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Privacy Policy

MIAN Privacy Policy

Effective Date: 2020-06-18

Updated Date: 2021-05-18

MIAN Inc., its affiliates and subsidiaries (“we”, “us”, “our”, “MIAN”) are committed to protecting your privacy. This Mobile Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

        ·MKANG Smart Mobile Application

        ·MKANG Smart WeChat mini program

In this Privacy Policy, “Personal Data” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual.“Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart fire fighting equipment, smart home appliances, smart wearable devices, smart air cleaning devices, etc. “Apps” refers to those mobile applications developed by MIAN that provide end users remote control to Smart Devices and with the ability to connect to MKANG IoT Platform.

For other branded mobile applications powered by MIAN, our Clients control all the Personal Data collected through our Products. We collect the information under the direction of our Clients and the processing of such information shall be limited to the purpose of providing the service for which our Clients has engaged us.If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.

What Personal Data do We Collect

In order to provide our services to you, we will ask you to provide 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 you with our products or services.

When you are still in the stage of understanding our products, you can directly use some products or services of this application, such as searching or browsing the functions on the MKANG application. At this time, we will not collect your account and related information.

However, if the products and / or services you use or purchase are based on your account information, please go to the registration / login page to register or log in.

1. Information You Voluntarily Provide Us

-Account information: when you register our account, we will collect your account name and contact information, such as your email address, telephone number, user name and login credentials. During your interaction with our products, we will further collect the nickname, avatar, country code, language preference or time zone information in your account.

-Feedback: when you use the feedback and suggestion function in our products, we will collect your email address, mobile phone number and feedback content, so as to deal with your problems and equipment faults in time.

At the same time, according to different application products and services, MKANG will collect corresponding and necessary personal information to provide you with products and services.

-Information collected based on additional features provided

In order to provide you with more convenient and high-quality products and / or services and strive to improve your experience, we will collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of the basic services of MKANG application and MKANG wechat applet, but you cannot obtain the user experience brought to you by these additional services. These additional services include:

(1)Additional services based on location information:

When you enable the location function of your mobile device through system authorization and use the location-based services, we will collect and use your location information so that you can distribute the network with your smart device by using MKANG application or MKANG wechat applet. You can turn off the location service in the system of your mobile device and stop our collection of your location information.

(2)Camera based add-on services:

You can use this function to scan the code after turning on the camera permission, which is used to add the equipment you purchased, shoot videos and other functions. Please know that even if you have agreed to turn on the camera permission, we will only obtain information when you actively scan code, shoot, etc.

(3) Additional services for picture / video access and upload based on photo album (picture library / Video Library):

You can use this function to upload your photos / pictures / videos after opening the photo album permission, so as to realize the functions of changing avatars, reporting equipment use problems and providing certificates. When you use avatar and other functions, we will not recognize this information; However, when you report a device use problem, we will locate your problem through the photos / pictures you uploaded.

(4)Additional services based on storage permissions:

We apply to you for this permission to ensure the stable operation of the client. After you turn on the permission that we can read / write to your device storage, we will read or write necessary information such as pictures, files and crash log information from your device storage space to provide you with functions such as information publishing or local recording of crash log information.

(5)Additional functionality based on message notification permissions:

We apply to you for this permission to push you notifications about products or services. In particular, you need to send an alarm to you when you purchase relevant services so that you can capture the real-time status.

(6)Additional functions based on message push service:

In order to provide you with the message push service function, we have integrated a push SDK to better send alerts to you so that you can capture the real-time status. However, the SDK will collect device information, application list information, network information, location and other related information.

You understand and agree that the above additional services require you to open your access rights to location information (geographical location), camera, photo album (Picture Library) and internal and external storage in your device, so as to realize the collection and use of the information involved in these rights. You can check the status of the above permissions one by one in your device settings, and you can decide whether to turn them on or off.

Please note that if you open any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. If you close any permission, you cancel the authorization. We will no longer continue to collect and use relevant personal information based on the corresponding permission, nor can we provide you with the services corresponding to the permission. However, your decision to close the permission will not affect the previous information collection and use based on your authorization.

2. Information We Collect Automatically

• Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, 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 our app, the system and exception log may be uploaded.

• Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as robot cleaner and weather service.

3. Smart Devices Related Information:

• Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

• Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example, MKANG gas detector may report your device installation address and location, gas concentration, alarm/failure time; A smart camera might collect images or videos it captures.

4.Third party SDK collection and usage instructions

In order to ensure the stable operation of MKANG service or realize relevant functions, we may access the software development kit (SDK) provided by a third party to achieve the above purpose. We will conduct strict security inspection on the application program interface (API) and software tool development kit (SDK) for authorized partners to obtain relevant information, and agree strict data protection measures with authorized partners to enable them to process personal information in accordance with this policy and any other relevant confidentiality and security measures.

The third-party SDK we access mainly serves the needs of you and other users. Therefore, when meeting new service requirements and business function changes, we may adjust the third-party SDK we access. We will promptly disclose the latest situation of accessing the third-party SDK to you in this description.

The situation of MKANG accessing the third-party SDK is as follows (the personal data collection is determined according to whether you use the following third-party services):

Third party name Purpose of use Function type Personal information collection details Privacy policy address
Getui·Push Push message Push notification function Device information, application list information, network information, location related information, etc. https://docs.getui.com/privacy/
Xiaomi Push Push message Push notification function Your IMEI / oaid (applicable to systems above Android q), IMEI MD5 / meidmd5, Android ID, Vaid, AAID, as well as your mid (applicable to MIUI system), device model and other information. https://dev.mi.com/console/doc/detail?pId=1822
Huawei Push Push message Push notification function Your ID, APP ID, APP package name, server public IP address. If you create a message push task on the appgallery connect website, we will collect information about the usage frequency, task name, message content and push range (application token, or subject name, or audience group name) of Huawei push functions. https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides-V5/privacy-statement-0000001050042021-V5
OPPO Push Push message Push notification function Your device related information (such as IMEI number, serial number, IMSI, user ID, Android ID, Google Advertising ID, mobile phone region setting, device model, mobile phone power, mobile phone operating system version and language), application information using push service (such as app package name, version number, running status), push SDK version number, and network related information (such as IP or domain name connection result, current network type), message sending result, notification bar status (such as notification bar permission, user click behavior), lock screen status (such as whether to lock the screen and whether to allow lock screen notification). https://open.oppomobile.com/wiki/doc#id=10288
VIVO Push Push message Push notification function Device and application information: including operating system version number, application information, device identifier (such as IMEI number, SIM and IMSI, mobile country code and mobile network number of vivo Android device, etc.), MAC address, mobile operator, use language, system settings and other system, device and application data during your use of vivo devices and services. https://www.vivo.com.cn/about-vivo/privacy-policy
Baidu Software Co., Ltd Binding device Binding device function WLAN status information, location information, terminal device unique identifier, application package name, mobile phone screen density / size / model / system version. https://lbsyun.baidu.com/index.php?title=open/privacy

Purposes and Legal Basis for Processing Personal Data

The purpose for which we may process information about you are as follows:

• Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Improve Our Services: We process your device information, usage data, 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 Use.

• 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 may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating 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 process; (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 or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

Who do We Share Personal Data with?

At MIAN, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

• 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.

• 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.

• To an affiliate or other third party 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 stock (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.

• As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

Except for the third parties described above, to third parties only with your consent.

Your Rights Relating to Your Personal Data

We respect your rights and control over your Personal Data. You may exercise any of the following rights:

• Via the “Me > Personal Center > Account and Security” or via “Me > FAQ&Feedback” in our Products

• By emailing us at mian@miansafe.com

You do not have to pay a fee for executing your personal rights. According to different data protection laws, if you are dominated in Mainland China, we will aim to respond you within 15 business days; and if you are dominated ex-Mainland China, and we will aim to respond you within 30 calendar days.

If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may:

• Request access to the Personal Data that we process about you;

• Request that we correct inaccurate or incomplete Personal Data about you;

• Request deletion of Personal Data about you;

• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;

• Request 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 Personal Data about you where our use is based on your consent or our legitimate interests.

Security Measures

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. MIAN provides various security strategies to effectively ensure data security of user and device. As for device access, MIAN proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. 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 could immediately notify us of the problem by emailing mian@miansafe.com

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 retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct 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 such use of your Personal Data.

Changes to this Policy Policy

We may update this Privacy Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically rediv this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

MIAN Inc.

Postal Mailing Address: Room 324, Building 3, Huahan Science and Technology Industrial Park, 19 Lanjin 4th Road, Pingshan Street, Pingshan District, Shenzhen City, Guangdong Province, China.

Email: mian@miansafe.com