APP Privacy Protection Guidelines

This Guideline will explain how APP collects, uses and stores your personal information, along with the rights you are entitled to. We will use this Guideline to explain the relevant details, including the following:

We will describe the types of personal information we collect and their corresponding use in order for you to understand how we collect specific type of personal information for a particular function, the reasons for its use and the methods of such collection.
Whilst using some features, we will collect your personal information after obtaining your consent. For example, when you use APP' s “Movement” function, we will collect information on the number of your steps taken; where you use the “recommended contacts/friends” function, we will collect your mobile contact information; and where you use the “people nearby” and “shake” function, we will collect your location information. Unless it is required by the relevant laws and regulations for you to provide such information, refusing to provide such information will only result in your not being able to use the specific functions relating to such information, but does not affect your normal use of other functions of APP.
At present, APP will not actively share or transfer your personal information to any third parties outside of Berld. Where the sharing or transferring of your personal information arises in some other situation or you require us to share or transfer your personal information to a third party outside of Berld, we will directly obtain, or verify the third party has obtained your prior express consent to such share or transfer of your personal information. Also we will evaluate the risks of such sharing or transferring.
At present, APP will not actively obtain your personal information from a third party outside of Berld. If there is a requirement to obtain your personal information indirectly from a third party for future business development purposes, we will clarify with you the source, type and scope of such personal information. For example, if the processing of personal information for a specific development is beyond the scope of what you originally agreed to provide to a third party, we will obtain your prior express consent before processing your personal information, and we will strictly abide by the relevant laws and regulations and require that the third party guarantees the legitimacy of the information provided.
You can access, correct and delete your personal information through the instructions listed in this Guideline, or you can withdraw your consent, cancel your account, report complaints and manage your privacy settings.

For more detailed information on the above, please refer to the relevant sections in following index:

The Information We Collect
The Location and Time Period of Storing Information
Information Security
How We Use Information
External Parties
Your Rights
Amendments
Protection of minors
Others
Contact us

1.The Information We Collect

In the process of using APP service, APP will, in accordance with the following ways, collect information provided by you during the use of the service or information generated by the use of the service, in order to provide such services to you, to optimize our services and protect your account security:

Children's basic information: Basic personal information about your children that you voluntarily provide, including nickname, height, weight, profile picture and other information.
Device information: Information related to your child's device, including watch IMEI number, watch serial number (SN), watch MAC address, watch Bluetooth MAC address, watch power, firmware version number, and application version number.
Wi-Fi information: the current Wi-Fi connection mode (LAN mode, remote mode) of the device, the IP address assigned by the device, the name of the connected Wi-Fi, the Wi-Fi signal strength, and the received Wi-Fi signal strength indicator (device RSSI), router MAC address.
Equipment setting information: The setting information of your child when using the device, including positioning mode, smart power saving mode switch status, class anti-disturbance function setting information, and automatic answering setting.
The mobile terminal information of the connected device: When your child' s device is bound to a mobile terminal such as a mobile phone (hereinafter referred to as “mobile terminal” or “hand Machine”), we will collect information related to the mobile terminal, including mobile phone operating system (such as MIUI version, Android version), brand model information, and device manufacturer information.
Communication and call related information: We will collect the network operator of your children's device, watch number, IMSI number, watch mobile signal value, mobile phone caller number, family member list (including friend's nickname, watch number, friend list), and call Record, call whitelist switch, chat message (voice for communication between mobile phone and device), SMS whitelist switch. Please rest assured that your chat information will be encrypted and stored on the server; we will not read the content of your chat information.
Location information: We will collect the current geographic location information of the device and mobile terminal, as well as the specific location and scope of the safe area (home and school).
Step counting information: When your child uses the step counting module, we will collect your child's daily steps, target steps, exercise distance, energy consumption, and ranking of steps. The height and weight you actively provide will also be used to calculate the energy consumed.

In addition, in accordance with relevant laws and regulations and national standards, in the following circumstances, we may collect and process your relevant personal information without asking for your consent:

1) When it is directly related to national interests such as national security and national defense, or it is directly related to major public interests such as public safety, public health, and public knowledge;

2) When it is directly related to a criminal investigation, prosecution, trial or execution of judgments;

3) In order to protect vital legitimate interests of you or of other individuals, such as right of life, property, and reputation, while it' s hardly to obtain the consent of the individual;

4) When the personal information is disclosed to the public by yourself;

5) When the personal information is collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, etc.;

6) When it is necessary for entering into and/or performance of a contract to which you are the party;

7) When it is necessary for maintenance of the safe and stable operation of the products or services provided, such as discovering malfunctions and/or troubleshooting products or services;

8) When it is necessary for legitimate news reporting;

9) When it is necessary for conducting statistical or academic research which is for public interest, and when the results of academic research or description are provided externally, the personal information contained is de-identified.

10) Other circumstances as stipulated by laws and regulations.

Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not in the above description and your information is collected, we will explain to you the type of information, the scope and the purpose of the information collection by means of page prompts, interactive processes, website announcements or other ways, to obtain your consent.

Please note that at present, APP will not actively obtain your personal information from a third party outside of Berld. In the event that we need to obtain your personal information indirectly from a third party for future business developments, we will inform the source, type and scope of the use of your personal information to you prior to obtaining such information. For example, where APP requires to process personal information for a specific development which is beyond the scope of what you originally agreed to provide to a third party, we will obtain your prior express consent before processing your personal information; In addition, we will strictly abide by the relevant laws and regulations, and require that third parties guarantee the legitimacy of the information provided.

2.Storage of Information

2.1 Where Information is Stored

We will act in accordance with laws and regulations and store personal information collected within the territory in Kuwait.

2.2 The Duration Storing Information

In general, we will only keep your personal information for the time necessary to achieve a specific purpose, for example:

Mobile phone number:When you use APP service, we will need to store your mobile phone number to ensure your normal use of the service; when you delete your APP account, we will delete the corresponding information;

Album information: When you upload an album, we need to save your album information to ensure that you can use the album function normally. When you delete your album information, we will delete the corresponding information.

Location information: If you need to use the APP service, we need to save your location information to ensure that you use the location function normally. When you delete your location information, we will delete the corresponding information.

In the event where we cease our products or services, we will notify you in the form of push notifications, announcements, etc., and delete your personal information or anonymize such information within a reasonable period of time.

3.Information Security

We strive to secure users' information to prevent information leakage, improper use, unauthorized access or disclosure.

We will use a variety of security measures to ensure the security of information within reasonable security standards. For example, we will use encryption technology (for example, SSL), data anonymization and other means to protect your personal information.

We use ever-improving technical means to enhance the security of the software installed on your device to prevent your personal information from leaking. For example, we will perform partial information encryption on your device for secure transmission; to prevent viruses, Trojans or other malicious programs or website, we will collect the information about applications installed on your device or process information regarding the running application.

We have set up specialized management systems, processes and organizations to ensure the security of information. For example, we strictly limit the range of people who may access such information and require them to comply with the confidentiality obligations and conduct audits.

In the case of information leakage or other incidents involving information security, we will initiate contingency plans to prevent the wide spread of security incidents and inform you in the form of push notifications and announcements.

4.How We Use Information

In order to ensure the security of our services, and to enable us to better understand the operations of our applications, we may record information such as your frequency of using our applications, crash logs, overall usage, performance data, and the sources that apps are installed from. We will not combine the information stored in the analytics software with any personally identifiable information you provide in the application.

Where we utilize your personal information beyond the scope of our collection statement or a direct or reasonable connection, we will inform you and obtain your prior express consent again before using your personal information in such situations.

5.External Parties

At present, we will not actively share or transfer your personal information to a third party outside of Berld. If there are other circumstances in which your personal information is to be shared or transferred or where you require us to share or transfer your personal information to a third party outside of Berld, we will directly obtain or verify the third party has obtained your prior express consent to such share or transfer of your personal information.

We will not publicly disclose personal information collected by us. If we have to disclose such information publicly, we will inform you of the purpose of such disclosure, type of information disclosed and the sensitive information that may be involved, and obtain your prior express consent.

As our business continues to develop, we may engage in mergers, acquisitions, transfers of assets, etc. We will inform you of such circumstances and continue to protect your personal information and require new controllers to continue to protect your personal information in accordance with the laws and regulations and the standards as strict as required by this Guideline.

In addition, in accordance with relevant laws and regulations and national standards, in the following circumstances, we may share, transfer, or publicly disclose personal information without prior consent of the subject of personal information:

1) When it is directly related to national security or national defense;

2) When it is directly related to public safety, public health, or major public interests;

3) When it is directly related to a criminal investigation, prosecution, trial or execution of judgments;

4) When it is for protecting vital legitimate interests of you or of other individuals, such as right of life, property, and reputation, while it' s hardly to obtain the consent of the individual;

5) When the personal information is disclosed to the public by yourself;

6) When the personal information is collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, etc..

6.Your Rights

During your course of using APP, in order to provide you with an easier way to access, change, delete your personal information while ensuring you with the right to withdraw your consent regarding the use of personal information and the right to cancel your account, we have provided you with the applicable function when designing the product. You may refer to the following operational Guideline. In addition, we have also set up a report and complaints channel, in order to address your feedback in a timely manner.

6.1 Access Personal Information

6.1.1 Access your profile picture, mobile number, name, birthday, gender, height, weight, grade and other information of device:

1) After entering APP, tap on "Settings”;

2) Tap on the column with your profile picture;

3) Access your information.

6.1.2 Access your APP ID, profile picture and name:

1) After entering APP, tap on "Settings”;

2) Tap on"System Settings";

3) Tap on "My information".

4) Access your APP ID, profile picture and name.

6.1.3 Access Album' photos:

1) After entering APP, tap on "Home”;

2) Tap on the image album;

3) Access the album information.

6.1.4 Access device contacts:

1) After entering APP, tap on "Settings";

2) Tap on “Family”

3) Access device family contacts.

6.2 Deleting Personal Information

6.2.1 Delete one-to-one chat history:

After entering APP, tap on "Settings";

2) Tap on “Device settings”.

3) Tap on “Clear Chat History”.

6.2.2 Delete parts of the chat history:

1) After entering APP, select and open the specific chat history, press and hold on the specific message to be deleted;

2) Select "Delete" to delete the message.

6.2.3 Delete your profile or admin account information:

1) Personal information cannot be deleted temporarily, you can delete it by logging out of the APP

6.2.4 Delete photo in album:

1) After entering APP, tap on "Home”;

2) Tap on the image album;

3) Tap on delete at the upper right corner to delete the photo.

6.3 Amending Your Personal Information

6.3.1 Changing devices' profiles picture, mobile number, name, birthday, gender, height, weight, grade and other information of device:

1) After entering APP, tap on "Settings”;

2) Tap your profile picture to check details;

3) Change devices' profiles and save.

6.3.2 Change your profiles:

1) After entering APP, tap on "Settings”;

2) Tap on "Settings";

3) Tap on "System settings" in the upper left corner;

4) Change your mobile phone number, APP password, voiceprint, emergency contacts.

6.4 Withdraw Permission

6.4.1 Withdraw privacy authorization (partial)

1) Enter the mobile phone system settings (different mobile phone systems have different interfaces);

2) Find "Privacy";

3) Select the corresponding "location", "microphone", "camera", "camera" and other permissions to operate;

6.5 Delete Account

6.5.1 Delete APP Account

1) After entering APP, tap on "Settings”;

2) Tap on "System Settings";

3) Tap on "Account management";

4) Tap on "Delete Account"

6.6 Feedback

1) After entering APP, tap on "Settings”;

2) Tap on "System Settings";

3) Tap on "About";

4) Tap on “Feedback”.

7.Amendments

We may revise this Guideline in due course. In the event where the terms of this Guideline are amended, we will show you amended Guideline by way of push notifications and/or pop-up windows when you log in or when the APP version has been updated. Please note that we will follow the updated Guideline to collect, use and store your personal information only after you have tapped on the consent button in the pop-up window.

8.Protection of minors

We place great importance in the protection of personal information of minors. If you are a minor under the age of 18, according to the relevant laws and regulations, your parents' or legal guardian's written consent should be obtained prior to you use of APP service. If you are a legal guardian of a minor, you may contact us through the contact information specified in Section 10 where you have queries regarding the personal information of your minors.

In particular, we have formulated the APP Watch Children Privacy Protection Rules for the user under the age of 14. Children under 14 years old and their guardians should carefully read the APP Watch Children Privacy Protection Rules before completing the account registration. Children under 14 years old can only use the APP service after obtaining the guardian' s consent to the APP Watch Children Privacy Protection Rules.

9.Others

Berld' s "Privacy Policy" is Berld' s unified application of the general privacy terms, where the prescription of users' rights and information security measures are applicable to APP users. Where there are any inconsistencies or conflicts between Berld's "Privacy Policy" and this Guideline, this Guideline will prevail.

The APP Watch Children Privacy Protection Rules is a personal information protection regulation applicable to children under the age of 14. In the scope of the APP Watch Children Privacy Protection Rules, if there is any inconsistency or discrepancy between Berld' s "Privacy Policy" and this Guideline, the APP Watch Children Privacy Protection Rules shall prevail.

10.Contact us

If you have any other complaints， suggestions， or quarries regarding personal information of minors, please contact us

We will review your queries as soon as possible and respond within fifteen days after verifying your identity.

APP Watch Children Privacy Protection Rules

introduction

The term "children" in these protection rules refers to minors under the age of fourteen. For the collection, use, transfer, and disclosure of children' s personal information, the child' s guardian shall be notified in a conspicuous and clear manner, and the child' s guardian' s consent shall be obtained. For minors who have reached the age of fourteen, the explicit consent of the minor or his guardian should be obtained before collecting personal information. We fully consider the needs of you and your children. This protection rule aims to help you as a child guardian fully understand how we collect, use, disclose, process and store the personal information that you and your children provide to us when using our products. At the same time, it is important to ensure that you ultimately have control over the personal information provided to us.

Finally, what we want is to bring the best experience to our users. If you have any questions about the data processing practices outlined in this privacy policy, please contact our data protection officer so that we can deal with your special needs. We are happy to deal with your problem directly.

What information is collected and how is it used?

Children's basic information: Basic personal information about your children provided by you, including nickname, height, weight, and profile picture.

Device Information: Information related to your child's device, including watch IMEI number, watch serial number (SN), watch MAC address, watch Bluetooth MAC address, watch power, firmware version number, and application version number.

Communication and call-related information: We will collect the network operator of your children's device, watch number, IMSI number, watch mobile signal value, mobile phone caller number, family member list (including friend's nickname, watch number, friend list), and call Record, call whitelist switch, chat message (voice for communication between mobile phone and device), SMS whitelist switch. Please rest assured that your chat information will be encrypted and stored on the server; we will not read the content of your chat information.

Location information: We will collect the current geographic location information of the device and mobile terminal, as well as the specific location and scope of the safe area (home and school).

Step counting information: When your child uses the step counting module, we will collect your child's daily steps, target steps, exercise distance, energy consumption, and ranking of steps. Your child' s height and weight provided by you will also be used to calculate the energy consumed.

We may use your child's information for the following purposes:

Verify the uniqueness of the equipment. When you bind a APP watch for the first time, the watch IMEI number, watch serial number (SN), watch MAC address, watch Bluetooth MAC address, and firmware version number of the hardware will be used to verify the uniqueness of the device. The above information will also be used to update the system or software, restore factory settings, etc.

Provide communication and call functions: We collect communication and call-related information to provide you and your children with communication and call-related functions. For example, you can call your child by dialing the SIM card number of the device; you can also protect your child's safety by setting a call whitelist; we collect the chat information, address book information, nickname, Avatar, to provide you with the service of chatting between your device and your phone.

Provide location-based services: When you use program services or functions based on location information, we will collect the geographic location information of your child' s device and/or mobile phone to enable online or real-time (reporting every 20 seconds) to view your child' s Current location and footprint; you can view the distance between your current location and the device location, and initiate navigation.

Step counting function: We collect step counting information to show you the sports details of you and your children. You can view it in day view or weekly view; you can also view the ranking of your children's exercise steps. To do this, we need to collect step counting information, children's height and weight (used to calculate calories), and location information.

Retention policy

If it is necessary to achieve the purpose of collecting information, or to comply with applicable legal requirements or permission, we will always retain personal information. As long as it can be reasonably inferred that the purpose of collecting personal information cannot be achieved by retaining personal information, and when it is no longer necessary to retain information for legal, dispute resolution, enforcement of our agreements, or other business purposes, we will no longer retain personal information or eliminate A way to associate personal information with specific individuals. Your information will be stored for 30 days: your geographic location information will be stored on our server for 90 days

You can control the information of your children

You have the right to request access and/or correction of any personal information we hold about you or your children. When you update personal information for your child, we will ask you to verify your identity before we process your request. Once we have sufficient information to process your request to access or correct your or your child's personal information, we will respond to your request within the time specified by applicable data protection laws.

We usually provide these services for free, but reserve the right to charge a reasonable fee for your data access request.

If you wish to request access to the personal data we hold or if you believe that any information we hold about you or your children is incorrect or incomplete, please email us as soon as possible:

Withdraw consent

You can revoke your consent to collect, use and/or disclose the personal information of you and your children that we hold or control by submitting a request. This can be done by contacting us to submit related operations. We will process your request within a reasonable time after you make the request, and will no longer collect, use and/or disclose your and your children's personal information in accordance with your request.

Please note that your withdrawal of consent will result in certain legal consequences. Depending on the scope of your withdrawal of consent to allow us to process the personal information of you and your children, this may mean that you cannot enjoy beautiful products and services.

Four, contact us

This protection rule is a special rule for the protection of children's information using APP watch, and is an important part of the "APP Privacy Protection Guidelines". If there is any inconsistency between the “APP Watch Children Privacy Protection Rules

” and the “APP Privacy Protection Guidelines” involved in the special agreement for children' s mode, this protection rule shall prevail; if this protection rule does not agree, the “APP Privacy Protection Guidelines" shall prevail.