Privacy Policy
Effective Date:
01 May 2024
Updated:
21 May 2024
Western International LLC
and subsidiaries (“we”, “us”, “our”, “
Western International LLC
”) are committed to protecting your privacy. This Privacy Policy (“Policy”)
describes our practices in connection with information privacy on Personal
Data we process through your individual use of the following services,
products, and related mobile applications (collectively, the “Products”):
·
Western
Mobile Application
Before you use our Products, please carefully read through this Policy
and understand our purposes and practices of collection, processing of
your Personal Data, including how we use, store, share and transfer Personal
Data. In the Policy you will also find ways to execute your rights of access,
update, delete or protect your Personal Data.
When you accept this Policy when you register with your Personal Data,
or if you start to use our Products and does not expressly object to the
contents of this Policy, we will consider that you fully understand and
agree with this Policy. If you have any question r regarding this Policy,
please do not hesitate to contact us via: 18742 WIG, NIP, Dubai.
Definition
In this Policy, Personal Data means information generated, collected,
recorded and/or stored, electronically or otherwise, that can be used to
identify an individual or reflect the activity of an individual, either
from that information alone, or from that information and other information
we have access to about that individual.
Personal Sensitive Data includes personal biometric information, communication
records and contents, health information, transaction information, and
precise location information. When we collect Personal Sensitive Data from
you, we will generate an explicit notification for your consent before
we collection personal sensitive data about you.
Smart Devices refers to those computing devices produced or manufactured
by hardware manufacturers, with human-machine interface and the ability
to transmit data that connect wirelessly to a network, including: smart
home appliances, smart wearable devices, smart air cleaning devices, etc.
Apps refers to those mobile applications developed byWestern International
LLCthat provide end users remote control to Smart Devices and with the
ability to connect to the supplier IoT Platform.
What Personal Data do we collect
In order to provide our services to you, we will ask you to provide necessary
Personal Data that is required to provide those services. If you do not
provide your Personal Data, we may not be able to provide you with our
products or services.
1.Information You Voluntarily Provide Us
·Registered Account Data: When you register an account with us, we may
collect your name and contact details, such as your email address, phone
number, user name, and login credentials. During your interaction with
our Products, we may further collect your nickname, profile picture, country
code, language preference or time zone information into your account.
However, if the Services you request or purchase are based on your account,
please go to the registration/login page for guidance.
Information based on additional functions:
Confirm: the system permissions that allow in the your App
In order to offer you with more convenient and higher-quality Services
with optimized user experiences, we may collect and use certain information
if you consent to use additional functions in the App. Please note, if
you do not provide such information, you may continue to use basic Services
of the App and connected Smart Devices, but certain features based on these
additional functions may not be available. These additional functions may
include:
1)Additional functions based on location information:
When you enable the location-based functions through permission settings
on your mobile device, we will collect and process your location information
to enable these functions, such as pairing with your Smart Devices. Also,
we may collect information about your: a) real-time and precise location,
for instance when you choose to use the automation scenarios for controlling
your Smart Devices, or b) non-precise geo-location when you use certain
Smart Devices or the Services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fence feature, your location
information will be generated and shared with Google Maps services. Please
note that Google has corresponding data protection measures, which you
may refer to Google’s Data Processing and Security Terms for more details.
You may disable the collection and use of your location information by
changing your mobile device settings ("My - Setting - Privacy Right Setting
- Switch on/off Location Information"), upon which we will cease to collect
and use your location information.
2)Additional services based on camera:
You may use the camera to scan the code by turning on the camera permission
to pair with a Smart Device, take video, etc. Please be aware that even
if you have agreed to enable the camera permission, we will only obtain
information when you actively use the camera for scanning codes, video
recording, etc.
You may opt-out the using of camera permission: "My - Setting - Privacy
Right Setting - Switch on/off Camera".
3)Additional services for accessing and uploading pictures/videos based
on photo albums (picture library/video library):
You can use this function to upload your photos/pictures/videos after
turning on the photo album permission, so as to realize functions such
as changing the avatar, reporting device usage problems by providing photo
proofs, etc.. When you use the photos and other functions, we will not
recognize this information; but when you report a device usage problem,
we may use the photos/pictures you upload to locate your problem.
You may opt-out the using of photo album permission: "My - Setting - Privacy
Right Setting - Switch on/off Photo Album".
4)Additional services based on storage permission(Android):
The purpose is to ensure the stable operation of the App by utilizing
the storage permission. After you give or indicate the permission to read/write
your mobile device’s storage, we will access pictures, files, crash log
information and other necessary information from your mobile device’s storage
to provide you with functions, such as information publications, or record
the crash log information locally.
You may opt-out the using of storage permission: "My - Setting - Privacy
Right Setting - Switch on/off Storage".
5)Additional services based on Notification permission:
The reason why we ask you for the permission is to send you notifications
about using the Smart Devices or Services, especially if you have purchased
security services and you require an alert or message so that you can capture
the real-time status.
You may opt-out the using of App notifications: "My - Message Center -
Setting - Switch on/off Notifications".
6) Additional services based on Bluetooth permission:
You can enable Bluetooth functions after turning on the permission, including
controlling the Smart Devices, acquiring status of, discovering and configuring
Smart Devices. In these functions, we will communicate with Smart Devices
via Bluetooth. Please be aware that even if you have agreed to enable the
Bluetooth permission, we will only use Bluetooth for communication in these
scenarios: display device status on the home page and Smart Device panel;
perform device control on the home page and Smart Device panel; discovering
Smart Devices on the home page and the add device page, Smart Device distribution
network.
You may opt-out the using of Bluetooth via "My - Settings - Privacy Setting
- Disable/Enable Bluetooth permission".
Please note that if you turn on any permission, you authorize us to collect
and use relevant personal information to provide you with corresponding
Services. Once you turn off any permission, we will take it as canceling
the authorization, and we will no longer continue to collect Personal Data
based on the corresponding permissions, and the related functions may be
terminated. However, your decision to turn off the permission will not
affect the previous collection and use of information based on your authorization.
2.Information We Collect Automatically
·
Mobile Device Information
: When you interact with our Services, in order to provide and maintain
the normal operation of our Services, to improve and optimize our Services,
and to protect your account security as well, we automatically collect
mobile device information, such as mobile device model number, IP address,
wireless connection information, the type and version of the operating
system, application version number, push notification identifier,
log files, and mobile network information. Meanwhile, we will collect your
software version number. In order to ensure the security of the operating
environment or to provide services, we will collect information about the
installed mobile applications and other software you use.
·
Usage Data
: During your interaction with our websites and Services, we automatically
collect usage data relating to visits, clicks, downloads, messages sent/received,
and other usage of our websites and Services.
·
Log Information
: When you use the App, in order to improve your user experience, the
system and exception log may be uploaded, including your IP address, language
preference setting, operating system version, date or time of access, so
that we can facilitate and accurately identify problems and help you solve
them in timely manner.
Please note
that we cannot identify a specific individual by using device information
or log information alone. However, if these types of non-personal information,
combined with other information, may be used to identify a specific individual,
such information will be treated as Personal Data. Unless we have obtained
your consent or unless otherwise provided by data protection laws and regulations,
we will aggregate or desensitize such information..
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you are as follows:
·
Provide You with Our Services:
We process your account data, mobile device information, usage data, location
information, and Smart Device related information to provide you with the
Services that you have requested. The legal basis for this processing is
to perform our contract with you according to user agreement or some other
terms of user? Confirm.
·
Improve Our Services:
We process your mobile device information, usage data, location information
and Smart Device related information to ensure the functions and safety
of the Services, to develop and improve the Services, to analyze the efficiency
of our operations and to prevent and trace fraudulent or inappropriate
usage. The legal basis for this processing is to perform our contract with
you according to our user agreement or some other terms of user? Confirm.
·
Non-marketing Communication:
We process your Personal Data to send you important information regarding
the Services, changes to our terms, conditions, and policies and/or other
administrative information. At the same time, we will also send you notifications
related to the services you have purchased, such as alert services. You
can check the “App Notification” in the App ("Me &rt; Message Center
&rt; Setting &rt; Notification Setting”) to manage these communications.
When you decide not to enable the Notifications function, we will no longer
process your information for such purpose. The legal basis for this processing
is to perform our contract with you according to our user agreement or
some other terms of user? Confirm.
·
Data Analysis:
In order to analyze the usage of the products we provide and improve your
user experience, we will analyze the data you provide us, a) we need to
check your problems when you encounter any malfunctions during the usage
of the product, under such circumstance, you may not able to opt-out because
it is highly relate to your functionalities and quality of using our product
and service, and b) analyze data about how you interface with the product
or under particular scenarios so that you can better enjoy the convenience
brought by our Services, under such circumstance, if you do not agree to
data analysis of your data, you can enter the privacy settings of App (“My
&rt; Settings &rt; Privacy Settings &rt; Data Analysis”) to
opt-out your selection. The legal basis for such processing is based on
your consent.
·
Marketing Communication and Personalization:
We may process your account data, usage data, device information to personalize
product design and to provide you with services tailored for you, such
as recommending and displaying information and advertisements regarding
products suited to you, and to invite you to participate in surveys relating
to your use of the Services. If you do not allow us to process your Personal
Data for personalization, you may opt out when you enter the App, or by
changing your preferences in “Privacy Settings” (“Me&rt; Settings &rt;
Privacy Settings &rt; Personalization”) in the App. The legal basis
for this processing is your consent.
·
Legal Compliance
. We disclose information if we are legally required to do so, or if we
have a good faith belief that such use is reasonably necessary to:
·comply with a legal obligation, process or request;
·enforce our User Agreement and other agreements, policies, and standards,
including investigation of any potential violation thereof;
·protect the rights, property or safety of us, our users, a third party
or the public as required or permitted by law; or
·detect, prevent or otherwise address security, fraud or technical issues.
If there is any change in the purposes for processing your personal data,
we will inform such change to you via email and/or a prominent notice on
our website of such changes of purposes, and choices you may have regarding
your Personal Data.
Who do we Share Personal Data with?
At
Western International LLC
, we only share Personal Data in ways that we tell you about. We may share
your Personal Data with the following recipients: Confirm the following
details
·To our third-party service providers who perform certain business-related
functions for us, such as website hosting, data analysis, payment and credit
card processing, infrastructure provision, IT services, customer support
service, e-mail delivery services, and other similar services to enable
them to provide services to us.
·To our customers and other business partners who provide you, directly
or indirectly, with your Smart Devices, and/or networks and systems through
which you access and use our websites and Services.
·To subsidiaries or affiliates within our corporate family for purpose
of regular business activities based on our instructions and in compliance
with applicable law, this Policy and other appropriate confidentiality
and security measures.
·To an affiliate or other third party in the event of any reorganization,
merger, sale, joint venture, assignment, transfer or other disposition
of all or any portion of our business, assets or stock (including without
limitation in connection with any bankruptcy or similar proceedings). In
such an event, you will be notified via email and/or a prominent notice
on our website of any change in ownership, and choices you may have regarding
your Personal Data.
·As we believe in good faith that access to, or use, preservation, or
disclosure of the information is reasonably necessary or appropriate to:
(a)Comply with applicable law, regulation, legal process, or lawful governmental
request;
(b)Enforce our User Agreement and other agreements, policies, and standards,
including investigation of any potential violation thereof;
(c) Protect our operation and business systems;
(d)Protect the rights, property or safety of us, our users, a third party
or the public as required or permitted by law; or
(e)Perform risk management, screening and checks for unlawful, fraudulent,
deceptive or malicious activities.
Except for the third parties mentioned above, we only disclose your Personal
Data to other third parties with your consent.
International Transfer of Information Collected
Western International LLC
will comply with applicable data localization requirements in corresponding
jurisdictions with respect to storage of data. To facilitate our operation,
we may transfer, store and process your Personal Data in jurisdictions
other than where you live. Laws in these countries may differ from the
laws applicable to your country of residence. When we do so, we will ensure
that an adequate level of protection is provided for the information by
using one or more of the following approaches:
·Agreement on the basis of approved EU standard contractual clauses per
GDPR Art. 46. For more information, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If you would like further detail on the safeguards we have in place, you
can contact us directly as described in this Privacy Policy.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal Data. You may exercise
any of the following rights:
You may:
·Request access to the Personal Data that we process about you: "My-Setting-Privacy
Settings-Personal Data Export";
·Request that we correct inaccurate or incomplete Personal Data about
you: 1) Modify your account number (email address or phone number): "My-Setting-Account
and Security-Change your Account"; 2) Modify the nickname and/or time zone:
"My-Personal Information";
·Request deletion of Personal Data about you: "My-Setting-Account and
Security-Delete Account", when you confirm the deletion of your account,
your Personal Data will be deleted accordingly.
·Request restrictions, temporarily or permanently, on our processing of
some or all Personal Data about you: Please send over your request through
"My-FAQ & Feedback", or send over the email request to Confirm: the
emailbox?;
·Request transfer of Personal Data to you or a third party where we process
the data based on your consent or a contract with you, and where our processing
is automated: Please send over your request through "My-FAQ & Feedback",
or send over the email request to Confirm: the emailbox?;
·Opt-out or object to our use of Personal Data about you where our use
is based on your consent or our legitimate interests.
Withdrawal of consent Confirm the following details: We will exercise
your privacy right to withdraw consent through the following approaches:
1)For privacy permissions acquired through device system settings, your
consent can be withdrawn by changing device permissions, including Confirm:
location, camera, photo album (picture library/video library), microphone,
Bluetooth settings, notification settings and other related functions;
2)You may opt-out the non-marketing communication through “Me &rt;
Message Center &rt; Notification Settings” to manage your selection;
3)You may opt-out the data analysis features through “Me &rt; Settings
&rt; Privacy Settings”;
4)You may opt-out the Personalization feature through “Me &rt; Settings
&rt; Privacy Settings &rt; Personalization”;
5)Unbind the Smart Device through the App, and the information related
to the Smart Device will not be collected;
6)By using product with the "Try Now" mode, and not enable certain
location setting for particular smart scene, we will not collect
any Personal Data about you;
7)If you previously agreed to associate App account with a third-party
service, such as a health platform, please unbind it on the third-party
platform.
When you withdraw your consent or authorization, we may not be able to
continue to provide you with certain products or services correspondingly.
However, your withdrawal of your consent or authorization will not affect
the processing of personal information based on your consent before the
withdrawal.
About
Deletion of the Account
: You can find the Delete function through “Me &rt; Settings &rt;
Account and Security &rt; Delete Account” (Deactivate Account)
Security Measures
We use commercially reasonable physical, administrative, and technical
safeguards to preserve the integrity and security of your Personal Data.
Western International LLC
provides various security strategies to effectively ensure data
security of user and device. As for device access,
Western International LLC
proprietary algorithms are employed to ensure data isolation, access
authentication, applying for authorization. As for data communication,
communication using security algorithms and transmission encryption protocols
and commercial level information encryption transmission based on
dynamic keys are supported. As for data processing, strict data filtering
and validation and complete data audit are applied. As for data storage,
all confidential information of users will be safely encrypted for storage.
If you have reason to believe that your interaction with us is no longer
secure (for example, if you feel that the security of any account you might
have with us has been compromised), you could immediately notify us of
the problem by emailing
sharsad.n@westernint.com
.
Data Retention
We process your Personal Data for the minimum period necessary for the
purposes set out in this Policy, unless there is a specific legal requirement
for us to keep the data for a longer retention period. We determine the
appropriate retention period based on the amount, nature, and sensitivity
of your Personal Data, and after the retention period ends, we will destruct
your Personal Data.
·For as long as you require us to fulfill the products and services you
request from us as defined in the Confirm user agreement or some other
terms of use?;
·Personal Data will no longer be retained when you request to remove your
Personal Data, we will accordingly complete the task.
When we are unable to do so for technical reasons, we will ensure that
appropriate measures are put in place to prevent any further such use of
your Personal Data.
Children’s Privacy
Protecting the privacy of young children is especially important to us.
The Services are not directed to individuals under the age of thirteen
(13) (or such other age provided by applicable law in your country/region
of residence), and we request that these individuals do not provide any
Personal Data to us. We do not knowingly collect Personal Data from any
child unless we first obtain permission from that child’s parent or legal
guardian. If we become aware that we have collected Personal Data from
any child without permission from that child’s parent or legal guardian,
we will take steps to remove that information..
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information
practices. If we make any material changes we will notify you by email
(send to the e-mail address specified in your account) or by means of a
notice in the mobile applications prior to the change becoming effective.
We encourage you to periodically review this page for the latest information
on our privacy practices.
Contact Us
If you have any questions about our practices or this Privacy Policy,
please contact us as follows:
Western International LLC
Postal Mailing Address:
Corp Office, NIP, Jebel Ali, Dubai, 18742
Email:
sharsad.n@westernint.com