RingConn APP Privacy Policy

Last updated and effected: April [8th], 2026 

This Policy shall take effect from April 8, 2026. If you continue to use our Services after this Policy is updated, you shall be deemed to have fully read, understood, and agreed to the revised Policy.

You can view this Privacy Policy in RingConn Health App and/or on the bottom of our website.

This Privacy Policy covers:

1. Introduction

2. What data we collect

3. How we use your data

4. For Users in the People's Republic of China (Mainland China)

5. Our policy for children

6. How data is shared and disclosed

7. How we store and transfer data

8. Data Retention and Security

9. What are your rights

10. Update to this privacy policy

11. Contact Information

1.INTRODUCTION

Shenzhen Ninenovo Technology Limited, and its affiliates (collectively “RingConn”, “we” or “us”)  “RingConn” knows how important privacy and personal data are to our customers.

This Privacy Policy is meant to help you understand what data we collect, why we collect it, how we process, store and protect it and how you can update, manage, export, and delete your data. Please take a moment to carefully review this policy.

This Privacy Policy applies to personal data collected and processed by us through our “Services” which includes: our RingConn devices (“Devices”) , Application (“App”) , websites, software, APIs, emails, newsletters and our services. If a separate privacy policy or user service agreement exists for a specific product or service, the privacy policy or user service agreement for that product or service will prevail. If the privacy policy or user service agreement for the product or service is not covered by such product or service, this Policy shall prevail. If one of our affiliated companies uses the products or services provided by us in their products or services but does not set up a separate privacy policy, this Policy shall also apply to such products or services. Unless otherwise agreed, the terms used in this Policy shall have the same meaning as those defined in the RingConn Terms of Use.

Blood Pressure Trends Feature (Beta) Special Notice: This feature is provided in Beta form and involves processing your sensitive personal information (including blood pressure-related data). Before using this feature, you must give explicit consent through a separate page. This feature and all assessment results are not intended for disease diagnosis, treatment, or medical advice. If you feel unwell, please consult a professional medical institution in a timely manner.

Please note that the Policy does not apply to information collected through other means, such as offline channels or any other website operated by the company or any third parties. Additionally, any third-party application or content (including advertisements) that may link to or be accessible from this website is not covered by this Policy. This policy is not intended to override the terms of any contact you have with us, not any rights you may have under other applicable data privacy laws. Please take a moment to familiarize yourself with our privacy protection practices. If you have any questions or concerns, please contact us at data_protect@ringconn.com.

2. WHAT DATA WE COLLECT

When you use our Services, we collect the following types of data.

2.1 Information We Collect From You

Account and Profile Information: When creating an account, you provide us with your username, date of birth (month and year), gender (female, male, or prefer not to disclose), height, weight, email address, mobile number, password, and country/region. You may also choose to add a profile photo.

Health and Wellness Features:

Menstrual Cycle Tracking: If you activate this feature, and with your consent, we collect information such as your menstrual cycle timeline, period length, flow level, symptoms, alcohol or medication intake, and related sensor data from your RingConn device.

Sleep Apnea Monitoring (OSAHS): If enabled, and with your consent, we collect data such as height, weight, BMI, sex, age, neck circumference, medical history, sleep quality, and OSA-related symptoms.

Blood Pressure Trends Feature (Beta) : If you are invited to participate in the Blood Pressure Trends Beta and choose to use this feature, we will, through a separate page, explain to you the types of sensitive personal information processed, the purposes of processing, and possible impacts. After obtaining your separate consent, we will collect the following additional information:

The information you provide when using the Blood Pressure Trends feature may contain sensitive personal information (including personal health information and biometric information). Any leakage or unauthorized use of such information may adversely affect your personal safety, property security, or personal dignity. We have implemented strict encryption and security measures to protect such information.

Questionnaire Information: Including your gender, date of birth, height, weight, blood pressure status (normal, a little high, a little low, or not sure), use of antihypertensive medication in the past 30 days (never, occasionally, regularly, or not sure), family medical history, and specific diagnoses (like stroke, coronary heart disease, heart failure, atrial fibrillation, sleep apnea, high cholesterol, diabetes, etc.).

Manually Entered Values: Systolic and diastolic blood pressure values measured by you using an upper-arm blood pressure monitor and manually entered.

Activity Information: Activity tags related to blood pressure that you select or customize before each calibration or assessment (such as eating, alcohol, emotional stress, etc.).

Automated Decision-Making Explanation: The Blood Pressure Trends feature uses machine learning algorithms to analyze your PPG signals and other physiological data, automatically generating a qualitative assessment of your blood pressure status (e.g., “Good”, “Worth Noting”, “Improvable”) and other factors data. This assessment constitutes automated decision-making. You have the right to request an explanation of the assessment logic and the right to refuse decisions based solely on this automated decision-making that have significant legal or similarly significant effects on you.

Important Note: Because the core service of this feature (blood pressure status assessment) relies entirely on algorithm-generated results, if you refuse automated decision-making, you will not be able to obtain the assessment results, meaning you cannot use this feature. This is not a limitation on your right to object, but an objective description of the technical characteristics of this feature. You may stop using this feature at any time, and we will immediately cease further processing based on your data.

Other Wellness Features: You may choose to enter additional wellness-related information, such as daily stress levels, mood, or notes related to your health.

User Communication: When you contact us, participate in feedback, surveys, contests, or promotions, we collect the information you submit, such as your name, contact information, and message content.

2.2 Information Automatically Generated and Collected

As part of our core service offering, your RingConn device and mobile App automatically generate and collect a wide range of wellness and device-related data, including:

RingConn Device Data:

The RingConn smart ring uses built-in sensors (such as PPG(a light-based sensor), accelerometers, temperature sensors, and SpO₂ sensors) to collect raw measurement data.

These measurements are used to estimate and generate a wide range of biometric and activity data, including:

Sleep tracking data: sleep stages, duration, quality, and related vital signs (e.g., heart rate, respiratory rate, skin temperature, blood oxygen levels during sleep).

Heart rate and HRV(the variation in time between heartbeats): real-time heart rate, heart rate variability, and trends over time.

Blood oxygen (SpO₂): levels of blood oxygen, especially during sleep.

Respiratory rate: breathing rate during sleep or rest periods.

Stress and recovery metrics: data related to stress detection and stress management recommendations.

Daily activity tracking: step count, active minutes, calories burned, activity intensity, and sedentary behavior.

Vital signs monitoring: including skin temperature trends and fluctuations.

Periodic Wellness Reports: Based on the collected metrics, the App may generate personalized weekly, monthly, or annual wellness reports which summarize your sleep, activity, readiness, and overall health trends.

Blood Pressure Trends Related Data:

Circulation Stress Data: When you use the Blood Pressure Trends feature for calibration or assessment, the ring will collect data through the PPG sensor, and after analysis by the algorithm model, generate the “Circulation Stress” indicator used to describe blood pressure status and related qualitative assessment results (such as Good, Worth Noting, Improvable).

Other Factors Data: To comprehensively assess your blood pressure status, the system will calculate and generate related factor data such as “Day-Night Rhythm,” “Sleep Breathing,” “Post-Exercise Recovery,” and “Stress Response” based on PPG data and accelerometer data collected by the ring.

App Data:

Device and System Information: Device identifiers, synchronized RingConn device data, mobile OS version, system language, browser type, and IP address.

App Usage and Activity Logs: Interactions with app features, navigation behavior, search history, and user-generated content.

Performance Data: Diagnostic logs, crash reports, performance statistics, and feature usage analytics.

Location Data:

If you enable Bluetooth and location access, we may collect approximate or precise location data to ensure proper Bluetooth connectivity, find-your-device features, and data synchronization. This data may be gathered via GPS, Wi-Fi, or network provider data, and only with your consent.

We do not collect or use precise location data without your explicit permission, which can be revoked at any time in your device settings.

We may also derive approximate location based on your IP address for regional service optimization.

Third-Party SDK Data:

To ensure stable App operation and enhance service quality, we may integrate SDKs from trusted third parties or deploy SDKs ourselves when necessary. These SDKs may collect necessary technical information such as device identifiers, app crash logs, and performance data for crash analysis, performance monitoring, and issue diagnosis. We strictly manage SDK data collection practices, and additional consent will be obtained for the collection of sensitive personal information. Special Note: To improve App stability, we use a privately deployed (self-hosted) error monitoring solution based on the open-source Sentry code. All data processing for this solution takes place on our own servers within the territory of the People’s Republic of China and does not involve any cross-border data transfers. All sensitive health data for the Blood Pressure Trends feature is processed on RingConn’s own servers and is not shared with any third-party SDKs. We use Sentry and similar tools only to collect technical information about app crashes (e.g., error codes, stack traces), which does not include any health data or information that could be used to infer health status. For specific information about each SDK (including its name, provider, collection purpose, data types, privacy policy links, etc.), please refer to our separately provided List of Third-Party SDKs. RingConn does not authorize or encourage any third party to collect unnecessary or sensitive personal information unrelated to providing the service.

2.3 App Auto-Start Description

To ensure the continuity of core services and data integrity, this app may perform auto-start behavior under specific scenarios after obtaining your explicit consent. We hereby clearly inform you of the relevant scenarios, purposes, and necessity:

Bluetooth Data Transmission: Your RingConn device continuously syncs health data (such as sleep, heart rate, blood oxygen, etc.) with the app via Bluetooth. When the app moves to the background or is temporarily cleared by the system, the system may trigger the app to auto-start in order to restore background connections and services, ensuring uninterrupted data transmission.

Widget Data Refresh: If you have added RingConn health-related widgets to your phone‘s home screen, the system may trigger the app to auto-start to update widget data and maintain real-time display.

Necessity Explanation: The above behaviors are essential technical measures to achieve continuous device monitoring, data synchronization, and core widget functionality. If auto-start is not permitted, it may result in incomplete data records, failure of real-time alerts, or inability to update widgets normally.

Your Control Rights: You have the right to deny the app auto-start permission at any time through your operating system’s auto-start management settings. Please note that this may affect the normal use of the aforementioned features. If you do not want the app to transmit data in the background, you can achieve this by completely terminating the app process. If you do not want auto-start triggered by widgets, you can remove the RingConn health widgets from your home screen. We only initiate related behaviors when necessary for the above functions and after obtaining your explicit consent. You can manage auto-start permissions in your device settings. Your consent or refusal will not affect your use of other basic functions of the app.

2.4 Information From Third Parties

We may collect information from third-party sources when you choose to integrate or log in using third-party accounts or platforms:

Social Media and Login Providers:

If you sign in or link your account via WeChat, QQ (including TIM) or Apple, we receive data such as your account display name and profile photo from those services.

Health Platforms and Integrations (if supported):

You may choose to sync your RingConn data with third-party health platforms (e.g., Apple Health), in which case, we may receive or share certain health metrics according to your permissions and settings in those platforms.

3. HOW WE USE YOUR DATA

We use the personal data we collect for the following purposes.

3.1 To Provide and Maintain Our Services

We process your personal data to deliver and operate our Services effectively. For example, we use your health-related metrics to generate daily insights regarding your heart rate variability, sleep, and activity levels.

For the Blood Pressure Trends feature, we use the questionnaire information you provide, manually entered blood pressure values, and PPG data and accelerometer data collected by the ring, to analyze through the algorithm model and provide you with a qualitative assessment of blood pressure status and other factors analysis.

Subject to the notification permissions you grant, certain features may be activated automatically to enhance your experience—such as reminders and functional alerts—to ensure you receive important and timely updates related to the Application.

3.2 To Improve and Develop Our Products and Services

We use personal data, (including via third-party software development kits (SDKs), Please refer to the SDK PARTNERS) to improve product performance, enhance usability, and develop new features. This may include SDKs for crash diagnostics, push notifications, third-party logins, mapping, and location-based services.

We may process data such as device specifications, app logs, location data (e.g., IP-derived or GPS-based), unique application identifiers, and Android ID using the Sensors Data SDK. Where feasible, such processing will involve pseudonymized, aggregated, or otherwise non-identifiable information to protect your privacy.

We also process firmware update-related technical data to enhance device stability, ensure compatibility across software versions, and proactively address performance or security vulnerabilities.

If you grant access to your location data and enable mapping or navigation features within the App, we may use third-party mapping SDKs to provide the requested services. These SDKs may collect additional information, including your precise location, device type, hardware parameters, and system information.

Special Notice for Blood Pressure Trends (Beta) : This feature is provided in Beta form, mainly for verifying algorithm technical feasibility. Therefore, the data you provide or generate during use of this feature (including but not limited to questionnaire information, activity tags, manually entered blood pressure values, PPG data collected by the ring, and its analysis results) will be used for algorithm optimization, feature iteration, and product improvement. This processing activity is based on our legitimate interests in developing and improving products, as well as your explicit consent. We will not use this information for advertising or other commercial purposes.

Algorithm Training Data Usage Restriction : The above data will only be used for training and optimizing RingConn‘s own algorithm models. It will not be used to develop other products related to your health, nor will it be provided to any third party for their algorithm training or product development.

We analyze app crash information and performance data through our self-built application monitoring system (based on privately deployed open-source solutions) to quickly locate and fix issues, improving your user experience. Related data processing takes place on servers within the territory of the People's Republic of China in compliance with laws and regulations, ensuring the security of your data.

3.3 To Provide Customer Support

We process personal data to deliver customer service and manage communications with you. For instance, if you contact our support team with questions about your device or app data, we will use the information you provide to address your inquiry and help resolve any issues.

3.4 Customer Service Support

We use your account and product information for the following purposes:

Quickly identifying your identity to provide personalized services;

Verifying product ownership and warranty status;

Diagnosing technical issues and providing solutions;

Analyzing service requests to improve product quality.

3.5 To Comply with Legal Obligations

We may process your personal data as necessary to comply with legal and regulatory requirements, such as those related to accounting, taxation, legal claims, or other statutory obligations.

4. FOR USERS IN THE PRC (MAINLAND CHINA)

In accordance with applicable laws, when the Personal Information Protection Law (PIPL) applies to RingConn, the information and rights specified in this section shall apply to users residing in the People's Republic of China (Mainland China).

When we determine how to use personal information to provide services, we act as a "controller"; conversely, when we process personal information solely based on customer instructions, we act as a "processor", in compliance with the Personal Information Protection Law.

4.1 Legal Basis for Data Processing

The table below provides the ways we plan to use your personal data and which legal bases we rely on. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we rely on to process your personal data where more than one ground has been set out in the table.

Purpose / Activity

Type of Data

Legal Basis for Processing

Account registration and profile creation

Username
Email address
Mobile number
Password
Date of birth (month and year)
Gender
Height and weight
Region/country
Profile photo (optional)

Performance of a contract with you

Device pairing and operation

Bluetooth connection data
Device ID and serial number
Firmware version
Connection logs

Performance of a contract with you

Daily activity tracking

Step count
Calories burned
Activity level and intensity
Movement data (from accelerometer)
Sedentary behavior data

Performance of a contract with you

Sleep monitoring and reports

Sleep stages (light, deep, REM)
Sleep duration and quality
Nighttime heart rate
Blood oxygen during sleep
Respiratory rate during sleep
Skin temperature trends during sleep

Performance of a contract with you

Stress and recovery management

Heart rate variability (HRV)
Stress level trends
Recovery metrics
User-inputted mood/stress levels

Performance of a contract with you

Heart rate and SpO₂ monitoring

Real-time and average heart rate
Heart rate trends
Blood oxygen (SpO₂) levels

Performance of a contract with you

Vital signs monitoring

Skin temperature
Respiratory rate
Resting heart rate
Changes in physiological signals

Performance of a contract with you

Weekly, monthly, and annual wellness reports

Aggregated sleep, activity, and heart rate data
Summary charts
Trend analytics
Personal recommendations

Performance of a contract with you

Menstrual cycle tracking (optional feature)

Menstrual cycle timeline
Period start/end dates
Flow level
Symptoms
Alcohol/medication notes
Body signals from the device (optional)

Consent

Obstructive Sleep Apnea Syndrome (OSAHS) screening (optional feature)

Height, weight, BMI
Age, sex, neck circumference
Medical history
OSAHS symptoms
Sleep reports

Consent

Blood Pressure Trends Feature (Beta)

Questionnaire Information: Blood pressure status, antihypertensive medication usage, family history, diagnosed disease list. Manually entered data: Systolic and diastolic blood pressure. Raw data collected by ring: PPG signals for Circulation Stress analysis, accelerometer data, skin temperature. Derived analysis results: Circulation Stress indicator, qualitative blood pressure status conclusion (Good/Worth Noting/Improvable), Other Factors. Activity information: Activity tags and custom activity content before calibration/assessment.

Consent (Explanation: This feature is an optional Beta feature involving in-depth processing of your health data. We will request your authorization through a separate page before your first use.)

Blood Pressure Trends Optimization and Algorithm Iteration (Beta)

All data used for the Blood Pressure Trends feature, including PPG raw signals collected by the ring, accelerometer data, manually entered blood pressure values, questionnaire information, activity information, and assessment results.

Legitimate interests (product improvement) (Explanation: This feature is provided in Beta form, with the core purpose of verifying algorithm technical feasibility and collecting feedback. To this end, we need to conduct technical analysis and model iteration on relevant data. This processing activity is based on our legitimate interests in developing and improving products. We have assessed and ensured that this processing will not cause undue impact on your rights and freedoms.)

App usage analytics and troubleshooting

Crash logs
Diagnostic logs
Feature interaction data
App navigation patterns

Legitimate interests (to improve services)

Mobile device and system identification

Model
Operating system
Screen size
Unique device identifier
IMEI
MAC address
Browser type
Network provider
Language and time zone
Push code

Performance of a contract with you

Bluetooth and location services (for device connectivity)

Bluetooth signal data
Approximate GPS location (if permitted)
Wi-Fi/Bluetooth SSID info

Consent

SDK-related third-party analytics

Device information
App usage data
Installation list (if collected)
Crash data

Legitimate interests (for app functionality and performance)

Customer support and communication

Name
Email
Message content
App version and device data
Feedback or survey answers

Performance of a contract with you

Login via third-party platforms (e.g., Apple)

Third-party account ID
Display name
Profile photo

Performance of a contract with you

Integration with health platforms (e.g., Apple Health, )

Health metrics shared via APIs (based on user permission)

Consent

App Stability Monitoring (Error Log Collection)

Device identifiers, app crash logs, performance statistics, diagnostic information

Legitimate Interests (Improving Service Quality, Optimizing Product Performance, Enhancing User Experience)

4.2 Your Rights

This section describes your the Personal Information Protection Law (PIPL) rights. Please note that for security reasons, we may verify your identity before processing your request.

Right to access personal information: You have the right to obtain confirmation from us that we process your personal information and, if so, you may have the right to request access to your personal information. You can directly inquire or access your personal data in our product or service interface after logging in to your account. You can also query and access your personal data through RingConn Health App feedback or emailing us at data_protect@ringconn.com.

Right to data portability: You are entitled to obtain a copy of your personal data in structured, commonly used and machine-readable formats to the extent permitted by laws and regulations. For example, if you decide to change to a new service provider, you can move, copy or transfer your personal data between our IT-system and their IT system in a reliable, secure and easy way without affecting its use.

Upon providing formal authorization, you can exercise your right to data portability by contacting us via the feedback feature on RingConn Health App, or by sending an email to data_protect@ringconn.com .

Right to rectification of personal information: You have the right to request that we rectify inaccurate personal information concerning you and, depending on the purposes of the processing, you may have the right to have incomplete personal information completed. You can directly rectify and modify part of your personal data on the related function pages of products or services or contact us at data_protect@ringconn.com

Right to erasure/deletion: You have the right to request us to erase some or all of the personal information concerning you. You can directly erase/delete your submitted information in the product interface under your account. You can also contact us via the feedback feature on our platform or by emailing us at data_protect@ringconn.com .

Blood Pressure Trends Feature Data Deletion Special Notice : Given that the Blood Pressure Trends feature is in Beta, the following deletion rules apply:

Data Type

Deletion Method

Processing Timeframe

Remarks

Questionnaire Information

User may modify or delete at any time in the App

Effective immediately

Old data will be overwritten after modification

Manually Entered Blood Pressure Values

User may delete in the App

Anonymized within 30 days after deletion

After anonymization, no longer associated with your identity

Blood Pressure Assessment Records

User may delete in the App

Anonymized within 30 days after deletion

After anonymization, no longer associated with your identity

PPG Raw Signal Data

Due to technical architecture limitations, physical deletion for individual users is not possible during the Beta period. However, you may apply to stop using the feature, and we will immediately cease further processing of this data and isolate it from storage, no longer using it for new algorithm training. After the Beta period ends, we will irreversibly anonymize retained PPG data to ensure it cannot identify a specific individual.

Anonymization completed within 90 days after the Beta period ends

If you have concerns about this arrangement, we recommend considering whether to use this feature after the Beta period ends.

Right to Stop Use: You may stop using the Blood Pressure Trends feature at any time. After stopping use, we will no longer collect new Blood Pressure Trends related data and will cease further analysis and processing based on existing data (except for anonymization that has already been performed).

Right to restriction of processing: You have the right to request us to restrict the further processing of your personal information. In such cases, the respective information will be marked as restricted. We will store the data and process it for the sole purpose of responding to your request or with your consent in the future. You can submit the request to data_protect@ringconn.com .

Right to object: You have the right to object, on grounds relating to your particular situation, such as legitimate interests, exercise of public authority, direct marketing (including data pooling), and statistical reasons, to the processing of your personal information by us. You can submit the request to data_protect@ringconn.com .

Right to Refuse Automated Decision-MakingFor the automated decision-making used by the Blood Pressure Trends feature (algorithm-generated blood pressure status assessment), you have the right to request an explanation of the assessment logic and the main basis. If you disagree with the assessment results, you may request a review through the in-app feedback function or by contacting customer service. However, please note that because this feature relies entirely on algorithm-generated assessment results, refusing automated decision-making will result in your inability to use this feature. Important Note: The aforementioned “inability to use this feature” is not a limitation on your right to object, but an objective description of the technical characteristics of this feature. You may stop using this feature at any time, and we will immediately cease further processing based on your data.

Right to object to direct marketing: You have the right to object to the processing of personal information for direct marketing purposes. You can submit the request to data_protect@ringconn.com . If you no longer wish to receive our commercial advertisement, you can unsubscribe at any time via the feedback feature on our platform or by emailing us at data_protect@ringconn.com.

Right to withdraw consent: Where we rely on your consent to process your data, you have the right to withdraw consent you have provided to us at any time, and we will stop further processing. You can always provide your consent to us again at a later time. You can submit the request via the feedback feature on our platform or by emailing us at data_protect@ringconn.com.

Blood Pressure Trends Withdrawal of Consent Special Notice: For the Blood Pressure Trends feature, withdrawal of consent means:

You will no longer be able to continue using this feature.

We will stop collecting new Blood Pressure Trends related data.

Existing data will be processed in accordance with the deletion policy above.

Withdrawal does not affect the legality of data processing based on consent before withdrawal.

Application method: Please send an email to data_protect@ringconn.com to request withdrawal of consent.

Right to refuse automated decision-making: Under the Personal Information Protection Law (PIPL), you have the right not to be subject to decisions made by automated processing, including profiling, where the decision has a significant legal impact on you. We do not process your information in this manner. If you have any questions or concerns, please feel free to contact us at data_protect@ringconn.com.

Right to complaint: You have the right to file a complaint with the relevant competent authorities or other regulatory agencies if you are not satisfied with our responses to your requests or how we manage your personal information.

Health and other special categories of personal dataTo the extent that data we collect is health data or another special category of personal data subject to the Personal Information Protection Law (PIPL), we ask for your explicit consent to process the data. For the Blood Pressure Trends feature, we will obtain your separate consent through a separate page before your first use, which is independent of the general consent given during App registration.We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account. You can use your account settings in App and settings in your mobile device to withdraw your consent at any time, including by unpairing your device, or deleting your data or your account.

We encourage you to first or also reach out to us at data_protect@ringconn.com, so we have an opportunity to address your concerns directly. We will respond to your request within 30 days from the date of receiving your request and communicate with you in an appropriate way.

5. OUR POLICY FOR CHILDREN

We define “children” as individuals (i) under the age of 14 residing in the People's Republic of China (Mainland China);or (ii) individuals who qualifies as “children” under the applicable data protection laws of their respective jurisdiction.

Special Note: The Blood Pressure Trends feature is only available to adults aged 18 years or older. Minors under 18 are not permitted to use this feature.

We do not knowingly collect personal information from children. Children may not register for an account on our Platform or send us personal information such as their names, address, phone numbers, email address, etc., unless permitted by local law and their guardians have given their consent. We will only use or publicly disclose personal information collected from children with the consent of their guardians as permitted by law, with the consent of the guardian, or as necessary to protect the child.

If we become aware that we have collected personal information from a child without the consent of the child's guardian, we will delete the data as soon as we are aware of it. If you believe that we may improperly hold personal information from or about a child, please contact us.

6. HOW DATA IS SHARED AND DISCLOSED

We do not sell personal data of our users. We do not share your personal data except in the limited circumstances described below.

6.1 External Processing by Third Parties

We share your personal data with certain trusted partners, including our affiliates, service providers, and technical vendors—for the purposes of delivering our Services, maintaining our platform, and supporting business operations. We require our partners to process your personal data based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. We also require these partners to protect your personal data to at least the same standards that we do.

We use external processing services such as:

(1) storing our users’ data;

(2) providing customer services;

(3) managing and organizing our marketing activities. We only share website usage data with our advertising network partners for the purposes of analyzing and optimizing our marketing. We do not share the health-related data or other sensitive personal data with third party advertisers.

(4) analyzing information regarding the use of our online service to improve our service quality.

Special Note: All data for the Blood Pressure Trends feature is processed on RingConn’s own servers and is not shared with any third party for the original data or analysis results of this feature.

6.2 With Your Consent or at Your Direction

Sharing with Third-Party Applications

We may share your personal data with third parties only with your explicit consent or at your direction. This includes the following scenarios:

When you authorize third-party applications (such as Apple Health) to access your data, we may share relevant health data with them based on your instructions. Please note that the use of your data by these third parties will be governed by their respective privacy policies and terms. We recommend that you review those policies carefully.

You can revoke your consent at any time via your account settings.

Blood Pressure Trends Data Sharing Restriction: Assessment results generated by the Blood Pressure Trends feature (including Circulation Stress indicators, qualitative assessment conclusions, and Other Factors data) will not be synchronized or shared with any third-party health platform (including Apple Health) to ensure the highest level of protection for your sensitive blood pressure information.

Sharing with Friends and Family (Optional Feature)

If you choose to enable the "Shared with Friends and Family" feature in the Application, you consent to the sharing of your personal health data—including your weekly health reports, sleep data, activity data, stress levels, vital signs, and any high heart rate abnormalities—with other registered users of the Application whom you have explicitly invited.

Please note: Assessment results and related data from the Blood Pressure Trends feature are not included in this sharing scope.

These shared data may include measurements and metrics collected by your RingConn device, as well as any information you voluntarily provide while using the Application.

Sharing is facilitated through a one-time-use invitation link, which you control. You may stop sharing your data at any time by removing a user from your sharing list. Once a user is removed, they will no longer have access to any previously shared reports.

By enabling this feature, you consent to the sharing of your data solely for the purpose of enhancing your experience and enabling support from people you trust. If you do not wish to share your data, please do not activate this feature.

Important Notice for Recipients of Shared Data:

If you are invited by another registered user to access their shared health data, including weekly reports, sleep and activity metrics, stress levels, vital signs, or high heart rate abnormalities, you agree not to disclose, forward, copy, download, or share such data with any third parties who are not authorized by the data owner. Any misuse or unauthorized use of shared data may violate privacy laws. RingConn is not liable for any legal consequences arising from inappropriate or unlawful actions taken by recipients of shared data.

Account Synchronization Across Platforms

To provide a seamless and consistent user experience across platforms, we support account interoperability between different platforms, including our application and website. When you create an account or make a purchase on one platform, we may synchronize the account and related information on the other platform to integrate services.

When you create an account on the App, we will also generate a corresponding account on the Website with the same initial password and password rules. Conversely, creating an account on the Website will result in a corresponding account on the App. Password changes on one platform will not be automatically synced to the other.

If you make a subscription purchase using an existing App account and we detect a matching email account on the Website, we will automatically link both accounts so you can view unified purchase records and manage your subscription from either side. If no Website account exists, we will create one and complete the linking automatically.

To support these features, we may process and sync the following data:

 Basic account information (e.g., email, username, user ID).

 Purchase and subscription history.

 Account status and login activity.

Please note that we will not use or share your sensitive data for undisclosed purposes without your explicit permission. You can review and manage your data processing preferences in your privacy settings.

6.3 Data Sharing in Customer Service System

To deliver efficient customer support, we will share necessary account and product information with our customer service platform partners when you initiate a service request. Such sharing strictly adheres to the principle of data minimization and implements appropriate security safeguards.

(1) Types of Data Shared and Purposes

When using customer service, we may share the following data categories with third-party service providers:

Data Type

Sharing Purpose

RingConn ID

User identification & issue tracking

User alias

User identification & issue tracking

Gender

User identification & issue tracking

Age

User identification & issue tracking

Contact email

User identification & issue tracking

Types of Smart Ring

User identification & issue tracking

(2) Sharing Mechanism & Security Measures

Minimization Principle: Only essential data for resolving inquiries is shared; sensitive data such as health information related to the Blood Pressure Trends feature is excluded.

Contractual Obligations: All third-party providers sign data processing agreements specifying their protection responsibilities.

Technical Safeguards: Data transmission is encrypted, stored with pseudonymization, and access is permission-controlled.

Usage Restrictions: Third parties are prohibited from using data beyond agreed purposes.

6.4 Protection of User Rights

You retain the following rights regarding data shared with third-party customer service systems:

Right to Know: Query shared data via data_protect@ringconn.com.

Right to Opt-out: Choose alternative channels (e.g., email) that don’t involve data sharing.

Right to Rectification: Request corrections for inaccurate shared data via service channels or privacy email.

Right to Erasure: Request deletion of temporary shared data post-service (excluding legally mandated retention periods).

6.5 Legal Compliance and Law Enforcement

We reserve the right to disclose personal data to protect our legal rights and property; and to comply with valid legal requirements.

We may preserve or disclose data about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

We may share non-personal data that is aggregated so that it cannot reasonably be used to identify an individual with or without combining additional information. We may disclose such data publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us, or as part of the community benchmarking data we provide to users of our subscription services.

We will not transfer your personal information to any companies, organizations or individuals, except in the following circumstances:

a) Transfer with explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent.

b) In cases involving merger, acquisition, or sale of assets, we will continue to take measures to protect the personal data privacy and give affected users notice before transferring any personal data to a new entity. Where a transfer of personal data is involved, we will require the new entity to continue to be bound by this privacy policy before we requested to seek independent consent from you to collect and process your data.

7. HOW WE STORE AND TRANSFER DATA

As we provide our Products or Services through resources and servers around the world, we process and back up personal data through a global operating and control infrastructure.

(1) If you use our Services, the personal information we collect from and generate in the People's Republic of China will be stored on servers in the People's Republic of China. For the Blood Pressure Trends feature, all relevant data of mainland China users is stored only on servers within the territory of the People‘s Republic of China and does not involve any cross-border transfer.

(2) If you use our Services, the personal Information that we collect and generate outside the People's Republic of China will be stored on servers outside of the People's Republic of China, including in jurisdictions other than the one in which the data was collected, or subject to access from such jurisdictions.

(3) Currently, we use servers deployed within the territory of the People's Republic of China to process the personal data of users in Mainland China, including our self-built privately deployed monitoring system.

(4) Data Storage for Third-Party Customer Service Systems

Data shared with customer service systems will be stored on cloud servers located in Mainland China. Upon service completion, such data will be automatically archived or anonymized.

If it is necessary to provide your personal information outside the territory of the People‘s Republic of China (for example, if you actively request to transfer the data to servers outside the territory), we will conduct a personal information protection impact assessment in accordance with the provisions of the Cyberspace Administration of China, obtain your separate consent as legally required, and, if necessary, complete a security assessment or file standard contracts.

If you have a complaint about our international data transfer, please contact us by means described in “CONTACT INFORMATION” section. You may make a complaint to the competent regulatory authority in your jurisdiction.

8. DATA RETENTION AND SECURITY

8.1 Data Retention

We will only store your personal information for as long as necessary for the purposes described in this Policy and for as long as required by law, regulation and supervision, unless there is a mandatory retention requirement by law. If we terminate the service or operation, we will promptly stop the activities of continuing to collect your personal information, and, unless otherwise required by applicable laws and regulations, delete or anonymize your personal information. Where the immediate deletion is not possible, for example, because your Personal Information has been stored in backup archives, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Special Retention Rules for Blood Pressure Trends Feature :

Data Category

Retention Period

Deletion Method

Remarks

PPG Raw Signals, Accelerometer Data, Skin Temperature

During Beta period

Irreversibly anonymized within 90 days after Beta period ends (using technical means such as signal perturbation and feature extraction followed by deletion of raw waveforms, ensuring that specific individuals cannot be re-identified by any technical means)

Used for algorithm verification; physical deletion for individual users is not possible during the retention period, but you may apply to stop use and isolate storage

Assessment records

Within 30 days after user deletion

Anonymized

You can delete at any time in the App

Manually Entered Blood Pressure Monitor Data

Within 30 days after user deletion

Anonymized

User can delete at any time in the App (except calibration data, which is retained until account closure or feature discontinuation)

Questionnaire information

During account existence or until feature discontinuation

Deleted or anonymized within 30 days after feature discontinuation

User can modify at any time

Algorithm inference results

Deleted simultaneously with raw PPG signals

Deleted or anonymized within 30 days after feature discontinuation

Including Circulation Stress indicator, qualitative assessment

Important Note: If you wish to delete raw PPG signal data collected by the ring in advance, please send an email to data_protect@ringconn.com to request withdrawal of consent for the Blood Pressure Trends feature. We will process within 30 days after identity verification, but this may affect feature usage experience during the Beta period.

8.2 Data Security

We have taken reasonable and practicable security measures, consistent with industry standards, to protect your information from unauthorized access, disclosure, use, modification, damage or loss of personal information. We take the following steps to keep your data secure:

1. Using encryption technology to improve the security of personal information.

2. Use of trusted protection mechanisms to prevent malicious attacks on personal information.

3. Deploy access control mechanisms and make every effort to ensure that only authorized personnel have access to personal information.

4. Conducting security and privacy training courses to enhance employees' awareness of the importance of protecting personal information.

5. Specialized data compliance management systems, processes and organizations are in place to safeguard information. For example, we strictly limit the scope of people who access information, require them to comply with confidentiality obligations, and conduct audits.

Blood Pressure Trends Feature Additional Security Measures : Given that the Blood Pressure Trends feature involves sensitive personal health information, we take the following additional protective measures:

Graded Encryption: PPG raw signals and blood pressure values are stored using encryption, with keys managed separately from the data.

Access Auditing: All access to Blood Pressure Trends data is logged and regularly audited.

Minimized Access: Only algorithm engineers and necessary technical personnel can access raw data in a controlled environment, requiring dual authorization.

Desensitized Display: Blood pressure-related data displayed in the App interface is desensitized to avoid screenshot leakage risks.

Transmission Encryption: Data transmission uses HTTPS (SSL/TLS) protocol encryption throughout.

We will take all reasonably practicable steps to ensure that no unrelated personal information is collected. We will retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy, unless otherwise required by the laws and regulations of your location.

The Internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send us. If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legal rights and interests, we will assume appropriate legal liability. After the unfortunate occurrence of personal information security events, we will strictly follow the requirements of the laws and regulations of your location and inform you in a timely manner of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents and fulfill the obligations stipulated in other laws and regulations in accordance with the requirements of regulatory authorities.

9. YOUR RIGHTS

9.1 Your Rights Under Applicable Laws

You have rights and choices to your data under applicable laws. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Please note that by exercising some of your following rights, for example, by withdrawing your consent to our Privacy Policy, we may not be capable to maintain our Services to you.

You may choose to exercise the following rights about your data:

(1) Right of confirmation and access. You can ask us to confirm whether your data has been processed, or request access to your data and receive a copy of personal data we have collected and stored about you.

(2) Right of rectification. You can update, rectify or change your data in the account settings of App. You can ask us to update, rectify or change your data where that data is not accurate.

(3) Right of erasure. You have right as provided by applicable laws to request us to erase, destroy, or anonymize your personal data. You may request us to cease the supply of personal data to a third party under certain circumstances according to applicable laws. For Blood Pressure Trends feature data, please see the special retention rules in Section 8.1.

(4) Right of portability. You have the right to data portability in circumstances where we rely on contractual necessity and consent as our legal basis. This means that you have the right to receive your data in a structured, commonly used, and machine-readable format and to share it with a third party.

(5) Right to withdraw consent. You can withdraw consent to the processing of personal data based on your consent, unless such withdrawal is restricted by the law or by contract. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made.

a. You can withdraw your consent in the account settings of your App.

b. If you want to unsubscribe from the electronic communications, please see your notification settings under account settings of your App to control our marketing communications to you.

(6) Right to object or restrict processing. You have the right to object to or restrict our processing of your data in certain circumstances, relying on legitimate interest or public interests on the basis of applicable laws. For example, according to applicable laws, you may require us to cease or not to begin processing their personal data for purposes of direct marketing. You may object to decision-making based solely on automated processing related to your profile, under certain circumstances according to applicable laws.

Blood Pressure Trends Feature Rights Exercise Special Channel:

Access/Correction/Deletion: In the App, go to “Blood Pressure Trends” → “More” → “History”.

Stop using the feature / delete all data: Send an email to data_protect@ringconn.com to request export.

In submitting an objection or restriction request, you should explain what specific processing activity you are objecting to or should be restricted, and why the processing should be stopped. We will stop the particular processing if we don’t have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

9.2 How to Exercise Your Rights

You may exercise these rights by logging into your account and using your account settings, or contacting us as specified in the “CONTACT INFORMATION” section in writing or by other means permitted by applicable laws.

We will ensure you can exercise your rights in accordance with the applicable laws. Depending on the applicable laws, there may be situations where we may refuse your requests, for example, when refusing is in pursuant to a court order, or exercising your rights would adversely affect the rights and freedom of others.

When you need to exercise your rights, we may ask you to authenticate your identification, such as through your RingConn Health account.

Normally, you don’t have to pay us when you’re exercising your rights under the applicable laws; however, we reserve the right to charge you a reasonable fee for the processing of any data access, correction request or other scenarios where charge of fee is permitted by applicable laws.

We will respond to your requests within the time limits provided under applicable laws in the country/regions of your residence. For requests related to the Blood Pressure Trends feature, we will complete identity verification and respond within 15 working days of receipt.

If you have any questions regarding this Privacy Policy or about exercising your rights, you may send your request in writing to the email address we provide below in “CONTACT INFORMATION”.

If you are of the opinion that the processing of your personal data by us is not in compliance with this Privacy Policy or applicable laws, you have the right to make a complaint to the competent regulatory authority in your jurisdiction.

10. UPDATE TO THIS PRIVACY POLICY

This Policy may be updated to provide you with better service and as our business evolves. However, we will not reduce your rights under this Policy without your consent. We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services. You can review previous versions of the policy at our website ( https://www.ringconn.com ) .

Blood Pressure Trends Feature Policy Update Special Notice : Since this feature is in Beta, we may need to update relevant terms more frequently according to algorithm iteration and feature improvement needs. Each update will only involve content related to the Blood Pressure Trends feature. If there are significant changes to the purpose, method, or type of personal information collected and used, or the data processing method, we will notify you through RingConn Health App pop-up windows, prominent page prompts, or other appropriate methods, and re-obtain your separate consent.

We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this policy on this page.

For material changes, we will also provide more prominent notice (including, for certain Services, email notification of specific changes to the Privacy Policy).

Material changes within the meaning of this Policy include, but are not limited to:

a. Significant changes to our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used.

b. Significant changes in our ownership structure, organisational structure, etc. Such as changes in ownership caused by business restructuring, bankruptcy and mergers and acquisitions.

c.Changes in the primary recipients of personal information shared, transferred, or publicly disclosed.

d. Significant changes in your right to participate in the handling of personal information and the manner in which it is exercised.

e. Changes in the department responsible for handling personal information security, contact information and complaint channels.

f. When the security impact assessment report of personal information indicates that there is a high risk.

11. CONTACT INFORMATION

If you have questions about this policy, or need help exercising your privacy rights, please contact our Data Protection Officer at

data_protect@ringconn.com

You may contact us at:

Shenzhen Ninenovo Technology Limited

8th Floor, Block B, National Engineering Laboratory Building, Gaoxin South 7th Road, Nanshan District,Shenzhen, Guangdong, China..

Customer Support Email Address

cs@ringconn.com

Working hours: 9:00-12:00, 14:00-18:00 (Beijing time) on working days.

Appendix: Privacy Policy for the Blood Pressure Trends Feature (Beta)

This Appendix is an integral part of the RingConn Health App Privacy Policy and applies to RingConn Health Blood Pressure Trends Feature (Beta). In the event of any conflict between this Appendix and the main Privacy Policy, this Appendix shall prevail.