AIMOTO PRIVACY POLICY
Last updated: September 28, 2020
Medical
Alert, Llc. (collectively, "Aimoto",
"we", "us", and "our") respect your privacy.
Therefore, we have developed a Privacy Policy (hereinafter referred to as
"this Policy") that covers how we collect, use, disclose, protect,
store and transfer your personal data.
Personal
data means any electronic or other information which alone or jointly with
other information can be used to identify a natural person or make him/her identifiable.
This Policy explains how Aimoto processes your personal data.
This Policy
applies only to Aimoto personal products, including wearable devices, smart
household appliances, accessories, computer applications, mobile services,
software, toolkits, websites, and services that display or mention this Policy.
This Policy
describes:
1. How Aimoto Collects and Uses
Your Personal Data
2. How Aimoto Uses Cookies and
Similar Technologies
3. How Aimoto Shares Your Personal
Data
4. How Aimoto Protects Your
Personal Data
5. How You Can Manage Your Personal Data
6. How Aimoto Protects Children's
Personal Data
7. Links to Third-Party Websites,
Products, and Services
8.
International Transfers of Your Personal Data
Before
using Aimoto products or services, you may need to provide personal data. You
do not have to provide your personal data to Aimoto, but in some cases, the
non-provision of certain personal data will cause the inability to provide you
with some related products or services.
Aimoto will
collect and use your personal data for the purposes stated in this Policy. Here
are some examples of personal data we may collect:
1. Personal data you provide to Aimoto
When you
log in with a Aimoto ID to shop online, download software, or purchase
services, we will ask you to provide relevant personal data, such as your name,
email address, mobile number, order information, shipping address, and payment
mode.
Some Aimoto
products allow you to communicate and share information with others. When you
use a Aimoto product to share things with your family and friends, you may need
to create a Aimoto ID that includes certain information which will be made
public, including a nickname and avatar. Aimoto may collect information related
to those people, such as their names, email addresses, and phone numbers.
Aimoto will take appropriate and necessary measures to ensure the security of
the information that you provide. You must ensure that the people, whose
information you provide, have consented to you providing their information to
Aimoto.
To meet
some jurisdictions' requirements on real-name authentication of accounts,
Aimoto might ask you to provide a proof of identity issued by the government or
relevant card information that can identify you.
2. Information Aimoto collects in your use of
services
Aimoto will
collect data about your device and how you and your device exchange information
with Aimoto products and services. This type of information includes:
(1) Device
and application information, such as the device name, device identification
code (IMEI), device activation time, hardware model, OS version, application
version, software identification code, and device and application settings
(such as region, language, time zone).
(2) Mobile
network information, such as the public land mobile network (PLMN) provider ID
and Internet Protocol (IP) address.
(3) Log
information. When you use Aimoto services or view Aimoto-provided content,
Aimoto will automatically collect and log some information, such as the time of
access, access count, IP address, and information about incidents (such as
errors, crashes, restarts, and upgrades).
(4)
Location information. Aimoto will collect, use, and process the approximate or
precise location of your device when you access some location-based services.
Location information can be obtained based on the GPS, WLAN, and service
provider network ID.
3. Collection and use of non-identifiable data
Non-identifiable
data refers to data that cannot be used to identify an individual. Examples of
non-identifiable data include statistics on website visits, application
downloads, and product sales volume. Aimoto will collect statistics information
to understand how users use our products and services. By doing so, we can
improve our services to better meet your requirements.
We keep
your personal data and non-identifiable data separate, and use each
independently. Circumstances may arise where Aimoto collects, uses, discloses,
and transfers non-identifiable data for other purposes at our own discretion.
Aimoto may
use your personal data for the following purposes:
(1)
Register and activate Aimoto personal and home products that you have
purchased.
(2)
Deliver, activate, and/or verify the products and services you have requested,
or perform changes and provide technical support and after-sales services for
the foregoing products and services based on your requirements.
(3) Send OS
or application updates and installation notifications to you.
(4) Provide
personalized user experience and content.
(5) Send
you information about products and services you might be interested in, invite
you to Aimoto promotional activities and market surveys, or send marketing
information to you. If you do not want to receive such information, you can opt
out at any time.
(6) Carry
out internal auditing, data analysis, and research; analyze business operation
efficiency and measure market shares; and improve Aimoto's
products and services.
(7) Process
pursuant to laws and regulations, e.g. tax, authority requests.
(8) Other
purposes within specific services or with your consent.
A cookie is
a text file stored by a web server on a computer or mobile device, and the
content of a cookie can be retrieved and read only by the server that created
the cookie. Cookies are unique to the browser or mobile application you are
using. The text in a cookie often consists of identifiers, site names, and some
numbers and characters. For further details, please check the Cookie Policy on
our official website.
We do not
share personal data with other companies, organizations and individuals unless
one of the following circumstances applies:
(1) Sharing
pursuant to laws and regulations: Aimoto may share your information as required
by laws and regulations, for resolving legal disputes, or as required by
administrative or judiciary authorities pursuant to law.
(2) Sharing
with Aimoto affiliates: Your information may be shared within Aimoto's affiliates only for explicit, and legitimate
purposes, and the sharing is limited only to information required by services.
(3) Sharing
with business partners: Some products and/or services are provided to you
directly by our partners. Aimoto also may share your information with them,
they may use your information to provide you with products and/or services you
request (e.g., products sold by third-party seller through Aimoto’s
applications), make predictions about your interests and may provide you with
advertisements, promotional materials and other materials
(4) Sharing
with service providers: Aimoto also may disclose your information to companies
that provide services for or on behalf of us. Examples of these service
providers include companies that provide hotline services, send email, or
provide technical support on behalf of Aimoto. The service providers can use
your information only for the purpose of providing services to you on behalf of
Aimoto.
In
scenarios 2 to 4, Aimoto will ensure that the lawfulness of this sharing and
sign stringent non-disclosure agreements (NDAs) and/or data processing clauses
with the companies, organizations, and individuals with whom personal data is
shared, requiring them to comply with this Policy and take appropriate
confidentiality and security measures when processing personal data.
Aimoto
attaches great importance to the security of your personal data and has adopted
standard industry practices to protect your personal data and prevent it from unauthorized
access, disclosure, use, modification, damage, or loss. To this end, Aimoto
takes the following measures:
(1) We take
reasonable and feasible measures to ensure that the personal data collected is
minimal and relevant to what is necessary in relation to the purposes for which
they are processed. We retain your personal data for no longer than is
necessary for the purposes stated in this Policy and privacy notice of specific
product or service.
(2) We use
a range of technologies such as cryptographic technologies to ensure the
confidentiality of data in transmission. We implement trusted protection
mechanisms to protect data and data storage servers from attacks.
(3) We
deploy access control mechanisms to ensure that only authorized personnel can
access your personal data.
(4) We
strictly select business partners and service providers and incorporate
personal data protection requirements into commercial contracts, audits, and
appraisal activities.
Aimoto is
committed to protecting your personal data. Nevertheless, no security measure
is perfect and no product, service, website, data transfer, computing system,
or network connection is absolutely secure.
If any
personal data incident occurs, Aimoto will notify you, pursuant to relevant
legal and regulatory requirements, of the basic information about the security
incident and its possible impact, measures that Aimoto has taken or will take,
suggestions about active defense and risk mitigation, and remedial measures.
The notification may take the form of an email, text message, push
notification, etc. If it is difficult to notify data subjects one by one, we
will take appropriate and effective measures to release a Security Notice.
A. Access,
rectification, deletion, data portability, restriction of processing, objection
to processing.
Legislation
in some countries to which Aimoto provides products and services or from where
Aimoto processes personal data, provides that data subjects the rights request
(hereinafter referred to as "requests") in regards to the accessing,
rectifying, deleting or erasure, porting, restricting, and objecting, the
processing of related personal data by Aimoto retains.
1. Requesting modes and channels
Data
subjects' requests must be submitted in accordance with Aimoto designated
privacy channels. The requests are valid even when the requester does not
specify the laws on which the requests are based.
Data
subjects' requests may be initiated through the official website Aimoto or Aimoto
Connect mobile app. If a data subject initiates a request via a hotline, email,
online customer service, service center, or another channel, we will instruct
the data subject to officially raise the request through one of the
aforementioned channels to facilitate communication and feedback of progress
and results. The dedicated request channels for data subjects are intended to
protect data subjects' lawful interests, ensure Aimoto's
normal operation, and prevent the right to request from being misused or fraudulently
used.
2. Validity of requests
This Policy requires data subjects to:
(1) Submit
requests through dedicated request channels provided by Aimoto (namely, the
official website of Aimoto, Aimoto Connect app).
(2) Provide
sufficient information for Aimoto to verify their identities (to ensure those
who initiate the requests are the data subjects themselves or those authorized
by them).
(3) Ensure
that their requests are specific and feasible.
There are
some circumstances, provided by laws and regulations, in which Aimoto may not
have to comply with the request in full or at all.
B. Consent
withdrawal
You can
change the authorized personal data collection scope or withdraw your consent
without affecting the lawfulness of the processing activities based on the
consent and prior to such withdraw.
C.
Deregistering
You can
deregister your account. After you deregister your account, we will stop
providing products and services, and delete your personal data unless otherwise
stipulated by law. Your account cannot be restored after deregistration. You
need to register a new Aimoto ID if you want to use related Aimoto products or
services again.
For the use
of Aimoto products and services by children, we are fully aware of the
importance of taking extra preventive measures to protect privacy and security.
Aimoto identifies whether data subjects are children based on the age of
majority defined by laws of the local countries and regions.
When
children's personal data is collected based on the consent of the holders of
parental responsibility, we will only use or disclose the information as
permitted by law, explicitly consented to by the holders of parental
responsibility, or required for protecting the children. Holders of parental
responsibility who need to access, modify, or delete the personal data of their
children and people under guardianship can contact us via the channels provided
in "IV. How Aimoto Protects Your Personal Data."
If Aimoto
accidentally collects children's personal data without obtaining consent from
provable holders of parental responsibility, Aimoto will delete the information
as soon as possible after becoming aware of it.
Aimoto
website, application software, products, and services may contain links to
third-party websites, products, and services.
All links
to third-party websites, products, and services are provided for users'
convenience only. You need to determine your interaction with such links on
your own. Before submitting your personal data to third parties, please read
and refer to these third parties' privacy policies.
Our
products and services are delivered through resources and servers located in
different places, to offer our products and services, we may need to transfer
your personal data among several countries. Authorized Aimoto personnel and
third parties acting on our behalf may access, use and process personal data
collected from you in a country/region that is different from the
country/region where you entered the personal data, which may have less
stringent data protection laws. When we transfer your personal data to other
countries/regions, we will protect that the personal data as described in this Policy
or as otherwise disclosed to you at the time the data is collected (e.g. via
privacy notice or supplementary Policy of specific product or service).
With
respect to personal data coming from the EU, we comply with applicable legal
requirements providing adequate safeguards for the transfer of personal data to
countries outside of the European Economic Area ("EEA"). We use a
variety of legal mechanisms, such as standard contractual clauses to implement
the cross-border transfer of your personal data; or implement security measures
like anonymisation on the data before the cross
border data transfer.
Aimoto
reserves the right to update this Policy at any time. Should this Policy be
revised from time to time, Aimoto will release the change notice via various
channels, for example, posting the latest version on our official website: http://aimoto.tech.
"Major
changes" in this Policy include but are not limited to:
(1) Major
changes in our service modes, for example, purposes of personal data
processing, types of processed personal data, and ways of using personal data
(2) Changes
in the main objects of personal data sharing, transfer, or disclosure
(3) Major
changes in your rights regarding personal data processing and the ways in which
you can enjoy those rights
(4) Changes
of Aimoto departments, contacts, and complaint channels responsible for the
security of personal data processing
We have
data protection officer. If you have any questions, comments, or suggestions,
please contact us by visiting the “contact us” page, or via the Aimoto Connect app.