LTWOO APP Privacy Policy



Our privacy policy was updated on January 1st, 2023.


Please take some time to familiarize yourself with our privacy policy. If you have any questions, please contact us.



Introduction



LTWOO APP is developed and operated by Zhuhai L-TWOO Sports Technology Co., Ltd. We know the importance of personal information to you, so we attach great importance to protecting your privacy and personal information. We also treat and handle the contents of this policy with great rigour.

You should carefully read and fully understand this Privacy Policy before using our products/services. If you do not agree with this policy, it may result in our products/services not functioning properly, or the service effect of our products/services not functioning properly. You should immediately stop accessing and using our products/services. Your use or continued use of the products/services we provide means that you fully understand and agree to the full contents of this Privacy Policy, including the updated version.

We will do our best to prevent your information from being leaked, damaged or lost through reasonable and effective information security technologies and management processes.

We strictly abide by laws and regulations, protect your communication secrets and provide you with secure communication services.

In order to provide you and other users with better service, we only collect the necessary information.



1. What information do we collect and how do we use it



(1) Where you authorize us to collect and use your personal information


The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws, regulations and other regulatory documents. You have the right to choose whether or not to provide this information, but in most cases, if you do not, we may not be able to provide you with the appropriate services or respond to your questions. These include:

(1) Device Connection


Provides services for LTWOO APP, enabling you to safely connect and manage smart devices. We may collect information about your login account number, mobile phone, IP address, device, and LTWOO APP account number and device. This information will be used to provide you with the ability to connect devices, discover nearby devices, and manage devices. The above information is detailed as follows:

* Login account information: account number (mobile phone number, email address), nickname, avatar information.
* Mobile phone related information: hardware device identification (imsi, imei, meid, device hardware serial number, SIM card identification, OAID, Mac address, Android ID), mobile phone model, system version information, system language, country or region set by mobile phone, version number of application store, mobile screen size and resolution, CPU and display device related information.
* Information collected during connection to smart devices: Based on the type of smart devices you need to link to, we may collect:

  o Smart devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, Wi-Fi Mac address, Wi-Fi password), device Mac address, device ID.
  o Smart devices connected via Wi-Fi after local connection via Bluetooth: Wi-Fi information (SSID, BSSID, Wi-Fi Mac address, Wi-Fi password), device Mac address, device Bluetooth Mac address.
  o Smart devices connected via Bluetooth: device Bluetooth Mac address, device ID.
  o Smart devices connected via Zig-bee: Mac address, device ID.



(2) You may choose whether or not you authorize us to collect and use your personal information


In order to better enjoy the control, management, etc. of the smart devices that LTWOO APP provides to you, your personal information may be collected and used in our additional functions below. If you don't provide this personal information, you can still use the basic services of LTWOO APP, but you may not be able to use the additional features that are convenient for you. These additional features include:

(1) Application and firmware upgrade


In order to keep you up to date with the latest LTWOO APP service, we may use the version information of your LTWOO APP application and the mobile phone model to upgrade your LTWOO APP application. In the meantime, we may collect a list of smart devices and version number information that you have connected to to provide you with upgrade capabilities for smart devices to ensure that you can use the latest version of services, including firmware versions.

(2) User Feedback


We may collect questions from you, fill in phone numbers or mailboxes, add pictures or videos, and submit problem logs that will be used to better understand your problems and to contact you.



(3) LTWOO APP alteration privilege call instructions


In addition, the following device privileges may be triggered when you use LTWOO APP. In order to better manage your information, we will synchronously inform you of the purpose of using this privilege when applying for product use process privileges, and if you do not open this privilege, you may want to review it carefully. Before you use a specific function, you can choose whether to authorize the following permissions. At the same time, you can change the authorization status at any time through the device's permission settings page.

The following are details of the functions and permissions to invoke them for your reference:

1. Read and write external storage (Android version): Used to read and write photos and files on devices such as upload avatars, user feedback, etc.

2. Location permissions (Android, iOS version): Used to identify areas, discover nearby smart devices, and discover lists of nearby WLANs.

3. Camera permissions (Android, iOS version): Used for functions such as taking photos and uploading avatars.

4. Read phone permissions (Android): Device identifier used to generate a mobile phone locally on the client.

5. Turn on WLAN permissions (Android, iOS version): Connect WIFI issued by the device for device communication when used for fast connection.

6. Turn on Bluetooth privilege (Android, iOS version): Connect the Bluetooth signal sent by the device for device communication when used for fast connection; For smart devices connected via Bluetooth, Bluetooth privileges are also required for communication.

7. Allow unknown app install permissions (Android, iOS version): When our product has updated requirements, we will inform users to upgrade our product via a pop-up box within the product; When users choose to upgrade, we need permission to install our products.

8. Get the software installation list and MAC address (Android, iOS version): Get the user's software installation list, and the MAC address of the peripheral that App needs to get for Bluetooth connection. App needs to get the install list to download App updates.

9. Get device information, IMEI privileges, Android_ID: Aurora Push Service gives APP the ability to push messages and notifications. After integrating Aurora Push SDK, Aurora Push SDK collects personal information necessary to use the service to deliver messages and notifications to end users through encrypted channels. Personal information collected by Aurora Push SDK includes:
1 Device IMEI Information, Android_ID : Used to identify unique users and ensure accurate delivery of message push;
2 Network information and location information: Optimize the network connection request between SDK and Aurora server to ensure the stability and continuity of service; Implement area push function.



10. Collect a list of specific types of sensors: When you use the App, you will obtain orientation sensor and gyroscope device sensor information to identify whether you are a real user. When you use video camera related functions, you will get accelerometer device sensor information, which is used to get the camera angle of the phone.

(4) You are fully aware that we do not need your consent to collect and use personal information in the following situations:


1. Relevant to personal information controllers fulfilling their obligations under laws and regulations;
2. directly related to national security and national defense security;
3. directly related to public safety, public health and important public interests;
4. directly related to criminal investigation, prosecution, trial and execution of judgments;
5. It is difficult to obtain the authorized consent of the principal or other individual for the purpose of safeguarding his or her vital and lawful rights and interests such as life and property; Br> 6. The personal information involved is made public by the subject of personal information to the public by himself;
7. Necessary for signing and performing a contract in accordance with the requirements of the subject of personal information;
8. Collecting personal information from lawfully disclosed information, such as lawful news reports, government information disclosure, etc.;
9. It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of malfunctions of the products or services;
10. Personal information controllers are necessary for news organizations to carry out legitimate news reporting;
11. Personal information controllers are academic research institutions that, when it is necessary to conduct statistical or academic research for the public interest, and when they provide results of academic research or descriptions to the outside world, process the personal information contained in the results to be de-identified.


(5) Non-personal Information


We may also collect other information that is not personally identifiable (that is, information that is not personal), such as statistical data generated when you use a particular service, such as user behavior (including clicks, page jumps, browsing times). The purpose of collecting this information is to improve the services we provide to you. The type and amount of information collected depends on how you use our products and/or services. We aggregate this information to help us provide more useful information to our customers about which parts of our website, products and services they are most interested in. For the purposes of this privacy policy, aggregated data is treated as non-personal information. If we use non-personal information in conjunction with personal information, such information will be treated as personal information during the combined use period.


(6) LTWOO APP access to third-party SDK directory


In order to ensure the stable operation of the Blueprint APP or to achieve related functions, we may access the software development kit (SDK) provided by a third party to achieve the aforementioned purposes. We will conduct strict security monitoring on the SDKs used by partners to obtain personal information to protect the security of your personal information. The relevant third-party SDKs we access are listed in the following directory. You can view the data usage and protection rules of third parties via the relevant links. Please note that the third-party SDK may change its personal information processing type due to version upgrades, policy adjustments, etc., please refer to its official announcement.

Crash Information Collection (Bugly SDK)
Name of the third party: Shenzhen Tencent Computer System Co., Ltd.
Purpose of use: to collect information when the app crashes, so as to troubleshoot problems
Processing method: third party processing by itself
Types of personal information collected: mobile phone model, mobile phone brand, Android system version, Android system api level, manufacturer system version, cpu architecture type, whether the device is rooted, disk space occupied, sdcard space occupied, memory space occupied, network type, Apply the currently running process name and PID
Third-party privacy policy or official website link: https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56




2. How do we use cookies and similar technologies



LTWOO APP and third-party service providers use technologies such as cookies, tags, and scripts to analyze trends, manage websites, track user activity on websites, and collect statistics about the entire user community. We will receive individual or aggregated analysis reports collected through the above techniques. Technologies like this help us better understand your behavior, let us know what parts of our website users are browsing, measure the effectiveness of advertising and web search, and improve them. We treat information collected through cookies and other technologies as non-personal information. However, if local laws treat Internet Protocol (IP) addresses or similar identifiers as personal information, we also treat such identifiers as personal information.

Log file: Like most Web sites, we collect specific information and save it in a log file. Such information may include Internet Protocol (IP) addresses, browser types, Internet Service Providers (ISPs), reference/exit pages, operating systems, date/time stamps, and/or click-stream data. We will not associate automatically collected log data with other information we collect.

Mobile Analysis: In some mobile applications, we use mobile analysis software to better understand the capabilities of our mobile software in your mobile phone. This software may record information such as how often you use the application, what happens within the application, cumulative use, performance data, and where the application crash occurs. We will not associate information stored in the analysis software with any personal information you submit in your mobile application.

Local Storage - HTML5/Flash: We use local storage objects (LSOs), such as HTML5 or Flash, to store content and preferences. Depending on your web browsing behavior, third parties who work with us to provide certain functions or advertise on websites also collect and store relevant information through HTML5 or Flash Cookies. Browsers provide their own management tools to delete HTML5 local storage objects.



3. Your Rights



(1) Control Settings


We acknowledge that privacy concerns vary from person to person. Therefore, we have provided some examples of the various ways LTWOO APP can provide you with options to restrict the collection, use, disclosure or processing of your personal information and to control your privacy settings:
Click on "My-Personal Information" to modify your personal information, including nicknames, avatars, etc. in the LTWOO APP application;
Hardware device control and debugging;
Log in or out of LTWOO APP account.

(2) Your rights to your personal information


According to the applicable national or regional laws and regulations, you have the right to request access to, correct or delete any personal information (hereinafter referred to as a request) that we hold in connection with you.

Most laws require that requests made by the subject of personal information comply with specific requirements. This privacy policy requires that your requests comply with the following circumstances:
Your request should be in writing (unless the local law expressly recognizes the oral application) through our dedicated request channel and for the sake of protecting your information security;
Provide enough information to enable us to verify your identity and ensure that the requester is the person or legal authorizer of the requested information subject;
Once we have sufficient information to confirm that your request can be processed, we will respond to your request within the time required by applicable data protection laws. Specifically:
Based on your requirements and applicable laws, we may provide you with a record of your personal information that we have collected and processed free of charge. If you make other requests for related information, we may charge you a reasonable fee based on the applicable laws and combined with the actual administrative costs.
If you believe that any information we hold about you is incorrect or incomplete, you may request that personal information be corrected or improved for use purposes.

You may be entitled to ask us to delete your personal data in accordance with the applicable laws and regulations. We will evaluate your deletion request and take appropriate steps, including technical means, if the relevant regulations are met. When you or we assist you in deleting the information, we may not be able to delete the information from the backup system immediately because of applicable laws and security technologies. We will store your personal information securely and isolate it from any further processing until the backup can be cleared or anonymous. For example, according to the E-Commerce Law of the People's Republic of China, your goods and services information and transaction information may not be kept for less than three years from the date the transaction is completed.

We have the right to refuse to handle duplicate requests that are meaningless/tangled, that impair the privacy of others, that are extremely unrealistic, that require disproportionate technical work, and that information that has been made public and given in confidentiality and that is not required by local law. If we believe that certain aspects of a request to delete or access data may prevent us from legally using the data for the aforementioned anti-fraud and security purposes, it may also be rejected.

(3) Withdrawal of Consent


You can withdraw your consent by submitting a request, including collecting, using and/or disclosing your personal information that we hold or control. Depending on the specific service you use, you can contact us by phone for related operations. We will process your request after you make it and will not collect, use and/or disclose your personal information after that.

Please note that your withdrawal of consent has certain legal consequences. Depending on the scope of the information you authorize us to process, this may prevent you from enjoying LTWOO APP products or services. However, your decision to withdraw your consent or authorization will not affect personal information processing that was previously developed based on your authorization.

(4) Account Deregistration


You may cancel your previously registered account at any time, and you may do so yourself by supplementing the way you cancel your account.

After you cancel your account, we will stop providing you with products or services and delete or anonymize your information at your request, except as otherwise stipulated by laws and regulations. This may also cause you to lose access to the data in your account. Please be careful.

Revoke your account description:
1. You need to cancel the account you registered with the official channel, you can do the following:
(1) You can apply for cancellation through [Log on to app] - [Click on My] - [Click on Settings] - [Log off Account];
In order to provide you with a more convenient way to log off, we will continue to optimize our products and inform you through a page announcement.
After the cancellation of your account, we will stop providing you with products or services, permanently delete your account, your registration data, all data in your account, and your traces of usage, except for those that must be retained for a certain period of time in accordance with relevant laws and regulations.

2. The cancellation completion time from the time when the customer submits the Cancellation Application to the time when the cancellation is completed shall be completed within 15 working days, excluding holidays.

3. After the cancellation is completed, the customer will no longer be able to log on through the canceled account. Once again log in with the original account as a new customer, The User Agreement, The Privacy Policy and so on need to be re-signed, and the identity of the customer needs to be re-verified.



4. Contact Us


If you have any comments or questions about this Privacy Policy or if you have any questions about our collection, use or disclosure of your personal information, please contact us at the address below and refer to the Privacy Policy. We have a professional team to solve your personal information related rights requests, questions, etc. If your question itself involves something important, we may ask you for more information. If you are not satisfied with the response received, you may refer the complaint to the relevant regulatory authorities in your jurisdiction. If you consult us, we will provide you with information on possible complaint avenues based on your actual situation.



Contact Address:


B-2 Plant No.8, Honghui Five Road, Shuanglin District, Liangang Industrial Zone, Jinwan District, Zhuhai
Telephone: 0756-7795990