Last updated and effected: January 12, 2023
2. What data we collect
3. How we use your data
4. Legal basis for processing data
5. Policy for children
6. How data is shared and disclosed
7. How we store and transfer data
8. How we safeguard your data
9. Data retention
10. What are your rights
11. Policy for European users
12. Policy for California users
15. Dual language
16. Cookies policy
17. SDK partners
18. Who we are and how to contact us
Guangdong Jiu Zhi Technology Co.Ltd, a company established under the laws of People’s Republic of China or JIUZHI-affiliated Company (collectively “RingConn”, “we” or “us”) “RingConn”) knows the importance of privacy and personal data to our customers.
If you do not agree with the terms contained herein, please do not use our Services.
2. WHAT DATA WE COLLECT
When you use our Services, we collect the following types of data.
2.1 DEVICE DATA
Your RingConn device collects measurement data to estimate a variety of metrics: PPG sensors data, accelerometer data and your skin temperature data. We use the measurement data to calculate and generate data like heart rate, heart rate variability, respiratory rate, calories burned, sleep phases, step count, stress levels and activity intensities throughout the day.
When your device synchronizaes with our App or software, data recorded on your device are transferred from your device to our servers.
2.2 USAGE DATA
When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, install our App or software, when you view or search content, create or log into your account, pair your device to your account, or interact with our Services with third-party accounts (such as Apple ID ).
also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, RingConn or mobile device information (including device and application identifiers), location (depending on the permissions you have granted us), and cookies.
2.3 LOCATION DATA
If you access or use any of our location-based services, such as by enabling GPS-based activity tracking through your App, we may process the approximate or precise location of your device while the service is active. This data may be obtained via your device’s service provider network ID, GPS, and/or Wi-Fi data.
We do not process such location data without first obtaining your consent. You may disable such location processing at any time via using your mobile device’s location permission settings. We may also derive your approximate location from your IP address.
2.4 DATA YOU PROVIDE
To create an account on our Services, you may provide us with data that includes: your user name, year and month of birth, gender (female, male or you choose not to disclose), height, weight, email address, mobile telephone number, password and country information. This is the data you have to provide to create an account with us. You may also choose to provide other types of information, such as a profile photo. If you contact us or participate in a survey, contest, or promotion, we collect the data you submit such as your name, contact information, and message.
2.5 DATA FROM THIRD PARTIES
When you choose to access to our Services via a WeChat, QQ (including Tim), Google, Facebook or Apple account, we collect its account name and profile photo.
3. HOW WE USE YOUR DATA
We use the data we collect for the following purposes.
3.1 To provide and maintain our services
We process personal data to provide our Services. For example, to provide you with daily insights about your heart rate variability, sleep, and activity.
3.2 To improve and develop our products and services
We process data regarding your use of the RingConn device and App to improve our services and develop new features. When possible, we will do this using only pseudonymized, aggregated, or non-personally identifiable data.
3.3 To provide customer service
We process personal data for the purpose of providing customer service and managing our customer communication. If you contact our customer support with questions regarding your app data, we may use the provided data to answer your questions and for solving any issues you may have.
3.4 To comply with statutory obligations
In certain cases, we must process certain data when it is required by applicable laws and regulations. Such statutory obligations are related, for example, to accounting and tax requirements, legal claims, or other legal purposes.
4. LEGAL BASIS FOR PROCESSING DATA
Our lawful basis for processing your data depends on the particular processing purposes, including:
When processing personal data for the purpose of providing Services we process it on the basis of a user contract, which is formed when you create your account and accept of our terms and conditions.
We process your health-related data only with your consent. Please note that some of the personal data we process, including any data concerning your health, is considered special or sensitive personal data. Under applicable law, such data is processed only if you have given your consent for processing.
4.3 Legitimate Interest
We process your personal data based on our legitimate interests when we process it for the purposes of marketing our products and services, providing our customer service and improving our products and services. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.
4.4 Legal obligation
We must process certain information to comply with statutory obligations which may vary in each country.
5. OUR POLICY FOR CHILDREN
Persons under the age of 18, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create RingConn accounts. If we learn that we have collected the personal data of a child under the relevant minimum age, we will take steps to delete the data as soon as possible. Parents who believe that their child has submitted personal data to us and would like to have it deleted may contact us (see “How To Contact Us” below).
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 FOR EXTERNAL PROCESSING
We share your personal data with certain trusted partners, including our affiliates, service providers, and other partners, so that we can provide you with our services and operate our business. 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.
6.2 WHEN YOU AGREE OR DIRECT US TO SHARE
You may direct us to disclose your information to others, for example, when you give a third-party application such as Apple Health or Google Fit permission to access to your data, and we may share your data with this third-party based on your requirements. Remember that their use of your data will be governed by their privacy policies and terms. Please carefully read their latest policies and terms. You can revoke your consent to share with third-party applications via using your account settings. We also reserve the right to disclose personal data when we have your express consent to do so.
RingConn use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy , including the Limited Use requirements.
RingConn will use:
to write health data to Google Fit, including sleep, activity, body, blood oxygen, heart rate and other information, so that users can view the data generated by the ring through Google Fit, and synchronize the health data with Google Fit.
to write health data to Google Fit, including sleep, activity, body, blood oxygen, heart rate and other information, so that users can view the data generated by the ring through Google Fit, and synchronize the health data with Google Fit.
6.3 FOR LEGAL REASONS
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.
If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal data and give affected users notice before transferring any personal data to a new entity.
7. HOW WE STORE AND TRANSFER DATA
We process and back up personal data through a global operating and control infrastructure. Currently, we use cloud services deployed in United Kingdom for processing personal data of users from the United States, United Kingdom and EEA.
We rely on multiple legal basis to lawfully transfer personal data around the world. These include your consent and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us. We are subject to the oversight of the US Federal Trade Commission and remains responsible for personal data that we transfer to others who process it on our behalf as described in “HOW DATA IS SHARED AND DISCLOSED” section.
In cases where personal data is processed outside of the jurisdiction in which it was collected, we always ensure your personal data is protected with appropriate safeguards in accordance with applicable privacy and data protection laws. Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a RingConn account and click “I agree” to data transfers.
If you have a complaint about our international data transfer, please contact us by means described in “HOW TO CONTACT US” section. You may make a complaint to the competent regulatory authority in your jurisdiction.
8. HOW WE SAFEGUARD YOUR DATA
We use technical and organizational safeguards to keep your data safe and secure. Where appropriate, these safeguards include measures such as anonymization or pseudonymization of personal data, strict access control, and the use of encryption to protect the data we process. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers. However, no method of transmitting or storing data is completely secure. If you have a security-related concern, please contact us by means described in “HOW TO CONTACT US” section.
We also ensure that our staff receives adequate training to ensure personal data is processed only in accordance with our internal policies, consistent with our obligations under applicable law. We also limit access to your sensitive personal data to personnel that have specifically been granted such access.
We regularly test our service, systems, and other assets for possible security vulnerabilities. We also update the RingConn App and the RingConn device firmware regularly. We recommend that you make sure that you always have the latest App and firmware versions installed in order to maximize protection of your data.
9. DATA RETENTION
The retention period for your personal data generally depends on the duration of your RingConn account lifecycle. Your personal data will be deleted when it is no longer needed for the purpose it was originally collected, unless we have a legal obligation to retain data for a longer period of time. For example, your measurement data regarding your sleep, stress and activity is stored only so long as your RingConn account is active.
We also have legal obligations to retain certain personal data for a specific period of time, such as for tax purposes. These required retention periods may include, for example, accounting and tax requirements, legal claims, or for any other legal purposes. Please note that obligatory retention periods for personal data vary based on the relevant laws.
If you wish, you may request deletion of your RingConn account by contacting [email protected].
10. WHAT ARE YOUR RIGHTS
10.1 YOUR RIGHTS UNDER APPLICABLE LAWS
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.
(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.
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.
10.2 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 “How To Contact Us” 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 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.
11. POLICY FOR EUROPEAN USERS
11.1 YOUR DATA CONTROLLER
Guangdong Jiu Zhi Technology Co.Ltd, a company established under the laws of People’s Republic of China, is your data controller and provides the Services if you live in the EEA, UK or Switzerland. For our contact information, please see the How To Contact Us section.
11.2 HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that data we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. 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.
11.3 HOW TO EXERCISE YOUR LEGAL RIGHTS
Please review the “WHAT ARE YOUR RIGHTS” section for how you may exercise your rights under GDPR.
Under the GDPR, you have a general right to object to the use of your data for direct marketing purposes. Please see your “Reminder Settings” under “Me” in App to control our marketing communications to you about our Services.
12. POLICY FOR CALIFORNIA USERS
12.1 HOW WE COLLECT, USE AND SHARE YOUR INFORMATION
Where a customer interacts with our Services, we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, defined as “Personal Information” under CCPA.
Information about the categories of personal information we collect, the purposes for which your personal Information is processed, and any sharing of your personal information can be found from relevant sections of this privacy statement above.
We never sell (in the manner defined by CCPA) the personal information of our users.
12.2 CALIFORNIA CONSUMER RIGHTS
If you are a California resident, you have certain rights under the CCPA:
(1)Right to know about the personal information we collect and share
The CCPA gives you the right to request that we disclose the personal information we have collected about you over the past 12 months, which we do after we receive and validate your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:
a.The categories of personal information we have collected about you;
b.The categories of personal information we have disclosed about you (if any);
c.The categories of sources for the personal information we have collected about you;
d.Our business or commercial purposes for collecting or selling that personal information;
e.The categories of third parties with whom we share that personal information; and
f.The specific pieces of personal information we have collected about you.
(2)Right of deletion
You have the right to request erasure of your personal information, subject to certain exceptions, such as where we have a legal obligation to retain the data in question. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information unless an exception applies.
(3)How to exercise your privacy rights under CCPA
If you are a California resident, you can request disclosure, access to, and/or deletion of your personal as described above by submitting a verifiable consumer request to us by either:
Sending an e-mail to [email protected], including the following information along with your request: your full name, company name (if applicable), address, e-mail address and a phone number. We may request that you provide additional information if necessary to confirm your identity. This is for security purposes and is required by law in some cases.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You have the right to make a free request up to two times in any 12-month period. We will respond to all validated requests within 45 days since receiving your request, unless we request an extension. In the event that we reasonably require an extension in order to respond to your request, we will notify you of any such extension within the initial 45-day period.
We do not discriminate against users who request exercise their privacy rights under the CCPA. Unless an exception applies, this includes our promise not to:
a.Deny you goods or services;
b.Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
c.Provide you a different level or quality of goods or services; or
d.Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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 ).
15. DUAL LANGUAGE
16. COOKIES POLICY
16.1 What are Cookies and Other Technologies we use?
At times, the Site may use “cookies” or other technologies (such as browser cookies, flash cookies, and web beacons).
Cookies. Cookies are small pieces of text file that can be stored on and accessed from your device when you visit our Online Services, to the extent you agree. They help that website remember information about your visit, which can both make it easier to visit the site again and make the site more useful to you. Some or all of the cookies or other technologies described below may be stored in your browser, app, or device.
Other Technologies. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Site. To see how our Site is performing we sometimes use conversion beacons, tags, scripts and pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We also use these tracking technologies to analyze usage patterns of our Services. The use of these technologies allows us to record that a particular device, browser, or application has visited a particular web page. The information provided below about cookies also applies to these other tracking technologies.
16.2 What are First and Third Party Cookies?
Whether a cookie is first or third party depends on where it comes from.
16.3 What are the purposes for using Cookies?
a.to make the Site and our Services function properly;
b.reporting, which allows us to measure and analyze the performance of our Services;
c.to conducting research and diagnostics to improve our content, products, and services；
d.to make login to the Site and application easier (such as by remembering your user ID);
e.to recognize you when you return to the Site and our Services and to remember information you have already provided and your preference of using our Site and Services;
f.to track your interaction with the Site and our Services;
g.to improve your security during your use of the Site and our Services;
h.to contact you to offer online or offline customer service using information voluntarily provided by you;
i.to ensure the Site and our Services compliant with local laws and regulations (if any).
Data generated during your interaction with the Site, which may include inter alia: personal data about you that you voluntarily choose to provide us with, and information automatically collected about your interactions with the Site.
Voluntarily provided information by you may include and not limited to : email address or other contact information, the account registered, the role information selected when registering for an account, information submitted by users when using the search tool in the Site and other voluntarily submitted information.
Automatically collected information may include and not limited to: IP address, browser type, browser language, domain name, data on actions taken to enter and exit the page, browsing behavior, length of stay and what content was clicked on, the order in which the content was clicked on, which videos were played, view count, and associated performance data, request times for the site, response speed data.
16.4 How to manage Cookies in your browsers?
We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Please note that if you delete, or choose not to accept cookies dropped by us or from all sources, you may not be able to utilize certain features of the Site to their full potential.
You can use the browser with which you are viewing this Site to enable, disable or delete cookies. If you do not want cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject all or some cookies.To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings).
If you want to remove previously-stored cookies, you can manually delete the cookies at any time through your browser settings. However, this will not prevent the Platform from placing further cookies on your device unless and until you adjust your internet browser setting as described above.
17. SDK PARTNERS
We may use or work with Mobile SDKs to collect information, such as Mobile IDs, and information related to how mobile devices and their users interact with our App. The SDK is computer code that app developers can include in their apps to enable data to be collected, and related services to be implemented.
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18. WHO WE ARE AND HOW TO CONTACT US
If you have questions about this policy, or need help exercising your privacy rights, please contact our Data Protection Officer at [email protected]
You may contact us at:
Guangdong Jiu Zhi Technology Co.Ltd
Adress: Room 411-18, Floor 4, Building C, Innovation Center Plant, No. 34, XiangShan Avenue, Cuiheng New District, Zhongshan City.
Customer Support Email Address： [email protected]
Telephone:+86 760 88586096