PRIVACY POLICY

Effective: July 5, 2022

 

Your privacy is important to us. We respect the privacy rights of all individuals and we are committed to handling your personal information responsibly and in accordance with the applicable law. Please take a moment to familiarize yourself with our Privacy Policy and let us know if you have any questions.

 

PURPOSE

 

This Privacy Policy describes how we manage your personal information for products and services provided by Anhui Huami Information Technology Co., Ltd. ("we", "our" or "us").This Privacy Policy also applies to personal information that is processed by us in the course of our business, including on mobile applications, websites, services, products (such as Zepp Clarity ONE), and other online or offline offerings unless otherwise indicated. All individuals whose responsibilities include the processing of personal information on our behalf are expected to protect this data by adherence to this Privacy Policy.

 

OUR COMMITMENT TO YOU

 

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of and confidence in our personal information collection and usage practices of any personal information provided to us.

 

In this Privacy Policy, "personal information" means any information relating to an identified or identifiable natural person. Such personal information may include, but is not limited to the information you upload or provide to us and information we obtain through your devices as described below.

 

We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws. We are equally committed to ensuring that all our employees and agents uphold these obligations.

 

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practices as summarized in this Privacy Policy, please contact privacy@zepp.com.If your questions are not adequately addressed, you may then contact our Data Protection Officer at dpo@zepp.com to address your specific concerns.

 

TRANSPARENCY: WHATINFORMATION IS COLLECTED AND HOW WE USE IT

 

The categories of personalinformation we may collect (directly from you or from third party sources) andour privacy practices depend on the nature of the relationship you have with usand the requirements of applicable laws. Some of the ways that we may collectpersonal information include:

We endeavor to collect only thatinformation which is relevant for the purposes of processing.

TYPES OF INFORMATION COLLECTED

HOW THE PERSONAL INFORMATION IS USED

We acquire, hold, use and process personal information for a variety of business purposes including for providing services and/or products to you, to respond to information requested and to fulfill legal compliance on our part under applicable laws. We may also process and disclose personal information to our affiliated companies and to third-party service providers for the purposes stated in this Privacy Policy.

You have the right to opt out of our proposed use of your personal information for direct marketing. If you no longer wish to receive certain types of email communication you may opt-out by following the unsubscribe link located at the bottom of each communication.

SECURITY SAFEGUARDS

 

We are committed to ensuring that your personal information is secure, and we will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information we process.

 

To prevent unauthorized access, disclosure or other similar risks and to comply with applicable privacy and security laws in the countries in which we operate, we have put in place reasonable administrative, technical and physical controls and procedures designed to safeguard and secure the information we collect from your use of our products and services. We will use reasonable efforts designed to safeguard your personal information.

 

For example, when you access your account, you can choose to use our two-step verification process for better security. When you send or receive data from your device to our servers, we make sure they are encrypted using Secure Sockets Layer ("SSL") and other algorithms.

 

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and endeavor to ensure that your personal information has an appropriate security level. The files and records containing your personal information will be kept in our offices and/or on our servers or those of our service providers and only those employees that require it for the purposes of their duties will have access to this file. We have also implemented controls to require that our third-party service providers and partners have appropriate safeguards designed to protect your personal information as well. We make sure that our employees and third-party service providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. In some cases, we have special access controls for cloud-based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, in an effort to guard against any unauthorized access and use.

 

However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent any interception or other type of misuse. We also depend on you to protect your information. If you become aware of any breach of security or privacy, please notify us immediately. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

 

By using our products and services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the website or through the product or service and/or by sending an e-mail to you. You may have a legal right to receive this notice in writing.

WHAT YOU CAN DO

YOUR PRIVACY CHOICES AND RIGHTS

 

YOURPRIVACY CHOICES

 

Theprivacy choices you may have about your personal information are determined byapplicable law and are described below.

 

Mobile devices

We may occasionally send you push notifications through our mobile applications with version updates and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

 

“Do Not Track”

Do Not Track (“DNT”) is a privacypreference that users can set in certain web browsers. DNT is a way for usersto inform websites and services that they do not want certain information abouttheir webpage visits collected over time and across websites or onlineservices. Please note that we do not respond to or honor DNT signals or similarmechanisms transmitted by web browsers.

 

Cookiesand Interest-Based Advertising

As noted herein, you may stop or restrict the placement of cookies and other technologies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

 

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp,or http://www.youronlinechoices.eu/and www.aboutads.info/choices/.

 

To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on third party websites that contain the Ad Choices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-personal information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

 

ACCESSING OTHERFEATURES ON YOUR DEVICE

 

Our applications may need access to certain features on your device such as Bluetooth. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the your mobile phone/computer and/or contacting us at privacy@zepp.com.

 

CONTROLLING SETTINGSFOR PRODUCTS AND SERVICES

 

We recognize that privacy concerns differ from person to person. Therefore, we provide examples of ways we make available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at anytime through your device or privacy settings as described above. If you have any questions, please email us at privacy@zepp.com.

RETENTION POLICY

 

We retain personal information we receive as described in this Privacy Policy for as long as you use our products, services and websites or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information.

 

If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by us even if the further processing is incompatible with original purposes in certain jurisdictions.

 

YOUR PRIVACY RIGHTS

 

In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

STORAGE AND TRANSFER OFPERSONAL INFORMATION

 

We have data center in the United States. Currently all users’ personal information is stored in data centers located in United States. To the extent that we may need to transfer 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. For example, when we transfer your personal information to countries outside the United States, we do so under the European Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses). In particular, we will ensure that all transfers will be in accordance with requirements under the applicable laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by us for this transfer of your personal information.

 

We may use overseas facilities operated and controlled by us to process or back up your personal information. You understand that your personal information collected via or by us may be stored outside of your jurisdiction. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you consent to the storage of your personal information in these locations.

 

MINORS/ CHILDREN’S PRIVACY

 

Our products and services are not directed to children, minors or individuals under 18 years of age (the “Child” or “Children”) and Children are prohibited from using our products or services. We don’t seek or intend to seek to receive any personal information from Children. Should a parent or guardian have reasons to believe that a Child has provided us with personal information, please contact us to ensure that the personal information is removed and the Child unsubscribes from any of the applicable services. If we learn that we have collected any personal information from Children under 18, we will promptly take steps to delete such information and terminate the Child’s account.

 

UPDATES TO THE PRIVACY POLICY

 

We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our information practices. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the products or services after the updated Privacy Policy is posted. If, at any point, you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the products and services. If we make material changes to our Privacy Policy, we will notify you by email(sent to the e-mail address specified in your account) or post the changes in our App. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or in our App. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on mobile phones and/or any other device will betaken as acceptance of the updated Privacy Policy. Before we use personal information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where your consent for the processing of personal information is otherwise required by law or contract, we will endeavor tocomply with the law or contract.

 

THIRD PARTY TERMS ANDCONDITIONS

 

Our Privacy Policy does not apply to products and services offered by a third party. Our products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other websites linked from our services.

 

OURAPPROACH TO MANAGE YOURPERSONAL INFORMATION

 

We will provide a systematic approach to managing personal information through our people, management processes and information systems by applying a risk management methodology. For instance, (1) we set up a Data Protection Officer (DPO) in charge the data protection, and the contact of the DPO is dpo@zepp.com, (2)we set up a procedure for conducting data protection impact assessments.

 

 

REDRESS/COMPLIANCEAND ACCOUNTABILITY

 

We are the controller of the personal information we process, unless otherwise stated. For information on how to contact us, please refer to “Contact Us” below. If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at privacy@zepp.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

 

CONTACT US

 

If you have any comments or questions about this Privacy Policy or any questions relating to our collection, use or disclosure of your personal information, please contact us at the address below referencing "Privacy Policy":

 

Anhui Huami Information Technology Co., Ltd.

Attn: Data Protection Officer

7/F, Building B2, Huami Global Innovation Center, No. 900, Wangjiang West Road, High-tech Zone, Hefei City, China (Anhui) Pilot Free Trade Zone.

Email: privacy@zepp.com

 

Thank you for taking the time to understand our Privacy Policy!

 

 

SUPPLEMENTAL CALIFORNIA ADDENDUM TO THIS PRIVACYPOLICY

 

This Supplemental California Addendum to this Privacy Policy (“California Addendum”) supplements and should be read in conjunction with this Privacy Policy. This California Addendum only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelvemonths. California residents can find this information below:

Category of Personal Information Collected by Us

Identifiers such as name, online identifier, IP address, MAC address, cookieidentifier, user ID or other similar identifiers.

Personal  information categories listed in Cal. Civ. Code § 1798.80(e), such as name, phone number, postal address

Commercial information such as records of products or services purchased, obtained, orconsidered, or other purchasing or consuming histories or tendencies.

Characteristics of protected classifications under California or Federal law, such as gender or age. (“Characteristics of Protected Classifications”)

Internet or other electronic network activity information such as browsing history, search history and information regarding a consumer's interaction with a website, application, or advertisement.

Inferences drawn from other personal information to create a profileabout a consumer

Categories of Third Parties Personal Information is Disclosed to for aBusiness Purpose

  • Service providers
  • Affiliates
  • Service providers
  • Affiliates
  • Service providers
  • Affiliates
  • Service providers
  • Affiliates
  • Service providers
  • Affiliates
  • Service providers
  • Affiliates

The categories of sources from whichwe collect personal information and our business and commercial purposes forusing personal information are set forth above in the relevant sections of thisPrivacy Policy.

 

Additional Privacy Rights for California Residents

SUPPLEMENTAL NEVADAADDENDUM TO THIS PRIVACY POLICY

 

This Supplemental Nevada Addendum to this Privacy Policy supplements and should be read in conjunction with this Privacy Policy.

 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@zepp.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” above.