Updated: January 30, 2023

Effective Date: August 31, 2022

JT-Innovation (Guangdong) Intelligent Technology Co., Ltd. (hereinafter referred to as "we," "our," or "JT-Innovation") understands the importance of your personal information and will do its utmost to protect it securely and reliably. We are committed to maintaining your trust and adhering to the following principles to protect your personal information: consistency of rights and responsibilities, clear purpose, opt-in consent, minimum sufficiency, ensuring security, subject participation, and transparency. We also promise to implement appropriate security measures in accordance with industry-standard security standards to protect your personal information. This Privacy Policy applies to all products and services we provide to you through the JT-Innovation website (www.jtcx.cn and its subdomains, hereinafter referred to as the "Website"), apps, and other terminal clients. This Privacy Policy explains how we collect, use, and share personal information through your use of our products and services (including but not limited to our mobile apps and robot user devices).

Please carefully read and understand this Privacy Policy (hereinafter referred to as "this Policy") before using our products or services, especially the terms in bold or bold underlined. You should read these carefully and confirm your full understanding and agreement before using our products or services. Unless otherwise stated, disagreement with this Privacy Policy or any updates (we will promptly notify you of such updates) may affect your ability to use or continue to use our products or services. If you have any questions, comments, or suggestions regarding this Policy, please contact us using the contact information provided in "XII. Contact Us."

1. How and what types of personal information do we collect?

1. Personal Information You Provide to Us

The categories of personal information you provide to us may include (please see Appendix 1 for detailed personal information we collect and the applicable types and functions of services):

(1) Contact information, such as name, address, location, telephone number and zip code;

(2) Online and device identifiers, such as device ID (i.e., the unique device identification code of the device you use, such as IMEI/Android ID/IDFA/OpenUDID/OAID, etc.), IP address, MAC address, small text file (Cookie), robot number, username and password;

(3) Account information, such as nickname, avatar, account number and password;

(4) Details of page browsing, such as visit time and duration.

2. Personal information we collect automatically.

This personal information includes log data, such as your device's IP address, browser type, browser version, the pages of our website you visit, the time and date of your visit, the time spent on those pages, and whether you accessed our pages from social media or an email advertisement. In addition, we may collect this personal information through various technologies, including cookies, web beacons, clear GIFs, and other means.

3. Personal Information We Collect Through Our Robot Device Clients.

Our robot device clients collect personal information to enable their proper operation. For example, the robot collects your Wi-Fi network information for wireless connection and operation. Furthermore, the robot collects information about its movement within the environment it is cleaning, which is necessary for the robot to create a "location map" of its work area and identify objects or obstacles encountered in its cleaning path. Please see Appendix 1 for the specific personal information we collect through our devices and the applicable features and services.

4. Personal Information We Collect from Third Parties

If you access our website through a third party (such as email, WeChat, or Weibo), or share our website content

If we use third-party social media service providers, the service provider will send us some of your personal information, if permitted by the third-party service provider and your account settings. The personal information we receive depends on the service provider's privacy policy and your account settings with the third-party service provider. Please note that we will protect indirectly obtained personal information using the same means and measures as we use for our own users' personal information. We will require third parties to commit to the legality and compliance of the sources of personal information. This personal information obtained from third parties will be used to provide you with services and to ensure the accuracy of the records we hold about you.

5. Requesting Device Permissions

When you use our products and services, we will only request the following device permissions when necessary:

(1) Camera and Gallery Permissions (iOS and Android operating systems): When you use interactive messaging (conversing with customer service), settings, editing user profile pictures, and screenshot feedback services, we need to apply for and obtain this permission from you to use the camera or access photos in the gallery so that you can use the relevant services. During your operation, our applications or products will open your camera or access your local pictures or videos. We promise to only read or store information necessary for the application. Disabling camera and gallery permissions will affect the use of interactive messaging, settings, editing user profile pictures, and screenshot feedback services, but will not affect other services.

(2) Local storage permission (Android operating system): When you use the APP upgrade and information error reporting services, we need to apply for and obtain this permission from you to read and write the contents of the memory card so that you can upload materials and download files. During your operation, our application or product will read your local location, mobile device ID, user account, robot ID, WIFI name and password, and log file list for your local preview. We promise to only read or store information necessary for the application. Disabling local storage permission will affect the use of APP upgrade and information error reporting services, but will not affect other services.

(3) Location permission (iOS and Android operating systems): When you use international dialing code positioning, network diagnosis, and network configuration related services, we need to apply for and obtain this permission from you to obtain your location in order to provide the international dialing code for your location.

During your operation, our apps or products will obtain your location and Wi-Fi SSID information. We promise to only read or store information necessary for the app. Disabling location permissions will default to +86, and network configuration services will be unavailable, but this will not affect other services.

(4) Local network (iOS operating system): When you use the APP to connect to the robot, we need to apply for local network permission to configure Wi-Fi. The APP scans the hotspot of the robot when configuring the network to perform the network configuration process. We promise to only read or store information necessary for the application. Disabling this permission will cause the network configuration service to fail, but will not affect other services.

II. How we use personal information

1. We use personal information in the following ways (please see Appendix 1 for the types of personal information collected and used for our various services and functions):

(1) Provide you with our products and services, including assisting you in purchasing and using our robot clients and related mobile applications;

(2) Analyze website usage and improve service levels accordingly;

(3) Facilitate market research, project planning and troubleshooting;

(4) Safeguard the interests of the state, the public, you, and others.

2. Authorization

If the information you provide contains the personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to us. If the information involves the personal information of minors, you must obtain the consent of the minor's guardian before publishing. In such circumstances, the guardian has the right to contact us through the channels described in Article 12 of this Policy to request correction or deletion of content involving the minor's personal information.

If we use information for other purposes not specified in this Policy, use information collected for specific purposes for other purposes, or proactively obtain your personal information from a third party, we will obtain your prior consent.

3. Exceptions to Obtaining Authorization and Consent

You fully understand and agree that we do not require your authorization and consent to collect and use your personal information in the following circumstances, and we may not respond to your requests for correction/amendment, deletion, deregistration, withdrawal of consent, or information access:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

(4) For the purpose of protecting your or other individuals' major legitimate rights and interests such as life and property, but it is difficult to obtain the consent of the individual;

(5) Personal information that you disclose to the public on your own initiative;

(6) Personal information collected from legally disclosed information, such as legal news reports, government information disclosure, and other channels.

(7) Necessary for the execution and performance of relevant agreements or other written documents with you;

(8) Necessary for the safe and stable operation of the products and/or services provided, such as discovering and handling product and/or service failures;

(9) Necessary for legitimate news reporting;

(10) When academic research institutions conduct statistical or academic research based on public interests and provide the results of academic research or descriptions to the outside world, they shall de-identify the personal information contained in the results;

(11) Other circumstances stipulated by laws and regulations.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, or we may conduct de-identified research, statistical analysis, and prediction on the collected information to improve our content and layout, provide product or service support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), then the use of such processed data does not require separate notification to you and your consent.

III. How we share, transfer, and disclose personal information

1. Sharing

We will not share your personal information with any company, organization, or individual other than JT-Innovation, except in the following circumstances:

(1) Affiliates and service providers. We will share your personal information with third-party service providers and any subcontractors as needed to provide you with our products and services. If we share your sensitive personal information or our affiliated companies change the purpose of using or processing your personal information, we will seek your authorization again. Please see Appendix 2 for a detailed list of the circumstances in which we share your personal information with third-party service providers.

(2) Third-party links and websites. Our website may contain links to third-party websites. If you access any of these links, please note that these websites have their own privacy policies and we do not accept any responsibility for these policies. Please check their privacy policies before submitting any personal information to these websites.

(3) Sharing with your explicit consent. We may share your personal information with third parties with your explicit consent.

2. Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

(1) Transfer with your explicit consent. We will transfer your personal information to a third party with your explicit consent.

(2) Transfers due to a change in control. Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of our business, part of the sale may include your personal information. In such circumstances, we will require the new company or organization holding your personal information to continue to be bound by this Policy. Otherwise, we will require that company, organization, or individual to re-ask your authorization and consent.

3. Disclosure

We will only disclose your personal information in the following circumstances:

(1) Disclosure with your explicit consent. We will disclose your personal information to third parties with your explicit consent.

(2) Disclosures Required by Law. We may disclose your personal information in response to lawful requests by public authorities, including to meet law enforcement requests. We may be required to disclose or share your personal information to comply with a legal obligation, to enforce or apply our terms and other agreements, or to protect our rights, property, and safety, or the rights, property, or safety of others. This also includes exchanging personal information with other businesses and organizations for fraud protection purposes.

4. Exceptions to prior authorization and consent for sharing, transferring, and publicly disclosing personal information

In the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of judgments;

(4) For the purpose of safeguarding your or other individuals' major legal rights and interests such as life and property, but it is difficult to obtain the consent of the individual;

(5) Personal information that you have disclosed to the public on your own;

(6) Personal information collected from legally disclosed information, such as legal news reports, government information disclosure and other channels.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore the data, the sharing, transfer, and public disclosure of such processed data does not require further notification to you and your consent.

IV. How do we use cookies and similar technologies?

1. Cookie

To enable our website and services to function properly, we sometimes place small data files called cookies on your computer, mobile device, or other device. Cookies are small data files that a website or mobile application saves on your computer, mobile device, or other device when you visit that website. They enable the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over time, so you don't have to re-enter them whenever you return to the site or switch from one page to another. We do not use cookies for any purpose other than those described in this policy. If your browser or browser add-on permits, you can adjust your acceptance of cookies or reject our cookies.

2. Cookie-like technologies

In addition to cookies, we may also use other similar technologies such as web beacons and pixel tags on our websites. For example, the email we send you may contain a click URL that links to our website content. If you click on that link, we will track this click to help us understand your product or service preferences and improve customer service. A web beacon is typically a transparent image embedded in a website or email. With the help of pixel tags in emails, we can know whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

5. How do we use the SDK?

To provide and optimize our services, third-party SDKs may be embedded in our apps. While working with us to provide you with more comprehensive services, these third-party SDKs may collect your personal information and, under our control, provide this personal information to third parties. We will take necessary measures to control the collection and use of your personal information by these third-party SDKs, and ensure, through contracts and other means, that your personal information is protected to a degree no less stringent than that stipulated in this Policy. For details on the identities of third parties and the purposes for collection, please see Appendix 3, "Description of Third-Party SDKs," of this Policy.

VI. Your Rights

1. Access, Correction, and Supplementation of Your Information. You have the right to access, correct, or supplement your information. You can do this yourself in the following ways:

(1) Log in to the website/client (APP) and go to "My" to query, correct or supplement your personal information, account and security, and my delivery address;

2. Delete your personal information. You may request us to delete your personal information in the following circumstances:

(1) If our collection and use of personal information violates laws and regulations;

(2) If our processing of personal information violates our agreement with you;

(3) If you no longer use our products or services, or you cancel your account;

(4) If we no longer provide you with products or services;

(5) If you agree that we collect and use your personal information but then withdraw your consent.

After you or we assist you in deleting the relevant information, due to applicable laws and security technologies, we may not be able to immediately delete the corresponding information from our backup systems. We will securely store your personal information and isolate it from any further processing until the backups can be cleared or anonymized.

3. Changing the scope of your consent. Each business function requires some basic personal information to complete. You may grant or withdraw your consent for the collection and use of additional personal information at any time.

4. Account cancellation by the personal information subject. Log in to the website and select "My Account - Customer Service Hotline" or log in to the app and select "Help & Feedback - Issue Feedback" for assistance, or contact us using the information in "XII. Contact Information." We may ask you to verify your identity before processing your request. We will complete the verification and processing within 15 business days. After canceling your account, we will stop providing you with products or services and delete your personal information upon your request, unless otherwise required by laws and regulations.

5. Requesting an explanation of this Privacy Policy. You have the right to request an explanation of this Privacy Policy at any time. Please contact us using the information in "XII. Contact Information" below.

6. Responding to your requests. For security reasons, you may be required to provide a written request or otherwise verify your identity. We may ask you to verify your identity before processing your request. We will respond within 15 business days. You may also file a complaint through our customer service at 0755-26656380. We may deny requests that contain information that is not directly related to your identity, are unnecessarily repetitive, require excessive technical effort (for example, requiring the development of new systems or fundamentally changing existing practices), pose a risk to the legitimate rights and interests of others, or are unrealistic.

VII. Cross-border Transfer of Personal Information

Personal information collected and generated during our operations within the People's Republic of China will be stored within China. In the following circumstances, we will provide your personal information to overseas entities after fulfilling our legal obligations:

(1) Applicable laws have clear provisions;

(2) Obtain your explicit authorization;

(3) You conduct cross-border transactions or other personal initiatives through the Internet.

In the above circumstances, we will ensure that your personal information is protected to a degree no less than that stipulated in this Policy through contracts and other means.

8. How We Protect Personal Information

We strive to protect your personal information and safeguard it from leakage, alteration, loss, misuse, unauthorized access, and disclosure. When you enter, submit, or access your personal information, we implement various security measures to maintain its security. For example, where possible, we will use encryption to transmit and store personal information. We will further restrict access to this personal information through access controls and confidentiality commitments.

However, no website, application, or transmission can guarantee the complete security of personal information. Therefore, while we have established and maintain procedures that we believe are reasonable to protect the confidentiality, security, and integrity of personal information obtained through our websites, products, and services, we cannot guarantee the security of any personal information you transmit to us.

IX. Storage Period of Your Personal Information

We will retain personal information associated with you or your device to fulfill the purposes of this Privacy Policy. When such personal information is no longer necessary to fulfill those purposes, we will delete it or store it in a form that does not identify you, unless we are required by law to retain it for a longer period. When determining the retention period, we consider various criteria, such as the types of products and services you have requested or provided to you, the nature and duration of your relationship with us, possible re-registration for our products or services, the impact of deleting personal information on the services we provide to you, mandatory retention periods required by law, and statutory limitations.

IX. Storage Period of Your Personal Information

We will retain personal information associated with you or your device to fulfill the purposes of this Privacy Policy. When such personal information is no longer necessary to fulfill those purposes, we will delete it or store it in a form that does not identify you, unless we are required by law to retain it for a longer period. When determining the retention period, we consider various criteria, such as the types of products and services you have requested or provided to you, the nature and duration of your relationship with us, possible re-registration for our products or services, the impact of deleting personal information on the services we provide to you, mandatory retention periods required by law, and statutory limitations.

We may change our Privacy Policy at any time. We will post any changes to this Privacy Policy on our dedicated page. We encourage you to review this Privacy Policy regularly to stay updated on the latest version. Your continued use of our products and services after an update to this Privacy Policy takes effect will constitute your full reading, understanding, and acceptance of the updated Privacy Policy and your willingness to be bound by it.

XII. Contact Information

You can contact us through the following methods, and we will respond within 15 business days:

1. If you have any questions, comments, or suggestions regarding this Policy or the personal information of minors, you may contact us through our website/client customer service.

2. We have appointed a Personal Information Protection Specialist, who can be contacted at: 0755-26656380

Appendix 1: JT-Innovation Services and Personal Information Collected

【For APP】

【For devices】

Appendix 2: Third-Party Service Providers and Personal Information Shared with Them

We send information to third-party service providers who support our business. This support includes providing technical infrastructure services on our behalf, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, facilitating payments, and providing logistics services. We require that the companies, organizations, and individuals with whom we share personal information handle personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

To continuously improve the features, services, and experience of JT-Innovation and its products, your personal information may be shared with the following third-party service providers who assist us in providing relevant capabilities:

1. Customer Service and Feedback: To promptly address your complaints and suggestions, we will share your account and related information about the complaint with third-party customer service and feedback service providers, and entrust them to promptly follow up on and respond to your feedback.

2. Marketing and Research: To collect your opinions, suggestions, or any other ideas about JT-Innovation and its products, we may use your contact information and device ID for market analysis.

Appendix 3: Third-party SDK Description

To provide and optimize our services, we have embedded third-party SDKs into our websites and apps. These third-party SDKs may collect your personal information while helping us provide you with more comprehensive services. Below is a list of the names of the third-party organizations and SDKs we currently use, along with the purposes for collection and use. If you have any questions about the collection of your personal information by third parties through SDKs, please refer to the privacy policies of those third parties.