Privacy Policy of SKG Care

I. Overview

We are committed to maintaining your trust in us and processing your personal information in the principles of legitimacy, propriety, necessity and good faith. Therefore, we formulate the Privacy Policy (hereinafter referred to as the “Policy”) for you to fully understand our work. The Policy will help you understand:
(1) How We Collect and Use Your Personal Information
(2) How We Process Your Personal Information
(3) How We Protect Your Personal Information
(4) How We Manage Your Personal Information
(5) How the Privacy Policy is Updated
(6) How to Contact Us

The Policy applies to all functions or Services we provide. Please carefully read and understand the Policy before using our products or services. For your sensitive personal information and clauses affecting your significant rights and interests, we write them in “boldface” as special reminders. You are kindly suggested to focus on reading them and start using our Services after confirming that you have fully understood and consented to them. If you have any objections, opinions, or suggestions on the contents of the Policy, you can contact us through the contact information we provide.

II. How We Collect and Use Your Personal Information

1. Circumstances which require you to authorize us to collect and use your personal information

As our Products or Services include some core functions, we may collect, store, and use the following information about you to realize the said functions. If you refuse to provide relevant information, you will be unable to provide products and services provided by us to you. These features include:

1.1 Account Registration, Login, Verification and Binding
1.1.1 When you register an account for a certain Product or Service, you need to provide us with the account name and password you intend to use, your own mobile phone number, E-mail, and the information of the third-party account (user ID, avatar and other information obtained by authorizing third-party sign-on) at least, and we will verify whether your user ID and related information are valid by sending a verification code to you. We collect the said information to help you register an account successfully. If you refuse to provide the said information, you will not be able to create an account on [Blood Pressure Watch R6].
1.1.2 In order to manage the devices that you use, we need to collect the identifier of your device (including MAC address), the information of its hardware, device usage, basic system and network when you bind your device to ours. We collect the said information to establish Bluetooth connections, manage device configurations, complete software upgrading, display data sources, make statistics on device activations and improve your experience in network connections. If you refuse to provide the said information, we will not be able to bind our Services to yours successfully or provide the Services related to the device.

1.2 Use of core basic functions
In order to manage your health data, we need to collect your blood sugar, blood pressure, blood oxygen, electrocardiogram, and heart rate as well as related measurement data and setting data when you use our watches. We collect the said information to measure, record, display, and make statistics on the health-related data in order to provide you with abundant health services. If you refuse to provide the said information, you will not be able to use our Services normally.

1.3 Health Maintenance
When you use the functions or services provided by us, we may automatically collect your detailed use of our services and save it as the relevant network log. We collect information such as the type of content you browse, the date and time of your access, the records of your access to the pages, and the length of your stay. This kind of information is the basic information we collect in order to improve the user experience. If you refuse to provide log information, you will not be able to use our Services normally.

2. Circumstances which give you the option to present your personal information

In order to help you use our Products or Services more conveniently, thus improving your user experience, we may collect and use your personal information in our following extensions. If you do not present such personal information, you can still use the core functions of the products or services, but you may not be able to use these additional functions provided by us to you. These additional functions include:

2.1 Health Assessment
In addition to the information that must be provided for using our watches as stated herein, you need to provide your basic information, such as gender, age, occupation, height, weight and sleep when you carry out a health assessment on other categories of our Products. We collect such information to provide you with proposals and suggestions on health. If you fail to provide such information, you may not be able to carry out relevant health assessments. Nevertheless, you can still use other functions of [Blood Pressure Watch R6] normally.

2.2 Health Management for Your Loved Ones
When you use the function of health management for your loved ones, you need to choose the user IDs of each other and share the basic information, such as heart rate, electrocardiogram, blood pressure, blood oxygen, blood sugar, pain score, cervical vertebra disorder index, and other information. If you fail to provide such information, you may not be able to share the health information with your loved ones. Nevertheless, you can still use other functions of [Blood Pressure Watch R6] normally.

2.3 Health Recording
When you use the function of health recording, you can choose to record the data such as pain, blood sugar and blood pressure and record relevant data simultaneously, so that you can learn the changes in your body. If you fail to provide such information, you may not be able to record the health data. Nevertheless, you can still use other functions of [Blood Pressure Watch R6] normally.

2.4 Problem Solving
When you use our problems & solutions, the information you upload, such as photos, texts, comments and favorites, will be stored in our server, which is necessary to enable this function. The information and contact details you upload shall be used for communicating and specifying your problems. If you do not provide such information, our developers will not be able to solve the problems you face. Nevertheless, you can still use other functions normally.

2.5 Feedback function
When you send feedback on our watches, you can provide us with your opinions or suggestions based on your actual user experience of the Products and Services. If you do not provide such information, you may not be able to send feedback to us. Nevertheless, you can still use other functions of [Blood Pressure Watch R6] normally.

(2) Call for Application Permissions

The following device permissions may be triggered when you enjoy [Blood Pressure Watch R6]. To manage your information in a more efficient manner, we will inform you of the purpose of the permissions while applying for the permissions to use the product, and the possible impact on your use of the services if you do not turn on the permissions. Please consult the information in real earnest. Before using a specific function, you may choose whether to authorize the following permissions. In the meantime, you may change the authorization status at any time via the page of permission setting of the device. The following are the details of the relevant functions and calling permissions:

1. Device information: We will receive and record your used device information according to the specific permissions granted by you during the software installation and use (including device name, device model, operating system, application version, language settings, unique device identifier (UDI), carrier network type, etc.). Device information is the basic information that must be collected to provide services. If you refuse to provide device information, you may not be able to use our service normally.

2. Bluetooth permission: When you use [Blood Pressure Watch R6] to control hardware, hoping to connect the hardware to [Blood Pressure Watch R6], we will obtain the Bluetooth permission of your mobile phone with your consent, so as to control the device. Refusal to give such permission will stop you from using the aforesaid function, but will not affect your normal use of other functions.

3. Location information: When you use location-related services, we may record the location and weather of your equipment in order to provide you with relevant services. When you use our Services, we may obtain information about your geographic location by IP address, positioning information, WIFI, or other means. If you do not provide your geographic location, you may not be able to search the devices nearby. Nevertheless, you can still use other functions normally.

4. Photos and videos: When you initiate customer service consultation on [Blood Pressure Watch R6], and take photos or videos to send the use status of your device to our customer service staff, you need to open the camera permission, so that we will be able to collect the photos and videos you upload. If you refuse to provide such information or refuse to open the camera permission, you will not be able to use the aforesaid function. Nevertheless, you can still use other functions normally.

5. Voice messages: When you initiate a customer service consultation on [Blood Pressure Watch R6] and use the function of voice recording, we will collect your voice messages. If you refuse to give the microphone and recording permissions, you will not be able to use the aforesaid functions, but it will not affect your normal use of other functions.

6. Calendar data (Android): You can enable the function of “Reminder” and customize the time period for you to use our Product. We will obtain your calendar data and remind you via the calendar data when it’s time for you to use the Product as customized. Refusal to enable such a function will stop you from using the aforesaid function, but will not affect your normal use of other functions.

(3) Third-party application access

When you connect a third-party application to the names of our Products or Services, we may obtain your essential personal information from the developer and technical service provider of such third-party application for the purpose of providing technical support for docking and other purposes. If you refuse our collection of your relevant personal information, it may lead to the failure to use all or part of the functions of the third-party application. Nevertheless, you can still use other functions of the Products and Services normally.

The developer and technical service provider of such third-party applications may directly collect and use your personal information in accordance with their own privacy policies. You are kindly suggested to read and confirm your understanding of such privacy policies prior to accepting the relevant services and providing your personal information.

Please refer to Paragraph 3 of Article 2 hereof for the details of the connection of a third-party application to the Products and Services.

(4) Use of COOKIES or similar technologies

We may use COOKIES or similar technologies to obtain and use your information by means of web links and store such information as log information. COOKIES help us identify the pages and contents to which you link, the time you spend on a Product or Service and the name of the Product or Service you choose. By using COOKIES or similar technologies, we can provide you with simple and personalized online experience.

We will not associate the collected log information with other information we collect. If you wish to disable COOKIES or similar technologies, you may not be able to use our service normally.

(5) Non-personal information

We may also collect other information that cannot be used to identify a specific individual, and the information is not considered personal information in accordance with applicable laws. Such information is called non-personal information. We may collect, use, transfer and disclose non-personal information. The information is collected in order to improve the services we provide for you.

We aggregate this information to help us provide more useful information to you as well as to better understand which parts of our products, or services are of most interest to you. We will do our best to separate your personal information from non-personal information and make sure that the two types of information are used separately. For the purpose of the Privacy Policy, if we combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.

(6) Exceptional circumstances where personal information is collected and used without your consent

You fully understand that we do not need to obtain your authorization or consent to collect and use your personal information pursuant to applicable laws, in the event of any of the following circumstances:
1. Involving national security and interests as well as public interests of the society.
2. Where it is necessary for our performance of the statutory duties or legal obligations.
3. When it is required by relevant agreements or other written documents to which you are a party, and signed or performed by you.
4. Where it is necessary to respond to public health emergencies, or to protect the life, health and property of you and others in emergency situations.
5. When it is disclosed to the public by yourself within a reasonable scope.
6. Your personal information is sourced from legally and publicly disclosed information (such as legal news reports or information disclosed by the government) within a reasonable scope.
7. Other circumstances as stipulated by laws and regulations.
Please be aware that the functions and services we provide to you are subject to update and development. If any function or service not described above collects your information, we will inform you of the content, scope and purpose of such information collection by means of website popups, interactive processes, website announcements, or execution of additional agreements, etc., in order to obtain your consent.

III. How We Process Your Personal Information

The personal information we collect and generate in the territory of the People’s Republic of China in accordance with the provisions of laws and regulations will be stored at Alibaba Cloud servers within the territory of the People’s Republic of China.

To make sure that you can use the core functions of the Products and Services normally, we shall always keep the personal information that you must provide to enjoy the Products or Services as mentioned in Item 1 of Paragraph 1 of Article 2 hereof, unless you withdraw your consent or close your account.

To make sure that you can use the extensions of the Products and Services normally, we shall also always keep the personal information that you choose to provide or authorize to use as mentioned in Item 2 of Paragraph 1 of Article 2, Paragraph 3 and Paragraph 4 of Article 2 hereof, unless you decide to disable the aforesaid extensions and exercise the right to delete the information, or withdraw your consent to use such information.

You can contact us via the contact information set forth herein or via [Contact the Customer Service] in [Blood Pressure Watch R6] and other ways. We shall respond to your request within the time limit in the ways set forth herein, and delete the foregoing information within 24 hours after verification.

If we stop our operation, we will promptly stop collecting your personal information, and will notify you in the form of an announcement of such discontinued operation. We will also delete or anonymize the personal information we hold.

(2) Entrusted Processing

If we entrust a third party to process your personal information, we shall agree with such third party on the purposes, period, processing methods, types of personal information, protective measures, rights and obligations of the Parties, etc., and shall supervise such third party amid its processing of your personal information.

(3) Sharing

We will share your personal information in the principles of lawfulness, propriety, and necessity. Meanwhile, we will first carry out an impact assessment on the sharing of personal information protection beforehand and record the handling situation.

We have made the following List of Personal Information Shared with Third Parties to inform you of your personal information shared by us:
1: URORA SDK (Shenzhen Hexun Huagu Information Technology Co., Ltd.): Device information, MAC address, network information, and location. We collect such information to facilitate you to receive and browse our messages, and to optimize the request of network connections between SDK and Aurora Server, thus making sure that the Services are stable and continuous. [Link]
2: Growing IO SDK (Beijing Growing IO Technology Co., Ltd.): Device identification information (such as IMEI, Android ID and OAID), device type, device version, system version, geographic location, network device manufacturer, IP address and network mode. We shall use such information to make statistics on your usage data and analyze your usage conditions in order to improve our Products and Services. [Link]
3: Service Provider of WeChat Open Platform (Shenzhen Tencent Computer System Co., Ltd.): Device information (IMEI, MAC address, Android ID, IMSI information of SIM card and UUID of the hardware), user ID, avatar and WeChat account. We collect such information to realize sharing and signing in with WeChat so that you can login to our platform to use and share our Products and Services. [Link]
4: NetEase Qiyu SDK (Hangzhou NetEase Zhiyun Technology Co., Ltd.): Mac address, device information (IMEI, MAC address, android ID, IMSI information of SIM card and UUID of the hardware). Such information is used to help you learn the networking status and changes of the device to keep the network connections as stable as possible. [Link]
5: Umeng SDK (Umeng Tongxin (Beijing) Technology Co., Ltd. and Beijing Ruixun Lingtong Technology Co., Ltd.): WeChat ID. We collect such information to carry out statistical analysis and calibrate the report data. Such information is also used for third-party authorization, including third-party sign-on, sharing relevant content to third-party platforms and optimizing the Products and Services. [Link]
6: Tencent bugly SDK (Shenzhen Tencent Computer System Co., Ltd.): Operating and abnormal information. Such information is used for providing professional exception reporting and operation statistics to help us find and resolve exceptions promptly and master the operating dynamics of the Products, thus following up your feedback in a timely manner. [Link]
7: Alibaba Cloud One-Click Login SDK (Alibaba Cloud Computing (Beijing) Co., Ltd.): IP address, network type, device manufacturer, device model, the operating system of the mobile phone and device information (IMEI, MAC address, android ID, and IMSI information of SIM card). Such information is used for realizing one-click login with your mobile phone number, helping you login to and use our Products and Services. [Link]
8: Alibaba Cloud SMS SDK (Ali Cloud Computing Co., Ltd.): Mobile. We’ll send the SMS verification code to you via Alibaba Cloud SMS SDK, helping you login to and use our Products and Services. [Link]
9: Tencent browsing SDK (Shenzhen Tencent Computer System Co., Ltd.): N/A. Such information is used for displaying the H5 page on [SKG Care], so that we can provide you with better Services. [Link]
And also the Partners:
1: Mi Push (Xiaomi Communications Co., Ltd.): Information of Common Personal Device: It serves as a secondary channel to improve the reach rate on Mi devices. [Link]
2: Oppo push (Guangdong Huantai Technology Co., Ltd.): Information of Common Personal Device: It serves as a secondary channel to improve the reach rate on Oppo devices. [Link]
3: Vivo push (vivo Mobile Communication Co., Ltd.): Information of Common Personal Device: It serves as a secondary channel to improve the reach rate in vivo devices. [Link]
4: Huawei push (Huawei Technologies Co., Ltd.): Information of Common Personal Device: It serves as a secondary channel to improve the reach rate on Huawei devices. [Link]

We will not transfer your personal information to any subject unless under one of the following circumstances:
1. We have obtained your express prior consent or authorization beforehand;
2. When it involves the transfer of personal information due to our mergers, separation, dissolution, or bankruptcy, we will inform you of the recipient's title or name and contact information. The Recipients shall continue to fulfil their obligations hereunder. If the recipient changes the original purpose of processing or processing method of personal information, your consent shall be obtained again.

(5) Public Disclosure

We will only disclose your personal information to the public except under the following circumstances:
1. To disclose the specified information as required by you via the disclosure means expressly agreed upon by you.
2. Disclosure to the public as legally required by laws, regulations, rules, legal procedures, litigation, or the order of government department.

(6) Cross-border Transmission

The personal information we collect in the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China. We will not transmit your personal information overseas.

(7) Exceptions to Prior Authorization and Consents when Processing Your Information

In the following cases, your prior authorization and consent are not required to share, transfer, or disclose your information under any of the following circumstances:
1. When it involves national security and national defense security.
2. When it involves national security, public health and national defense security;
3. When it relates to criminal investigation, prosecution, trial, and execution of judgments.
4. When it is collected to protect the life, property, or other major legal rights of you or other individuals in the situation where it is difficult to obtain your consent.
5. When it is disclosed to the public by yourself.
6. When the personal information is sourced from legally and publicly disclosed information, such as legal news reports or information disclosed by the government.

III. How We Protect Your Personal Information

(2) We shall conduct due diligence on the third-party service providers and business partners to ensure that they are capable of protecting your personal information. We shall also check whether the third parties have implemented appropriate security standards by enforcing appropriate contractual restrictions and carrying out audits and assessments when necessary. In addition, our employees, third-party service providers, and business partners who have access to your personal information shall all abide by strict contractual confidentiality obligations.

(3) We have adopted security technologies, taken organizational and management measures and other protective measures in line with the industrial standards, including but not limited to a network firewall, encrypted storage, de-identification, desensitization display, access control measures and host network isolation, sort management of information, etc., made and organized contingency plans for personal information security incidents, so as to minimize the risk of disclosure, damage, misuse, unauthorized access, unauthorized disclosure and alteration of your information.

(4) We will have training programs and examinations on security and privacy protection to increase employees’ awareness of the importance of personal information protection. We will take all feasible measures required by law to protect your personal information.

Please be aware that although we will make every effort to protect any information you send to us, the Internet is not 100% safe and we are not liable for any risks or losses arising from or in connection with information security incidents. In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the type, reasons, and possible harms of the security incident or the personal information that is possibly disclosed, altered, or lost. We will also notify you of the remedial measures we will take and the relief measures you can take. We may promptly inform you of relevant procedures of the events by means of e-mail, correspondence, phone calls, or push notifications. When it is difficult to notify each individual concerned one by one, we will make an announcement in a reasonable and effective way. At the same time, we will take the initiative to report the disposal of personal information security incidents as required by regulatory authorities.

(5) Our protection of the minors’ personal information

We attach great importance to the protection of the minors’ personal information. The minors mentioned herein refer to minors under the age of 14 in accordance with the Personal Information Protection Law of the People’s Republic of China, Law of the People’s Republic of China on the Protection of Minors as well as other laws and regulations. Our services are not provided for minors under the age of 14, and we shall not intentionally collect any personal information from minors under the age of 14 without their parent’s consent. If you are a minor under the age of 14, please do not use or access the services at any time or in any way.

If we become aware that the personal information of a person under the age of 14 has been collected for the Services without his/her parent’s consent, we shall take appropriate measures to delete such information. If you are a parent or guardian, when you find that your child under the age of 14 has obtained a service account from us, you can contact us via the contact information set forth herein and request us to delete your child’s personal information from our system.

IV. How We Protect Your Personal Information

(1) Right to know and right to decide

You have the right to know and decide how to process your personal information, and the right to refuse our processing of your personal information. You can view your avatar, user ID, mobile phone number and other personal information of your account by [Logging in to SKG Care > My > Click the symbol on the right of the user ID], and view your age, gender, date of birth, occupation, height, weight, blood type and other personal archival information by [Logging in to SKG Care > My > Health archive].

(2) Right of access and right of reproduction

You have the right to request looking up and copying your personal information from us, and you also have the right to ask us to provide a copy of your personal information. You can contact us via the contact information set forth herein or via [Contact Customer Service] in [Blood Pressure Watch R6] and other ways, and we will respond to your request within the time limit in the ways set forth herein.

(3) Right of rectification

If you find that your personal information is inaccurate or incomplete, you can change your avatar, user ID, mobile phone number, and other information of your personal account by [Logging in to SKG Care > My > Click the symbol on the right of the user ID], and change your age, gender, date of birth, occupation, height, weight, blood type and other personal archival information by [Logging in to SKG Care > My > Health archive].

(4) Right to delete

You can delete relevant information by yourself on [Blood Pressure Watch R6]. Please note that we may not be able to delete the corresponding information from the backup system immediately due to restrictions of applicable laws and security technologies. In such event, we will ensure that your personal information is kept secure and prevent it from being subjected to any further processing until the backup can be cleared or anonymized.

You can also contact us via the contact information set forth herein or via [Contact Customer Service] in [Blood Pressure Watch R6] and other ways, and we will respond to your request to delete the information within the time limit in the ways set forth herein.
If we decide to respond to your request for information deletion, we will also notify the entities that have obtained your personal information from us and require them to delete it in time, unless otherwise stipulated by laws and regulations, or these entities obtain your independent authorization.

(5) Withdrawal of Consent

You may also withdraw the scope of your authorization for us to continue collecting your personal information or withdraw your authorization by [Logging in to Blood Pressure Watch R6 > My > Settings > Authorization Management > Deauthorization]. You may also withdraw your full authorization for us to continue collecting your personal information by [Logging in to SKG Care > My > Settings > Closing Account].

Please understand that we may need to collect necessary personal information from you in order to enable you to use our Products or Services. When you withdraw your consent, we will be unable to continue providing you with services corresponding to your consent already withdrawn, provided that it will not affect personal information processing previously performed with your authorization.

(6) Cancellation of Account

You may close the account that you previously registered at any time by online account closing or contacting Customer Service. After you close your account, the contents, information, data, records, etc. under the account shall be deleted or anonymized (unless otherwise stipulated by laws and regulations or required by regulatory authorities). Meanwhile, once the account is cancelled, it cannot be restored.

Please note that, for your reasonable request, we do not charge in principle. However, we will charge a certain cost for repeated requests, and requests beyond reasonable limits as the case may be. We may refuse requests that are repeated without any good reason, require too many technical means, may bring risks to other people’s legal rights and interests, or are very unrealistic.

(7) Exceptions to Response to Your Claim

1. When it involves the performance of our obligations under laws and regulations.
2. When it involves information directly related to national security and national defense security.
3. When it involves information directly related to public security, public health, and substantial public interests.
4. When it involves information directly related to criminal investigation, prosecution, trial, and execution of judgments.
5. When there is sufficient evidence to prove that the subject of personal information is subjectively in bad faith or abuse your or other’s power.
6. Information collected to protect the life, property, or other major legal rights of you or other individual subject in the situation where it is difficult to obtain your consent;
7. When responding to the request of the subject of personal information of you or others will cause serious harm to the legal rights and interests of such subject or other individuals or organizations.
8. When any trade secret is involved.

V. How the Privacy Policy is Updated

Our Privacy Policy may be subject to change in due course. We will post any modification to the Privacy Policy on [Blood Pressure Watch R6]. With respect to major changes, we will give a more prominent notice, for example, we will give a special tip by means of browsing the webpage for specific changes to the Policy. Without your express consent, we will not reduce the rights that you enjoy according to the Policy.

Significant changes referred to in the Privacy Policy include, but are not limited to:
1. Our service mode may change greatly.
2. The main objects of personal information sharing, transfer, or public disclosure may change.
3. Your right to participate in personal information processing and the way to exercise such right may significantly change.
4. Any change in our way of contact and complaint channel.
5. The influence and evaluation report of personal information security shows that there is a high risk.

We will also keep the old versions of the Policy in the archives for your reference. If you do not accept the updated Privacy Policy, you may refuse to accept the changed Privacy Policy and stop using our Services or functions when the Policy is updated.

VI. How to Contact Us

Generally, we will give our response within fifteen working days. If you are not satisfied with our response, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also make complaints or reports to the regulatory authorities such as cyberspace, telecommunications, public security, industry, and commerce, or file a lawsuit to a court with jurisdiction for resolution.