To protect user information, maintain user trust and optimize user experience, Kluger Automation GmbH. (hereinafter referred to as "the company") formulates these provisions in accordance with the network security law of Germany, the personal information protection law of Germany and other relevant laws, regulations, and judicial interpretations, and in accordance with the notice on carrying out special rectification of APP infringement on user rights and interests. These Provisions are applicable to quoting or linking equipment, websites or applications related to the company (collectively referred to as "services").
Before using the company's services, users should carefully read these Provisions, especially the exemption and limitation clauses.

In these Provisions, "personal information" refers to all kinds of information recorded electronically or otherwise that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. Any personal information collected by the company shall be approved by the user in advance. Before using the company's services, the user clicks "agree" at the end of the provisions presented at a specific location on the web page, which is deemed to be the user's consent to the company's relevant information collection behaviour in the provisions. In the following links of providing services, the company involves the collection of necessary information of users:

1. Member registration
Mobile phone name is gender, date of birth, ID number, cell phone number, e-mail address, address, head, nickname, password, and other information (such as the province and city, postal code, longitude, latitude, etc.) and the data and data required when the user synchronize with the Kluger company. This information is collected to help you complete the app account registration and protect the security of your app account. Mobile phone numbers are sensitive information, which is collected to meet the network real name system requirements of relevant laws and regulations. If you do not provide such information, you may not use our services.

2. Purchase, delivery and installation, etc
To process an order, you need the user's name, contact information, shipping and billing addresses, and credit card information. In order to meet the personalized needs of users, the company can collect other information such as the number of users' families and food preference with the consent of users. After signing a special agreement with users, the company formulates personalized, ultra convenient and high-tech services for special users. Within the scope permitted by law, the company collects personal sensitive information, such as voiceprint, fingerprint, facial recognition features, health physiological information, location positioning, etc., which is limited to the customer's service needs for purchase, delivery and installation without permission, It is not allowed to use the above information of the customer for other business promotion or profit. The company has the right to interpret what is "user personal information". The company obtains users' personal information and mainly provides personalized services in line with their personal preferences for specific users, so as to improve user satisfaction and optimize user experience. Before collecting such information, a special service agreement shall be signed with the user to specify the information protection matters. The company abides by its commitments and protects users' personal information according to law. Such information should be used with care and in strict accordance with the purpose of collection. In case of any damage caused to users due to misuse of information, the company shall bear corresponding liability for compensation according to law. If the company is unable to provide the services agreed in the agreement or has service defects due to the user's failure or wrong provision of information, the corresponding consequences shall be borne by the user.

3. Information in the equipment where the user undertakes the service
The software and related information in the equipment that users undertake the company's services, such as equipment information, log information, location information, etc., may also be collected. For the avoidance of ambiguity, this provision defines such information: Device information: when users download or use the company's client software, or access the web page to use the company's services, the company will read the user's mobile device related information, including but not limited to hardware model, IMEI number and other unique device identifier, MAC address, IP address, operating system version and the settings of the device used to access the services; Read the use information of Internet of things appliances used by users, including but not limited to equipment model, equipment operation status, equipment use frequency, camera shooting inside the equipment, etc. Log information: when users use the company's services or visit the company's website, the company automatically receives and records the user's browser and computer information, including but not limited to: IP address, browser type, language, access date and time, software and hardware characteristic information, log in web page records and other data; Log information of IOT devices. Location information (only applicable to specific services / functions): when users download or use the company's client software or access web pages and use relevant services, the company may read information related to the user's location, such as GPS signal of the device or relevant information of nearby Wi Fi access points and mobile phone signal transmission towers, country code, city code, mobile network code, cell ID Longitude and latitude information and language settings. Location information can help find and protect the user's equipment after it is lost or stolen; It helps to provide users with the correct version of services and accurate location navigation, and improve the user experience. It is a user selected function. Usage information: when users use the company's services, in order to push personalized services to users, the company obtains relevant measurement data or other usage information according to their personal preferences after obtaining the user's written consent, such as health data measured by body fat scale, skin meter, health housekeeper, skin meter, blood glucose meter, urine detector and other equipment, food material storage information or photos, To push health reminders, delicious tongue tips and other information to users.

4. Third party source information
The company may obtain user information from other users or cooperative institutions, including but not limited to dealers, third-party social network services selected by users, etc.

5. Information collected in other links
The company may also collect relevant information in other links of service provision. For example, questionnaire survey, user experience activities and other links. The collection content and collection method will be explained during collection, and the user's consent will be obtained.

6. User selective information
Collection of nickname, avatar and mobile phone number information:
When you register the app, we will collect your nickname, avatar and mobile phone number. The purpose of collecting this information is to help you complete the app registration and protect the security of your app account. Mobile phone numbers are sensitive information, which is collected to meet the network real name system requirements of relevant laws and regulations. If you do not provide such information, you may not use our services.

Geographic Information permissions
When you use the application to bind your home account, we will obtain the geographic location information permission of the mobile phone after obtaining your independent choice and consent, to provide you with account binding services for smart home and smart devices. information is sensitive. Refusing to provide this information will only prevent you from fully using the services provided by us, but it will not affect your normal use of other services provided by application.

Application permission for mobile phone background geographic location information
When you use the intelligent scene in the app, we will obtain the geographic location information permission of the mobile phone in the background of the mobile phone after obtaining your independent choice and consent. The purpose is to provide you with that when you are about to go home, the smart home can run the intelligent device in advance to give you a better family life experience. This information belongs to sensitive information, refusing to provide this information will only prevent you from fully using the services provided by us, but will not affect your normal use of other services provided by the application.

Camera and microphone application permission
When you use smart cameras and other devices, we will obtain the microphone permission of the mobile phone after obtaining your independent choice and consent. The purpose is to provide you with voice intercom service. Refusing to provide this information will only make you unable to fully use the personalized services provided by us, but it will not affect your normal use of other services provided by the application.

Mobile phone address book permissions
When you invite family members, we will obtain the permission of mobile phone address book (the information obtained includes mobile phone number and name) after you choose and agree. The purpose is to provide you with this service. Refusing to provide this information will only make you unable to fully use the personalized services provided by us, but it will not affect your normal use of other services provided by the application.
Software installation list, wake up applications for other software:
We will obtain the user's software installation list sensitive information behavior description after obtaining your independent choice and consent, which is used to wake up the target application. Refusing to provide this information will only prevent you from fully using the personalized services provided by us, but will not affect your normal use of other services provided by the application. Users can choose not to provide some information (such as location, health data measured by equipment, etc.), but this may affect the ability of users to use some services. The user can individually cancel the connection between each networked device and the Internet through the app, the device itself (applicable to some devices) or restore the factory settings, so as not to provide usage information and log information.

Storage of information
The company shall reasonably arrange the storage location according to the user's choice. Usually stored in Germany. If you want to select a foreign server, cross-border transmission is required. The company will obtain the user's authorization separately and ensure the user's information security in accordance with the laws and regulations of the location of the server.
We or our third-party partners may collect your information through cookies or similar technologies, including your device information, browsing information and click information, and store such information as log information for remembering your identity, analyzing your use of our services and optimizing advertising. You can deny or manage the use of cookies or similar technologies through browser settings. At the same time, we will also use the third-party SDK to realize the above collection and use. If you use the mobile phones of some mobile phone manufacturers (such as Xiaomi, Huawei, vivo, oppo and other brands) to use the app, the push SDK of the above mobile phone manufacturers we access needs to collect the unique identification information of the mobile phone (IMEI / android id), and may collect your mobile phone model, system type, system version Parameters such as device screen size are used to push our product information.

Cookie Technology: when users visit the company's website or use its related services, the company will identify the user's identity through small data files, so as to eliminate the steps of users repeatedly entering login information, or help judge the security of user accounts, so that the company can understand the most popular services and improve services. Cookies are small files that store information on computers, televisions, mobile phones, or other devices. Users can choose to turn off cookies, but some services of the company can only be realized by using "cookies". Modifying or deleting cookies may affect the use of these services. In addition, the company also uses website beacons and pixel tags, mobile analysis software and other similar technologies.

1. Website beacons and pixel Tags
Electronic images of web pages (called "single pixel" GIF files or "web beacons") can help users access some cookies and facilitate companies to collect information about users browsing web pages to push relevant information according to users' preferences. If users do not want such information to be collected, they can unsubscribe at any time.

2. Mobile analysis software
Such software includes Kluger behavior statistics SDK to help the company understand the use information of the company's app in users' mobile phones, including use frequency, use accidents, cumulative times, performance data and the location of program crashes.

The personal information collected can only be used for the following items:

1. Storage of information
Information storage mode and duration
• We will store your information in a secure way, including local storage (such as data caching with APP), database and server log.
• Generally, we will only store your personal information within the time necessary to achieve the purpose of the service or under the conditions specified by laws and regulations.
Region of information storage
• We will store the user's personal information collected in Germany in accordance with laws and regulations.
• At present, we will not transmit or store your personal information across borders. If cross-border transmission or storage is required in the future, we will inform you of the purpose, receiver, security assurance measures and security risks of information leaving the country, and obtain your consent. notice when the product or service stops operation
• When the operation of our products or services stops, we will notify you in the form of push notice, announcement, etc, and delete your personal information or conduct anonymous processing within a reasonable period of time (the so-called "anonymous processing" refers to the process that the subject of personal information cannot be identified and the processed information cannot be restored through the technical processing of personal information), unless otherwise stipulated by laws and regulations.

2. Create a user's KLUGER account, verify the user's identity, and protect the security of his account.

3. Process user orders.

4. It is convenient for users to activate, control and use the equipment
The information used in the login and activation process of some Kluger devices includes MAC address, machine code, typeID, WiFi password, etc. If activation fails, you need to read the relevant equipment information and log information to determine the failure reason.

5. Understand the status of user equipment

6. Easy for users to find equipment
The software "find device" function helps to find and protect the user's device after it is lost or stolen. Users locate the device, clear the device content or lock the device with the location information provided by app or website.

7. Providing location-based services
The company will use location information to provide users with the correct version of services and accurate location to improve the experience.

8. Convenient for users to use third-party functions
A few of the company's services are provided by third-party service providers. Therefore, some information of users’ needs to be shared with Limited third parties.

9. Equipment automation
The event information reported by the user equipment (information from the equipment added by the user) can be used to create their personal automation tasks.

10. Provide push service
The account number and IMEI number shall also be used to provide Kluger push service and send device notifications to users. Users can turn off this function at any time by changing their preferences under "message settings".

11. For automatic equipment decision
In some business scenarios, companies may only make decisions based on non-manual automatic decision-making mechanisms such as information systems and algorithms. The decision is for reference only, and the company does not assume any responsibility arising therefrom.

12. Collect user feedback
In order to track the feedback that users choose to provide, the company may use the personal information provided by users to contact them and keep records.

13. Evaluate and analyze market, customers, products and services
The company collects information from all parties and makes comprehensive analysis to improve services and enhance services.

14. Provide users with community interactive services
If users participate in the company's user community and communicate with other users in the community, their avatar, nickname, and other personal information shall be displayed on the forum page.

15. Send notification
The company may use the user's personal information to send important notices to them, such as equipment exceptions, customized equipment push, shopping logistics information and changes in company regulations.

16. Manage promotions such as lucky draw
If users participate in lottery, competition and other promotion activities, their information will be used to manage such activities. If the user's mobile phone number or nickname is desensitized, it may be written into the public winning list. If the activity is jointly promoted by the company and a third party, some information of the user may be shared with the third party so that it can distribute prizes or provide services to the user.

17. Promote products or services
The company may use the user's name, telephone number, e-mail address, KLUGER account, etc. to promote services to them. In order to improve the user experience, recommend services according to the user's purchase history, website browsing history, birthday, age, gender and geographical location. The user can cancel the push at any time according to the prompt.

18. Provide other company services
The company may provide more diversified services for users by updating website pages, APP versions or device firmware. When the user's information is used for other purposes not specified in the provisions, or the information collected for specific purposes is used for other purposes, the user's consent shall be obtained in the form of confirmation agreement, specific confirmation behavior, updated privacy agreement, etc.

In order to carry out necessary business, the company can prudently share some user specific information with the following cooperative third parties with the consent of users:

1. Affiliated companies of the company
In order to facilitate the company to provide services and recommend information to users based on the unified account system and protect relevant information and property security, some user specific personal information may be shared among the company's affiliated companies. When sharing personal information, a special information protection agreement shall be signed.

2. Authorized partner
The company may share user information with trusted authorized partners, including account information, device information and location information, so as to ensure the smooth provision of services for users. The company is not responsible for the information infringement of partners. The authorized partners of the company include but are not limited to the following types:

(1) Advertising and analysis services;

(2) Supplier, service provider.

The second item includes institutions providing technical services, telecommunications services, customer services, risk control services, audit services, legal services, e-commerce companies, offline stores and other entities. The company shall sign a strict confidentiality agreement with the shared object and ensure that it protects and processes the shared information according to law and regulations. For sensitive data, the third party shall be urged to adopt encryption technology. In case of any breach of contract, effective measures shall be taken to stop it in time until the cooperation is terminated. In addition to the above sharing, the company can also share some user specific information with other third parties with the consent of users.

According to relevant laws, regulations and standards, the company has the right to collect and use user information without its consent under the following circumstances:

1. In order to cooperate with the state power organs in safeguarding national security, protecting public health, litigation and other acts;

2.Information that has been voluntarily disclosed by users, or has been disclosed by news reports, government information disclosure, statistical reports, academic research, etc;

3. Personal information necessary for performing the contract signed with the user;

4. Information necessary for maintaining the safe and stable operation of products or services, such as finding and handling relevant faults;

5. Other circumstances permitted by laws and regulations.

We will store your information in a secure way, including local storage (such as data caching with APP), database and server log.

Generally, we will only store your personal information within the time necessary to achieve the purpose of the service or under the conditions specified by laws and regulations.

In order to maintain the continuity of services and the consistency of user experience, personal information is usually not deleted immediately after the completion of a single service. However, it will not be stored for a long time. The storage periods of various information are as follows:

Save user problems and feedback data for 3 years; User personalization related data shall be saved for 2 years; The retention period of other data shall not exceed 10 years. The information beyond the retention period shall be deleted or anonymized, unless otherwise provided by law.

1. Take all feasible and effective measures to protect users' personal information
(1) The data exchanged between the user browser and the "service" is protected by SSL encryption;(2) The website provides HTTPS Safe Browsing mode; (3) Using data encryption technology; (4) Using MD5 salt adding mechanism to hash and save user passwords; (5) Use trusted protection mechanism to prevent hacker attacks; (6) Deploy personal information access control mechanism, implement post specific authority control, sign confidentiality agreement, monitor operation, etc; (7) Strengthen the information protection training of the company's employees.

2. Establish an information security responsibility system
If the user's information is accessed, publicly disclosed, tampered with or destroyed without authorization, the company shall compensate the user for the losses incurred and investigate the legal liabilities of relevant personnel. If the user fails to maintain the privacy of personal information, resulting in the leakage or illegal disclosure of the user's personal information, the losses caused shall be borne by the user.

After an information security incident occurs, the user shall be informed of the basic situation and possible impact, the measures taken or to be taken, the suggestions for independent prevention and risk reduction, and the remedial measures for the user.

1. Strengthen user account security counselling
(1) Before the user permanently sells or transfers the right to use the equipment to a third party, ensure to exit the user account and delete the paired website or app;(2) When selling equipment (such as household appliances), the user shall reset the equipment and restore the factory settings;(3) When purchasing second-hand equipment, users should check the account settings in the app or the equipment supplier to ensure that they are not associated with unknown users; (4) Relevant items shall be set in the software or equipment to timely answer, coach and solve the user's information security problems.

2. Information sharing responsibility
If the company shares personal data from EEA area with a third party, whether the third party is an affiliated company or partner outside EEA or not, the company assigns responsibilities according to EU standard contract terms or gdpr.

1. Access, correct and delete my personal information; If the company violates the law, breaches the contract or uses user information without consent, the user has the right to require it to correct and eliminate the adverse effects immediately; If the user logs off the account and the company stops providing services, the user can ask the company to delete his / her information.

2. Change the scope of user authorization. Users can submit requests, change or revoke the agreement that the company collects their personal information. If part of the company's services cannot be carried out due to the user's breach of contract and revocation of authorization, the user shall bear the losses caused to the company.

3. Users are entitled to access, correct, update, delete and other services provided by the company free of charge, but reserve the right to charge reasonable fees for user data access requests.

Under special circumstances, the company shall not provide users with their personal data. For example, receiving data by users may be dangerous to them; he user's personal data involves ongoing judicial investigation and other procedures; The user's personal data involves business sensitive decisions; Other people's personal data are also included in the same record.

The minority audience served by the company is minors. Within the legal scope, the company can collect the personal information of minor users with the consent f parents or guardians. If the collection of minor information violates legal procedures or without consent, the company shall bear corresponding responsibilities and immediately delete the corresponding information.

The personal information collected by the company shall be stored in Germany. Through resources and servers all over the world, users' personal information may be transferred to or accessed from overseas jurisdictions in the countries / regions where users use products or services. Although the data protection laws of these countries or regions are different, the company shall ensure that the user's personal information is protected equally in Germany.

This provision does not apply to the products and services provided by the company's cooperative relationship, or the third party authorized by the company. The following specific products or services are provided to third parties:

1. Alipay, WeChat or other third-party payment services;
2. Social media push function in the company's website;
3. Users can log in quickly using wechat, QQ, Taobao, JD, etc;
4. Users use third-party services through the application end provided by the company, such as opening, accessing, browsing, retrieving or registering to log in to video websites, music applications, map applications, weather query applications, etc.
5. Other situations where information may be collected by a third party.

When users use third-party functions, information security accidents shall be handled in accordance with the information security agreement signed with the third party or the provisions on third-party information protection, and the company shall not be responsible.

The revised version of these Provisions shall take effect immediately upon publication. Without the consent of the user, the changed provisions shall not reduce the rights that the user should enjoy according to the original provisions. The company shall timely notify users of relevant major changes in a convenient and effective way.

"Major changes" include but are not limited to:
1. The company's service mode, including the purpose of processing personal information, the type of personal information processed, the use of personal information, etc;
2. Major changes in the ownership structure of the company, such as business adjustment, bankruptcy and M & A;
3. The main objects of public disclosure of personal information have changed;
4. Significant changes have taken place in the right of users to participate in information protection and the way they exercise it;
5. The company's department dealing with personal information security, contact information and complaint channels have changed;
6. When the personal information security impact assessment report indicates that there is a high risk.