PongBot Privacy Policy

Our Privacy Policy will take effect on January 06, 2023. From this date onwards, this Privacy Policy can provide privacy details on how we manage your personal information for PongBot products and services. Please take a moment to familiarize yourself with our Privacy Policy and let us know if you have any questions.

Our commitment to you

Shanghai Future Mind Co., Ltd. (hereinafter referred to as "PongBot", "we", "our" or "us") highly value your privacy. PongBot is a smart device control and management platform provided to you by PongBot.

Your privacy is extremely important to us. This Privacy Policy is a statement and commitment covering the aspect of privacy for PongBot app and constitutes an integral part of the PongBot Privacy Policy. In the event of any inconsistency between the PongBot Privacy Policy and another specific agreement involving PongBot, the terms of this Privacy Policy shall take precedence. Matters not expressly provided for under this Privacy Policy shall by governed by the PongBot Privacy Policy. We recommend that you carefully read the PongBot Privacy Policy and pay particular attention to provisions on “protection, security measures, and cross-border data transfers of information of minors”.

This Privacy Policy was formulated to fully take your needs into account. It is important that you fully understand our personal information collection and usage practices and ensure that you are ultimately able to exercise control over the personal information you provide to us. This Privacy Policy sets out how we collect, use, disclose, process, and store any information that you provide to us when you use our PongBot app. As used in this Privacy Policy, “personal information” means information that can be used to identify an individual, either from that information alone or in conjunction with other related information. We will only use this information in strict accordance with this Privacy Policy.

Ultimately, we hope to give our users the best experience possible. Should you have any questions about our data handling practices as described in this Privacy Policy, please contact us by visiting yanfa@futuremind.com.cn so that we can respond to your specific concerns. We would be happy to receive any feedback you may have.

I. What Information We Collect and How We Use It

(I) Circumstances which require you to authorize us to collect and use your personal information

Personal information is collected in order to provide you with products and/or services as well as to ensure legal compliance on our part with applicable laws, regulations, and other regulatory documents. You have the right to choose whether or not to provide this information. However, in most cases, if you do not provide such information, we may be unable to provide corresponding services to you, or we may be unable to respond to a problem you encounter. These features include:

(1) Smart device connections

In order to provide you with PongBot services and allow you to securely connect to and manage smart devices, we may collect your Wi-Fi information, location information, account login information, information related to your mobile phone and smart device, and information associated with your PongBot account and smart device. This information will be used to provide you with various functionality including pairing with and connecting to smart devices, discovering nearby devices, and device management. Specific examples involving the above information are set out below:

• Account login information: PongBot account, nickname, and profile picture information.
• Mobile phone related information: Hardware-based identifiers (MAC address, Android ID), phone model, OS version, OS language, country or region, App Store version, screen size and resolution, CPU, and display device related information.
• Information to be collected during connection to a smart device: Based on the type of the smart device you need to get connected to, we may collect the following information:
• Smart devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, MAC address of Wi-Fi, Wi-Fi password), MAC address of the device, and device ID.
• After establishment of a local connection via Bluetooth, smart devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, MAC address of Wi-Fi, Wi-Fi password), MAC address of the device, and MAC address of Bluetooth on the device.
• Smart devices connected via Bluetooth: MAC address of Bluetooth on the device, and device ID.

(2) Using smart devices for scenes management:

We may collect information that you provide relating to scenes settings for smart devices in order to facilitate smart scenes management. This will allow you to enjoy greater convenience when using smart devices (for example, when using multiple smart devices, being able to quickly identify that a robot is in home instead of club).

(3) Device sharing

We provide support for you to share smart devices with others through PongBot accounts. Sharing a smart device with someone else allows them to also control the device. In order to enjoy this feature, we may collect your account ID, the ID you provide relating to the account with which you share access, and shared device information (including device ID, device name, device verification key, and sharing status of device). Such information allows us to give you the ability to share device control and usage with the accounts of other PongBot users as well as to display the device’s sharing status on the My Devices page in the PongBot app.

(4) App and smart device updates:

To ensure you can continue enjoying the latest PongBot services, we may use the version information of your PongBot app and phone model in order to provide you with updates to the PongBot app. We may also collect a list of your connected smart devices and associated version information in order to provide you with smart device updates so that you can use the latest version of the service (including firmware version).

(5) Smart scenes (smart device connections):

We provide support for you to configure certain rules to establish smart connections between devices under specific conditions. In order to enjoy this feature, we may collect your location information, smart scene rule settings, and designated device status so as to enable specific device functions to be executed according to the commands you give. Please rest assured that this functionality cannot be enabled without your express consent and rule configurations.

(6) Provision of content-related support (for example, articles and audio content playback)(In some jurisdiction only):

To help you make better use of smart devices, we will provide you with selected articles on such devices. When you view these articles, we will not collect any information from you.

If you’ve gotten connected to PongBot a smart device that plays media content, you can select and control on the corresponding support page the music or content to be played. We may collect smart device type registered with your account, to make available corresponding smart device control functions.

(II) Circumstances which you may authorize us to collect and use your personal information

To make you enjoy better control and management of smart devices provided by PongBot, we may collect and use your personal information in the following additional features. If you do not provide these personal information, you can still use the basic services of PongBot, but you may not be able to use such valuable additional features. These additional features include:

(1) User feedback:

We may collect feedback from you on issues that you report to us, a feedback log, and any phone numbers or email addresses that you provide to us. This information will be used to help us better understand any problems you encounter as well as to allow us to contact you.

(III) Situations where we obtain your personal information from a third party

Under certain conditions permitted by law, we may obtain your personal information from a third party. For example, with the smart scenes function (smart device connections), if you provide authorization, we may obtain the device status of the smart device from the area where the smart device is located in order to determine whether to activate a smart scene. You can add or remove smart connection rules on the “Smart” page. You can also choose whether to enable or disable smart connections on the Smart Devices page.

(IV) Non-personal information

We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service, such as including clicks, page redirects, and browsing time Such information is collected in order to improve the services we provide to you.

II. Sharing Your Personal Information with Third Party Service Providers

We do not sell any personal information to third parties. To help us provide you with products and services described in this Privacy Policy, we may, where necessary, share your personal information with our third party service providers and business partners. PongBot will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. Location-based service providers: The location-based services component of our services is provided by third party providers including AutoNavi. In order to offer you location-based services, we may provide information such as your device identifier information to any of these service providers. If we share your personal information with these third parties, we will use encryption technology or other means to keep your information secure. We perform reasonable reviews of the data security practices of companies and organizations with which we share personal information and/or also sign strict data processing agreements with them. Furthermore, we require third parties to take adequate measures to safeguard your information and to strictly comply with applicable laws, regulations, and regulatory requirements.

III. Retention Policy

We will retain personal information for the period of time needed to fulfill the purpose for which it was collected as described in this Privacy Policy, or we will retain personal information in order to comply with applicable legal requirements. We will cease to retain your personal information and will delete or anonymize it once the purpose of collection is fulfilled, or after we confirm your request for deletion or cancellation, or after we discontinue the corresponding product or service. We will continue to retain relevant information in accordance with applicable laws even if further information processing is unrelated to the original purpose of collection, provided that doing so would be in the public interest or for scientific or historical research or statistical purposes.

IV. Your Rights

(I) Settings control

We recognize that privacy concerns differ from person to person. Therefore, we provide examples of ways PongBot makes available for you to choose to restrict the collection, use, disclosure, or processing of your personal information and control your privacy settings: Enable or disable location access, camera, microphone, and read/write access permissions on your phone;

• Modify personal information such as your nickname or profile picture. To do so, open the PongBot app and go to “Me > Settings > Personal data”;
• Enable or disable smart device connections;
• Log into or out of your PongBot Account.

If you have previously agreed to our using of your personal information for the abovementioned purposes, you may change your mind at any time by writing us a letter or visiting yanfa@futuremind.com.cn .

(II) Your rights to your personal information

Subject to the applicable laws and regulations of your country or region, you have the right to request access to, correct, and/or delete any personal information we have about you (hereinafter referred to as a “request”).

For details relating to the personal information in your PongBot account, you may also access and change them by logging into your account on your device. For more information, please write us a letter or contact us by visiting yanfa@futuremind.com.cn. Most laws require a data subject to meet certain requirements when making a request. This Privacy Policy requires any request you make to meet the following conditions:

• To safeguard your personal information, your request should be made in writing through our designated request channel (unless oral requests are expressly permitted by local law);
• Provide enough information for us to verify your identity and ensure that the requester is the data subject or is otherwise legally authorized to request the information;
• Once we have a sufficient amount of information and confirm that we are able to process your request, we will respond to your request within the period specified by applicable data protection laws. Specifically:
• We may provide to you, in accordance with your request and applicable laws and regulations, a free copy of the record of personal information about you that we have collected and processed. However, if you make an additional request regarding related information, we reserve the right, pursuant to applicable law, to charge you a reasonable fee for your data access request based on actual management costs involved.
• If you believe that any information we have about you is incorrect or incomplete, you may request to correct or modify your personal information based on the purpose of use.
• Subject to your applicable laws and regulations, you may have the right to ask us to delete your personal data. We will conduct an evaluation according to your request for deletion and, if corresponding rules are met, we will take corresponding steps, including technical measures, to carry out your request. After you delete or after we assist you in deleting your information, it may not be possible for us to immediately delete corresponding information from our backup systems due to applicable laws and security technologies. In such event, we will ensure your personal information is kept secure and prevent it from being subjected to any further processing until the backup can be cleared or anonymized. For example, the “E-Commerce Law of the People’s Republic of China” requires your goods and services information and transaction information to be retained for a period of no less than three (3) years from the date of completion of the transaction.
• We have the right to refuse to process requests considered to be frivolous or vexatious, requests that harm the privacy of others, extremely unrealistic requests, requests that would require a disproportionate technical effort, requests that are not required to be granted under local law, and requests involving information already available to the public or given under confidential conditions. We may also refuse a request in cases where we believe that certain aspects of a request to delete or access data might cause us to be unable to legally use the data for the aforementioned anti-fraud and security purposes.

(III) Withdrawal of consent

• You may withdraw your consent for the collection, use, and/or disclosure of your personal information in our possession or control by submitting a request. You may contact us for relevant requests by going to "Me > User Agreement and Privacy Policy" or visiting yanfa@futuremind.com.cn based on the specific service you are using. We will process your request within a reasonable time frame from the time when the request was received, and thereafter not collect, use and/or disclose your personal information as per your request.
• Please note that your withdrawal of consent could result in certain legal consequences. Depending on the extent to which you authorize us to process your personal information, it may mean that you will no longer be able to enjoy the use of PongBot products or services. However, any decision on your part to withdraw your consent or authorization will not affect personal information processing previously performed with your permission.

(IV) Cancellation of service or account

If you wish to cancel a specific product or service, you may do so by visiting yanfa@futuremind.com.cn. If you wish to cancel your Mi account, please exercise caution before doing so, as canceling your account will prevent you from being able to enjoy the full line of PongBot products and services. To protect the legitimate rights and interests of you and others, we will determine whether to grant your cancellation request based on your usage of PongBot products and services. For example, if you an outstanding amount due, we will not be able to immediately grant your request.

V. HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY

PongBot runs and controls facilities worldwide to process and back up personal information. Currently, PongBot runs data centers in China and the United States. For the purposes of this Privacy Policy, your information may be transferred to these data centers according to applicable laws.

We may also share your personal information with our Third Party Service Providers and business partners, therefore, your information may also be transferred to other countries or regions. The jurisdiction of these facilities worldwide may not implement the same personal information protection standards as in your jurisdiction. Risk may exist depending on different data protection laws. However, this does not change any of our commitments to comply with this Privacy Policy and safeguard your personal information.

Specifically,

• The personal information collected and generated during our operations in the mainland of the People's Republic of China will be stored in the data centers operated in China's mainland, except for information that is allowed for cross-border transfer according to applicable laws.

• The personal information collected and generated during our operations in USA will be processed and stored in the data centers operated in USA, except for information that is allowed for cross-border transfer according to USA laws.

To the extent that we may need to transfer your personal information outside of your jurisdiction, whether to our affiliated companies or Third Party Service Providers, we shall do so in accordance with the applicable laws. We will ensure that all transfers will be carried out in accordance with requirements under your applicable local data protection laws by putting in place consistent and appropriate safeguards. You are entitled to learn the security mechanism we implemented by visiting yanfa@futuremind.com.cn to contact us.

VI. Third Party Websites and Services

Our Privacy Policy does not apply to products or services offered by a third party. PongBot products or services may include, depending on which ones you use, third-party products or services such as location-based services. Some products or services may be provided in the form of links to third-party websites, while others may be in the form of SDKs, APIs, etc. Third parties may collect your information when you use such products or services. For this reason, we strongly suggest that you read the third party’s privacy policy just as you have taken the time to read ours. We are not responsible for and cannot control how third parties use the personal information that they collect from you. Our Privacy Policy does not apply to other websites that are linked via our services.

An example of third-party terms and a privacy policy which apply when you use the aforementioned products or services is provided below:

• Location-based service provider’s privacy policy:
  • AutoNavi Software Co., Ltd. Privacy Policy

VII. Contact Us

If you have any questions or feedback regarding this Privacy Policy, or if you have any questions regarding how we collect, use, or disclose your personal information, please contact us at the following address or by visiting yanfa@futuremind.com.cn and mention that your message is in reference to the “Privacy Policy”. Our dedicated response team will be able to handle any issues you may have about rights requests or questions about your personal information. If you have a particularly critical issue that needs to be addressed, we may ask you to provide us with more information. If you are not satisfied with the response you receive, you may escalate your complaint to the applicable regulatory authority in your jurisdiction. Upon request, we will provide you with information on how to file a complaint based on your actual circumstances.

Address:

• Building A, 1107, No. 199 Jinwan Road, Pudong New District, Shanghai.