Effective Date: May 12, 2021
Revision Date: May 12, 2021
X-Sense USA LLC and its subsidiaries (“X-Sense Home Security,” “we,” or “us,” “X-Sense USA LLC”) are committed to protecting your privacy. This X-Sense Home Security Mobile Application Privacy Policy (referred to as the “Policy”) describes our practices related to information protection of Personal Data that we process through your individual use of the following services, products, and related mobile applications (collectively referred to as “Products”).
When you interact with our Products, please read through the Privacy Policy carefully, and understand our purposes and practices of collection and processing of your Personal Data, including how we use, store, share, and transfer Personal Data. In the Policy you will also learn how to exercise your rights related to accessing, updating, deleting, and protecting your Personal Data.
When you “consent” to this Privacy Policy by registering with your Personal Data or by initiating and using our Products in an appropriate way, if you have not made any statements to the contrary or voiced any concerns, we will assume that you fully understand and have agreed to the Policy. If you have any questions or concerns related to the Policy, please do not hesitate to contact us via:
Privacy Office: [email protected]
For other branded mobile applications powered by X-Sense USA LLC, we control all the Personal Data collected through our Products. We collect the information and the processing of such information shall be limited to the purpose of providing the service for which we have been engaged.
Definitions
In the Privacy Policy, Personal Data refers to information recorded, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information paired with what other information about that individual that we have access to.
Personal Sensitive Data includes ID numbers, personal biometric information, bank account information, communication records and content, property information, credit information, records of whereabouts, accommodation information, health information, transaction information, and Personal Data of minors.
Smart Devices refer to non-standard computing devices produced or manufactured by hardware manufacturers with a human-machine interface and the ability to transmit data that connects wirelessly to a network, and includes smart home appliances, wearable smart devices, smart air-cleaning devices, etc.
Personal Data We Collect
In order to provide our services to you, we will ask you to provide the necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide parts of the services, or even the entire product or service.
1. Information You Voluntarily Provide to Us
Account or Profile Data: When you register an account with us, we may collect your name and contact details, including your email address, phone number, username, and log-in credentials. During your interaction with our Products, we may also collect your nickname, profile picture, country code, language preference, and time zone information from your account.
Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.
2. Information We Collect Automatically
Device Information: When you interact with our Products, we automatically collect device information, such as the MAC address of your devices, IP addresses, wireless connection information, the operating system type and version, application version number, push notification identifiers, log files, and mobile network information.
Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
Log Information: When you use X-Sense Home Security Mobile Application or control Smart Devices through the App, the system and exception log may be uploaded, including the IP address, language you use, version of the mobile operating system, access time, etc. Please note that device information or log information alone is not able to identify specific individuals. If we combine this type of non-personal information with other information or combine it with personal information processes, this type of non-personal information will be treated as personal information, unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such information.
Location Information: When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information, allowing you to use the X-Sense Home Security Mobile Application to pair to your smart device. When you use our specific products or services (such as Bluetooth pairing and location in your country), we may collect your real-time accurate or inaccurate geo-location information. You can reject the location permissions in your mobile device to avoid collection of your location information.
Information Related to Smart Devices
Basic information on Smart Devices: When you connect your Smart Devices to our Products or Services, we may collect basic information about your Smart Devices, including device name, ID, online status, activation time, firmware version, and update information.
Smart Device Settings Information: When you purchase a smart device and set the name or description, for example a Base Station that you name “Living Room Base Station,” as well as any information concerning location changes to the smart device it is paired to, and any adjustments to this setting.
Information Reported by Smart Devices: Depending on the different Smart Devices you have connect to our Products or Services, we may collect different information reported by your Smart Devices. For example, motion sensors can capture objects in motion and report these captured objects back to the base station.
Purposes and Legal Basis for Processing of Personal Data
The purposes for which we may process your personal data are as follows:
To Provide You with Services: We process your account and profile data (including information about the type of services), device information, data usage, location information, and Smart Device related information to provide you with our Products and Services that you purchased. The legal basis for this processing is to perform our contract with you according to the Terms of Service.
To Improve Our Services: We process your device information, data usage, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Service.
Non-Marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you cannot opt out of receiving these communications. The legal basis for this processing is to perform our contract with you according to our Terms of Service.
Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you regarding our Products and Services. If we do so, each communication sent will contain instructions detailing how to opt out of receiving future communications of this nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest, or other promotion, we may use your Personal Data to manage these activities.
Personalization: We may process your account and profile data, data usage, and device information to personalize product design and to provide you with services tailored to you, such as recommending and displaying information and advertisements regarding products suited for you, and to invite you to participate in surveys related to your use of our Products. The legal basis for this processing is your consent.
Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations, (b) to comply with legal processes, (c) to respond to requests from public and government authorities, (d) to enforce our terms and conditions, (e) to protect our operations, business, and systems, (f) to protect our rights, privacy, safety of property, and/or that of other users, including you, and (g) to allow us to pursue available remedies or limit damages we may sustain. If there are any changes to the purposes for processing your personal data, we will inform you of such changes via email (specified in your account) and/or a prominent notice on our website of such changes of purposes and the choices you may have regarding your Personal Data.
Sharing, Transferring, and Disclosure of Personal Data
Data Sharing
At X-Sense USA LLC, we only share Personal Data in ways that we tell you about. We may share your Personal Data under the following circumstances:
Only when we have obtained your explicit consent or authorization in the first place, or when we are required to provide information to support your dispute resolutions with other uses in accordance with your formal request.
(a) In accordance with relevant agreements we have with you (including electronic agreements and corresponding Terms of Service), or other legal documents provided.
(b) In accordance with applicable laws and regulations, judicial procedures, and other mandatory administrative or judicial requests.
(c) In order to comply with the law, execution orders, or to adhere to our Terms of Service and other agreements to the extent permitted by laws and regulations, and only to protect the rights, privacy, property, and security from damage for X-Sense USA LLC affiliates, partners, yourself, and other X-Sense USA LLC users.
(d) To protect our facilities, operations, and systems, and to seek remedies available for this purpose or to limit the damages we may need to provide.
(e) For the academic research.
(f) For public interest in compliance with laws and regulations.
(g) To subsidiaries or affiliates within our corporate family to carry out regular business activities. We will only share necessary Personal Data for the said purpose, and our affiliates will also be bound to this Privacy Policy. When the purposes of processing Personal Data changes, we will obtain your explicit consent again so that we can continue to process your Personal Data.
(h) To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us. In this respect we share your Personal Data in a legitimate, necessary, specific, and defined purpose, and only the Personal Data that is required.
(i) To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.
Except for the third parties listed above, when we decide to share your Personal Data, only your consent can authorize us to proceed. The third parties we share Personal Data with are required to be bound to a Non-Disclosure Agreement, as well as this Privacy Policy to process Personal Data according to the defined instruction, security measures, and confidentiality.
Data Transfer
At X-Sense USA LLC, we only transfer Personal Data in ways that we tell you about. We may transfer your Personal Data according to the following reasons:
(a) To obtain your explicit consent or authorization in the first place.
(b) In accordance with applicable laws and regulations, judicial procedures, and other mandatory administrative or judicial requests.
(c) In accordance with relevant agreements we made with you through contract (including electronic agreements and corresponding Terms of Service) or other legal documents provided.
(d) In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stocks (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data. Under such circumstances, we will require the third parties who have transferred Personal Data to comply with this Privacy Policy, otherwise we will require them to obtain your consent and authorization to process your Personal Data.
Data Disclosure
We will only disclose your Personal Information under the following conditions, and will adopt industry-standard security measures:
(a) Upon your request and through the way in which you consent;
(b) Where it is necessary to provide Personal Data in accordance with laws and regulations, mandatory administrative enforcement, or judicial requirements. Under the premise of complying with laws and regulations, when we receive the above request for a disclosure of Personal Data, we will require the corresponding valid legal documents, subpoenas, or investigation letters. To the extent permitted by laws and regulations, the files we disclose will be protected by encryption keys.
Security Measures
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data, including but not limited to the following security measures: establishing strict internal data management systems and processes, encryption of Personal Data (including transmission, storage, and processing), desensitization of such data, segregation of employees’ roles and duties, conducting security and privacy awareness training for our internal employees, access control and monitoring, etc., to prevent leakage, illegal usage, unauthorized access or infringement of Personal Data.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you should immediately notify us of the issue by emailing the Privacy Office.
If a security incident affects the security of your account or Personal Data, we will promptly notify you via email, phone, or Notification Center, etc. that you have provided to us, and keep you informed of any appropriate actions to reduce or prevent related risks. When necessary, we will immediately take the appropriate remedial measures in accordance with the internal security response plan and report to the relevant authorities accordingly.
Individual Privacy Rights
We respect your rights and control over your Personal Data. You may exercise any of the following rights via Help & Feedback by emailing us through the Privacy Office.
You do not have to pay a fee for executing your personal rights. According to different data protection laws, your request of personal rights will be handled within 15 business days, or within 30 calendar days, due to different response requirements.
If you decide to email us, please make clear what information you would like to have changed in your request, whether you would like to have your Personal Data deleted from our database, or any other limitations you would like to have put on your Personal Data. Please note that we may ask you to verify your identity before taking further actions on your request for security purposes.
You may:
Request access to your Personal Data that we have collected;
Request that we correct inaccurate or incomplete Personal Data about you;
Request deletion of your Personal Data;
Request restrictions, temporarily or permanently, of our processing of some or all of your Personal Data;
Request a transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated;
Opt out or object to our use of your Personal Data where our use is based on your consent or our legitimate interests.
About Deleting the Account: You can find the Delete function through the Personal Center>>Account Settings>>Email.
International Transfer of Collected Information
X-Sense USA LLC adheres to Data Localization Requirements and Minimum Data shall involve International Transfer. In order to facilitate our operations, we may transfer, store, and process your Personal Data in jurisdictions outside of where you live. Laws in countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using the following approach:
Including but not limited to the agreement based on approved EU standard contractual clauses per Art. 46 GDPR. For more information, visit:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
If you would like further details on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.
Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy unless there is a specific legal requirement for us to keep the data for a longer period.
We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after this retention period ends, we will destroy and/or delete your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further use of your Personal Data.
Privacy of Minors
Protecting the privacy of minors is especially important to us. According to the different data protection and privacy regulations, the Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of eighteen (18) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of eighteen (18) without permission from that child’s parent or legal guardian, we will take steps to remove that information.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices, at least on an annual basis. We will not undermine your privacy rights under this Privacy Policy without your explicit consent. For any regular updates, we will provide such information in the Policy page, or Notification Center in the Application, or other appropriate channels. We encourage you to periodically review this page for the latest information on our privacy practices.
If we make any material changes, we will notify you by channels that you can easily access, for instance, email or SMS (sent to the email address specified in your account), or by means of a notice on this website prior to these changes becoming effective.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us at:
X-Sense USA LLC
Postal Mailing Address: 1209 Orange St, Wilmington, DE 19801, USA
Privacy Office: [email protected]