Title

Privacy Policy on Ringa Platform

The Privacy Policy (hereinafter referred to as "this Privacy Policy") is included in the Service Terms of Ringa Platform and forms a part thereof. China Mobile International Limited (hereinafter called "we" or "our") is committed to compliance with applicable data protection and privacy laws and regulations (hereinafter referred to as "Applicable Laws"). Applicable Laws include but are not limited to the Regulation (EU) No. 2016/697 (General Data Protection Regulation) ("GDPR"). To the fullest extent permitted by the Applicable Laws and subject to the valid consent required to be obtained under the Applicable Laws, by using our software (including without limitation to CMI Ringa Platform and RingaX APP), services and/or products, you agree and accept this Privacy Policy. Please read carefully the following contents, especially in bold and capitalized fonts. If you disagree with any of the following contents, please stop access to/use of the site or any other mobile applications, software and services immediately.

Except as otherwise indicated in the context of this Privacy Policy, all words used in this Privacy Policy shall have the same meaning as those defined in the Service Terms of Ringa Platform. We may update this Privacy Policy from time to time, to reflect changes in our software, services and/or commodities and comments from customers or changes in the Applicable Laws. We will revise the privacy policy when necessary, when we amend this Privacy Policy, we will update the "Last Updated" date at the bottom of this Privacy Policy.

Without your consent, we will not reduce or modify your rights in accordance with this privacy policy. In case of any major changes to this Privacy Policy or to the way in which we will use your personal data, we will seek your consent again before we implement such changes. We encourage you to regularly and carefully read this Privacy Policy so as to obtain the latest version.

Major changes include the following scenarios:

1. Significant changes have taken place in our services, including the purpose of processing personal data, the types of personal data processed, and the way in which personal data is used;

2. Significant changes occur in our ownership structure, organizational structure or related aspects;

3. The main objects of personal data sharing, transfer or public disclosure have changed;

4. There is a major change in your rights to participate in the processing of personal data and how to exercise them;

5. Our commissioner responsible for handling personal information security, contact information and complaint channels have changed;

6. When the personal data security impact assessment report shows that there is a high risk.

List of Content

1. Definition

2. Data Collection

3. Use of Data

4. Data Disclosure and Transfer

5. Data Collected By the 3rd party SDK

6. Data Deletion

7. Data Security and Retention Period

8. User Personal Data Management

9. Description of Personal Sensitive Data

10. Protection of Personal Data

11. User rights

12. Policy update

13. Contact Us

1. Definition

1.1 Smart device

refers to the device products that you buy and use, and are produced or manufactured by hardware manufacturers that have Internet access functions, data transmission capabilities, and human-computer interaction interfaces, including smart home appliances, smart wearables, and smart environmental purification equipment.

1.2Ringa

platform and RingaX APP: refers to a smart home platform and applications jointly developed by China Mobile International Limited. and China Mobile Internet of Things Company Limited., which, through China Mobile International Limited, provides users with smart devices operation services and data display services.

1.3User personal information

refers to any information that identifies a user individually or in combination with other information or any other information that is defined as "personal information" by applicable laws (Hereinafter referred to as "personal information") .

2、Data Collection

In order to provide you with better services, we will follow the principle of "reasonable, relevant and necessary" and collect data based on your valid consent. We will not collect information that is prohibited by applicable laws.Subject to your valid consent under applicable legal requirements, we may collect personal data or other information from you from time to time in order to provide you with our products or services. These functions include the functions necessary to realize the Ringa platform, APP software, services and/or products. We will collect, store and use your personal information below to realize these functions. If you do not provide relevant information, you will not be able to enjoy our products or services.

Our relevant business functions and the Personal Information we will collect are as follows:

2.1Information required to register as a user of the Ringa Platform and to use the Ringa Platform In order to be able to use our products and services, you will need to create an account. In the process of creating an account, you will need to submit your Personal Information, of which it is necessary to collect: region, email (such information is and will only be collected when creating an account). This information will help you to activate, manage or use the services from "Ringa Platform" or "RingaX APP" ("Ringa Platform" or "RingaX APP" are collectively referred to as “Ringa”).

2.2Other personal data of user account You can add and modify your nickname and profile photo at your discretion in [Me]-[Personal Information]. If you choose to add a nickname and profile photo, we will associate your nickname and profile photo with your account to facilitate your access to our products and services. (After registration, there is a default name and profile photo, not required)

2.3User's mobile phone information During your use of Ringa, we collect information such as your cell phone model, operating system, unique device identifier, login IP address, the software version number of "RingaX" APP, method and type of access to the network, these are used to provide necessary “PUSH” messages. At the same time, these are also basic information necessary for us to provide services.

You can choose to provide mobile-based personal information:

To enhance your experience, we may collect and use your personal information based on the relevant permissions of your mobile device operating system. If you do not provide relevant information, you can still use our other products and services.

Automatic city selection based on location information, voice function usage permissions, and personalized recommendation function: We will collect your precise or approximate location information to determine where you are, and automatically select the WIFI information for your location. It is used to recommend the WIFI you can choose to configure the networking between the RingaX APP and your smart device;

Camera-based function shooting, video recording and authentication function: You can use this function to publish a personal profile photo with pictures or videos or scan the QR code on the Ringa smart terminal manual to obtain related services;

Storage function based on external memory (SD card): You can use this function to expand the storage space of mobile application data;

Microphone-based recording function: You can use this function to conduct voice conversations and send voice information during customer service consultations.

These features may require you to open your geographic location (location information), camera (camera), photo album (gallery), external storage (SD card), address book/contacts, microphone, and Access authority to realize the collection and use of information involved in these functions. You can find the details of the application through the settings on your device, click on the access permissions to view the status of your above permissions, and you can decide to turn these permissions on or off at any time.

Please note that when you turn on these permissions, it means that you authorize us to collect and use this personal information to achieve the above functions. If you turn off the permissions, you cancel these authorizations, and we will no longer continue to collect and use your personal information. We cannot provide you with the above-mentioned functions corresponding to these authorizations once you cancel these authorizations. Your decision to close the authority will not affect the previous processing of personal information based on your authorization.

2.4 Smart device information

When you use the smart device, we will collect the unique device identifier ("UDID"), MAC address, IP address, wireless connection information, operating system type and Version, push notification identifier, and mobile network information (necessary to collect, otherwise the device cannot be controlled). At the same time, in order to provide you with Ringa smart home services, the Ringa platform obtains the information you use and bind based on your smart device management settings. The information collected by the smart device information so that you can view the information of the smart device through the APP and remotely operate and manage the device through the APP. The information of these smart devices is classified as follows according to the type of smart device you use:

Information that we need	Information provided to us by you
Email，Mobile Phone number and password	Name, email and other contact information of authorized users in your company.
	Examples of information provided to us when your device connects to our Ringa Cloud – this will differ, depending on the nature of your device and information you require
	On / off status
	Location
	WiFi network name
	Temperature/Humidity/Brightness/Air Gas Concentration
	Open/close status
	Schedules
	Other (will depend on the nature of your device and information you may collect.)

2.5 Picture/video information captured by the camera When you need to use the camera to scan a QR code, take a user profile picture, and take information feedback pictures (if you use a camera, you must collect it, otherwise you cannot use the function), we will collect the picture/video information captured by your camera, and this information will be used for mobile monitoring and alarm services.

2.6 Feedback information We will collect your feedback information through smart device to help you troubleshoot

2.7Infrared (IR) Data We will collect your infrared remote control information through smart terminal equipment to enable you to operate your other infrared devices through the App.

2.8User Scenario (linkage) DataWhen you use the scene, automation and other functions, we will collect the preset conditions that you configure, perform actions, select equipment and other related setting information to provide you with intelligent scene services. (Such as usage scenarios, automation and other functions must be collected, if not used, it will not be collected)

2.9Personal Health DataWhen you use our body fat scale products, we will collect your body fat data such as your height, weight, body fat, BMI, and skeletal muscle content. (If the body fat scale product is used, it must be collected, and it will not be collected if it is not used)

2.10Others Please understand that the services we provide to you may be subject to further updates and developement. If you use other services that are not covered in the foregoing description, when we need to collect your data based on that service, we will separately explain the scope and purpose of data collection to you through page prompts, interaction procedures, agreement agreements or revision of this policy. We will not collect your personal data before we get your consent.

You are not obligated to provide us with your personal data, but if you do not provide us with specific personal information, we may not be able to provide you with the products and services you need.

3、Use of Data

3.1 Our primary purpose in collecting information is to provide you with a safe, smooth and efficient customized experience. Subject to your valid consent as required by Applicable Laws, we may collect and use, or engage third-party service providers to collect and use on our behalf, personal data about you to the extent that we have obtained permission or where necessary, to:

Provide you with product business functions or other services (as described at the time we collect the information);
Provide you with product business functions or other services (as described at the time we collect the information);
Improve your user experience (including: enabling you to achieve registration-free and/or automatic login on the platform of your business partners);
Provide you with customer support and troubleshooting problems;
Compare the accuracy of the data;
Inform you of service updates and failures;
Ask for feedback or participation in an online survey;
Resolve disputes;
Verify your identity;
Improve our software, services or website;
Protect your and our interests including, in particular, the enforcement of our Ringa Platform Service Agreement and the prevention and combating of fraud;
Review feedback and improve software, service or website;
Contact you to convey messages regarding malfunctions and service problems;
Make you aware of final claims regarding the use of the software, products or website by way of email, software or newsletter, including, but not limited to, claims of infringement of third party rights;

(collectively called [Purposes])

3.2 How We Use Cookies and Similar Technologies

We will collect and use Cookies for reasons such as improving user experience, data analysis or security.

*Purpose of data analysis: we will collect and analyze Cookies to further improve the experience for use of our software.

*Your preferences and user experience: we will collect user's device data, geographic location, operator's information, etc. to better improve user experience and recommend products that better meet user needs.

* Security purpose: we will use Cookies to limit some network security attacks of particular types.

* Internet fraud prevention: we will use Cookies to investigate or prevent the occurrence of Internet fraud.

* For a better user experience: we will collect user’s behavior within the App and use it for App flow improvement.

* If you are under 16 years old, you must obtain prior consent from your parents or guardians before providing any personal data. If you are a minor, we suggest that you ask your parents or guardians to read this Privacy Policy carefully and do not use our services or provide information to us until you gain the consent of your parents or guardians. When we are about to collect the Personal Information of minors for providing our products or services to the minors with the consent of their parents or guardians, we will only use, share, transfer or disclose such data to the extent that it is permitted by laws and regulations, with the explicit consent of parents or guardians or when it is necessary for the protection of minors.

4、Data Disclosure and Transfer

Except as described below, we will not sell, rent, trade or transfer any personal and/or traffic data or communications without your valid and express permission as required by Applicable Laws, unless we are obligated to do so by Applicable Laws or under the order of a competent authority.

China Mobile International Limited’s subsidiary in United Kingdom (China Mobile International (UK) Limited, Address: 125 Old Broad Street, 24th Floor, London, EC2N 1AR, United Kingdom) is the operator of RingaPlatform and RingaX APP, and is responsible for collection and processing of all personal data. We uses servers located in Ireland and/or other countries of European Economic Area to store your personal data.

We may disclose the Personal Data to respond to legal requirements, to exercise our legal rights or to defend against claims, to protect our interests, to combat fraud and to enforce our policies or to protect the rights, property or safety of any person.

We, our local partners or the operators or companies that facilitate your communications may provide personal data, communications and/or traffic information to appropriate judicial, law enforcement or government agencies that lawfully request such information. Subject to your valid and express consent as required by Applicable Laws (which we are required to obtain if required by Applicable Laws), we may provide your personal data to companies located in Chinese mainland, Hong Kong or other countries outside the European Union to provide services to you, and these companies may be third party suppliers or our affiliates. The circumstances in which we will share and disclose include, but are not limited to, those described below:

We will anonymously process the statistical data of your smart devices and provide them to our partners in time, including China Mobile IoT Company Limited (Chinese mainland) and / or China Mobile International Limited (located in the Hongkong Special Administrative Region of China). After anonymization, personal data such as your name, account number, password, telephone number, email and so on will not be involved, and such anonymized data cannot be used to identify any natural person;
We may disclose information about you if we determine that such disclosure is reasonably necessary to enforce our terms and conditions, to protect our operations or users, or involve major public interests.
In the case of a corporate transaction, if the Company undergoes a sale, merger, acquisition or other corporate reorganization or restructuring, your personal data may be disclosed, shared or transferred to a controlling legal entity, or a third party authorized by it to carry out the Company's business;
Your personal data may be provided to our advisors, agents or other interested parties for the purpose of protecting our rights and property;
In any other case, your personal data may be provided to any third party with your prior written consent.

Some links may appear on this website/APP which may cause you to leave this website/APP and/or be taken to other third-party websites. You should note that any personal data you provide to these third-party websites is not governed by this Privacy Policy and therefore we are not liable for any loss, damage, costs or expenses suffered or incurred by you as a result of providing or making available personal data or other information to these third-party websites.

5、Data Collected By the 3rd party SDK

In certain business scenarios, we may use third-party SDKs to provide services to you in order to improve business processing capabilities, reduce costs, or for other reasons. These SDKs may collect and use your Personal Information, which we will obtain with your authorized consent.

Third-party SDKs include:

Third-party SDK Name	Personal Data Collected	Applied authorization	Business Function	Remarks
Jiguang -Message Push SDK	Device Identifier, device identification code	Device information, modify local files	Receive APP push messages	If you don’t grant permission, you will not be able to use the feature service
Xiaomi Open Platform -Message Push SDK	Device Identifier, device identification code	Device information, modify local files	Receive APP push messages	If you don’t grant permission, you will not be able to use the feature service
Huawei Developer Alliance APP -Message Push SDK	Device Identifier, device identification code	Device information, modify local files	Receive APP push messages	If you don’t grant permission, you will not be able to use the feature service
OPPO Open Platform -Message Push SDK	Device Identifier, device identification code	Device information, modify local files	Receive APP push messages	If you don’t grant permission, you will not be able to use the feature service
VIVO Open Platform News -Message Push SDK	Device Identifier, device identification code	Device information, modify local files	Receive APP push messages	If you don’t grant permission, you will not be able to use the feature service

（1） Jiguang Message Push SDK: In order to provide you with message notification services including alarm message and APP messages in a timely manner, we use the Jiguang Message Push SDK provided by Shenzhen Hexunhuagu Information Technology Co., Ltd., and need to obtain your network information and device information. The related permissions include ACCESS_NETWORK_STATE to view network status, CHANGE_NETWORK_STATE to change network connectivity, READ_PHONE_STATE to read mobile phone status and identity, ACCESS_WIFI_STATE to view WLAN status. If you want to know more, you can visit the relevant documentation of the SDK: https://docs.jiguang.cn//jpush/guideline/intro/

（2）Xiaomi Open Platform Message Push SDK: If you are using a Xiaomi mobile phone, in order to provide you with message notification services including order status reminders, system reminders, event reminders, SMS reminders, incoming call reminders, comments and responses, we use Beijing Xiaomi Technology Co., Ltd. The Xiaomi Open Platform Message Push SDK provided by the company needs to obtain your network status information (including device MAC address, IP address, wireless network name, wireless network device MAC address), device information (including device unique identifier, IMEI, system version, Mobile phone manufacturer, SIM card serial number, AndroidID, device MAC address), read local files, write local files, the permissions involved include: WRITE_EXTERNAL_STORAGE modify/delete the content in the SD card, READ_EXTERNAL_STORAGE read the content on the SD card, ACCESS_NETWORK_STATE view Network status, CHANGE_NETWORK_STATE to change network connectivity, READ_PHONE_STATE to read mobile phone status and identity, ACCESS_WIFI_STATE to view WLAN status. If you want to know more, you can visit the relevant SDK documentation: https://dev.mi.com/console/appservice/push.html

（3）Huawei Developer Alliance Message Push SDK: If you are using a Huawei mobile phone, in order to provide you with message notification services including order status reminders, system reminders, event reminders, SMS reminders, incoming call reminders, comments and responses, we use Huawei Technologies Co., Ltd. The Huawei Developer Alliance News Push SDK requires obtaining your network status information (including device MAC address, IP address, wireless network name, wireless network device MAC address), device information (including device unique identifier, IMEI, system version, mobile phone) Manufacturer, SIM card serial number, AndroidID, device MAC address), read local files, write local files, the permissions involved include: WRITE_EXTERNAL_STORAGE to modify/delete the content in the SD card, READ_EXTERNAL_STORAGE to read the content on the SD card, ACCESS_NETWORK_STATE to view the network Status, CHANGE_NETWORK_STATE to change network connectivity, READ_PHONE_STATE to read mobile phone status and identity, ACCESS_WIFI_STATE to view WLAN status. If you want to learn more, you can visit the relevant SDK documentation: https://developer.huawei.com/consumer/cn/doc/development

（4）OPPO Open Platform Message Push SDK: If you are using an OPPO mobile phone, in order to provide you with message notification services including order status reminders, system reminders, event reminders, SMS reminders, incoming call reminders, comments and responses, we use OPPO Guangdong Mobile Communication Co., Ltd. The OPPO open platform message push SDK provided by the company needs to obtain your network status information (including device MAC address, IP address, wireless network name, wireless network device MAC address), device information (including device unique identifier, IMEI, system version, Mobile phone manufacturer, SIM card serial number, AndroidID, device MAC address), read local files, write local files, the permissions involved include: WRITE_EXTERNAL_STORAGE to modify/delete the content in the SD card, READ_EXTERNAL_STORAGE to read the content on the SD card, ACCESS_NETWORK_STATE view Network status, CHANGE_NETWORK_STATE to change network connectivity, READ_PHONE_STATE to read mobile phone status and identity, ACCESS_WIFI_STATE to view WLAN status. If you want to know more, you can visit the relevant SDK documentation: https://open.oppomobile.com/wiki/doc/search

（5） Vivo Open Platform Message Push SDK: If you are using a vivo mobile phone, in order to provide you with message notification services including order status reminders, system reminders, event reminders, SMS reminders, incoming call reminders, comments and responses, we use Vivo Mobile Communications Limited The vivo open platform message push SDK provided by the company needs to obtain your network status information (including device MAC address, IP address, wireless network name, wireless network device MAC address), device information (including device unique identifier, IMEI, system version, Mobile phone manufacturer, SIM card serial number, AndroidID, device MAC address), read local files, write local files, the permissions involved include: WRITE_EXTERNAL_STORAGE to modify/delete the content in the SD card, READ_EXTERNAL_STORAGE to read the content on the SD card, ACCESS_NETWORK_STATE view Network status, CHANGE_NETWORK_STATE to change network connectivity, READ_PHONE_STATE to read mobile phone status and identity, ACCESS_WIFI_STATE to view WLAN status. If you want to learn more, you can visit the relevant SDK documentation: https://dev.vivo.com.cn/documentCenter/doc/135

We will conduct strict security technology testing and access control on the SDK of authorized partners. For companies and organizations with which we share personal information, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with this privacy policy and our other relevant confidentiality and security measures. Our partners have no right to share your personal data for any other purposes. If we want to change the purpose of processing personal information, we will again ask you for your authorization and consent.

6、Data Deletion

If you no longer use our products and services and do not want to keep your account, you can apply to cancel your account.

6.1Ways to cancel account You can log out your account by clicking "Profile—My Profile Picture—Delete Account". After you confirm and choose to delete your registered account, we will delete your personal account and all your personal data;

6.2You can also contact us at to deactivate your personal account and delete all your personal data

7、Data Security and Retention Period

We will retain your information for the period (1 year) to achieve the purposes described in this personal data protection policy. We will store your personal data while you are our customer or after you no longer use our services, but this is only necessary or in response to legal requirements. We will strictly implement applicable obligations and exceptions under relevant laws, and take appropriate organizational and technical measures to protect the personal data and traffic data provided to us or collected by us. Your personal data and traffic data are only accessible by authorized employees or third parties, and will only be stored when necessary until the original purpose of the collection or a directly related purpose is fulfilled, unless the personal data and traffic data are also stored To comply with any applicable laws or contractual obligations.

8、User Personal Data Management

You can contact us by email, change the scope of your authorization to continue to collect personal data or withdraw your authorization by notifying us to delete your personal data and turning off the device function. You can also withdraw all our authorization to continue to collect your personal data by canceling your account.

9、Description of Personal Sensitive Data

Sensitive personal data refers to personal data that, once leaked, illegally provided, or misused, may endanger personal and property safety, and easily lead to personal reputation, physical and mental health damage, or discriminatory treatment.Mainly include: personal property information (including bank accounts, loan information, transaction and consumption records), personal biometric information (including fingerprints, facial recognition features), personal identification information (including ID cards, passports, driving licenses, social security cards, residence ID card and other information that can be used for identification), other information (including address book, personal phone number, whereabouts, web browsing records, accommodation information, precise location information).These personal sensitive information will be strictly protected. The Ringa platform privacy policy reminds you that your personal sensitive data may be disclosed when you use the products or services we provide you. Therefore, you need to carefully consider before using the products or services we provide you. You agree that this personal sensitive data will be processed in accordance with the purposes and methods stated in this privacy policy.

10、Protection of Personal Data

We will take various precautions to protect your personal information to protect your personal information from loss, misappropriation and abuse, as well as unauthorized access, disclosure, alteration or destruction. To ensure the security of your personal information, our company has strict information security regulations and procedures, and a dedicated information security team strictly implements the above measures within the company. We attach great importance to the protection of the personal information of minors. If you are a minor (European Union: under 16 years old; other regions: please refer to applicable local laws and regulations), you should obtain the consent of your legal guardian before using our products and services. We protect the personal information and privacy of minors in accordance with the requirements of applicable laws.

11、User rights

According to specific scenarios, you have the right to exercise the following rights at any time:

11.1 Have Right to Access:

You can obtain the following information:: Confirm whether your personal information is processed, the purpose of processing (purpose), data type, storage period or standard.; Your rights information (rights to correct, delete, restrict, and refuse).; A copy of your personal information.

11.2 Have Right to correction:

You have the right to correct wrong personal information.

11.3 Have Right to erasure:

You have the right to delete your personal information.

11.4 Have Right to restrict processing:

Under certain circumstances, you have the right to request us to restrict the use of your personal information. When you think that your personal information still needs to be retained, but we are not allowed to use it, you can make a request for restriction of processing.

11.5 Data Portability:

You have the right to request the transfer of your personal information to another data controller, and we should cooperate.

11.6 Right to object:

As the data subject, you have the right to withdraw your previous consent, but it does not affect the processing based on your consent before the withdrawal.
If the legal basis for processing personal information is in the public interest, or the legitimate interests of the data controller and third parties (that is, the last two of the six legal basis for processing personal data), you have the right to object, the data controller This part of the data processing must be stopped immediately.

11.7 Not subject to automated decision-making (including portraits):

You, as a data subject, have the right not to be subject to automated decision-making. Any automated decision (including portrait) requires your express consent.

11.8 Have Right to complain

You also have the right to make a complaint to the supervisory authority. In this case, you need to contact the supervisory authority.

12、Policy update

We may revise and update this policy at any time. Subject to your valid consent under applicable legal requirements, if you continue to use the relevant services of the Ringa platform on the date when the revision and update formally take effect, you are deemed to agree to our revision and update.

13、Contact Us

If you have any questions, comments or suggestions about this policy or related to personal data protection or privacy protection, please contact our personal information protection officer by email: iot@cmi.chinamobile.com