayu version.
14.2 SINGAPORE
Scope and Applicability of this Schedule
In addition to our Privacy Policy, this Schedule describes our practices in Singapore in connection with Personal Information that we collect from you in person and through your use of our products and services, including Glasses, mobile apps and websites. The Privacy Policy shall be construed as part and integral part of this Schedule, and the Privacy Policy and this Schedule shall be binding on you as user of our products and services, including Glasses, mobile apps and websites in Singapore.
Personal Information and Sensitive Personal Information
For the purposes of Singapore,
(a) “Personal Information” as referred in the Privacy Policy shall refers to and be construed as “personal data” as defined under the Singapore Personal Data Protection Act 2012（“PDPA”） and refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access, such as your name, contact details, payment details, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly, other personal data you submitted to us from time to time and all other personal data we again collect from you on any subsequent occasion.
(b) "Sensitive Personal Information" means any personal data consisting of information as to individuals' national identity card numbers (e.g. national registration identity card and passport numbers), personal data of a financial nature, insurance information, sensitive medical conditions, and personal information of minors.
The above terms shall be construed accordingly in our Privacy Policy.
How We Use Your Personal Information
In Singapore, we receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our Glasses, mobile apps and websites.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either
· to provide a requested service or carry out a contract with you;
· to take steps at your request with a view to entering into a contract;
· where we have a legal obligation;
· where you have given us your consent, whether explicitly or by your conduct of your sharing the Personal Information with us;
· where it is necessary for our legitimate interest;
· to protect your vital interests;
· for the administration of justice; or
· for the exercise of any functions conferred on any person by or under any law.
By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you:
· consent to us collecting, using, disclosing and/or processing your Personal Information for the Purposes as described in this Privacy Policy;
· consent to us collecting personal data about you from sources other than yourself and using, disclosing and/or processing the same, for one or more of the Purposes as described in this Privacy Policy;
· consent to us disclosing your Personal Information to third party as described in this Privacy Policy;
· consent to us transferring your Personal Information out of jurisdiction to third party as described in this Privacy Policy;
· represent and warrant that you have read and understood the terms and conditions of this Privacy Policy, and you agree, accept and consent to the terms and conditions of this Privacy Policy.
Please bear in mind that if you choose not to provide information requested by us, or if you object to our use of your Personal Information where we have made it clear that this information is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.
Your obligations
(a) It is solely your responsibility and obligation to ensure that the Personal Information you submitted or supplied to us is accurate, complete, not misleading. You are also responsible for updating your Personal Information as and when it becomes incorrect or out of date.
(b) In the event you may need to provide us with Personal Information relating to third parties or other persons (for example about your spouse or children), you confirm that you have (i) obtained their consent or otherwise entitled to provide their Personal Information to us and for us to process according to the Privacy Policy, and (ii) warrant that they have read our Privacy Policy and this Schedule and acknowledge and agree to the terms and conditions set out herein.
(c) Our products and services are not directed to children under the age of 18. We do not knowingly collect Personal Information from the children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at 【dpo@xrglobal.xjmz.com】. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you submit or disclose Personal Information of children under the age of 18 or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Information in accordance with the Privacy Policy .
Sensitive Personal Information
(a) We ask that you not send us, and you not disclose to us, any Sensitive Personal Information, and information related to sexual orientation or sex life, on or through our products and services or otherwise unless we expressly request this information.
(b) If you submit or share your Sensitive Personal Information to us (directly or indirectly), you give us your explicit consent to us processing the sensitive Personal Information.
Your Privacy Rights
(a) If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict, erasure or delete Personal Information), you may contact us at: 【dpo@xrglobal.xjmz.com】. We will respond to your request consistent with applicable law.
(b) In your request, please make clear what actions you are requesting we carry out with regards to your Personal Information and the specific information that your request concerns, so that we can action your request more readily. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.
(c) You may withdraw your consent to our use and disclosure of data with reasonable notice. We will stop using your personal data as soon as possible after withdrawing your consent, and doing so may result in some features being unavailable to you.
(d) We may charge a reasonable fee for access. We will allow you to access to your Personal Information provided that you have made payment for the fee for access. This right of access is further subject to the legal restriction. We reserve our right to refuse to grant you the access in certain circumstances such as when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or if the access will compromise the Personal Information of others.
Marketing
We do not sell or rent your personal information to third parties for marketing purposes without your express consent. If you do not wish to receive marketing communications from us or participate in our customized advertising programs, you can set your preferences in the settings we provide you or by contacting us.
Updates To This Privacy Policy
We may change, amend, modify or update this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you or otherwise post updated versions on our products and services from time to time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our products and services. By you submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree that you have accepted and consented to the terms of this Privacy Policy including the amended, modified or updated version of this Privacy Policy.
Security
We have in place security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
However, transactions done via personal devices may not be secured and communications over those devices may be exposed to unauthorized third-party interception.
We cannot accept responsibility for any unauthorised access or loss of Personal Information.
While we cannot guarantee that loss, misuse or alteration of Personal Information will not occur, we make reasonable efforts to prevent such unfortunate occurrences.
14.3 THAILAND
SENSITIVE PERSONAL INFORMATION
We ask that you not send us, and you not disclose to us, any sensitive Personal Information (e.g., information related to racial or ethnic origin, sexual orientation or sex life, political opinions, religion or philosophical beliefs, health related information, genetic information, disability information, criminal background or trade union information) on or through our products and services or otherwise unless we expressly request this information. If we need to collect, use, or disclose your sensitive Personal Information, we will obtain your explicit consent or do so in compliance with applicable laws.
YOUR PRIVACY RIGHTS
Subject to the legal requirements under the Personal Data Protection Act B.E. 2562 and other applicable laws in relation to data protection, you have the following rights in relation to Personal Information:
· Right to access: You have the right to access or request a copy of the Personal Information we collect, use, or disclose about you.
· Right to data portability: You have the right to obtain Personal Information we hold about you, in a structured, electronic format, and to send or transfer such information to another party.
· Right to rectification: You have the right to have incomplete, inaccurate, misleading, or not up-to-date Personal Information that we collect, use, or disclose about you rectified.
· Right to objection: You have the right to object to certain collection, use or disclosure of your Personal Information in certain circumstances.
· Right to restriction: You have the right to restrict the use of your Personal Information in certain circumstances.
· Right to erasure: You have the right to request that we delete or anonymize your Personal Information that we collect, use or disclose about you.
· Right to withdraw consent: You can withdraw your consent at any time where we collect, use, and disclose your Personal Information based on your consent.
· Lodge a complaint: You have the right to lodge a complaint to the competent authority under the applicable data protection law.
If you would like to exercise your rights in relation to your Personal Information above, you may contact us at: 【dpo@xrglobal.xjmz.com】
Please refer to section 9 for further details on how to exercise your rights under the applicable laws.
Transfer Of Your Personal Information To Places Outside Thailand
(a) We may transfer your Personal Information to places outside Thailand (including Singapore) including if the transfer is to our facilities that are located outside Thailand or if any of our service providers or strategic partners who are involved in providing part of our and/or service or data storage or data processing services for and on behalf of us is located outside Thailand or has servers and/or related equipment outside Thailand or if you use the products and/or services from a country other than Thailand. You consent to us transferring your Personal Information to places outside Thailand in these instances. We may also transfer your Personal Information to places outside Thailand where permitted by law.
(b) By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree to the terms and conditions set out in this Privacy Policy and you consent to us to us collecting, using, disclosing and/or processing your Personal Information, and you hereby give us your consent to transfer your Personal Information to a place outside Thailand, including Singapore.
CHILDREN
Our products and services are not directed at children under the age of 20. We do not knowingly collect Personal Information from children under the age of 20. If you have reason to believe that a child under the age of 20 has provided Personal Information to us through our products and services, please email us at 【dpo@xrglobal.xjmz.com】. We will investigate any notification and if appropriate, delete the Personal Information from our systems.
CONFLICT
In the event of any inconsistency between the English version and the Thai version of this Privacy Policy and this Schedule, the English version shall prevail over the Thai version.
14.4 INDONESIA
SENSITIVE PERSONAL INFORMATION
We ask that you not send us, and you not disclose to us, any special Personal data (e.g., information related to biometric data, genetic data, crime records, child data, personal financial data, health data) on or through our products and services or otherwise unless we expressly request this information. If we need to collect, use, or disclose your sensitive Personal Information, we will obtain your explicit consent or do so in compliance with applicable laws.
How We Use Your Personal Information
In Indonesia, we receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our Glasses, mobile apps and websites.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either
· to provide a requested service or carry out a contract with you;
· where we have a legal obligation;
· where you have given us your explicit consent;
· where it is necessary for our legitimate interest;
· to protect someone's vital interests; or
· to protect public interests.
YOUR PRIVACY RIGHTS
Subject to the legal requirements under the Law No. 27 of 2022 on Personal Data Protection, you have the following rights in relation to Personal Information:
a. right to information;
b. right to access (means to obtain access, track record of processing, and copy of personal data);
c. right to correction (means to complete, update and/or correct errors and/or inaccuracies of personal data);
d. right to erase, destroy, ad/or terminate processing of personal data;
e. right to withdraw consent;
f. right to object to automated decision-making processes;
g. right to restrict personal data processing;
h. right to data portability (means to obtain and use their personal data in a form that is in accordance with the commonly used structure or format readable by an electronic system. Subsequently, they also have the right to request controllers to send their personal data to other controllers as long as the electronic systems are compatible).
If you would like to exercise your rights in relation to your Personal Information above, you may contact us at: 【dpo@xrglobal.xjmz.com】
Transfer Of Your Personal Information To Places Outside Indonesia
(a) We may transfer your Personal Information to places outside Indonesia (including Singapore) including if the transfer is to our facilities that are located outside Indonesia or if any of our service providers or strategic partners who are involved in providing part of our and/or service or data storage or data processing services for and on behalf of us is located outside Indonesia or has servers and/or related equipment outside Indonesia or if you use the products and/or services from a country other than Indonesia. You consent to us transferring your Personal Information to places outside Indonesia in these instances. We may also transfer your Personal Information to places outside Indonesia where permitted by law.
(b) By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree to the terms and conditions set out in this Privacy Policy and you consent to us to us collecting, using, disclosing and/or processing your Personal Information, and you hereby give us your consent to transfer your Personal Information to a place outside Indonesia, including Singapore.
CHILDREN
Our products and services are not directed at children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at 【dpo@xrglobal.xjmz.com】. We will investigate any notification and if appropriate, delete the Personal Information from our systems.
CONFLICT
In the event of any inconsistency between the English version and the Indonesian version of this Privacy Policy and this Schedule, the English version shall prevail over the Indonesian version.
14.5 United Kingdom and European Economic Area
Scope and Applicability of this Schedule
In addition to our Privacy Policy, this Schedule describes our practices in the United Kingdom (“UK”) and the European Economic Area (“EEA”) in connection with Personal Information that we collect from you in person and through your use of our products and services, including Glasses, mobile apps and websites. The Privacy Policy shall be construed as part and integral part of this Schedule.
Transfers outside of the UK and EEA
Where UK and/or EU data protection laws apply, we only transfer your personal information to another entity in a country outside the UK or EEA (as applicable):
(a) if UK data protection laws apply, where the UK government has decided the particular country ensures an adequate level of protection of personal information (known as an “Adequacy Regulation”) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here; and/or
(b) if EU data protection laws apply, where the European Commission has decided that the particular country ensures an adequate level of protection of personal information (known as an “Adequacy Decision”) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here; and/or
(c) if EU data protection laws apply, where your Personal Information is transferred to a country or region without an equivalent level of data protection recognized by the EU, we will use various legal mechanisms, such as signing standard contractual clauses approved by the European Commission or seeking your consent for the cross-border transfer of personal data, or implementing data anonymization and other security measures before the cross-border data transfer. You can obtain a copy of the EU standard contractual clauses at here; and/or
(d) if UK data protection laws apply, where your Personal Information is transferred to a country or region without an equivalent level of data protection recognized by the UK, we will use various legal mechanisms, such as signing standard contractual clauses approved by the UK or seeking your consent for the cross-border transfer of personal data, or implementing data anonymization and other security measures before the cross-border data transfer. You can obtain a copy of the UK standard contractual clauses at here; and/or
(e) where a specific exception applies under relevant data protection laws.
What Are Your UK And EEA Privacy Rights?
You have the following rights where UK or EU data protection laws apply (subject to certain conditions and limitations):
a) Access - the right to be provided with a copy of your personal information
b) Rectification - the right to require us to correct any mistakes in your personal information
c) Erasure - (also known as the right to be forgotten) - the right to require us to delete your personal information in certain situations
d) Restriction of processing - the right to require us to restrict processing of your personal information in certain circumstances, e.g. if you contest the accuracy of the data
e) Data portability - the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
f) To object – (i) at any time to your personal information being processed for direct marketing (including profiling); and (ii) in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
g) The right to withdraw consent - if you have provided us with a consent to use your personal information you have a right to withdraw that consent easily at any time. Withdrawing consent will not affect the lawfulness of our use of your personal information in reliance on that consent before it was withdrawn.
For more information on each of those rights, including the circumstances in which they apply, or if you would like to exercise any of these rights please see the “Contacting Us” section above.
We may need to request specific personal information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not shared with any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
Depending on whether UK and/or EU data protection laws apply you may have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues, and/or to the data protection supervisory authority in your jurisdiction.
We would, however, always appreciate the chance to deal with your concerns directly you approach a supervisory authority by contacting us on dpo@xrglobal.xjmz.com.
Contact details for the ICO are available here.
For a list of EEA data protection supervisory authorities and their contact details see here.