Privacy Agreement

Effective date: May 15th, 2020

Shanghai Kieslect Technology Co., Ltd. (hereinafter referred to as [Kieslect] or [we]) is committed to protecting your privacy in compliance with applicable laws on information protection and privacy. This privacy policy describes the information collected and processed by us when you use Kieslect products and services. If you have any question on this privacy policy, please contact us at the email address listed below.

1. Information collected

2. Usage of information collected

3. Sharing your information

4. Third-party service providers

5. Protection measures

6. Data transmission

7. Data retention

8. Your rights

9. Privacy of minors/children

10. Privacy in California

11. Managing your personal information under GDPR

12. Update of privacy policy

13. Contact us

1. Information collected
When you use our products and services, we may collect the following information.

Account information: you need to provide such information as your country or region, email address, password, date of birth, gender, height, and weight to create an account on the APP. You can also provide other informationon your discretion, such as nickname, weight goal, step goal, and profile picture.

Sports & health-related information: steps, distance, speed, exercise duration, calories, sleep duration, heart rate, blood pressure, blood oxygen saturation, walking time, medium to high-intensity exercise, type of exercise, details of each exercise type, medal awards (virtual medals are issued to recognize your achievements), etc.

Location information: certain location-based services, such as outdoor sports mode, weather, and positioning service, depend on GPS positioning information. If you disable the access to GPS function on your phone, location information will not be collected.

Equipment and APP information: certain information will be collected when you use the equipment and APP, including but not limited to user configuration, device MAC address, device version number, serial number, firmware version, language, APP version, mobile phone OS version, device configuration, IP address, network type, and device identification.

Service information: certain features of Kieslect devices and APP may access your personal information. For example, to use the female menstrual cycle reminder, you must provide information like menstrual cycle and ovulation period; to use the call reminder, the device may access your call status and contact list, but your call records will not be saved on this device; when you use the notification function, the device may access the notification status of third-party applications, and this device will temporarily store the notification content; if you use the music control function, the device may read playback settings and status, such information will not be saved; if you enable alarm clock, the device may access the clock information on your phone.

Feedback information: If you have any question or suggestion, please give feedback through “My>Question and Suggestion”, where you can provide your contact information on your discretion. Your feedback helps us better understand the problem you are experiencing. During the feedback process, if you agree, we may access your phone’s camera, and photo album, etc.

Log information: we collect some usage data, such as the log on creating or logging in to your account, account and device pairing, number of device restarts, network usage, errors, crashes, restarts and upgrades of the system. The latest 7-day log is automatically stored locally on your phone, and the earlier log information is be automatically deleted. We do not collect your log information unless you choose to upload the log to our server through “My>Question and Suggestion”.

Visitor information: visitor function, which is applicable when you are not registered or logged in, allows you to experience some limited services on our products. The visitor’s personal data (nickname, gender, height, weight, date of birth, sports health data, etc.) is only stored on your phone.

Payment information: If you purchase products and/or services (such as dial market) in the Kieslect app, you may need to provide your bank account information. Information on bank and transaction are collected and processed by third-party payment service providers, and we may collect summary on the transaction, such as order information, but we will not collect or store your bank account information.

Other information: We may also collect other types of information, which are not directly or indirectly related to individuals, but aggregated, anonymous or de-identified.

2. Usage of information collected
We use the collected information for the following purposes:

Provide, process, maintain, improve and develop our products and/or services, including after-sales, customer support and services on your device;

Send you service notifications when necessary, and reply to you when you contact us;

Store and maintain your information according to our service content or legal obligations;

Use of non-personal data

We will collect some log information that does not involve personal data, such as the error code of device hardware, the error code and log of device restart, the log of the Bluetooth connection, and the device and application usage of as an anonymous user (if you join in), and analyze such log to fix errors, monitor usage and optimize our services.

3. Sharing your information
Without your consent, we will not provide your personal information to any third party for processing for any purpose. We will seek your explicit consent to share any personal or sensitive data. We do not disclose or transfer your personal information to any unaffiliated third party, unless:

1. It is upon your request. For example, you may authorize sharing your personal information, such as the step counting, distance, height, weight, heart rate, calories and other exercise data, to third-party devices or platforms. Please read the privacy policies of such third-party devices or platforms, because your activities thereon will not be subject to this privacy policy;

2. It is required to implement our policies or contracts;

3. It is required by the law;

4. We need to share your personal information sometimes:

(a) With service providers, to monitor and analyze use of services, for example, to process payment on a third-party platform after you visit our services.

(b) With business partners, to provide you with certain products and services.

4. Third-party service providers
We may rely on a third party to realize Kieslect services and you can choose whether to use third-party services. When you agree to use third-party services, the third party may collect your information. We strongly recommend you to read the third-party’s privacy policy. We are not responsible for how such third party uses your personal information as we cannot control such usage. Service providers can only access your personal data to implement Kieslect services on our behalf, and are obliged not to disclose or use it for any other purposes:

With Google Fit , you agree to Google Fit’s Terms of Service and Privacy Policy :

With Apple Health, you agree to Apple’s Terms of Service and Privacy Policy :

1. Map service provider

You can obtain track information on your outdoor movement from Google, and Apple. When you use map service, your position information will be collected and provided to the service provider. For specific data collection and processing, please refer to the privacy policy of the map service provider. You can turn off GPS on your phone to terminate the collection of position information.

Amap Maps , Amap Positioning : Need to call your location permissions , will collect your device information , network status , location information , Wi-Fi information , so as to provide you with maps and location services when you are outdoors ; privacy policy :
Google Map : Need to retrieve your location permission , will collect your device information , network status , location information ; provide you with location records when you are outdoors ; privacy policy :

2. Weather push service provider

If your device supports weather push function, your location information will be shared with the weather service provider (IBM) to receive weather information. You can turn off the weather push function in “Device>More>Weather Push”. After your personal information is anonymized, it will not be used to identify or locate you.

3. Cloud storage service provider

The cloud storage service is provided by Amazon (Amazon Web Services EMEA SARL or Amazon Web Services, Inc.). When you choose to store your data on the cloud, your personal data are uploaded to Amazon’s servers. Please refer to Amazon’s privacy policy for specific data storage conditions.

4. Alexavoice service provider

Alexavoice service is provided by Amazon (Amazon Web Services EMEA SARL or Amazon Web Services, Inc.). When you choose to store your data on the cloud, your personal data are uploaded to Amazon’s servers. Please refer to Amazon’s privacy policy for specific data storage conditions.

5. Payment service provider

We may provide paid products and/or services within the Kieslect app, which involves third-party service providers for payment processing. We will not store or collect your payment details. Your payment information is directly provided to the third-party payment service provider, and their use of your personal information is subject to their privacy policy.

5.Protection measures
We are committed to ensuring the security of your personal information. We will take all practical steps, including encryption, identity verification tools, and secure servers, to protect your personal information. In order to prevent unauthorized access, disclosure or other similar risks, we will take reasonable administrative, technical and physical protection measures and make all reasonable efforts to protect your personal information. However, you should be aware that we cannot 100% guarantee the security or confidentiality of the information you provide to us.

6. Data transmission
At present, Kieslect uses servers at various locations provided by Amazon. Generally, the data of local residents is only stored on servers within the local jurisdictions and will not be transferred across borders. With your consent, we may transfer your data across borders in accordance with applicable laws. Meanwhile, we will take appropriate protective measures to ensure that such all transmissions comply with local data protection laws. You have the right to be informed of the protective measures Kieslect takes to transfer your personal information.

7. Data retention
If you use our products and services, we may collect and store your information, which may be stored as long as you keep your account. However, once you cancel or request to cancel your account, we will delete or anonymize your information as soon as possible, no later than 90 days from the date of your request.

8. Your rights
Kieslect promises to respect the confidentiality of your personal information and guarantee that you can exercise your rights. According to this privacy policy and relevant laws and regulations, you have the right to:

1. Request access to your personal information. You can directly access your personal information in “My>Personal Data”. If you fail to access your data, please contact us via the contact information provided below. Upon your request, we will provide free copies of your personal information collected and processed by us. If your raise other requirements for such information, we may charge reasonable fees based on applicable laws and actual costs.

2. Request correction of your personal information. You have the right to ask us to correct any incomplete or inaccurate information we hold. Meanwhile, you can directly correct your personal information in “My>Personal Data”.

3. Object to processing of your personal information. You have the right to terminate the use and disclosure of your personal information. If you have given consent to the processing of your personal or sensitive information by the Kieslect device and application, you can withdraw such consent at any time. You can also contact Kieslect for further processing. In order to provide you with our services, you need to provide personal information required by such services. If you do not provide such information, we may not be able to provide you with our products or services.

4. Request deletion of your personal information. You have the right to request us to delete your personal information. In addition, you can delete or permanently anonymize the corresponding data by canceling your account, clearing personal data on the cloud, etc.

5. Request transmission of your personal information. Where technology permits, we will provide you or a third party chosen by you with your personal information in a structured, commonly machine-readable format. Please note that this right only applies to the information that you initially authorized us to use or that we collected to enforce the contract.

6. Withdraw your consent. You have the right to withdraw your consent on using your personal information. If you withdraw your consent, we may not be able to provide you with access to certain features of services. However, your withdraw of consent or authorization will not affect the previous personal information processing. You can withdraw your authorization or change your authorization scope of collecting your personal information by deleting the device in the application, disconnecting the device and the application, restoring factory settings, clearing online personal data, turning off data synchronization, or canceling your account.

9. Privacy of minors/children
Our products and services do not target or collect personal information of children under the age of 16 (under the age of 13 in some jurisdictions). Kieslect does not and will not receive any personal information from minors. If we learn that we have collected any personal information from children under the age of 16 (under the age of 13 in certain jurisdictions), we will immediately delete such information and terminate minors’ accounts, regardless of whether we have obtained the permission of their parents.

Article 22581 of “California Business and Professions Code” allows California residents under the age of 18 (registered users of online websites, services or applications) to request for and obtain the deletion of content or information made public by them. To request deletion of such data, if you are a California resident, you can contact us via the contact information provided below and provide us with the email address associated with your account. Please note that your request cannot guarantee the complete deletion of online content or information you made public, and in some cases the laws may not allow the deletion.

10. Privacy in California
Californian laws allow users who are residents of California to request and obtain a list of third parties to whom we disclosed their personal information (if any) for direct marketing purposes in the previous year and the categories of such personal information disclosed. Kieslect will not share your personal information with any third parties for marketing purposes.

11. Managing your personal information under GDPR
If you are an EU user under the jurisdiction of GDPR, you can contact us to manage your personal information.

In addition, according to GDPR, you have the right to make a complaint to the regulatory authority.

12. Update of privacy policy
We will review our privacy policy on a regular basis and may update this privacy policy to reflect our changes to information practices. By using the product or service after our updated privacy policy is published, you will be deemed to accept the updated privacy policy. If you do not agree to any part of the privacy policy, you should immediately stop using our products and services.

13. Contact us
If you have any comment or question related to this privacy policy or to the collection, use or disclosure of your personal information by Kieslect, please feel free to contact us at:

Shanghai Kieslect Technology Co., Ltd.


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