SHENZHEN SHYUGJ TECHNOLOGY CO., LTD. (hereinafter referred to as “SHYUGJ” or “we”) attaches great importance to your privacy. Halo Smart (including services provided by products such as the App, hereinafter referred to as “Products and Services”) is a platform provided by SHYUGJ for the control and management of smart devices.

We value your privacy very much. This privacy policy is a statement and commitment made by SHYUGJ regarding the privacy aspects of Halo Smart.

This privacy policy has been formulated with full consideration of your needs, ensuring that you fully understand our practices for collecting and using personal information, while also ensuring that you ultimately have control over the personal information you provide to us, which is crucial. This privacy policy specifies how we collect, use, disclose, process, and store the information you provide to us when using our Halo Smart. “Personal information” under this privacy policy refers to data that can identify specific individuals either on its own or when combined with other information. We will strictly adhere to this privacy policy in the use of such information.

Finally, we aim to provide users with the best experience. If you have any questions about the personal information processing practices described in this privacy policy, please contact us through the email address: info@eukaus.com. So that we can address your specific needs. We are happy to receive your feedback.

1.What information do we collect and how do we use it
1.1 Circumstances in which you need to authorize us to collect and use your personal information

The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws, regulations, and other normative documents. You have the right to choose whether to provide this information, but in most cases, if you do not provide it, we may not be able to provide you with the corresponding services or respond to the issues you encounter. These functionalities include:

(1) Smart device connection

Provide the Redbox Smart service, allowing you to securely connect and manage smart devices. When you connect a smart device, we may collect your login account information, phone-related information, IP address, smart device-related information, and associated information for the smart device. This information will be used to provide you with functions such as smart device quick connection, connection, discovering nearby devices, and device management. The detailed list of the above information is as follows:

Login account information: phone number, email address, nickname;
Information collected during the process of connecting smart devices: Depending on the type of smart device you need to link, we may collect:
Smart devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, Wi-Fi password), device MAC address, device ID;
Smart devices connected via Bluetooth after establishing a local connection, then through Wi-Fi: Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, Wi-Fi password), device MAC address, device Bluetooth MAC address;
Smart devices connected via Bluetooth: device Bluetooth MAC address, device ID
Smart devices connected via Zigbee: device MAC address, device ID.
(2) Quick Control Feature

To provide you with a convenient and quick smart device control experience, in cases where supported by device categories, you can achieve smart device control and status query functions quickly through entry points such as quick cards in the Halo Smart application before entering the device extension program. After you choose to enable the quick control feature and bind smart devices, we will collect the following information:

Device network status: for you to view the device connection status and display different operation interfaces based on the network status;
Device status information: for you to view device status and control devices;
If you have connected devices such as temperature and humidity sensors or motion sensors via the Halo Smart platform, we will also need to collect:

Device surrounding environment-related information: for you to accurately view the surrounding environment-related information detected by the device sensors, such as temperature, humidity, PM2.5, and whether someone passes by.
1.2 You can choose whether to authorize us to collect and use your personal information

To better enjoy the control and management of smart devices provided by SHYUGJ, the following additional functions may collect and use your personal information. If you do not provide this personal information, you can still use the basic services of Halo Smart, but you may not be able to use these additional functions that bring you convenience. These additional functions include:

(1) Invite User

We support you in sharing smart devices with others by inviting others into your account. After inviting, the invitee can also control the smart device(s). To achieve this function, we may collect your account ID, the invited account ID you provided, and the information of the device (device ID, device name, device verification key, and device sharing status), used to provide you with the function of sharing devices with other users for joint control and use, and to display the sharing status on the device list page.

(2) Application and Firmware Upgrade

To ensure you continue to enjoy the latest Halo Smart services, when you check the update status of the application and devices within the App, we may use your Halo Smart application version information to provide you with the upgrade service. At the same time, we may collect the list of smart devices and version information that you have connected to provide you with the device upgrade function.

(3) Scenes (Automation)

We support you to achieve the linkage function between smart devices under specific conditions by setting certain rules. When you set and use smart scenes, we may collect the rules you set for the smart scenes and the device states you specify to execute the functions of the devices according to the commands you specify, for example, when the sensor detects someone passing by, the light turns on. Please rest assured that this feature requires you to activate it by setting rules actively and can be turned off.

1.3 Halo Smart Permission Invocation Instructions

In addition, when you use Halo Smart, it may trigger the following device permissions. To better manage your information, we will inform you of the purpose of using this permission when applying for permission during the product usage process, and the impact on your service usage if you do not enable this permission. Please read it carefully. Before using specific functions, you can choose whether to authorize the following permissions. At the same time, you can change the authorization status at any time through the device’s permission settings page.

The details of the relevant functions and permission invocations are listed below for your reference:

(1) Location Permission (Android, iOS Versions): Used to provide functions such as smart device automation, obtaining WLAN and Bluetooth lists during device quick connection, and discovering nearby devices.

(2) Camera Permission (Android, iOS Versions): Used for scanning QR codes for device installation, device networking, and other functions.

(3) Enable WLAN Permission (Android, iOS Versions): Used to connect to the Wi-Fi emitted by devices during quick connection for device communication.

(4) Enable Bluetooth Permission (Android, iOS Versions): Used to connect to the Bluetooth signal emitted by devices during quick connection for device communication. Bluetooth permission is also required for communication with smart devices connected via Bluetooth.

1.4 You fully understand that the collection and use of personal information by us does not require your consent in the following situations:

(1) Related to fulfilling obligations stipulated by laws and regulations.

(2) Directly related to national security and defense.

(3) Directly related to public safety, public health, and major public interests.

(4) Directly related to criminal investigation, prosecution, trial, and judgment execution.

(5) Necessary to safeguard the vital interests of the personal information subject or other individuals’ lives, property, etc., but it is difficult to obtain the consent of the individual concerned.

(6) The personal information involved is voluntarily disclosed to the public by the personal information subject.

(7) Necessary for signing and performing contracts at the request of the personal information subject.

(8) Collecting personal information from legally publicly disclosed information, such as lawful news reports, government information disclosures, etc.

(9) Necessary to maintain the security and stable operation of the provided products or services, such as discovering and handling malfunctions of products or services.

(10) The personal information controller is a new unit, and the collection is necessary for the lawful news reporting.

(11) The personal information controller is an academic research institution, and the collection is necessary for statistical or academic research conducted for the public interest, when providing academic research or descriptive results to the public, the personal information contained in the results is de-identified.

2.How we use Cookies and Similar Technologies
Halo Smart and third-party service providers use technologies such as Cookies, tags, and scripts, which are used to analyze trends, manage the website, track users’ website activities, and collect statistical information about the entire user population. We receive individual or aggregated analysis reports collected through these technologies. These technologies help us better understand your behavior, identify which parts of our website users browse, measure the effectiveness of advertising and web searches, and make improvements. We consider the information collected through Cookies and other technologies as non-personal information. However, if local law considers Internet Protocol (IP) addresses or similar identifiers as personal information, we also treat such identifiers as personal information.

Log Files: Like most websites, we collect certain information and store it in log files. This information may include Internet Protocol (IP) addresses, browser types, Internet service providers (ISPs), referral/exit pages, operating systems, date/time stamps, and/or clickstream data. We do not associate automatically collected log data with other information we collect;
Advertising: We work with third-party service providers to display ads on our website or manage ads on other websites. Our third-party service providers may use technologies such as Cookies to collect information about your activities on their website or other websites to provide ads based on your browsing activities and interests. We obtain your explicit consent beforehand before providing you with ad services;
Mobile Analytics: In certain mobile applications, we use mobile analytics software to better understand the functionality of our mobile software on your device. This software may record information such as the frequency of your use of the application, events occurring within the application, aggregated usage, performance data, and the location where application crashes occur. We do not associate the information stored in the analytics software with any personal information you submit in the mobile application;
Local Storage – HTML5/Flash: We use Local Storage Objects (LSOs), such as HTML5 or Flash, to store content and preferences. Third parties working with us to provide certain features or deliver ads on our website may also collect and store relevant information through HTML5 or Flash Cookies based on your browsing behavior. Various browsers provide their own management tools to delete HTML5 Local Storage Objects. To manage Flash Cookies, please visit the following link.
3.Retention Policy
We retain personal information for the period necessary to fulfill the purposes outlined in this privacy policy or as required by applicable laws. Once the purpose of collection is completed, upon confirmation of your request for deletion or deregistration, or upon termination of the operation of the corresponding product or service, we will cease retention and proceed with deletion or anonymization. If retention is necessary for public interest, scientific, historical research, or statistical purposes, we will continue to retain relevant data based on applicable laws, even if further data processing is unrelated to the original collection purpose. Additionally, we are required to retain your personal information in the following circumstances according to relevant laws and regulations:

According to the “People’s Republic of China Electronic Commerce Law,” the retention period for your goods and services information and transaction information shall not be less than three years from the date of completion of the transaction.
4.Your Rights
4.1 Your Rights to Your Personal Information

According to applicable laws and regulations in your country or region, you have the right to request access, correction, or deletion of any personal information we hold about you (hereinafter referred to as “requests”).

Most laws require that requests made by data subjects follow specific requirements. In this privacy policy, your request should meet the following conditions:

Through our dedicated request channel, and for the protection of your information security, your request should be in writing (unless local law expressly recognizes oral applications);
Provide sufficient information for us to verify your identity, ensuring that the requester is the data subject or a legally authorized person; Once we receive sufficient information to confirm that we can process your request, we will respond to your request within the time frame specified by applicable data protection laws. Specifically:
Based on your request and applicable laws, we may provide you with a free copy of personal information records that we have collected and processed about you. If you make other requests regarding the relevant information, we may, based on relevant applicable laws and in combination with actual management costs, charge you a reasonable fee;
If you believe that any information we hold about you is incorrect or incomplete, you may request correction or supplementation of the personal information based on the purpose of use;
According to the applicable laws and regulations, you may have the right to request us to delete your personal data. We will assess your deletion request and, if it meets the relevant requirements, we will take corresponding steps, including technical means, to process it. After you or we assist you in deleting the relevant information, due to applicable laws and security technologies, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized. For example, according to the “E-Commerce Law of the People’s Republic of China”, the retention period of your goods and services information and transaction information shall not be less than three years from the date of completion of the transaction.
We reserve the right to refuse to process requests that are meaningless/repetitive, infringe on the privacy of others, extremely impractical, request disproportionate technical work, and requests that do not need to be granted under local laws, publicly disclosed information, and information given under confidentiality conditions. If we believe that certain aspects of requests to delete or access data may prevent us from lawfully using the data for the aforementioned anti-fraud and security purposes, we may also refuse them.
4.2Terminating Service or Account

If you wish to terminate specific products or services, you can contact us via the email address: info@eukaus.com. If you wish to terminate your Halo Smart account, please be cautious as terminating your Halo Smart account may make you unable to use all SHYUGJ products and services. We will assess whether to support your termination request based on your usage of SHYUGJ products and services, to protect your or others’ legitimate rights and interests. For example, if there are outstanding installments, we cannot immediately support your request.

5.How your personal information is transferred globally.
SHYUGJ processes and backs up personal information through globally operated and controlled facilities. Currently, SHYUGJ has data centers in the European Union. For the purposes described in this privacy policy, your information may be transferred to these data centers in accordance with applicable law.

We may also transfer your personal information to third-party service providers and business partners, so your information may be transferred to other countries or regions as well. The jurisdictions of these global facilities may not offer the same level of protection for personal information as the jurisdiction you are in, resulting in varying risks depending on different data protection laws. However, this does not change our commitment to complying with this privacy policy and protecting your personal information.

Specifically:

Personal information collected and generated during operations within the European Union will be processed and stored in data centers located in the EU, except as permitted for cross-border transfers under EU laws.

If we need to transfer personal information to jurisdictions outside your jurisdiction, whether to our affiliates or third-party service providers, we will comply with relevant applicable laws. We ensure that all such transfers meet the requirements of local applicable data protection laws by implementing consistent security measures.

If SHYUGJ transfers your information generated within the European Economic Area to SHYUGJ entities or third-party service providers outside the European Economic Area, we will rely on EU standard contractual clauses or security protection mechanisms as provided in the General Data Protection Regulation (GDPR).

6.Contact Us
If you have any comments or questions about this Privacy Policy, or if you have any concerns about our collection, use, or disclosure of your personal information, please contact us via info@eukaus.com. In general, we will respond within 1 working days. For inquiries regarding your rights related to personal information or other concerns, we have a professional team to address your questions. If your issue is significant, we may ask for more information. If you are not satisfied with the response you receive, you may complain to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on possible complaint channels based on your specific situation.