Privacy Policy of the 4Family 2 App
Our privacy policy is effective from September 23, 2023
Introduction
This privacy policy sets out how we collect, use and store the information you give us when you use our app. "Personal data" in this privacy policy means any information about an identified or identifiable natural person ("data subject").
1. Personal data administrator
The administrator of personal data is Smalt Communication Technology (Shenzhen) Co., Ltd. with its registered office in Shenzhen, room 403, building no. 2 Duoli industry Futian district, Shenzhen, email: lukasz@smaltcn.com.
2. What information we may collect and for what purpose and on what basis we use it
Depending on the application you use, we may collect your personal data for the following purposes:
(1) User account registration
You may need to set up a User account in order to pair your wearable smart device with our app. For this purpose, we may collect your account information, smart device identification information, device MAC address, software list, mobile phone device identification information (hashed IMEI number), mobile phone model, system version number, Bluetooth information about smart devices. These data are processed in order to enable you to use our application in conjunction with your device (Article 6(1)(b) of the GDPR). If you use applications that work without creating a User account, we do not store your personal data - they are stored by you only on your phone.
(2) Recording and displaying activity, health and location information
When you use smart devices, we may collect and record information about your activity, including step count, exercise mode, distance traveled, exercise time, and heart rate information. In addition, we may collect personal information, including your nickname, gender, date of birth, height and weight. This information will be used to calculate and display to you your heart rate, steps, exercise calories, sleep time, etc. on smart devices, application pages, so you can better understand your exercise status. The User's personal data may also be used in some applications to provide the User with exercise advice. This information will be displayed on wearable smart devices and application pages and can be viewed by the user at any time. If you use an application that allows you to track the location and health information (e.g. heart rate, medications taken) of a loved one whose device will be paired with the User's application, we may also process the above-mentioned data. data of that person - after they have consented to such processing on their device.
These data will be processed by us on the basis of your consent (Article 6(1)(a) and Article 9(2)(a) of the GDPR).
(3) Feedback from the User when a problem with the application is reported
We may collect the feedback you give us, your contact details and this information will be used to help us better understand the problem you have encountered user and contact him. If you actively submit a device data file (hereinafter referred to as "log") to resolve a problem, we will collect log information. The uploaded log contains exercise data (such as exercise mileage, exercise duration, etc.) and health data (such as heart rate, sleep time, stress data, etc. We ensure that the log information you submit will only be used for to solve the problem, and we will not use them for other purposes. These data will be processed by us on the basis of our legitimate interest, which is the need to ensure the proper operation of the application, and in the scope of data concerning your health - on the basis of your consent (Article 6(1)(a) and Article 9(1)(a) 2 letter a GDPR).
(4) Transfer of data to third parties
Our application may allow you to synchronize the route information of your paired wearable smart device with Google Maps. To support this feature, we will collect the Shared User's account ID on the Google platform. If you no longer use this feature, you can unpair your device and we will delete this information after unpairing.
(5) Allowing notifications from other applications to be sent to your paired smart device, as well as enabling notifications sent via our application to be sent to your loved one's paired device
Our apps support the sending of notifications from other apps to your paired smart device and allow you to control whether notifications for a particular app are sent via separate settings for each app. In order to support this function, we will be able to read the list of installed applications (Article 6(1)(b) of the GDPR) and - if you consent to the sending of notifications - messages in the notification bar (Article 6(1)(a) of the GDPR). Some of our applications allow you to send notifications sent through them to the paired device of your loved one, for this purpose we will process the messages sent. This function is operated in order to provide this service to you (Article 6(1)(b) of the GDPR) and on the basis of the consent of a third party (Article 6(1)(a) of the GDPR).
In addition, we may process personal data as part of additional features - if you do not provide this personal information, you will still be able to use the above core services, but may not be able to use these additional features, which may bring you more optimized services. These additional features include:
(6) Drawing the motion trajectory
An additional feature of some applications based on location information. If you want to record your movement trajectory in outdoor sports scenes, after enabling location permission in the application, we will collect information about your location to draw a movement trajectory for you (pursuant to Article 6(1)(a) of the GDPR).
(7) Sports Data Sharing
In order to provide you with a better sports data recording experience, you may actively choose to share your sports data on third party platforms (such as Facebook, Instagram) in some applications. To support this feature, we will collect your account information shared on third party platforms, including your account ID, account nickname and avatar. If you no longer use this feature, you can unlink it and stop providing it, and we will delete this information after you unlink. We will collect this data on the basis of our legitimate interest in ensuring the correct operation of this application function (Article 6(1)(f) of the GDPR).
(8) Additional application permissions based on the User's consent
In addition, the following device permissions may be triggered when using the app. In order to better manage your information, we will inform you about the purpose of using the permission when allowing the app to use the product and the possible impact on your use of the service if you do not enable the permission. Before using a specific function, the User can choose whether he wants to authorize given permissions. At the same time, the user can change the authorization status at any time via the device authorization settings page. Below are the details of related functions and calling permissions listed for reference:
a) Reading and writing external storage space (Android version): it is used to read the image on the phone when the User sets the picture of the watch face; when the User shares a photo, it is used to save the photo on the User's phone;
b) Location permissions (Android, IOS version): used to scan Bluetooth devices when the User pairs a smart device; when the User activates the external sports function, it is used to help the User record the movement path; used to display weather information to the User on a smart device synchronously;
c) Reading the address book and call history: it is used to synchronize the caller's number and contact name to the smart device for display when the User uses the "display contact" information function;
d) Making and receiving calls: used to control mobile phone calls from a smart device when the User uses the "call reminder" function;
e) Camera access (Android, IOS version): Used to scan devices with QR code. The processing of personal data as part of the application's additional rights is based on the user's consent, i.e. art. 6 sec. 1 lit. and the GDPR.
(9) In addition, we may process your personal data to the extent necessary to maintain the safe and stable operation of the services provided, such as detecting and removing failures in the operation of the application, as well as to determine, defend and pursue claims that may arise as part of the relationship between you and the Administrator and for other purposes that are necessary to implement the legitimate interests of the Administrator or a third party - pursuant to art. 6 sec. 1 lit. f GDPR.
wykrywanie i usuwanie awarii w działaniu aplikacji, a także w celu ustalenia, obrony i dochodzenia roszczeń, które mogą powstać w ramach relacji między Tobą a Administratorem oraz w innych celach, które są niezbędne do realizacji prawnie uzasadnionych interesów Administratora lub strony trzeciej - na podstawie art. 6 ust. 1 lit. f RODO.
(10) Non-Personal Information
We may also collect other information that cannot identify a specific person (that is, information that is not personal information), such as statistical data generated when you use a particular service, such as daily events. The purpose of collecting such information is to improve the services we provide to you. The type and amount of information collected depends on how you use our products and/or services. For the purposes of this privacy policy, aggregate data is considered non-personal information. If we combine non-personal information with personal information, such information will be treated as personal information for the duration of the combined use.
4. Recipients of personal data
(1) Location service provider: The location service for this activity is provided by third party company Google Ireland. We will provide your GPS location information to such service providers via SDK related technology to provide you with maps, sports-related location services. We guarantee that we only share personal data necessary to provide services to you for lawful, legal, necessary, specific and clear purposes. In addition, we use encryption and other measures to protect information. We define the practices and responsibilities of third parties through agreements to ensure that third party service providers adhere to the privacy standards applicable in your jurisdiction.
5. Transfer of personal data to other countries
Your use of our Application will result in the transfer of your personal data to other countries as well as storage and processing outside the European Economic Area, including countries for which the Commission has not found an adequate level of protection. However, all international data transfers are subject to the requirements of the GDPR and appropriate measures to ensure that your personal data is processed securely and as expected. These measures include, among others: standard contractual clauses that secure the process of transferring data outside the EEA.
6. Data storage period
We store the personal data we process for the period necessary to achieve the purpose of collecting information described in this privacy policy or to meet applicable legal requirements. The data stored by us will be deleted as a consequence of deleting the User's account.
Depending on the application, deletion of the account takes place by deleting the account as part of the application's functionality/settings or by contacting us at the e-mail address lukasz@smaltcn.com.
We will process your account deletion request within the period indicated on the website, which generally does not exceed 15 days as required by law. You should exercise due care when deleting your account, as this process will prevent you from using our products and services with your existing account.
7. Your rights
You have the right to access your personal data at any time and request their rectification, deletion, processing restrictions, transferring data to another administrator, not being subject to a decision based solely on automated processing, including profiling, objecting to their processing based on the legitimate interest of the data administrator (Article 6(1)(f) of the GDPR) or for statistical purposes (Article 89(1) of the GDPR) for reasons related to your particular situation, as well as for processing for direct marketing purposes. For all matters related to the processing of personal data, you can contact us at the e-mail address lukasz@smaltcn.com. We will process your request without undue delay and within a maximum of 30 days. In exceptional circumstances, we have the right to extend this period for another two months, which we will inform you about. You also have the right to lodge a complaint with the supervisory body dealing with the protection of personal data, if you believe that the processing of data by the Administrator is contrary to the GDPR.
8. Voluntary provision of data
You provide us with your data voluntarily, however, providing them is necessary for the proper operation of the application or its functions, and in some cases also for the implementation of the legitimate interests of the Administrator or third parties. If we process your data on the basis of your consent, you have the right to withdraw your consent to the processing of personal data at any time, without affecting the legality of our previous processing of this data.
9. Profiling and automatic decision making
The data you provide will not be used to make any automated decisions regarding you, including profiling.
10. Application Settings
We recognize that everyone has different privacy concerns. Therefore, we provide a few examples to illustrate the various methods provided by the application for the User to choose to limit the collection, use, disclosure or processing of his personal data and to control the privacy settings - we remind you that the User may:
a) Pair/unpair smart devices in the application;
b) Modify your personal information on the settings page.
11. Third Party Websites and Services
Our privacy policy does not apply to products or services provided by third parties. Depending on the products or services of the 4Family 2 application that the User uses, which may include third party products or services, including smart device settings and other types of data. They may also collect information about you when you use these products or services. Therefore, we strongly recommend that you take the time to read the third party's privacy policy as well as ours. We are not responsible for how third parties use the personal information they collect from you and we cannot control their use. Our privacy policy does not apply to other websites linked from our website.
Information for iOS users: We will not collect and store any data from your HealthKit in any form or sell it to advertisers or other operators.
12. How to update this policy
We will periodically review the privacy policy based on changes in business and technology, and we may update this privacy policy. If we make material changes to this privacy policy, we will notify you via in-app pop-up notifications so that you can understand what information we collect and how we use it. Such changes to the privacy policy will be effective from the updated notification date. We recommend that you regularly review the in-app privacy policy for the latest information on our privacy practices. Your continued use of the product, mobile phone and/or services on any other device will be deemed acceptance of the updated privacy policy. When we collect more personal information from you, or when we use or disclose that personal information for a new purpose, we will ask for your consent again.