Effective date: August 15,2023
This Privacy Policy contains the following sections:
We know privacy is important to you. We encourage you to read this Privacy Policy to understand the personal information we collect, how we use it, and the choices available to you.
This Privacy Policy applies to the products and services of Robosen OP ROTB App (collectively, the “Services”). This Privacy Policy does not apply to any other products, services, websites, features, or content which have their own privacy policies. Please note that this Privacy Policy does not apply to our offering of Services in the People’s Republic of China.
By using the Services, you agree to this Privacy Policy.
When we use the terms “Robosen”, “we”, or “us” in this Privacy Policy, we’re referring to the Robosen Robotics (Shenzhen) CO., LTD and/or its affiliated entities and subsidiaries.
The personal information we collect about you depends on the Services you use, how you use them, and the personal information you provide to us. We collect personal information in two main ways: (1) personal information you choose to provide to us and (2) personal information we collect automatically when you use our Services.
When you use our Services, you may choose to provide certain personal information to us. For example, we collect personal information directly from you when you participate in Robosen surveys, or communicate and interact with us.
Personal information (depending on the circumstance) we collect directly from you include:
· Connection information: such as MAC address of the device, MAC address of
Bluetooth on the device and network connection information (network access mode, type, status and quality and IP address).
· Location information: general location information (e.g. city/state) .
· Information you provide in connection with surveys or feedback: such as your interests, preferences, advice, and other information provided by your completion of surveys or feedback and communication records.
When you use our Services, we may automatically collect certain personal information. Some of the personal information we automatically collect when you use our Services includes:
· Software and/or Device information: your Robosen product’s serial number
(the last 4 digits), your Robosen software version, device identifiers (IMEI/MEID, Android ID, OAID, IMSI, information of SIM card, GAID, SN, IDFV, IDFA) and device related information.
· Logs information: like most software, product or services, we collect certain
information and store it in log files. Such information may include voice input, installation status, running status, crash status and performance data of your Robosen software and Robosen product. We do not correlate automatically collected log information with other information we collect.
Cookies and other similar technologies (collectively, “Cookies”) are commonly used on the Internet. When you use our Services, we will not use cookies or similar technologies.
Robosen uses your information for a variety of business purposes as described below:
· Provide our Services, such as providing access to certain areas, functionalities, and features of our Services.
· Promote our Services through direct marketing.
· Ensure internal quality control and maintain the safety of our Services by detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
· Improve, upgrade and enhance our Services by measuring your interest and engagement in our Services, conducting research (including marketing research), and debugging to identify and repair errors with our Services.
· Develop new products and Services.
· Conduct audits relating to interactions, transactions and other compliance activities.
· Share information with third parties as needed to provide the Services (if any).
· Comply with our legal obligations.
· Other Purposes as requested by you or as permitted by applicable law.
Legal Grounds
Robosen uses your personal information only when we have a valid legal basis. Depending on how you interact with our Services, Robosen may process your personal information on the following grounds:
· When we provide our Services, communicate with you or authenticate and verify your identity, we process your personal information as a necessity to perform a contract with you.
· When you use our Services, we may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
· We may also process your personal information where it is necessary for our or other’s legitimate interests, taking into account your interests or fundamental rights and freedoms. For example, we process your personal information to personalize your experiences when using our Services; promote our Services; ensure internal quality control and maintain the safety of our Services; improve, upgrade and enhance our Services; develop new products and Services; conduct audits; and share information with third parties as needed to provide the Services.
· We also process your personal information to comply with legal obligations, protect your vital interests or those of other persons, or perform a task carried out in the public interest.
5.1 Robosen may share or disclose your personal information in the following ways:
Affiliated companies
Our Services are supported by our affiliated entities globally. We may share your personal information with affiliated entities and subsidiaries to enable them to provide important functions for the business purposes outlined above.
Service Providers
We may engage service providers to provide the Services, operate our business, and enhance our Services and your customer experience. In which case, we may share personal information with them as necessary to enable them to provide their services such as data processing and storing.
Protection of Robosen and others
We may disclose the information we collect about you if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our terms of service or sale, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Robosen or others.
Business transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
When you initiate a connection with a third-party platform, website, application, or service through our Services, such third-party would collect, use, process and store your personal information only with your consent. If you choose to initiate these connections or services, we will no longer collect or process any personal information from you through our Services, and we do not govern your use of those third-party platforms, websites, applications and services. We urge you to read the privacy and security policies of these third parties.
You are responsible for the content you created and other information you created or shared publicly through our Services, and you should think carefully about what you make public.
As required by applicable law and our Terms of Use, we consider user under the age of 13 in the U.S. (and a higher age if required by the applicable law in another country) as a child. We do not knowingly collect, use or disclose personal information from children without verifiable prior consent from a parent or legal guardian, except as permitted under the Children’s Online Privacy Protection Rule (COPPA). If we learn that personal information of a child has been collected without verified prior consent from the child’s parents or guardians, we will attempt to delete relevant personal information as soon as possible. Parents or guardians can also ask us to delete the personal information we have collected in connection with their children’s accounts. If you are a parent or guardian and wish to make relevant requests, you may contact us as described in Section 12 “Robosen contact information” .
We are committed to protecting your personal information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your personal information.
We regularly monitor our Services for possible vulnerabilities and attacks. If you have any concerns about the security of our Services, please contact us as detailed in the Section 12 “Robosen contact information” so they may be addressed and resolved in a timely and effective manner.
We provide you with the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction.
You may request the following by contacting us as detailed in the Section 12 “Robosen contact information” :
· Access to, or a copy of, your information
· Correction or amendment of your information
· Deletion of your information
· Receiving your information in a structured, commonly used and machine-readable format and transferring the same to a third party
· Restriction or objection to certain uses of your information
· Complaint against our processing your personal information
· Withdrawal of your consent
· Objection or restriction to the processing of your personal information
For California residents in the United States, you may also request to exercise the following rights:
· Right of no retaliation following opt out or exercise of your rights;
· Right to know what and to whom the personal information is sold or shared with as defined by the California Privacy Protection Act (CCPA) and the California Privacy Rights Act (CPRA);
· Right to request and obtain removal of contents or information posted on our Services if you are under 18 years of age. You understand that this removal does not ensure complete or comprehensive removal of the content or information posted through our Services, and certain contents or information are permitted to be stored on or posted to our Services in accordance with the Privacy Rights for California Minors in the Digital World.
We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response consistent with applicable laws. Please note, however, that certain information may be exempt from such requests. For residents of Virginia, Colorado and Connecticut in the United States, if we refuse to take action on your request, you have the right to appeal our decision through the same method to submit your initial request.
You also have the choice to exercise the following controls regarding your information:
· Limit the information you provide to us. When you interact with us, you can choose to limit the information you provide. However, if you choose to do so, you may not be able to take advantage of many of our Services, and we may not be able to fulfill your requests.
· Update or close your Robosen account. You can update your account sign in details and profile information by logging into your Robosen account (if any). To close your account please contact us as detailed in the Section 12 “Robosen contact information” or delete your account through pressing the “Account and Security” button in our software (Operation for different versions of Services may vary slightly). Please note, if you choose to delete your account, you will not be able to access any Services where you sign in with that account and you may lose some features of your Robosen products and services that are connected to that account (excluding your information of robosen store on www.robosen.com, if any).
· Adjust your location, storage, camera, microphone and Bluetooth settings. You can enable or disable such permission on your mobile applications. This feature may vary by mobile device; please see your device settings or contact your device manufacturer for more information.
We retain information for different periods of time as necessary in relation to the purposes for which we collect and use it, as described in this Privacy Policy. The actual retention period may be determined in consideration of the following reasons:
· to provide Services during a customer relationship with you or by your requests;
· to comply with our legal obligations;
· to resolve disputes with any parties and/or to investigate or defend against potential legal claims;
· other business reasons reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed.
We will delete, anonymize or de-identify information after expiration of the retention period. There may be technical or other operational reasons where we are unable to fully delete, anonymize or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.
9.2 Robosen may store your personal information in the following locations:
We will store your personal information in servers located in the country or region where you use our Services. Your personal information would not be transferred outside of these servers. Whereas, we operate our Services globally, such information may be checked and visited by us or other third parties such as entrusted processor, trusted service providers and partners in locations around the world.
We operate globally and may transfer, store, and/or process your information to or with affiliated companies or other third parties such as trusted service providers in locations around the world (including the United States) for the purposes described in this Privacy Policy. By providing us with your information, you acknowledge any such transfer, storage, or processing. Wherever your information is transferred, stored, or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws.
If we transfer your personal information outside of the European Economic Area (EEA) or the U.K., we will ensure an adequate level of protection for such information by:
· relying on adequacy decisions made by competent authorities;
· implementing Standard Contractual Clauses approved by competent authorities to govern the transfer of your personal information;
· or other means recognized by applicable laws.
If you are a California resident, California law requires us to provide you with the following additional information:
· Categories of personal information collected and the sources from which personal information is collected: categories of personal information we collected in the preceding 12 months are described in Section 2 “The personal information we collect”.
· Purposes for collecting personal information: we explain why we collect personal information in Section 4 “How we use your personal information”.
· Disclosure of personal information for business or commercial purpose: we may disclose or have disclosed your personal information during the preceding 12 months for a business purpose as below:
Categories of persons to whom the Personal Information was disclosed for a business purpose | Categories of personal information disclosed for a business purpose |
Cloud storage service vendors | Connection information, location information, Information you provide in connection with surveys or feedback, software and/or device information and logs information |
The CCPA and CPRA set forth certain obligations for businesses that “sell” or “share” personal information to third parties. Based on the definition of “sell” under the CCPA, CPRA and current regulatory guidance, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.
To exercise any rights you may have with respect to your personal information under California law, please see Section 8 “Your controls and choices”.
The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share your personal information with third parties for their own direct marketing purposes.
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for “monetary consideration” (as such terms are defined under Nevada law) to a person for that person to license or sell such information to others. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any future sales under Nevada law by contacting us as detailed in Section 12 “Robosen contact information”. Please note we may take reasonable steps to verify your identity and the authenticity of the request.
From time to time we may change or update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. In that case, we will issue an updated version and remind you to read the updated Privacy Policy by pop-up window or other reasonable methods. You should review the Privacy Policy periodically. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. If we make material changes to the Policy, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective, in accordance with applicable legal requirements.
If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve such issues directly with us. However, if applicable, you may make a complaint or seek a remedy through competent authorities or organizations if you believe your rights have been violated.
If you have any questions or complaints in relation to this Privacy Policy, please contact us by:
· Call at +1 800 298 1623 (for the United States Users only)
· Email at privacy@robosen.com
· Postal address at 3703, Building 11A, Shenzhen Bay Science and Technology Ecological Park, No. 6, Gaoxin Nanjiu Road, Gaoxin Community, Yuehai Street, Nanshan District, Shenzhen, P.R.China.