Privacy Policy
Introduction
SPACEWALKER TECHNOLOGY HONG KONG CO., LIMITED and its affiliates (hereinafter referred to as “we” or “us”) respect and protect your privacy. This Privacy Policy (hereinafter referred to as “this policy”) specifies how we collect, use and share the information about you when you use our websites, application, devices and other services.
We understand and are fully aware of the importance of personal data to you, and we will do our best to protect the security of your personal data. We are committed to maintaining your trust in us and protecting your personal data by abiding by the principles of lawfulness, legitimacy, necessity and good faith, consistency of rights and responsibilities, clear purpose, selective consent, minimum sufficiency, security assurance, subject participation, and openness and transparency. We promise to adopt security protection measures to protect your personal data in accordance with industry-recognized security standards.
Please read and understand this policy carefully before using our products and services. If you have any questions, please contact us via any of the contact methods described in this policy. Our dedicated privacy department and personnel will reply to you within the time frame required by each country's policies and laws.
This policy will help you understand:
I. How We Collect and Use Your Personal Data
II. How We Use Cookies and Similar Technologies
III. How We Share Your Personal Data
IV. How We Retain and Secure Your Personal Data
V. Your Rights
VI. Protection of Minors
VII Transfer of Personal Data Between Countries
VIII. Contact Us
IX. Update of This Privacy Policy
I. How We Collect and Use Your Personal Data
Personal data refers to all kinds of information recorded electronically or in other ways that are related to an identified or identifiable natural person, excluding anonymized information.
(i) Collection of Your Personal Data
We believe that you can have great products and great privacy. This means that we strive to collect only the personal data that we need. The personal data we collect depends on how you interact with us.
When you create an ID of our Apps, purchase and/or activate a product or device, connect to our services, contact us (including by social media), participate in an online survey, or otherwise interact with us, we may collect a variety of information, including:
Account information. Your account ID of our Apps or websites, and related account details, including email address, phone number, third-party account used for registration and other information you provide.
Order information. Data about your orders of our products and services, billing information and method of payment.
Contact information. Data such as name, email address, physical address, phone number, or other contact information.
Device information. Data from which your device could be identified, such as device serial number, device ID, MAC address and other necessary information for use of the device.
Network and Bluetooth information. Data about your Wi-Fi information or Bluetooth information to connect your devices to our Apps.
Usage data. Data about your use of our products and services, such as cleaning records, videos and photos, browsing history, crash data, performance and other diagnostic data and other usage data.
Location information. Location only to support services such as find nearby devices or where you agree for region-specific services.
Other information you provide to us. Details such as the content of your communications with us, including interactions with customer support and contacts through social media channels.
You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.
(ii) Use of Your Personal Data
We use your personal data only when we have a valid legal basis to do so. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. More information is available in the product-specific information embedded in our products and features.
We use personal data to operate, provide, develop, and improve the products and services that we offer you. These purposes include:
Provide and improve our services. We collect personal data necessary to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of our services.
Purchase and delivery of products and services. We use your personal information to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers.
Communicate with you. To respond to communications, reach out to you about your orders or products, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.
Advertising. We use your personal information to display interest-based ads for features, products, and services that might be of interest to you based on your consent.
Comply with Law. To comply with applicable law, for example, to satisfy reporting obligations, or to comply with a lawful governmental request.
(iii) Obtaining Your Personal Data from Third Parties
We may obtain your personal data from third parties in some cases where permitted by law.
If our processing of your personal data required in the course of our business is beyond the scope of the consent you originally authorized when you provided your personal data to a third party service provider, we will obtain your express consent before processing such personal data. In addition, we will strictly comply with relevant laws and regulations and require third party service providers to guarantee the legality of the information they provide.
(iv) Non-Personal Data
We may also collect other information that could not identify a specific individual (i.e., non-personal data), for example, statistical data generated when you use a specific service, such as user actions (including clicks, page redirection, browsing time). The purpose of collecting such information is to improve the service we provide to you. The type and amount of information collected depends on how you use our products and/or services. Such information will be aggregated to help us provide more useful information to our customers and learn about which parts of our website, products and services are of most interest to them, so that our service interface can be optimized.
II. How We Use Cookies and Similar Technologies
We may store small data files called cookies on your device to ensure the proper functioning of our products and services. Cookies usually contain identifiers, site names, and some numbers and characters. We can use cookies to store your login account, preferences and other data to simplify steps for your repetitive operations (such as sign-up and login) and provide you with services that are more suitable for your personal needs.
We will not use cookies for any purpose other than those specified in this declaration. You may manage or delete cookies according to your preferences. If you do so, however, in some cases this may affect your safe access to our products and services and you may have to change the user settings each time you access our products and services.
III. How We Share Your Personal Data
We may share personal data with our affiliated companies, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. Further, we do not share personal data with third parties for their own marketing purposes.
(1)Service providers. We may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. Our service providers are obligated to handle personal data consistent with this policy and according to our instructions. They cannot use the personal data we share for their own purposes and must delete or return the personal data once they’ve fulfilled our request.
(2)Partners. At times, we may partner with third parties to provide services or other offerings. For example, some websites are offered by us and our partners. We require our partners to protect your personal data.
(3)Our Subsidiaries or Affiliates. We are an international company, to carry out business activities on a regular basis or to provide you better service and products, we may have to share personal data with our subsidiaries or affiliates.
(4)Others. We may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.
We do not sell your personal data including as “sale” is defined in Nevada and California. We also do not “share” your personal data as that term is defined in California.
IV. How We Retain and Secure Your Personal Data
(i) Where We Retain Your Personal Data
Currently, we run data centers worldwide. Your personal data is stored in the server according to the region you live. If you are Europe Union user under General Data Protection Regulation (hereinafter referred to as “GDPR”), your personal data will be stored in the German server.
(ii) Storage Period
We retain personal data for a period for the sake of information collection described in this Policy, or we do so in compliance with locally applicable relevant legal requirements. After fulfilling the purpose of personal data collection, or after we confirm your application of deletion or cancellation, or after we terminate the operation of corresponding products or services, we will stop retaining personal data and delete or anonymize it. If it is for the purpose of public interest, scientific, historical research or statistics, we will continue to retain relevant data based on applicable laws, even if further data processing is irrelevant to the original purpose.
(iii) Our Protection Measures
We are committed to guaranteeing the security of your personal data. To prevent unauthorized access, disclosure or other similar risks, we have implemented reasonable processes of physical, electronic and supervisory measures to protect the information we collect from you. We will take all reasonable measures to protect your personal data.
Your data will be classified according to importance and sensitivity, and your personal data will be protected with the highest level of security. We guarantee that employees and third party service providers who access this information to help provide products and services to you have strict contractual confidentiality obligations; otherwise, they will be subject to disciplinary action or termination of cooperation. In summary, we will regularly review information collection, retention and processing practices, including physical security measures, to prevent any unauthorized access and use.
We will take all feasible measures to protect your personal data. However, you should be aware that the use of information via the Internet is not always secure. Therefore, we cannot guarantee the security or integrity of any personal data transmitted bidirectionally over the Internet.
V. Your Rights
You have the right to exercise rights in relation to any personal data that we hold about you (hereinafter referred to as requests) in accordance with the applicable national or regional laws and regulations. Most laws require that requests made by subjects of personal data be subject to specific requirements. In this policy, your requests should comply with the following requirements:
1. For the purpose of protecting the security of your information, your requests should be in writing (unless oral requests are expressly recognized by local laws) and made through our dedicated request channel.
2. You need to provide sufficient information to enable us to verify your identity and ensure that the person making the requests is the subject of the requested information or is their legally authorized person.
We reserve the right to refuse to process meaningless/entangled repetitive requests, or requests for inappropriate technical tasks, or requests that compromise the privacy of others, or requests that are extremely impractical, or requests that are not required to be granted under local law. We may also reject some aspects of your requests if we believe that they may prevent us from using the data lawfully for the aforementioned anti-fraud and security purposes.
Once we have sufficient information to confirm that your requests can be processed, we will respond to your requests within the time period specified by applicable data protection laws.
You may exercise your right to know, access, correct, transfer, restrict the processing of, and delete your personal data by contacting us at privacy@mova-tech.com.
There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and we are legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical or unreasonable.
(i) Rights under GDPR
If you are Europe Union user under GDPR, you can exercise the following rights:
1. The right to obtain from us the erasure of your personal data. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
2. The right to obtain from us the restriction of processing your personal data. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal data under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
3. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
4. The right to receive your personal data in a structured, commonly used format and transmit the information to another data controller.
If you are Europe Union user under GDPR, we will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) we set up a Data Protection Officer (DPO) in charge the data protection; (2) we designate a representative; (3) procedure like data protection impact assessment (DPIA).
(ii) Rights under CCPA/CPRA
If you are a California resident and the California Consumer Privacy Act of 2018 (hereinafter referred to as “CCPA”) and The California Privacy Rights Act (hereinafter referred to as “CPRA”) do not recognize an exemption that applies to you or your personal data, you have the right to:
1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:
(1) the categories of personal data about you that we collected;
(2) the categories of sources from which the personal data was collected;
(3) the purpose for collecting personal data about you;
(4) the categories of third parties to whom we disclosed personal data about you and the categories of personal data that was disclosed (if applicable) and the purpose for disclosing the personal data about you; and
(5) the specific pieces of personal data we collected about you.
2. Request we delete personal data we collected from you, unless CCPA/CPRA recognizes an exemption.
3. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA/CPRA.
4. Have the right to opt out of certain uses and disclosures of your personal data. Where you have consented to our processing of your personal data, you may withdraw that consent at any time and opt-out to further processing by contacting us. In order to provide our services to you, we will ask you to provide personal data that is necessary to provide those services to you. If you do not provide your personal data, we may not be able to provide you with our products or services. Even if you opt-out, we may still collect and use non-personal data regarding your use of our products.
5. Do Not Track. We do not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on our websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited our specific website from a certain IP address. Third parties cannot collect any other personal information from our websites unless you provide it to them directly.
We aim to fulfill all verified requests within 45 days pursuant to the CCPA/CPRA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
VI. Protection of Minors
We believe that it is the responsibility of parents to monitor their children's use of our products and services. However, our policy does not require the collection of personal data of minors or sending any promotional materials to them.
We will not seek or attempt to seek to receive any personal data from minors. If a parent or guardian has reason to believe that a minor has submitted personal data to us without their prior consent, please contact us to ensure that such personal data is deleted and that the minor unsubscribes from any applicable services.
VII. Transfer of Personal Data Between Countries
Our products and offerings connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world, including our affiliated companies, to perform processing activities such as those described in this policy in connection with your use of our products and services. To the extent that we may need to transfer personal data outside of your jurisdiction, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection 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 data.
VIII. Contact Us
If you have any comments or questions about this policy, or about our collection, use or sharing of your personal data, please contact us via the contact information below. We will respond to you within 30 days after verifying your user status.
Email address: privacy@mova-tech.com
Tel.: +86-400-875-9511
IX. Update of This Privacy Policy
We reserve the right to update this policy from time to time. In case of any changes, we will inform you via a pop-up message or other prominent means. We will only collect, use and retain your personal data in accordance with the updated policy with your consent.
This policy takes effect from the update date.
Last update date: 2024/7/20
