The privacy policy was updated on May 2nd, 2023.
Xiaowei Health Technology (Shenzhen) Co. (the following text called “Xiaowei Health” or “we/us/our”) takes the protection of user privacy and personal information very seriously. When you use our services, related information may be collected and used. We hope to inform you of our policies and practices for the acquisition, management, and protection of your personal information through this Privacy Policy. If you agree and provide your personal information, that means you agree us to use, manage, and save your personal information for the purposes and in the manner described in the Privacy Policy.
We deeply understand the importance of your personal information, and we will try our best to keep your personal information safe and secure. We are committed to maintaining your trust in Xiaowei Health and protecting your personal information by adhering to the following principles: consistency of authorities and responsibilities, clarity of purpose, choice of consent, minimum necessity, security, subject involvement, transparency, etc. Meanwhile, we are committed to taking appropriate security measures to protect your personal information in accordance with proven industry security standards. When you use our products and/or services or continuing to use after this policy has been updated, we reckon that you have read, understood, and agreed to this policy and its updated version. If you disagree to any items of this policy, you have rights to stop using our products and/or services immediately.
This policy will help you understand the following contents:
1. Which information we will collect
2. How to use this information
3. How to share, transfer, and transparent information
4. How to store and protect your personal information
5. Your authorities
6. Protection of personal information who under 18s
7. Notification and amendments
1. Which information we will collect? (Whatever the information categories)
Personal information: information recorded electronically or by other means that, alone or in combination with other information, can identify a specific natural person or reflect the activities of a specific natural person.
We will collect and use your related information based on following purpose and approach:
n Information you have provided when registered. Including name, gender, password, address, mobile number, email address and date of birth.
n Information from equipment. We may collect the information through software and other methods during you are using our services, this information including equipment information and locations. When you open our website or App and fill in your registration information, we will read information about your computer and mobile device, including but not limited to your operating system, network operator, unique device identifier, etc. When you use location-related services (e.g., for finding a nearby Xiaowei sales store via GPS), we may obtain location via IP address and GPS.
Please note that information that does not identify a specific natural person, such as individual equipment information or service log information, is not your personal information. If we combine non-personal information with other information to identify a specific natural person or use it in conjunction with personal information, such non-personal information will be treated as personal information for the duration of the combined use and will be anonymised and de-identified unless authorised by you or otherwise required by law or regulation. You have the right to choose the types of information that will not be provided, but please double check that may affect the use of services.
You must authorise us to collect and use your personal information in the following circumstances.
Personal information is collected for the purpose of providing products or services to you, we promise that we will comply with the relevant law, regulations, and other regulatory documents. You have the right to decide if you will provide this information or not. But in most circumstances, if you do not provide it, we may not be able to provide you with the appropriate services or solve the problems you have. These functions include:
1) Connectivity for smart wearables
To support smart wearable devices connected to the App, we may collect some information, including the account of Xiaowei Health, the identification information for smart wearable devices, the mobile phone identification information (IMEI number, imsi, Mac address, meid, Android ID, device hardware serial number, SIM card identification, encrypted by hash algorithm), phone model, system version, Bluetooth information for smart wearable devices.
2) Language interaction and recording function
When you use the language interaction or recording function, we need you to authorise us to access your microphone and recording, and we may collect the information about your voice interaction and recorded voice. Your voice information is personally sensitive, and we ask you to be careful in providing it.
3) Location-based Bluetooth audio device connection feature
When using the Bluetooth audio device connection function through the app, we need your authorization to obtain your location permission and collect your location information so that you can quickly and stably connect to the Bluetooth device.
2. How to use this information?
Personal information is collected for the purpose of providing services to you and ensuring that we comply with applicable law. You consent to our processing of personal information for the purposes of this Privacy Policy and to the disclosure of personal information to us and third-party service providers.
1) Your information will be used for the purposes specified in the “what information will be collected” clause.
2) Your information may be used in the following scenarios that are directly or reasonably related to the purposes described in the “what information will be collected”:
a) We may store the collected information on the server based on the user’s personal information statistics.
b) We may send you a message, make a phone call or send an email.
3) Whenever we use your information beyond what is directly or reasonably related to the purposes described in the “what information will be collected” section, or when we want to use the information for purposes other than those described in this policy, or when we want to use information collected for a specific purpose for other purposes, we will obtain your express consent again in the form of an acknowledgement agreement, an acknowledgement act in specific situations, or an update to this privacy agreement.
4) Exceptions with consent. Please read carefully and agree that we will collect and use your personal information without your agreement in the following situation:
a) Related to national security or nation defence security.
b) Related to public security, public health, or vital public interest.
c) Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial, and sentence enforcement.
d) For safeguarding your or other individuals' significant legitimate rights and interests, such as life and property, but where it is difficult to obtain your consent.
e) Personal information that you disclose to the public at your own discretion.
f) Personal information collected from information that is lawfully and publicly disclosed, such as lawful news reports, government information disclosure and other sources.
g) as necessary to enter and perform the relevant agreement or other written document with you.
h) necessary for maintaining the safe and stable operation of the products and/or services provided, such as detecting and dealing with faults in the products and/or services.
i) necessary for legitimate journalistic purposes
j) necessary for an academic research institution to conduct statistical or academic research in the public interest, and where the results of the academic research or description are made available to the public, the personal information contained in the results is de-identified.
k) Other circumstances as provided for by laws and regulations.
3. How to share, transfer, and transparent information
1) Share information
We will not share personal information with any other companies, organizations, and individuals except in the case of Xiaowei Health, but we may share personal information in the following situations:
a) Sharing in statutory situations. We may share your personal information in accordance with laws and regulations, litigation, dispute resolution, or as required by law, administrative, or judicial authorities
b) Sharing with your consent. We will share personal information with others with your consent.
c) Sharing with authorised partners. For the purposes stated in this policy, some of our services will be provided by authorized partners and we may share some of your personal information with our partners to provide a better user service and experience. We will only share your personal information for lawful, legitimate, necessary, and specific purposes, and only as much personal information as is necessary for the authorized partner to provide the service. Currently, our authorised partners include the following types:
i. Authorized partners for advertising and analytics services. We do not share your personal information with partners who provide analytics services unless we have your permission. We may entrust these partners with information related to the effectiveness of the service, but we do not provide your personally identifiable information or we de-identify this information so that it does not identify you personally. Such partners may combine the above information with other data they have lawful access to to carry out the service recommendations we have commissioned.
ii. Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business by providing technical infrastructure services commissioned by us, analysing how our services are used, measuring their effectiveness, or conducting academic research and surveys. We will sign strict confidentiality agreements with our authorised partners and agree to strict data protection measures so that they handle personal information in accordance with the purpose of our engagement, the service description, this privacy policy and any other relevant confidentiality and security measures.
2) Transfer information
We will not transfer your personal information to any other companies, organizations, and individuals, but expect for following satiations:
Ø Obtain your consent
Ø In the event of a merger, acquisition or bankruptcy and liquidation involving the transfer of personal information, we will require the new company or organisation holding your information to continue to be bound by this privacy policy, otherwise we will require such company or organisation to seek your authorised consent again
Ø comply with mandatory legal requirements, court orders or governmental requirements
3) Public disclosure
We will only disclosure your personal information in the following situations:
Ø Obtain your consent
Ø Disclosure based on law: We may disclose your personal information publicly if compelled to do so by law, legal process, litigation or governmental authority
4) Exceptions to prior authorized consent for sharing, transfer, and public disclosure of personal information
Your prior authorised consent is not required for the sharing, transfer, or public disclosure of your personal information in the following situations:
Ø related to national security and defence security
Ø related to public safety, public health and vital public interests
Ø cooperating with investigations by national judicial and administrative authorities, in connection with crime, investigation, prosecution, trial and execution of judgments
Ø for the purpose of safeguarding your or other individuals' vital property interests such as life and property
Ø other circumstances in the defence of the public interest
Ø personal information that you disclose to the community on your own.
Please note that, in accordance with applicable law, where we have taken technical and other necessary measures to process personal information in such a way that the recipient of the data cannot re-identify a specific individual and cannot recover it, the sharing, transfer, or public disclosure of such processed data does not require separate notification to you and your consent.
4. How to store and protect your personal information
1) Store personal information
a) General storage period: Unless otherwise expressly required by law or with your permission, we will only retain your personal information for as long as is necessary for the purposes described in this Privacy Policy. In order to maintain continuity of service and consistency of user experience, personal information will not normally be deleted immediately after completion of a single service
b) Location of storage: Personal information that we collect and generate in the People's Republic of China will be stored in the People's Republic of China
2) How to ensure your personal information safety
a) Data safety: We use appropriate technical measures to protect the security of personal information and we have used standard security measures to protect the personal information you provide against unauthorised access, use, modification, public disclosure, damage, or loss of data. Some of the security measures we use include data anonymisation, data encryption, firewalls, and data access authorisation controls. We take data security very seriously and therefore regularly review and update the security mechanisms used for data protection to provide an effective means of protection against data misuse
b) Your account is protected by security features, so please take care of your account information. However, please understand that the Internet environment is not 100% secure due to technical limitations and the possibility of malicious acts, and that there is no "perfect security" on the information network.
c) In the event of a security incident such as an information leak, we will activate the appropriate emergency plan to prevent the incident from spreading as far as possible and inform you of the incident in a timely manner in the form of push notifications, announcements, etc.
d) If you believe that the security of your data has been compromised, or if you would like more information about the measures we use to protect your data, please contact us using the information in "Contact us" below.
5. Your rights
We protect your rights with respect to your personal information as follows:
1) You have the right to access, correct and delete your personal information.
a) Access to your personal information. If you wish to access or edit your personal information in your account, you can log in your account and visit the settings page for other information generated during your use of our services.
b) Correct your personal information. If you discover an error in the personal information, you have the right to correct it by yourself or ask us to correct it.
c) Delete your personal information. You may make a request to us to delete personal information in the following situations:
i. If our handling of personal information violates laws and regulations
ii. If our handling of personal information is in breach of our agreement with you
When you delete information from our service, we may not delete the corresponding information in our backup system immediately, but will delete it when the backup is updated.
2) Change the range of your authorised consent
You may revoke your authorization for us to collect, use and disclose the personal information we hold about you by submitting a request. However, please understand that we will also be unable to provide the services to which the authorisation relates.
3) Cancellation of account
a) You can request a cancellation of your account. We will not impose unreasonable conditions to prevent you from cancelling your account, but we will advise you whether to indicate your cancellation request in the context of your use of our services if it would affect your legal rights or those of others.
b) Cancellation of your account may affect the use of the relevant services and we would like to remind you that the act of cancelling your account may cause a lot of inconvenience to your subsequent use of our services.
c) If you have decided to cancel your account and meet all the conditions for cancellation, please contact us through contact details. We will not be liable for any adverse impact on you because of your request to cancel your account.
6. Protection of personal information of minors
If you are under 18 years old, please obtain the consent of your parents or guardian before using our services. We recommend that your parents or guardian need to read this Privacy policy carefully. We will only use personal information lawfully collected from minors as permitted by law, with the express consent of the guardian, and as necessary to protect the minor. If we find that we have collected personal information from a minor without obtaining verifiable parental or guardian consent, we will seek to delete the data as soon as possible. If a parent or guardian reckon that a minor has submitted personal information to us without their consent, please contact us to ensure that such personal information is deleted and that the minor unsubscribes from our services.
7. Notification and Amendment
a) The Private Policy will be updated to provide you with a better service. We will not reduce your rights under this policy without your consent. We will issue an updated version on the platform and notified you to the updated by appropriate methods.
b) For vital updates, we will provide a prominent notification (usually by way of a special notification on the page and explain the specific updates to our private policy). Vital updates of this policy include, but are not limited to:
i. Significant changes to our service model. Such as the purposes for processing personal information, the types of processing personal information, and the manner of using personal information.
ii. Significant changes in our ownership structure, organizational structure, etc. Such as those resulting from business restructuring, bankruptcy mergers and acquisitions, etc.
iii. Changes in the primary recipients of personal information sharing, transfer, or public disclosure
iv. Significant changes in your rights to participate in the processing of personal information and how you deal with them
v. Changes to our department responsible for handling personal information security, contact details and complaint methods
vi. When a personal information security impact assessment report indicates a high risk
8. Who we share your information with?
we may disclose your personal information to third parties (as defined below) to provide the products or services you have requested. We may make disclosures to third party service providers and affiliated companies listed below in this section. We will only share your personal information in accordance with your authorisation and your authorisation to us will include sub-processors who process your personal information. You should be aware that in any case described below, when we share your personal information with a third-party service provider, we will contractually set out the practices and obligations of the third party and comply with applicable local data protection laws. The Division will ensure, including by contract, that the third-party service provider complies with the privacy standards applicable to them in the jurisdiction to which you belong.
8.1 Sharing information with our company and third-party service providers
We may disclose your personal information to other affiliates (which are involved in hardware, social media, technology or cloud businesses) or third party service providers (our mailing houses, delivery service providers, telecommunications companies, data centres, data storage facilities, customer service providers, advertising and marketing service providers, agents on our behalf) or to third parties that we deem trustworthy in order to conduct our business operations smoothly and to provide you with the full functionality of our products and services. (Our mailing houses, delivery service providers, telecommunications companies, data centres, data storage facilities, customer service providers, advertising and marketing service providers, agents on our behalf) [affiliates and/or other third parties] (collectively, "Third Party Service Providers") or third parties that we deem trustworthy to disclose your personal information. Such Third-Party Service Providers may process your information on our behalf or for one or more of the purposes described above. When using certain applications on our devices, we may share your IP address with third parties in order to provide you with certain services that you have requested.
8.2 Sharing information with others
We may disclose your personal information without further consent when required by applicable relevant laws.
8.3 Information that does not require consent
1) Our company may share anonymous information in aggregate form with third parties (such as advertisers on the Division's website) for commercial purposes; we may share with them general usage trends of the Division's services, such as the number of customers among specific groups of people who purchase certain products or engage in certain transactions.
2) To avoid query, we will collect, use or disclose your personal information without your consent only to the extent and only in the circumstances expressly permitted by local data protection laws
8.4 Third party providers and their services
Do I have to agree to any third party terms and conditions?
Our privacy policy does not apply to products and services provided by third parties. Depending on the products and services you use, these may include third party products and services involving types of analytics statistics, mapping services, login services, etc. Some of these may be provided as links to third party websites and others may be accessed as SDKs, APIs, etc. When you use these products or services, information may also be collected about you. Therefore, we strongly recommend that you take the time to read that third party's privacy policy, just as you would read ours. We are not responsible for how third parties use the personal information they collect from you and cannot control its use. Our privacy policy does not apply to other websites linked through our services.
In addition, we have integrated the following SDKs, and when you use these particular products, the information collected about you by the SDKs, the purpose of use and the applicable third-party privacy policies are listed below:
Ø WeChat Log in: Access to your network, external storage write access, collection of your network status and provision of account login and information sharing services as specified by you; Private policy address: http://weixin.qq.com/agreement
Ø QQ log in: Access to your network, external storage write access, collection of your network status and provision of account login and information sharing services as specified by you; Private policy address: http://www.qq.com/privacy.htm
Ø Weibo log in: you will accept the Privacy policy from: http://weibo.com/signup/V5/protocol
Ø Our products are integrated with the AUO SDK, which is required to collect your device Mac address, unique device identifier (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) in order to provide statistical analysis services and to provide basic anti-cheating capabilities by calibrating the accuracy of report data through geolocation. By using AUO, you are agreeing to AUO's Terms of Service and Privacy Policy: https://www.umeng.com/page/policy
If you have any comments or queries about this privacy policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us at the following address.
Address: C501, Skyworth building, Hi-Tec south first road, Nanshan district, Shenzhen
Email address: service@xiaowe.cc
Postcode: 518108