Nooie Privacy Policy

• How we collect and use your personal information
• How we use cookies and similar technologies
• How we share, transfer and disclose your personal information
• How we store and protect your personal information
• Your rights to your personal information
• How we process children’s personal information
• Third-party service providers and their services
• How we transfer your personal information globally
• How we update this Policy

• How we collect and use your personal information

1. Personal data we collect

• Personal data directly provided by you

• When you register an account, you need to provide your user nickname, email address, and region information to complete the account registration.
• If you make an after-sale or warranty request, you will need to provide the product order information, your contact information, address, email address, mobile phone number, so that we may respond to your request.
• In the process of login, you will need to provide your email address, area information, phone model, phone system language, so as to complete the login function.
• Data we record about how you interact with our products

• Device information,including information about the attributes of your device, for example, your mobile phone’s model number, operating system version, device screen size, unique device identifier, international mobile equipment identity (IMEI) number, network device hardware address (MAC address); device location information, for example, location information obtained via GPS, Bluetooth or WIFI signals; and other device information such as type of browser, telecom operators, device language, device time zone, device application list, unique application number (s),mobile push code, mobile phone Brand.
• Log and operation log information, Including your use of our products or services, the operation records of your use of various functions of the product, such as registration time, recent login time, logout time, time and number of device additions, video viewing, recording, photographing, intercom, Use of mute, timing function, number of verification code requests, video/photo download records, crash information, and information about your IP address, download, installation, or use of mobile applications and software.
• Location information. When you turn on your smart device location function and use our location-based services, we may collect and process information about your actual location, so that you will be able to access services without manually entering your own geographic coordinates. We use various technologies to determine your location, including IP addresses, GPS and other sensors that can provide relevant information (such as information about nearby devices, Wi-Fi access points and base stations).
• Information regarding the environment captured by the camera, Including indoor layout, floor item information, item distribution, indoor personnel and pets, etc. Depending on the specific scenario in which you use this product, this information may contain personal data of you or other subjects, including personal facial information, motion detection information, sound detection information, etc.
• Voice information: the voice information that you produce when you use remote conversation functions, voice information of other individuals having remote conversations with you via our smart device and voice information that you produce when you use the smart voice control function.

Information based on additional functions:

• This product features the ability to set profile pictures and scan QR codes, which requires camera permissions to take photos.
• The product offers a feature to save to the phone's gallery, requiring read and write permissions to save and access photos and videos in the device's gallery.

• We obtain your personal data indirectly from a third party
• When you log on the Product using a third party account, we shall, based on your authorization, obtain your nickname, mobile phone number, email address, gender, photo, birth date, domicile, age, current city where you are located and personal statements you provided to the third party platform.
• When you purchase our products on a third-party e-commerce platform (Amazon), we obtain information about your nickname on the platform, order number, mailing address, payment amount and payment time from the third-party e-commerce platform and payment service provider.

2. How do we use your personal data

• To provide you with the functions or features of our products and services:
• We will create an account for you using the user name, email address provided by you, or information about your account on a third party account that we obtain from such third party platform.
• In order to provide you with video surveillance, video/picture capture, live video, video storage, video download, remote conversation functions, our smart device will take videos and provide you with video content, or transmit sounds/voices in real time based on the way you operate the Product. We take or record such video and sound/voice information only for the purpose of performing the relevant functions of the smart device. Without the consent of you or any other relevant persons, we will not access or process such information, nor use such information to recognize the identity of you or any other person, or use such information for any other purposes.
• This product is equipped with Amazon Alexa and Google Assistant voice services. When you enable smart voice services, third-party smart voice service providers will collect and process your voice information based on your operations so that our smart devices can respond to you Voice commands. For these voice information, we do not do any collection, access, or processing. Alexa, Google Assistant
• Provide you with other functions of this product. For example, when this product is equipped with a network, it needs positioning permission to automatically obtain wifi information, GPS permission, mobile phone camera permission to change avatar, mobile phone photo album read and write permission, and device intercom function requires mobile phone microphone permission.
• To maintain, improve or enhance the performance of products or services: we use your personal data to maintain the normal operation of products or services, to troubleshoot products or services, to improve the security performance of products or services, and to update the function of products or services, etc.
• To send you selected products: when you purchase our products or services through online sales channels, we will use the address and contact information provided by you to contact you and deliver the products to you.
• To provide after-sale service or warranty service: when you make a request for after-sale service or extension of warranty, we will need you to provide the order and the product information for verification, and to provide the specific contact information so that we may contact you in time.
• Information subscription and push:we will send information and notices to you, including but not limited to verification code necessary to ensure the completion of a service, push notices necessary for using our products or services, news about our products or services, product marketing campaigns and promotions, product or service surveys or other content that may be of interest to you. If you do not wish to continue receiving the information above, you may opt out in accordance with the method provided in the information we send to you.
• Statistical Analysis of Product Use: in order to understand the use of various functions of our products and services, we may conduct statistics and analyze our users' use of our products or services.
• To protect the security of your account and our products or services:we may comprehensively analyze the information we collect and determine the security of your account and trading risks based on your using habit, carry out identity verification, detection and prevention of security incidents, and take necessary recording, auditing, analysis and handling measures according to the law to better prevent security risks such as website phishing, fraud, network loopholes, computer virus, network attack, network intrusion and other security risks and to more accurately identify actions in violation of laws and regulations or the relevant product or service agreements to protect the legitimate rights and interests of you, other users and us.
• To respond to law enforcement requests as required by applicable laws, court orders or government regulations.

• How we use cookies and similar technologies

1. Cookie

• What is a cookie?

• Cookies we use

• Clean /Disable cookies

• Microsoft Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Google Chrome
• Safari for macOS
• Safari for iOS
• More about cookies

2. Beacons and pixel labels

3. Do Not Track

• How we share, transfer and disclose your personal information

1. Apeman may share some personal data with third parties from time to time. Your personal data will not be shared with third parties for their own marketing or business purposes.
2. Only for the purposes stated in this Policy, some of our services will be provided with the assistance of authorized partners. We may share some of your personal data with our partners to provide better customer services and user experiences. We will share your personal data only for legal, legitimate, necessary, specific, and explicit purposes, and will only share personal data necessary for provision of our services. Our partners are not allowed to use shared personal data for any other purpose.

• Technical Service Providers: We cooperate with Tuya technical service providers who will provide us with technical support for specific functions of products or services and provide back-end support services for our smart devices. To this end, the Tuya technical service provider will need to obtain your username, email address, log information, operation records, and location information.
• Smart Voice Service Provider: the Product has embedded third-party smart voice control services. When you enable such services, the third-party smart voice service provider will collect and process your voice information based on your actions so that our smart devices can respond to your voice instructions. We do not collect, access or process such voice information.For information on how third-party smart voice service providers collect and process your personal data, please visitAlexa:https://www.amazon.com/gp/help/customer/display.html?nodeId=468496&pop-up=1 Google Assistant:https://developers.google.com/assistant/console/policies/privacy-policy-guide?authuser=1.
• Cloud Service Providers:we engage third-party cloud storage service providers, so as to provide you with video and audio content storage services. Please be noted that without your prior consent, neither we nor any of our third-party service providers will access, process or use such information, or to use such information to recognize the identity of you or other persons or for any other purpose.
• Advertising Service Providers:in order to promote our marketing information to you, we may share your email address to third-party advertising service providers, so that they may push marketing information that may be of interest to you. If you do not wish to continue receiving such information, you may opt out in accordance with the methods disclosed within such information;
• Message Push Service Providers:We share your email information and device push code with third-party information push service providers to push product or service related information or notifications to you on our behalf.

3. If the transfer of personal data is involved in a merger, acquisition or bankruptcy liquidation, we will require the new company or organization that hold your personal data to continue to be bound by this Policy; otherwise, otherwise, additional authorization and consent will be obtained from you by said company or organization.
4. We sign stringent confidentiality agreements with companies, organizations and individuals to which we share your personal data and require them to use personal data in strict accordance with the purposes set forth in this Policy, and take relevant confidentiality and security measures to process personal data.
5. We will comply with relevant laws and regulations and keep your personal data confidential. We will not disclose your personal data to a public extent we obtain your prior explicit consent or authorization or as required by law. We will only disclose your personal data to the public where the disclosure are required by law, or when we need to comply with a subpoena or other legal process, lawsuit, or when we are mandatorily requested by a government authority. We may disclose your personal data to the public if we believe in good faith that such disclosure is necessary to protect our rights, the security of you or other persons, investigate fraud or respond to a government request.

• How we store and protect your personal data

1. The personal data we collect will be retained for the minimum period necessary to achieve the purpose of collection stated in this Policy, unless a longer retention period is required by law. We will delete or anonymize your personal data when the aforementioned retention period expires. For example, we will continuously retain your personal data during the period you register and use our products or services. If you cancel your account, we will delete or anonymize your personal data once you have finished account cancellation, unless otherwise required by laws and regulations.
2. If we cease to operate some or all of our products or services for special reasons, we will promptly notify you and cease the collection and processing of personal data of the related products or services, and delete or anonymize personal data in our possession in relation to that products or services, unless otherwise required by laws and regulations.
3. We take reasonable and practical management and technical measures to protect the information we collect which relates to our products or services. Please note, however, that, although we take reasonable steps to protect your information, no website, internet transport, computer system or wireless connection is absolutely secure.
4. We have used security measures which are in compliance with industry standard to protect the personal data of you against unauthorized access, public disclosure, use, modification, or damage or loss of data. We will take all reasonably practicable steps to protect your personal data, including the following:

• At present, we have taken measures to ensure the security of data transmission and storage, such as encrypting the data itself or encrypting the documents, and we have adopted strict management measures and access restrictions for our servers, which can only be accessed in our LAN environment.
• We have set up authority allocation for internal data access and data export within the company,and we only allow the employees necessary to know the personal data for purpose of processing such information to access such personal data. Where high-sensitivity information such as user privacy is involved, the relevant personal data may be accessed only upon the approval of superior managers;
• The security of your information is very important to us. Therefore, we will continue to ensure the security of your personal data, and implement security measures such as encryption throughout the storage and transmission process to prevent your information from being accessed, used or disclosed without authorization. Meanwhile, the details of some encrypted data are not accessible to anyone other than the user.

5. In the event of a personal data security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the incident, the measures we have taken or will take to deal with it, suggestions that you can take on your own to guard against and mitigate the risks, and our remedial measures to you. We will inform you of the relevant information of the incident in a timely manner by email, letter, telephone, push notice or otherwise. When it is difficult to inform the subject of personal data one by one, we will take reasonable and effective means to issue announcements. At the same time, we will also follow the requirements of the regulatory authorities, and take the initiative to report the handling of personal data security incidents.

• Your rights to your personal data

1. Right to know:we inform you of how we process your personal data by releasing the Policy. We are committed to ensuring the transparency in use of your information.
2. Right to access:you can directly inquire or access your personal data in our product or service interface. You can login your account at any time through the product or App page, to access your account related personal data, including basic information, operation records, audio and video information, etc.

3. Right to rectification:you have the right to ask us to rectify or supplement any incorrect or incomplete processing of your personal data (if any). You can directly rectify and modify part of your personal data on the related function pages of products or services. Otherwise, you can contact us via the contact information disclosed herein to request the rectification or supplement of your personal data, if the self-modification channel is not provided. In such circumstances, we will process your request and give feedback in time according to the laws and regulations.

4. Right to erasure/deletion: You can directly erase/delete your submitted information in the product interface under your account, such as email address, etc. You can contact us via the contact information disclosed herein to request the erasure/deletion of your personal data collected and used by us in violation of our agreement with you (if any),and we will deal with it in a timely manner according to the requirements of laws and regulations.

5. Right to restriction of processing:you have the right to ask us to restrict our processing of your personal data. This means that we can store your personal data, but cannot further process it. We will only keep the data necessary for responding to your request in the future.

6. Right to data portability: you are entitled to obtain your personal data in structured, commonly used and machine-readable formats to the extent permitted by laws and regulations. For example, if you decide to change to a new service provider, you can move, copy or transfer your personal data between our IT system and their IT system in a reliable, secure and easy way without affecting its use.

7. Right to object: Even if your data is processed for our legitimate interests, exercise of public authority, direct marketing (including data pooling), and statistical reasons, you have the right to deny creative processing of your personal data by apes.

8. Right to withdraw consent:If you agreed to our processing of your personal data, but changed your mind later, you may withdraw your consent at any time, and we must stop processing your personal data. You can change the scope of your consent for us to continue to collect your personal data or withdraw your consent by deleting information, turning off device permission settings, changing related product or feature settings, cancelling your account, etc.

9. Right to refuse automated decision-making:you have the right not to be subject to decisions made by automated processing, including profiling. If these decisions significantly affect your legitimate rights, you can refuse to automated decision-making by sending an e-mail to the following address Feedback via Nooie app；2. Via email, email address: support@nooie.com and we will respond to your request and take appropriate measures if necessary.
10. Right to complaint:You have the right to contact us to make a complaint via the contact information disclosed herein, or make a complaint to the data protection agency in your country about our processing of your personal data.

• How we processchildren’s personal data

1. This product is not intended for children under the age of 16 (or the age stipulatedin local legislations of the Member States of the European Union). For such children, we will only process their information with the consent of the minors’ guardian to the extent legally permissible.
2. We will use our best efforts to verify that a child's personal data has been processed with the consent of their guardian. If we find that personal data has been collected on a child without first obtaining a verifiable guardian's prior consent, we will endeavor to delete relevant information as soon as possible.
3. Please note that while you use our product with a camera or a smart voice control product, our product, or the relevant smart voice service provider, will photograph or record certain content that may contain personal data about a child, including a child's facial information, voice information, etc., solely due to implementation of the product function. Although we will not access or process this information, we will remind you in a prominent way of what personal data about a child might be photographed or recorded by such function when you activate relevant feature and obtain the explicit consent of you, as the child's guardian, or prompt you for the child's verifiable guardian’s explicit consent.

• Third-party service providers and their services

1. Our websites, products, and services may contain links to third-party websites, products, and services. You may choose whether to visit third-party websites, products, and services.
2. We cannot control the privacy and data protection policies of third parties, and such third parties are not subject to this Policy. Before submitting your personal data to these third parties, please refer to their privacy policies.

• How we transfer your personal information globally

1. In principle, your personal data will be stored within the territory of European Economic Area (EEA).
2. As we provide products and services globally. Therefore, your personal data (including the categories of data listed in the Clause “How we collect and use your personal data”) may be transferred to other jurisdictions outside the country/region where you use the Products, or may be accessed by users from these jurisdictions for the sake of our global business.These jurisdictions include, but not limited to, mainland China, the Hong Kong Special Administrative Region of China etc.
3. When your personal data is transferred to a country outside the EEA, we will ensure that appropriate measures are taken. For example:

• The country or region where the personal data recipient is located benefits from the adequacy decision made by the European Commission under Article 45 of the General Data Protection Regulation ("GDPR"); or
• The personal data recipient has signed the standard data protection contractual clauses which have been approved or adopted by the European Commission pursuant to Article 46 of the GDPR.

4. In the absence of aforementioned appropriate protection measures, will ask your explicit consent to the international transfer of your personal data, and take encryption, de-identification and other security measures to protect your personal data.
5. If you would like to obtain the standard data protection contractual clauses or to know more about the protection measures related to the transfer of personal data outside the European Economic Area, please contact us by email at support@nooie.com.

• How we update this Policy