SKG Health Privacy Policy

I. Overview
Shenzhen SKG Care Co., Ltd. is an enterprise registered at Room 23AF, Building 3, Zhongke R&D Park, 009 Gaoxin South 1st Road, Gaoxin Community, Yuehai Sub-district, Nanshan District, Shenzhen. Shenzhen SKG Care Co., Ltd. (hereinafter referred to as “SKG” or “We”) attaches great importance to your privacy. [SKG Health] app is a platform through which SKG provides you with Internet-based information as well as software technologies and services.

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:
(I) How We Collect and Use Your Personal Information
(II) How We Process Your Personal Information
(III) How We Protect Your Personal Information
(IV) How We Manage Your Personal Information
(V) How the Privacy Policy is Updated
(VI) 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) Information collected actively during your use of the products and services

1. The circumstances under which you must 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 functions. If you refuse to provide relevant information, our services and products will not be available to you. These features include:

1.1 Account Registration, Login, Verification, and Pairing
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 [SKG Health].
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 glucose, 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. Your autonomous right to select and provide 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 [SKG Health] normally.

2.2 Health Management for Your Family
When you use the health management function for your family, 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 glucose, 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 [SKG Health] normally.

2.3 Health Recording
When you use the function of health recording, you can choose to record the data such as pain, blood glucose, 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 [SKG Health] 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 on 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 [SKG Health] normally.

(2). Call for Application Permissions

The following device permissions may be triggered when you enjoy [SKG Health]. 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 [SKG Health] to control hardware, hoping to connect the hardware to [SKG Health], 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 [SKG Health], 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 [SKG Health] 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 the public interests of 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

(1) Storage

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 [SKG Health] and other ways. We shall respond to your request within the time limit through the methods as 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 according to 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:

We will not share your information with any third parties beyond the foregoing platform, except under the following circumstances:
(1) We have obtained your express prior consent or authorization beforehand.
(2) It is required by applicable laws and regulations, legal procedures, and mandatory administrative, or judicial requirements to share your information with the public.
(3) Only by sharing your personal information can the core functions of our products and services be realized or the services you need be provided.
(4) With a view to realize the goal of furnishing you with related products or services, we will show you content that may be of interest, and protect the security of your account and transactions. Furthermore, we may share your personal information with our affiliates. We may share your personal information with our affiliates as agreed in the Privacy Policy, provided that we will only share the necessary personal information and are subject to the principles stated in the Privacy Policy. If our affiliates intend to change the purpose of processing personal information, we will seek for your authorization and consent again.
(5) We may share your information with third parties such as its partners to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legal, proper, necessary, specific and clear purposes, and will only share the personal information required for the provision of services.

(IV) Transformation

We will not transfer your personal information to any subject unless it falls 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.

(V) Public Disclosure

We will only disclose your personal information to the public 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.

(VI) 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.

(VII ) 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 involves information related 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.