Effective Date: June 1, 2025
Hangzhou Fengyuan Technology Co., Ltd. and its affiliated companies (hereinafter collectively referred to as "we" or "Fengyuan") are committed to protecting your personal privacy.
The Privacy Policy (hereinafter referred to as "this Policy") applies to all products and/or services provided by our platform, including mobile applications (client applications) and web pages (collectively referred to as "Services"). When you use our services, we will collect and process your relevant information. Therefore, please read this policy carefully and ensure that you understand our rules for collecting and processing your personal information (including how we collect, use, store, and share such information), as well as the ways we provide for you to access, update, delete, and protect this information.
When you agree to this Privacy Policy, or start or continue to use our products or services in an appropriate manner, and have not contacted us in an appropriate way to express the contrary, we will regard you as fully understanding and agreeing to this Policy. During the reading process, if you have any questions, opinions, suggestions, or complaints, especially if you believe that our personal information processing actions have infringed upon your legitimate rights and interests, you may complain/suggest about our services through the appropriate regulatory channels, or contact us through the following contact information:
Privacy Office: contact@seastart.cn
If you are a minor under the age of 18, in accordance with relevant laws and regulations, you should obtain the consent of your parent or legal guardian before using our products or services. At the same time, if you are a child under the age of 14, please read the Children's Privacy Protection Statement and ensure that you and your guardian or parent are clear about the relevant children's privacy protection information.
This policy mainly explains to you:
· What personal information we collect
· The purposes and legal basis for processing personal information
· Who we share your personal information with
· The transfer of the collected information
· Rights related to personal information
· Information security measures
· Information retention period
· Protection of children's personal information
· Statement on policy changes
· Contact us
Definitions
In this Policy,
· Affiliated companies: Companies that are directly or indirectly controlled by us; or directly or indirectly control us; or jointly control the same company with us; or are controlled by the same company as us, including but not limited to parent companies, subsidiaries; subsidiaries controlled by the same parent company as us, etc.
· Personal information: Information recorded in electronic or other forms that can be used alone or in combination with other information to identify a person's identity or reflect the activities of a specific individual.
· Sensitive personal information: Includes personal biometric information, communication records and content, health information, transaction information, precise location information, etc. When we provide you with specific products or services and involve the collection of sensitive personal information, we will obtain your consent through a prominent and clear notice before collecting your sensitive personal information.
· Smart device: Refers to non-standard computing devices produced or manufactured by hardware manufacturers that have a human-machine interface and can transmit information through a wireless network, including smart home appliances, smart toys, etc.
· Application: Refers to the mobile applications (including client applications, web pages) developed by us, which can help end users remotely control smart devices and connect to our platform.
To provide you with our services, we will ask you to provide the personal information necessary for such services. If you do not provide personal information, we will not be able to provide you with the corresponding products or services.
Under Login Mode:
Account Registration Information: When you register for our account, we will collect your account name and contact information, including your email address, phone number, username, and login credentials. During your interaction with our products, we will further collect your account's nickname, country code, language preferences, or time zone information.
User Feedback: When you use our services and submit feedback and suggestions related to the services, we will collect the email address, phone number, and feedback content (including added images or videos) you fill in, as well as the problem logs submitted. This information will be used to promptly handle your application issues and smart device-related malfunctions.
Third-Party Account Login Authorization: When you choose to log in using a third-party account, we will obtain the account information you share (default system avatar, nickname, region information) from the third party and bind it to your account with us for quick login. We will use your personal information in accordance with the agreement with the third party and the terms regarding the sharing of personal information in the third party's published privacy policy, and in compliance with relevant regulations.
Information Collected for Additional Services
To provide you with more convenient and high-quality products and/or services and to continuously improve your experience, we will collect and use your personal information in the following additional services. If you do not provide this information, it will not affect your use of the basic services of our application, but you will not be able to enjoy the user experience brought by these additional services. These additional services include:
Location-Based Additional Services:
When you authorize the system to enable the location function of your mobile device and use location-based services, we will collect and use your location information (approximate location, latitude and longitude) to enable you to use our application to configure the network for smart devices. Additionally, when you use our specific products or services (weather services/home management), with your consent, we will collect your real-time precise or non-precise geographical location information. You can stop the collection of your location information by disabling the location service in your mobile device's system. The add-device function requires location permission (Android system only). When you enter the add-device page, the search for nearby devices requires Bluetooth scanning, which in turn requires location permission; otherwise, it will affect the user's device addition.
Album (Photo Library/Video Library) Access and Upload for Photos/Videos:
You can enable the album permission to upload your photos/videos to report device usage issues and provide proof, as well as to upload photos/videos for some special device panels. When you report device usage issues, we will use the uploaded photos/videos to identify the problem.
Storage Permission for Android System:
We request this permission to ensure the stable operation of the client application. After you enable the permission for us to read/write to your device's storage, we will read or write necessary information such as photos, files, and videos from/to your device's storage space to provide you with the functions of information publishing and local recording of crash log information.
Message Notification Permission:
We request this permission to push notifications related to products or services to you, especially when you have purchased relevant services and need to receive alerts to keep you informed of real-time situations.
Bluetooth-Related Additional Services:
After enabling Bluetooth permission, you can use Bluetooth functions, including device control, device status acquisition, device discovery, and device network configuration. In these functions, we will communicate with terminal devices through Bluetooth. Please note that even if you have agreed to enable Bluetooth permission, we will only use Bluetooth for communication in the following scenarios: displaying device status on the home page and device panel; controlling devices on the home page and device panel; discovering and configuring devices on the home page and add-device page.
How to Manage Permissions:
You can manage the above permissions through the following steps:
· Location Information: [Me] - [Settings] - [Privacy Permission Settings] - Turn on/off [Location Information] permission
· Album: [Me] - [Settings] - [Privacy Permission Settings] - Turn on/off [Album] permission
· Storage: [Me] - [Settings] - [Privacy Permission Settings] - Turn on/off [Storage] permission
· Message Notification: [Me] - [Message Center] - Top-right [Settings] - Turn on/off [Message Push] permission
· Bluetooth: [Me] - [Settings] - [Privacy Permission Settings] - Turn on/off [Bluetooth] permission
You understand and agree that the above additional services require you to enable your location information (geographical location), album (photo library), internal and external storage, and Bluetooth in your device to collect and use the information involved in these permissions. You can check the status of the above permissions one by one in your device settings and decide to turn these permissions on or off by yourself.
Please note that enabling any permission means you authorize us to collect and use the relevant personal information to provide you with the corresponding services. Once you disable any permission, it means you revoke the authorization, and we will no longer collect and use the relevant personal information based on that permission, nor can we provide you with the services corresponding to that permission. However, your decision to disable permissions will not affect the information collection and use that has been carried out based on your previous authorization.
· Mobile Device Information: When you interact with our products, to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience, and ensure your account security, we will automatically collect mobile device information, including mobile device model, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information. At the same time, we will collect your software version number. To ensure the security of the operating environment or to provide the required services, we will collect information about the mobile applications and other software you use, as well as the application installation list of the application (for the purpose of application performance monitoring).
· Service Log Information: When you use our applications, in order to provide you with a better user experience and to improve and optimize our services, system and exception logs will be uploaded for analysis, which includes your IP address, preferred language of use, version of the operating system, dates or times of access, usage information, etc., so that we can accurately identify issues and help you resolve problems encountered during the use of our services.Please note that mobile device information and service log information alone cannot identify the identity of a specific natural person. If we combine this type of non-personal information with other information to identify the identity of a specific natural person, or use it in combination with personal information, then during the period of combined use, this type of non-personal information will be regarded as personal information. Except as otherwise provided by law or with your authorization, we will anonymize and de-identify this type of information.
When you use smart devices, we collect information that is inherent to the smart devices themselves, as well as information generated during the use of these devices.
· Basic Information of Smart Devices: When you use smart devices that are connected to our products or services, we collect basic information about the smart devices, including the device name, device ID, online status, activation time, firmware version, and upgrade information.
· Information Collected During the Connection Process of Smart Devices: When using the APP and services, in order to facilitate device identification/activation/control, perform data statistics and analysis, and ensure the security and quality of network access and service operations, we will receive and record relevant information about the devices you use based on the specific operations you perform while using the products and the types of smart devices you need to connect. The information we collect includes:
o Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, Wi-Fi password)
o Device MAC address
o Device ID
o Device IP address
o Device Bluetooth MAC address
· Information Reported by Smart Devices: Depending on the different types of smart devices you choose to connect with our products or services, we collect information reported by your smart devices. To help you better understand the use of our services, the following examples of smart devices and the information they report are provided. The reported information applies only when you use the corresponding type of service:
The purposes for which we process your information are as follows:
· To Provide Services to You: We process your account information, mobile device information, usage information, location information, and information related to smart devices to provide the products and services you have requested. The legal basis for this processing is the performance of our contract with you as stipulated in our User Agreement.
· To Improve Our Services: We process your mobile device information, usage information, location information, and information related to smart devices to ensure the functionality and security of our products, develop and improve our products and services, analyze our operational efficiency, and prevent and track fraudulent or improper use. The legal basis for this processing is also the performance of our contract with you as stipulated in our User Agreement.
· Compliance: We process your personal information only when required by law to disclose such information or when we deem it necessary or appropriate to do so for the following reasons:
o (a) To comply with applicable laws and regulations, legal processes, or requests from public authorities and government bodies.
o (b) To fulfill our terms of use and other agreements, policies, or standards, including investigating any potential violations of use.
o (c) To protect the rights, privacy, security, or property of us and/or other users, including you.
o (d) To seek available detection, prevention, remedial measures, or limitations on damages we may need to provide or to resolve security, fraud, or technical issues.
We also use the personal information we collect in other ways, providing specific notice at the time of collection and obtaining your consent as required by applicable law. If there are any changes to the purposes for which we process your personal information, we will notify you of such changes via email and/or through a prominent notice on our website, and inform you of your choices regarding personal information.
We share your personal information only in the ways that you are aware of. We share your personal information with the following entities:
· Third-Party Service Providers: We disclose your personal information to third-party service providers who provide certain business-related services for us, including website hosting, data analysis, payment and credit card processing, infrastructure supply, IT services, customer support services, email sending services, and other similar services, to ensure that they can provide services to us.
· Customers and Other Business Partners: We disclose your personal information to customers and other business partners who directly or indirectly provide you with smart devices and/or the networks and systems you use to access and use our website and services.
· In the Event of Business Transactions: We disclose your personal information to affiliates or other third parties when there is a restructuring, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including but not limited to the above situations related to any bankruptcy or similar proceedings). In such cases, you will receive clear notice of the change in ownership, the incompatibility of the new use of personal information, and your choices regarding personal information via email and/or our website.
· In Necessary or Appropriate Situations: We will lawfully and reasonably share your personal information for the following reasons:
o (a) To comply with applicable laws and regulations, legal processes, policies, and/or standards, or the requirements of relevant public authorities and government bodies.
o (b) To fulfill our terms of use and other agreements, policies, and standards, including investigating any potential violations.
o (c) To protect our operations, business, and systems.
o (d) To protect the rights, privacy, security, or property of us and/or other users, including you.
o (e) For risk management, detection, and identification of illegal, fraudulent, deceptive, or malicious activities.
o (f) To disclose your personal information to subsidiaries or affiliates of our company for regular business activities.
Except for the aforementioned third parties, we do not rent, sell, or provide personal data to third parties and only disclose your personal information to other third parties with your consent.
Please be aware that we will not collect your personal information through third parties under any circumstances.
When you use services provided by third parties, we will share the corresponding information only after ensuring that the third party has obtained your authorization and consent, and in other circumstances that comply with the provisions of laws and regulations. You can understand which personal information the third party will collect and how they will handle this information through the relevant information listed in this inventory. We will also strictly regulate the behavior of third parties in obtaining personal information to protect the security of your personal information.
In addition, to ensure the stable operation of our applications or to implement related independent functions, we will embed third-party SDKs in our applications. Please note that the types of personal information processed by third-party SDKs may change due to version upgrades, policy adjustments, or other reasons. Please refer to their official announcements for the details. Please click on the Third-Party Information Sharing and SDK Service List to view the details of third-party SDKs.
We conduct business globally, and as such, the personal information we collect under this policy may be transferred, stored, and processed across different countries or regions. The laws and regulations applicable in the countries or regions where we operate may differ from those in your country of residence. However, we strictly adhere to the laws and regulations related to the protection of personal information. Within the framework of personal information protection, to facilitate our operations, we may transfer personal information to the countries or regions where we conduct business. No matter where your information is stored, our privacy and security practices are designed to provide global protection for your personal information.
This includes the European Commission's determination that certain countries or regions outside the European Economic Area (EEA), the UK, or Switzerland have mechanisms in place for the adequate protection of personal information. When personal information of users from the EEA, Switzerland, or the UK is transferred to countries or regions outside the EEA, Switzerland, or the UK, and to recipients not deemed to have an adequate level of information protection, we ensure compliance with the "EU Standard Contractual Clauses" for information transfer. You can click here to view the agreement concluded under the "EU Standard Contractual Clauses" approved by Article 46 of the GDPR.
Specifically, personal information collected and generated in the course of our operations within the Mainland China region will be stored and processed in data centers within the Mainland China region, except where cross-border transfer is permitted by applicable laws and regulations.
If you would like to learn more about our security measures, you can contact us directly through this policy.
We respect your rights and will also manage your personal information.
You can exercise your personal rights without paying any fees. In accordance with the requirements of local information protection laws, if your account service is within the Mainland China region, we will complete the verification and processing of your request within 15 working days; if your account service is outside the Mainland China region, we will respond to your request within 30 days.
If you decide to send us a request via email, please specify which information you would like to change, whether you would like your personal information to be deleted from our database, or what restrictions you would like us to place on the use of your personal information. Please note that, for security reasons, we will require you to verify your identity before further processing your request.
If you have any further questions, please contact us through [My] - [Frequently Asked Questions and Feedback] in our application, or send an email to contact@seastart.cn.cn.
We take commercially reasonable physical, managerial, and technical security measures to maintain the integrity and security of your personal information. We provide a variety of security strategies to effectively ensure the information security of users and devices.
· In terms of device access, we use our proprietary algorithms to ensure data isolation, access authentication, and authorization applications.
· In terms of data communication, we support secure communication using secure algorithms, transmission encryption protocols, and commercially viable information encryption transmission based on dynamic keys.
· In terms of data processing, we adopt strict data filtering and validation, as well as a complete data audit process.
· In terms of data storage, all confidential information of users will be securely encrypted for storage.
In addition to the above technical security measures, we have also established a series of security measures at the institutional and control levels, including defining roles and responsibilities, conducting security and privacy protection training courses, enhancing employees' awareness of data protection, and controlling access permissions, to prevent data loss, illegal use, unauthorized access, leakage, tampering, or destruction.
If for any reason you believe that your interaction with us is no longer secure (for example, if you believe that the security of your account has been compromised), please immediately notify us by sending an email to contact@seastart.cn.cn.
In the event of a security incident that affects the security of your personal information, we will notify you through the email address, phone number, or message center push notifications you have provided, and inform you of suggestions to mitigate or prevent the relevant risks. When necessary, we will take corresponding remedial measures in accordance with our internal security incident emergency response plan and report to the relevant authorities as required.
We have obtained the Enterprise Privacy Certification (EPC). To learn more about the EPC, please click here.
We will process your personal information for the shortest period necessary to achieve the purposes stated in this policy or as required by laws and regulations, unless a longer retention period is required by specific legal requirements. We will determine the appropriate retention period based on the quantity, nature, and sensitivity of the personal information. After the retention period has ended, we will destroy your personal information.
1. To provide the products and services you have requested in accordance with the User Agreement and this policy;
2. When you explicitly request the deletion of your personal information, we will set this as a task and no longer retain your personal information.
When we confirm that the purpose of collecting and processing personal information has been achieved based on 1), or when we confirm your deletion or account cancellation request based on 2), or when we cease operations of the relevant products or services, we will stop retaining and delete your personal information. Generally, once the specified information retention period is reached, we will no longer retain your personal information. If we are unable to destroy the information for technical reasons, resulting in the retention of personal information beyond the storage period, we will take appropriate measures to prevent your personal information from being further used, including anonymization.
We place great importance on the protection of children's personal information. If you are under the age of 14 (or the age specified in your country/region), you must carefully read the Children's Privacy Protection Statement and obtain written consent from your parent or legal guardian before using our services. We protect children's personal information in accordance with the relevant laws and regulations of each region, country, or area. Please note that if we discover that we have collected children's personal information without obtaining verifiable parental or legal guardian consent in advance, we will endeavor to delete the relevant personal information as soon as possible.
We will update this policy at least once a year in accordance with changes in our information practices. If we make any significant changes, we will notify you by email (sent to the email address specified in your account) or by posting a notice within this application before the changes take effect. We recommend that you regularly visit this application to obtain the latest information on our privacy practices.
If you have any opinions or questions about this privacy policy, or if you have any concerns about our collection, use, or disclosure of your personal information, please contact us through [My] - [Frequently Asked Questions and Feedback] in the application or through the contact details provided below, and specify "Privacy Policy." When it comes to your rights requests and inquiries related to personal information, we have a professional privacy and security team to address your issues. If your issue involves more significant matters, we may ask you to provide more information to confirm the nature and scope of the issue. If you are not satisfied with the response you receive, you may escalate your complaint to the relevant regulatory authority. When you contact us, we will provide information on the relevant complaint channels based on your specific situation and will complete the verification and processing of your request within 15 working days.
Contact Information and Address:
Hangzhou Fengyuan Technology Co., Ltd.
Address: 901, Pioneer Technology Building, 298 Weiye Road, Puyan Street, Binjiang District, Hangzhou, Zhejiang Province
Privacy Office: contact@seastart.cn.cn