Ecovacs Robotics Privacy Policy

Effective date: November 4, 2024

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This Privacy Policy describes Our policies on the collection, use, retention, disclosure and share of information about You in connection with Your use of Our Services, including those offered through Our websites (“Websites”), through Our electronics and/or consumer products (“Products”) and services (collectively, the “Services”).
The terms “We”, “Our”, “Us” and “Ecovacs” refer exclusively to Ecovacs Robotics, Inc., and its subsidiaries and affiliates. The terms “You” and “Your” refer exclusively to You, as a user of the Services.
We reserve the right to change Our Privacy Policy from time to time by posting the changes here. We will notify You of any changes by posting the new Privacy Policy on this page. If We make any changes to this Privacy Policy that significantly affect Your rights, We will let You know via email and/or a prominent notice on Our Website or through Our Services, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your use of Our Services after We have made changes to Our Privacy Policy will mean that You have accepted those changes.
BY USING THE SERVICES, YOU AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THESE TERMS, PLEASE DO NOT USE THE SERVICES.
If You have questions about anything in Our Privacy Policy, please contact us through the information as disclosed in this Policy.

1. INFORMATION WE COLLECT

Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer. The following data is logged:

• IP address of the calling computer
• Operating system of the calling computer
• Browser version of the calling computer
• Name of the retrieved file/website
• Date and time of retrieval
• Transferred amount of data
• Referring URL

This data is processed in order to be able to present the website, to ensure the security, availability and integrity of the website (e.g., detection and defense against DoS attacks or access by bots), to improve the quality and presentation of the website, to be able to identify and correct errors and for statistical purposes.

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You provide Your email, or log in for a third-party account, to create an online account or subscribe to Our communications. When creating Your account, You may be asked to enter certain information, such as: Your name, avatar, age, gender, address, telephone number, email address, username and password, nickname and portrait (possibly obtained through third-party software), etc.  If You refuse to provide such information, You may not be able to create an account on Our Website, and You may not be able to use the Services completely or properly.

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If you contact us, e.g., by e-mail, via a contact form, live chat or other information transmission tools, the information you provide will be stored for the purpose of processing the request.
We need the information requested in a contact form or live chat to process your request, to address you correctly and to send you a reply.
When you utilize our customer service, i.e. if you contact us, by e-mail, telephone, via a contact form or via live chat, the information you provide will be stored for the purpose of processing the request. We need the information to process your request, to address you correctly and to send you a reply. We process the data as part of the provision of our contractual services. In this context, your Ecovacs ID, inventory data (surname and first name of the contact person(s), country), contact data (e-mail address, telephone number, address), contract data (subject matter of the contract, term), payment and shipping data (payment amount, payment method information, user name, billing and/or shipping address), communication records and other data collected in the context of the provision of services and/or required for the provision of services are processed. If the problem you meet would obtain a clearer description by taking a photo/screenshot or video, you may also consider sending to the customer service such pictures and videos. The information collected will be used to provide and improve our customer services. The processing described in this section is necessary to provide you with the services requested. Inquiries and customer relations are regularly stored and processed in our CRM system. To process your request, we are using Zendesk, provided by Zendesk, Inc. located in the United States. The information collected will be used to provide and improve our customer services. If the problem you meet would obtain a clearer description by taking a photo/screenshot, you may also consider sending to the customer service such pictures or audios.
Inquiries and customer relations are regularly stored and processed in our CRM system. The data processed in this context (surname, first name, title, postal address, date of birth if applicable, your specific interest with regard to our products and services and your interactions with us) may also be used by us for direct marketing purposes, in particular for postal advertising, in compliance with the legal requirements.

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On our website, you can register to receive a newsletter by e-mail. During registration, the data from the input mask, the IP address of the calling computer and the date and time of registration are transmitted to us. For the processing of the data, your consent is obtained during registration and reference is made to this Privacy Policy.

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We may partner with advertising networks and other advertising serving providers (“Advertising Providers”) that may push advertisements on our behalf and others within the website or to your email account. Some of these advertisements may be personalized based on your user profiling. This type of advertising is known as interest-based advertising. We will distinct advertisements with an “ad” imprint on all advertisements for your ease of identification.
We involve Advertising Providers to identify advertising that might be of interest for you and/or for products that can be used with your Device and to present them to you within the website and to analyze the effectiveness of our advertisements presented in the website and your interactions with them. This information will not be used to identify you personally, but to analyze it in a pseudonymized way. This technology enables us to pursue our legitimate interests to present you advertisements that suit your individual interests and to perform direct marketing campaigns for our products and services to our customers.
You may opt-out from such personalized advertising, by using the "Do Not Track" or relevant functions of a supporting browser, by deactivating the execution of script code in your browser or through other methods as described in this Privacy Policy or those of the service providers. Please note that electing to opt out will not prevent advertisements from appearing in your browser or applications. However, opting out will allow the advertisements pushed to you to be irrelevant to your interests. When participating in one of our offline or online competitions/sweepstakes, we collect and process the personal information provided by the participant as part of the participation in the competition, usually first name, address and e-mail address and other information if necessary, subject to the specific notifications separately.
We collect this data in order to enable participation in the competition, to carry out the competition, to inform the participant of a prize, if applicable, and to send the participant a possible prize.
We process the participants' personal information to conduct the competition and to determine and notify the winners.
Insofar as participants provide information as part of their participation that is not required for participation in the respective competition, this is done on a voluntary basis.
If you do not provide us with the data required to participate in a competition, it will not be possible to participate in the competition or to contact you regarding notification of a prize.

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We may collect and use information obtained from Facebook, Google, Amazon, and other accounts You use to login to the Services (“Third-Party Accounts”), such as: Your name, Your user name or handle, birth date, picture, and other details You may have on Your Third-Party Account profile (“Third-Party Information”). We do not have access to Your Third-Party Account passwords. The data We receive from Third-Party Accounts is dependent upon Your privacy settings with these third parties. You should always review, and if necessary, adjust Your privacy settings on Third-Party Accounts before linking or connecting them to Our Website or Services.  We use Third-Party Information to operate, maintain, and provide to You the features and functionality of the Services, to process and ship orders, to provide customer Services, and to communicate directly with You, such as to send You information about Your orders, Product sales, special offers, and new site features. Our website uses cookies and implements third-party tools and functions.
Cookies are pieces of information that are transferred from our web server or third-party web servers to your browser and stored there for later retrieval. Cookies may be small files or other types of information storage. Information is stored in cookies that is related to the specific end device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. A cookie also contains information about its origin and the storage period. However, this does not mean that we gain immediate knowledge of your identity.
We also use third-party tools and functions, for example, to expand the functional scope of the website, to analyze the use of the website, and to optimize the content accordingly. When integrating tools and functions from third-party providers, personal information may be transmitted to the providers of the integrated tools and functions in order to be able to provide the tools and functions. Except for the introductions as below, you may refer to more information about how these third parties collect information in Chapter 6 HOW WE DISCLOSE, SHARE OR TRANSFER THE PERSONAL INFORMATION.
Cookies and third-party tools and functions are referred to uniformly below as "cookies" for the sake of simplicity.

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When visiting our website, cookies are set that are absolutely necessary for the operation of the website. These essential cookies may be, for example, cookies that are required for the display of the website with a content management system, which are used to recognize language settings, or which are used to document whether you have consented to the setting of further (non-essential) cookies or whether you have rejected them.
The technically necessary cookies, including their purpose and storage period or deletion period, are explained to you in our cookie banner, which is displayed when you access the website.
We also use non-essential cookies, for example to collect additional information about the interests of visitors to our websites or about their usage behavior, in order to analyze and optimize our website and generally our customer interactions on this basis.
Non-essential cookies, including their purpose and storage period or deletion period, are also explained to you in our cookie banner, which is displayed when you access the website.
Non-essential cookies are only set if you have expressly consented to the setting of non-essential cookies. You can also select different categories of non-essential cookies that you wish to allow in the cookie banner.

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On our website, we use the cookie consent management tool Cookiebot to obtain your consent to store certain cookies in your browser and to document this in accordance with the relevant data protection law. The provider is Cybot A/S , with its registered seat in Denmark  (hereinafter Cookiebot ).
When you enter our website, a cookie is stored in your browser, in which the consents you have given or the revocation of these consents are being stored. This data is not shared with the service provider. You can change the settings here: https://www.cookiebot.com/de/privacy-pol

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On our website we use the tool Google Tag Manager. Google Tag Manager is provided by Google Ireland Limited in Ireland. Through this tool, website tags can be managed via an interface. Google Tag Manager only implements tags, but no cookies are used, and no personal information is collected. Google Tag Manager triggers other tags, which in turn may collect data, but Google Tag Manager does not access this data.

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We use web analytics services to understand how our website and our Platform are used by their visitors or users and to optimize the website and the Platform in terms of content and technology.

Google Analytics

We use the web analytics service Google Analytics with IP anonymization.
JavaScript tags allow us to collect information about your use of the website and the Platform. Google Analytics also regularly uses cookies to collect information about a user's interactions with the website or Platform.
Within the scope of the use of Google Analytics, your IP address and information about the use of the website or Platform, browser type and version, operating system used, the previously visited page and the time of the server request are transferred to Google servers and processed there.

Tracking Pixel

Tracking pixels from various providers are used on our website to track website usage and the actions of website visitors for the purpose of conversion tracking. Tracking pixels from the following providers may be used: LinkedIn, Bing, Meta, Google Ads, Outbrain, Pinterest, Snapchat, Taboola, TikTok, Twitter/X, Yahoo Native (Gemini).
Tracking pixels are a code snippet that allows us to track the actions of website visitors, which further allows us to personalize and improve our advertisements and measure their success. This allows us to evaluate our website for statistical and market research purposes and optimize advertising campaigns.
The data collected via the tracking pixels may be used by the providers of the respective pixels for their own tracking and advertising purposes. For further details, please refer to the privacy statements of the providers of the respective pixels.
If you are a member of a social media platform of one of the providers of the tracking pixels and have allowed the respective provider to do so via the settings of your user account with the social media network, the provider of the social media network or the tracking pixel may link the information collected about your visit to our website to your user account with the respective social media network and use it for the targeted placement of advertisements.
We can also measure the effectiveness of advertisements on the respective social media networks and see whether a user was redirected to our website via such ads (conversion measurement). In order to display the content of our website correctly and graphically appealing across browsers, we use the font library Web Fonts of Google (hereinafter “Google”). When you call up a website on which a font library is integrated, the required font is loaded into the browser cache in order to display texts and fonts correctly. In doing so, the operator receives the information that the font required for our website or platform was called up from your IP address.
You can prevent the use of such libraries and the associated data transmission by installing a JavaScript blocker (e.g. www.noscript.net). If the use of Web Fonts is not supported or prevented, a default font will be used by your computer.

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YouTube videos are embedded on our website. These are provided, via a plugin, by Google ("YouTube").
We use the "extended data protection settings" for embedded YouTube videos, this means that YouTube does not set any cookies.
Nevertheless, when you visit a website with the YouTube plugin, a connection to YouTube is inevitably established and your IP address is transmitted to YouTube in the process.
Further information on data protection at YouTube can be found in YouTube's Data Protection and Security Centre:
https://support.google.com/youtube/topic/2803240?hl=de&ref_topic=6151248

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On our website, we use the reCAPTCHA service of Google. With reCAPTCHA, we determine whether a person or a computer makes a certain entry in a form. Google uses the following data to check whether a person or computer makes an entry: IP address of the end device used, the website that is visited on our site and on which the captcha is embedded, the date and duration of the visit to the website, information on the browser and operating system type used, the Google account if the user is logged in to Google, mouse movements on the reCAPTCHA areas and tasks in which images are to be identified.
Further information on data processing and data protection at Google can be found in Google's Privacy Policy at https://policies.google.com/privacy?hl=en.

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On our website, we use the service Friendly Captcha, provided by Friendly Captcha GmbH in Germany. With Friendly Captcha, we determine whether a person or a computer makes a certain entry in a form. As part of this process, Friendly Captcha captures the IP address of the requesting end device in order to send a cryptographic task to the end device. This task is solved in the background and once solved, a confirmation is sent by Friendly Captcha to the server that the user is a natural person and not a bot. Friendly Captcha uses the following data to check whether a person or a computer is making an entry: Anonymized IP address of the requesting computer, information about the browser used, as well as operating system, anonymized counter per IP address to control the cryptographic tasks, website from which the access took place (so-called referer URL).
For more information about data processing and data protection at Friendly Captcha, please see the Privacy Policy of Friendly Captcha at ttps://friendlycaptcha.com/en/privacy.

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We use the IP address and other information provided by the user (in particular postcode as part of registration or ordering) to address regional target groups (so-called "geotargeting").
The regional target group approach is used, for example, to automatically show you regional offers or advertising that are often more relevant for users, for the purpose of ensuring a more precise target group approach and thus providing offers and advertising with higher relevance for users.
In doing so, part of the IP address as well as the additional information provided by the user (in particular postal code) are only read out data.
You can prevent geo-targeting, for example, by using a VPN or proxy server that prevents accurate localization. In addition, depending on the browser used, you can also deactivate location localization in the corresponding browser settings (as far as the respective browser supports this).

3. SOCIAL MEDIA Social media buttons of various social media networks (e.g. Linkedin, Instagram, YouTube, Twitter/X , Facebook and TikTok) are integrated on our website.
If you click on one of these social media buttons, you will be redirected to our pages on the respective social media network. In this case, the provider of the respective social media network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the respective social media network or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a server of the respective provider. If you click on a social media button and are either logged in to the respective social media network or then log in to the page of the respective social media network, the transmitted information can be assigned to your account with the social media network.
For information on the purpose and scope of data collection and processing by the providers of the respective social media network, the provider identification, a contact option and your rights and setting options for data protection, please refer to the respective privacy policy of the providers of the social media networks.

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We maintain a publicly accessible profile on various social media networks (e.g. Linkedin, Instagram, Twitter/X and Facebook).
If you visit our social media pages and are logged in to the respective social media network, the provider of the respective social media network can analyze your usage behavior and assign the information collected to your account with the social media network and enrich it there. Even if you are not logged in or if you do not have an account with the respective social media network, personal information may be collected by the provider of the respective social media network, for example your IP address or data collected via a cookie.
The operators of the social media networks can use this data to create user profiles. Based on your user profile, you can then be shown interest-based advertisements both on the websites of the social media network and on other websites.
If you visit one of our social media pages, we are jointly responsible with the provider of the social media network for the collection and processing of your personal information that takes place there. For information on the collection and processing of your personal information that takes place there, we refer you to the privacy policy of the respective social media network.
You can assert your data subject rights both against us and against the provider of the respective social media network. In this context, we would like to point out that we can only influence the processing of personal information and the implementation of data subject rights within the framework of our social media pages within the scope of the possibilities made available to us by the respective provider. We may use Your Personal Information for legitimate business purposes, including:

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• To create, and administer accounts, fulfil and record transactions, and provide You with related assistance (e.g., technical help, answer inquiries relating to Personal Information, etc.).
• To send administrative information to You, for example, information regarding Our Services and changes to Our terms, conditions, and policies.

We will engage in these activities to manage Our contractual relationship with You, with Your consent, and/or to comply with Our legal obligations.

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• To send You marketing communications and offer other materials that We believe may be of interest to You, such as to send You newsletters or other direct communications.
• To share information with other marketers (and their Services providers) to permit them to send You marketing communications, consistent with Your choices.
• To allow You to participate in sweepstakes, contests or similar promotions.
• To facilitate social sharing functionality if You choose to do so.

We will engage in this activity with Your consent, to manage Our contractual relationship with You, or where We have a legitimate interest.

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• To better understand You and Our other users, so that We can tune and personalize Our offering.
• For trending and statistics, and to improve Our Products and Services.

We will engage in this activity because We have a legitimate interest.

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• For audits, to verify that Our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• For responding to legal duties, such as requests from public and government authorities.

We will engage in these activities to comply with a legal obligation or because We have a legitimate interest.
To the extent that We process Your Personal Information based on Your consent, You may withdraw Your consent at any time. We will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy or required or permitted by applicable Laws. We will retain and use Your Personal Information to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your information to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies. When assessing these periods, we carefully examine our needs to collect personal information at all as revealed herein, and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by the Law.
If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal information will be routinely anonymized or deleted in accordance with the statutory provisions. Unless otherwise required under relevant laws and regulations, if we stop the provision of services or business operation, we will promptly cease to collect your personal information, and also delete or anonymize your personal information collected by us for such purpose without delay. In a case where certain categories of your personal information become unnecessary to be collected or processed to achieve all the applicable purposes specified herein, we will also stop collecting the relevant personal information and/or anonymize or delete those have been collected. We will also give notice to you individually or by publishing the relevant information on our website. If it is necessary for providing you with better or satisfactory products or services, your personal information might be disclosed or shared with our affiliates or third-party service providers. Insofar as we use service providers within the framework of the provision of the website and/or Platform or other services, we take appropriate legal precautions as well as appropriate technical and organizational measures to ensure the protection of your personal information.
With regard to our affiliates, please note that we are a global operating group of companies, which has multiple legal entities or affiliates across different jurisdictions. The internal departments or organizational units in charge will receive your data to fulfil their tasks, to fulfil contracts with you if necessary, for data processing with your consent or to safeguard our legitimate interests.
With regards to third-party service providers, please note that personal information will only be passed on to third parties within the framework of legal requirements. Categories include those supporting the fulfilling orders of products or services, delivering packages, sending postal mail and email, analyzing data, providing marketing assistance, providing search results and links, processing payments, transmitting content, and providing customer service. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes.

• We currently involve cloud services providers to host the website and store data in the United States to collect information about the crash history of the website and your using behavior and to send out push notifications.
• We may provide paid Products and/or Services within Our Services.  When You make payments or conduct transactions through Our Websites, We will receive Your transaction information. The information that We collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method.  Different payment methods may require the collection of different categories of information.  The payment method information that We collect will depend upon the payment method that You choose to use from the list of available payment methods that are offered to You by Us.
• We participate in interest-based advertising and use third-party advertising companies to serve You targeted advertisements based on Your online browsing history and Your interests.  We permit third-party online advertising networks, social media companies and other third-party Services, to collect information about Your use of Our Website over time so that they may play or display ads on Our Website, on other websites, apps or Services that You may use, and on other Devices You may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with Our third-party advertising partners to help identify You across Devices. We and Our third-party partners use this information to make the advertisements You see online more relevant to Your interests, as well as to provide advertising-related Services such as reporting, attribution, analytics and market research.  For more detailed information, please refer to Chapter 2 COOKIES AND THIRD-PARTY TOOLS/FUNCTIONS of this Policy and the separate Privacy Policy of the third-party advertising as listed in below table.  

The following is a list of third party service providers such as plugins and content delivery networks on our website that may either directly or indirectly process the personal information from You. Please review the relevant privacy policies (links current as of the date of publication of this Privacy Policy) for further information on how each third party handles Your Personal Information:

Service	Service Provider	Country located	Purposes of data processing	Privacy Policy of the third parties
Amazon Cloud	Amazon Web Services, Inc.	USA	Content Delivery Networks	https://aws.amazon.com/privacy/?nc1=h_ls
Digicert Trust Seal	DigiCert, Inc	USA	Functional	https://www.digicert.com/digicert-privacy-policy?inid=dc_cookiebanner_privacy-policy
Cookiebot	Cybot A/S	Denmark	Cookie-Consent	https://www.cookiebot.com/de/privacy-pol
Google Analytics	Google LLC.	USA	Tracking	https://policies.google.com/privacy?hl=en
Google Tag Manager	Google LLC.	USA	Tag configuration and integration of Google services	https://policies.google.com/privacy?hl=en
Facebook pixel	Meta Platforms Ireland Ltd.	Ireland (USA)	Tracking	https://www.facebook.com/about/privacy
Omnisend	Omnisend, Inc.transac	USA	Email Marketing	https://www.omnisend.com/privacy/
85-Sixty	85SIXTY, Inc.	USA	Data Analysis and Tracking	https://www.85sixty.com/privacy-policy/
Sensors Data	Sensors Data Network Technology (Beijing) Co., Ltd.	China	Data Analysis	https://www.sensorsdata.cn/market/privacy_policy.html
Zendesk	Zendesk, Inc.	USA	Customer Service Platform	https://www.zendesk.com/company/agreements-and-terms/privacy-notice/?_ga=2.214252756.273093329.1710397592-1728491643.1710397592
LiveChat	Text, Inc.	USA	Customer Service Tool	https://www.livechat.com/legal/privacy-policy/?_ga=2.222831964.672473113.1709619407-1477929159.1709619405
Affirm	Affirm, Inc.	USA	Payment service	https://www.affirm.com/privacy

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There are also cases where we are required to provide your personal information to the competent supervisory authorities pursuant to the Law, court orders, any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies. Information sharing under this circumstance may not require your prior authorization or consent.

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If We are involved in a merger, acquisition or asset sale, Your Personal Information may be transferred. We will provide notice before Your Personal Information is transferred and becomes subject to a different Privacy Policy.

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We may disclose Your Personal Information in the good faith belief that such action is necessary:

• To comply with a legal obligation
• To protect and defend the rights or property of Ecovacs
• To prevent or investigate possible wrongdoing in connection with the Services
• To protect the personal safety of users of the Services or the public
• To protect against legal liability

In principle, the personal information as collected and produced during our provision of relevant products and services is stored in our servers located in the United States. However, since we provide products or services based on our resources and servers worldwide, your personal information might be transmitted to a jurisdiction or accessed from a jurisdiction outside of the country where you reside. Such destination jurisdictions include: (i) the jurisdiction where your personal information is stored (if it is the same as where you are located (cross-border transfer does not apply); (ii) China, where our affiliates’ registered office, our affiliates which are involved in our Websites products and services and most of our service providers, are located, and when our employees need to have access to your personal information for handling your issues and also conducting general analysis; (iii) the storage location of some other service providers which serve you on behalf of us through their API integrated into the Website, mostly at your local jurisdictions, or at the jurisdiction where their relevant branch resides to specifically serve your local jurisdiction; and (iv) some other jurisdictions from where your Website account was once logged in, provided that the data storage location for such jurisdiction differs from your domicile country. Specifically, if you send to data-privacy@ecovacs.com an email, your personal information contained in such email and its delivery will be directed to China, where our email-box server is located.  All such international transfers are made in connection by and between the relevant servers housed in third-party cloud facilities and physically located in such jurisdictions, and we will require third-party cloud suppliers to adopt appropriate safeguards in compliance with the Law. We take appropriate technical and organizational measures in accordance with the state of the art to ensure a level of protection for the personal information we process that is appropriate to the risk of the respective processing and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, inquiries or payment data that you send to us.
Our employees receive regular training on data protection and information security and are committed to confidentiality and data protection.
A restrictive rights and roles concept on a "need to know" basis ensures that employees only have access to the personal information they absolutely need to perform their duties. This Website is not intended or designed for use by minors under the age of 16 (or other age as a minor pursuant to the laws and regulations in your jurisdiction), including any children under the age of 13. We do not knowingly collect personally identifiable information from or about anyone under the age of 16. If you are a minor pursuant to the laws and regulations of the place in which you reside, we recommend you to ask your parents or guardians to read this Policy and use our services or provide your information to us with the prior consent from your parents or guardians. If your guardians do not allow you to use our services or provide your information to us according to this Policy, please stop using our services immediately and give a notice on time so that we can react accordingly. If, due to reasons out of our control such collection occurs, we will remove such information once we are notified. We will keep personal information collected confidential and safe in accordance with the relevant laws and regulations. We aim to take reasonable steps to allow You to correct, amend, delete, know and access, Opt-out of sharing or limit the use of Your Personal Information.
In certain circumstances, You have the right:

• To access and receive a copy of the Personal Information We hold about You
• To rectify any Personal Information held about You that is inaccurate
• To request the deletion of Personal Information held about You
• Opt-out of sharing or limit the use of Your Personal Information.

If You wish to be informed what Personal Information We hold about You and if You want it to be removed from Our systems, please contact us through the information provided in the last chapter of this Policy.
You have the right to data portability. You can request to obtain a copy of Your Personal Information in a commonly used electronic format so that You can manage and move it. Be advised that We may not be able to delete Your Personal Information without also deleting Your user account. You will not be permitted to examine the Personal Information of any other person or entity and may be required to provide Us with Personal Information to verify Your identity prior to accessing any records containing information about You. We may not accommodate a request to change or delete Personal Information if We believe doing so would violate any law or legal requirement or result in incorrect information.
You may click on the “unsubscribe” button in emails sent by us or contact us through the information provided in the Policy to refuse to receive promotion notifications. You can also apply restrictions in the user setting interface (if applicable) to avoid receiving promotion notifications. Furthermore, you may also opt out of targeted advertising as by choosing to opt out through the methods described in this Policy, thus advertisements pushed to you would be irrelevant to your interests. Please note that you may not unsubscribe or refuse to receive any emails related to your account (e.g. account verifications, order confirmations, changes or updates of service functions, or notices regarding technology and safety, etc.) as long as you have not cancelled your account, and related to the fulfilment in our existing contractual relationship.
You may opt out of our sharing your data with a third party by contacting us through the information provided in the Policy.
If You do not want Us to collect Your Personal Information, please do not provide it to us. Please understand that if You choose not to provide certain Personal Information to us, Your choice might restrict Your ability to access some content and use some of the functionality of Our Services.
For Your protection, We may only implement requests with respect to the Personal Information associated with the particular email address that You use to send Us Your request, and We may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable. If You are a California resident, You can learn more about Your consumer privacy rights by reviewing the California Privacy Notice as below. We reserve the right to amend this Privacy Policy from time to time so that it always complies with current legal requirements and/or in order to implement changes to our services in the Privacy Policy, e.g. when introducing new services. When visiting the website or using our services, the current privacy policy always applies. If You have any concerns relating to this Privacy Policy, You may correspond with Us at the following address:
Ecovacs Robotics, Inc.
www.ecovacs.com/us
E-mail: data-privacy@ecovacs.com
  The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information.  If you are a California resident, this section applies to you.
California Consumer Privacy Act
In the preceding 12 months, we have collected the following categories of personal information: (i) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers; (ii) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (iii) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement; (iv) Audio, electronic, visual or similar information; and (v) Inferences drawn from any of the information identified under Cal. Civ. Code § 1798.140(v)(1)(k) to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.  For details about the precise data points we collect, the categories of sources of such collection, and the business and commercial purposes for collecting your personal information, please see the section “INFORMATION WE COLLECT”, and“USE OF INFORMATION” above.  In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information	Commercial or Business Purpose for the Collection	Categories of Recipients
Identifiers such as a unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers	Processing performance of commands; Verifying your information; Maintaining and servicing accounts; Analytics regarding use of our ‌website and/or product; Improving our products and services; Advertising or marketing	Service providers Advertising networks Data analytics providers Affiliates
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Verifying your information; Maintaining and servicing accounts; Analytics regarding use of our ‌Website and/or product; Improving our products and services; Advertising or marketing	Service providers Data analytics providers Affiliates
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement	Processing performance of commands; Verifying your information; Maintaining and servicing accounts; Analytics regarding use of our ‌Website and/or product; Improving our products and services; Advertising or marketing	Advertising networks Service providers Data analytics providers Affiliates
Audio, electronic , visual or similar information	Processing performance of commands; Improving our products and services;	Service providers Affiliates
Inferences drawn from any of the information identified under Cal. Civ. Code § 1798.140(o) to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Processing performance of commands; Analytics regarding use of our ‌Website and/or product; Improving our products and services; Advertising or marketing	Advertising networks Service providers Data analytics providers Affiliates

California law requires that we provide transparency regarding personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which Ecovacs has shared personal information with third parties in exchange for valuable consideration.  We might share personal information for purposes of advertising and analytics.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except as specified in the contract.
You have the right to opt out of the sales as described above at any time by visiting our “Do Not Sell or Share My Personal Information” webpage https://www.ecovacs.com/us/ccpa.  If You are under 16 years old, you are restricted from using our Website.  We do not provide service to anyone under 16 years old.
Subject to certain limitations, you have the right to (1) request more information about the categories and specific pieces of personal data we collect, use, disclose, and share or sell, (2) request deletion of your personal information, (3) opt out of any “share or sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights.  You may make these requests by the contact information as indicated at https://www.ecovacs.com/us/support/contact-us or sending an email to data-privacy@ecovacs.com.  We will verify your request by asking you to provide information related to your recent interactions with us, such as your email address, password and Ecovacs ID.  If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.  If you are an authorized agent seeking to make a request, please contact us.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to [45/90] days), We will inform You of the reason and extension period in writing. We will deliver Our written response by mail or electronically, at Your option. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your Personal Information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.
We will not discriminate against you if you exercise your rights under the CCPA.
We may offer you certain financial incentives permitted by the CCPA resulting in different prices, rates, or service levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to Your Personal Information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt ‑in consent, which you may revoke at any time.
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes.  If you are a California resident and would like to make such a request, please contact us at data-privacy@ecovacs.com.