Updated on: April 15, 2020

Effective date: April 15, 2020

The Company is fully aware of the importance of personal information to users, and will try to protect users' personal information and privacy security in accordance with laws and regulations. Before using the "Homedm" software and related services, users are expected to carefully read and confirm that they have fully understood the contents of this clause, namely the user's privacy policy (hereinafter referred to as the "privacy policy"), and allow users to make appropriate choices according to the guidance of the privacy policy.

The privacy policy applies to users' access to and use of "Homedm" software and related services through company applications, web pages, Homedm Software Development Kit (SDK) and Application Programming Interface (API) for third-party websites and applications. When users use or open related functions or use services, the company will collect and use relevant permissions or information necessary for realizing functions and services. Unless it is necessary information to realize basic business functions or according to laws and regulations, users can refuse to provide without affecting other functions or services. The company will explain which information is necessary item by item in the privacy policy. If the user does not log in to the user account, the company will guarantee the basic function of information push through the corresponding identifier information of the device. If the user logs in to the account, the company will push the information according to the account information. The camera, microphone and address book permissions will not be enabled by default. They can only be used to achieve specific functions or services with the express authorization of the user, and the user can also revoke the authorization. In particular, the company will not collect user information when relevant functions or services are not needed, even if it has obtained these sensitive permissions with the authorization of users.

The following companies will introduce to users in detail how the company collects, uses, stores, transmits, shares, transfers (if applicable) and protects personal information; How to help users understand the ways to query, access, delete, correct, and revoke authorized personal information. Among them, the company also clearly shows the important content about users' personal information rights and interests, please pay special attention.

How the company collects and uses personal information

Use of cookies and similar technologies

How to share, transfer and publicly disclose personal information

How companies store personal information

How does the company protect the security of personal information

Manage users' personal information

Minor clause

Amendment and notification of privacy policy

Contact Company

1、 How the company collects and uses personal information

The company will collect the information provided by users actively when using the service, as well as the information generated by users in the process of using the function or receiving the service through automatic means in the following ways:

1.1 Registration, Login and Authentication

1.1.1 When the user uses "Homedm" software and related services, the user can create a user account through WeChat and mobile phone number, and the user can improve the relevant network identification information (avatar, nickname, password, etc.), which is collected to help the user complete the registration. Users can also fill in gender, birthday, region and personal introduction according to their own needs.

1.1.2 The user can also log in and use the third-party account. The user will authorize the company to obtain the public information (avatar, nickname and other information authorized by the user) registered by the user on the third-party platform for binding with the user account of "Homedm" software and related services, so that the user can directly log in and use this product and related services.

1.1.3 When the user uses the identity authentication function or service, according to relevant laws and regulations, the user may need to provide the user's real identity information (including but not limited to the real name, ID card number, telephone number, etc.) to complete the real name verification. This information belongs to personal sensitive information, and users can refuse to provide it, but users may not be able to obtain relevant services, but it will not affect the normal use of other functions and services.

1.2 About the Mall

1.2.2 The company may recommend more interesting products to users. To achieve this function, the company may collect necessary log information, including:

(1) Behavior information of user operation and use: click, favorite, tag, search, browse and share;

(2) Information actively provided by users: feedback, likes, comments;

(3) Geographic location information: GPS information, WLAN access point, Bluetooth, base station and other sensor information.

1.2.3 The above information collected and used by the company has been de identified. The data analysis only corresponds to specific codes that cannot be directly associated with the user's identity and will not be associated with the user's real identity.

1.2.4 In order to provide users with goods, services, prizes and rewards in "Homedm" software and related services, the company will collect necessary personal information about users, including but not limited to name, contact number, WeChat, order information and payment status information. If there is no relevant information, the company will not be able to provide users with the aforementioned goods, services, prizes and rewards.

1.2.5 If the user discloses the user's information in the information uploaded or published in the public area visible to other users in the "Homedm" software and related services, or in the user's response to the information uploaded or published by others, such information may be collected and used by others. When users find that others improperly collect or use user information, they can contact the company through the feedback channels listed in the "Contact Company" clause of the privacy policy.

1.3 Information release and product sharing

1.3.1 When users publish comments, the company will collect the information published by users and display their nicknames, avatars and published content.

1.3.2 Some single services in the "Homedm" software and related services may require users to open specific access rights (such as user's location information, camera, photo album, microphone, sending SMS, address book and/or calendar, vibration, red dot alert, etc.) in the user's equipment to collect and use the information involved in these rights. If the user refuses to provide authorization, this function will not be available, but it will not affect the user's normal use of Homedm software and other functions of related services.

1.3.3 Information collected by the company due to the user's use of "Homedm" software and related services, for example, information published by other users may contain part of the user's information (such as user related information in comments, messages, publishing, etc.).

1.3.4 When the user shares the "Homedm" software and related services to the user's friends, involving the use of the mass sending invitation function, the company needs to obtain the user's contact permission, and complete the mass sending by calling the address book permission, but this permission will not be opened by default, and it can only be obtained or invoked with the user's authorization and consent.

1.4 Search

When users use the company's search service, the company will collect the user's search keyword information and log records. In order to provide an efficient search service, some of the above information will be temporarily stored in the user's local storage device, and the search result content and search history can be displayed to the user.

1.5 Safe operation

1.5.1 Safety assurance function

The company is committed to providing users with safe and reliable products and use environment, and providing high-quality and reliable services is the core goal of the company. The information collected to realize the safety assurance function is necessary information.

1.5.2 Equipment information and log information

(1) To ensure the safe operation of software and services, The company will collect information about users' devices (including but not limited to hardware model, client version, operating system version number, international mobile device ID, unique device identifier, network device hardware address, IP address, WLAN access point, base station, software version number, network access method, type, status, network quality data, operation, use, service log, device startup, device wake-up), Information about the location of the device (including but not limited to GPS location and WLAN access point, Bluetooth and base station sensor information that can provide relevant information).

(2) In order to prevent malicious programs and be necessary for safe operation, the company may collect information about applications installed in mobile phones or running processes, the overall operation, usage and frequency of applications, application crashes, overall installation and usage, performance data or application sources.

(3) The Company, its affiliated companies and partners may use the user's account information, equipment information, service log information or information that can be shared according to law to judge account security, conduct identity verification, detect and prevent security events, provided that they have obtained the user's authorization.

1.6 Others

1.6.1 When users use the company's value-added services to improve the user experience, the company may retain the user's recharge or purchase records to ensure the traceability and security of related transactions; However, the company will not collect or store the user's bank card information or identity authentication information.

1.6.2 When the user contacts the company, the company may save the user's communication/call records and contents or the contact information left by the user, so as to contact the user or help the user solve the problem, or record the solution and results of related problems.

1.6.3 The "Homedm" software needs to be used when there is a network. If the network cannot be connected at present, the software will try to recover the use of the software by disconnecting the WLAN network and then reconnecting.

1.7 Changes in the purpose of collecting and using personal information

Please understand that with the development of the company's business, The functions and services provided by "Homedm" software may be adjusted and changed. In principle, when "Homedm "When the new function or service of the software is related to the function or service currently provided by the company, the personal information collected and used will have a direct or reasonable connection with the original processing purpose. In the case of no direct or reasonable connection with the original processing purpose, the company will again inform the user of the personal information collected and used, and obtain the user's consent.

1.8 Exemption from personal information collected and used with consent according to law

Please understand that under the following circumstances, according to laws, regulations and relevant national standards, the company does not need to obtain the user's authorization to collect and use the user's personal information:

1.8.1 Those directly related to national security and national defense security;

1.8.2 Those directly related to public safety, public health and major public interests;

1.8.3 Those directly related to criminal investigation, prosecution, trial and judgment execution;

1.8.4 It is difficult to obtain my consent for the purpose of protecting the life, property and other major legitimate rights and interests of the personal information subject or other individuals;

1.8.5 The collected personal information of users is disclosed to the public by users themselves;

1.8.6 Personal information of users collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

1.8.7 It is necessary to sign or perform the contract according to the user's requirements;

1.8.8 It is necessary to maintain the safe and stable operation of software and related services, such as finding and handling software and related service failures;

1.8.9 Necessary for legal news reporting;

1.8.10 When an academic research institution is necessary to carry out statistics or academic research based on the public interest and provides the results of academic research or description to the public, it de identifies the personal information contained in the results;

1.8.11 Other circumstances stipulated by laws and regulations.

The user shall be specially reminded that if the information cannot identify the user's personal identity alone or in combination with other information, it does not belong to the user's personal information in the legal sense; When the user's information can identify the user's personal identity alone or in combination with other information, or when the company uses the data that cannot establish contact with any specific personal information in combination with the personal information of other users, these information will be treated and protected as the user's personal information in accordance with the privacy policy during the combined use.

2、 Use of cookies and similar technologies

Cookies and similar technologies are widely used in the Internet. When users use "Homedm" software and related services, the company may use related technologies to send one or more cookies or anonymous identifiers to users' devices to collect and store information when users access and use this product. The company promises that it will not use cookies for any purpose other than those stated in the privacy policy. The company uses cookies and similar technologies to achieve the following functions or services:

2.1 Guarantee the safe and efficient operation of products and services

The company may set cookies or anonymous identifiers for authentication and security to enable the company to confirm whether the user has logged in to the service safely, or whether he has encountered embezzlement, fraud and other illegal acts. These technologies will also help companies improve service efficiency and speed up login and response.

2.2 Help users get a more easy access experience

The use of such technologies can help users eliminate the steps and processes of repetitive users to fill in personal information and enter search content (example: record search).

2.3 Recommend, display and push the content that users may be interested in

2.3.1 The company may use cookies and similar technologies to understand users' preferences and usage habits, conduct data analysis, improve product services, recommend information or functions that users are interested in, and optimize users' choice of advertising.

2.3.1 On the sharing page of the "Homedm" software, the company may use cookies to record browsing activities, which are used to recommend information to users, check the exceptions related to crashes and delays, and explore better service methods.

2.4 Cookie Clearing

Most browsers provide users with the function of clearing cached data in the browser. Users can clear the corresponding data in the browser settings function; For "Homedm" software, to clear cookies, users need to uninstall "Homedm" software. If the user clears, the user may not be able to use the services or corresponding functions provided by the company depending on cookies.

3、 How to share, transfer and publicly disclose personal information

3.1 Sharing

3.1.1 Sharing principle

(1) Principle of authorization and consent: Sharing the user's personal information to the company's affiliates or other third parties requires the user's authorization and consent, unless the shared personal information is de identified information and the company's affiliates or other third parties cannot re identify the natural person subject of such information. If related parties or other third parties use the information for purposes beyond the scope of the original authorization, they need to obtain the user's consent again.

(2) The principle of legitimacy and minimum necessity: the data shared to the related parties or other third parties must have legitimate and legitimate purposes, and the shared data must be limited to the extent necessary to achieve the purpose.

(3) The principle of security prudence: The Company will carefully evaluate the purpose of related parties or other third parties to use shared information for data, comprehensively evaluate the security capabilities of these partners, and require them to comply with the cooperation legal agreement. The company will strictly monitor the security of software tool development kits (SDKs) and application program interfaces (APIs) that partners obtain information to protect data security.

(4) The Company will not share the user's personal information with its affiliates or other third parties, except for the following circumstances:

(a) To the extent permitted by laws and regulations, it is necessary to protect the interests, property or safety of the Company, its affiliates or partners, users or other users or the public from damage;

(b) The application user needs to handle disputes or controversies between users and others for users;

(c) Use based on academic research;

(d) It is used in accordance with the social public interest of laws and regulations.

3.1.2 Shared information for realizing functions or services

(1) When users use the functions provided by the company's affiliates or other third parties in the "Homedm" software, or when software service providers, intelligent device providers, system service providers and the company jointly provide services for users, the company will share the de identified personal information with these affiliates or other third parties for comprehensive statistics and feature and preference analysis through algorithms to form indirect crowd portraits, It is used to recommend, display or push information that users may be interested in, or push specific functions and services that are more suitable for users.

(2) Payment and collection function: The payment and collection function is provided by a third-party payment institution cooperating with the company. The third-party payment institution may need to collect the user's name, WeChat account information, bank card type and number, validity period and mobile phone number. The bank card number, validity period and mobile phone number are personal sensitive information, which are necessary for payment and collection functions. Refusing to provide them will result in users being unable to use this function, but will not affect the normal use of other functions.

3.1.3 Shared information for security and analysis statistics

(1) Ensuring the security of use: The company attaches great importance to the security of accounts and services. In order to ensure the security of users' and other users' accounts and properties, and protect the legitimate rights and interests of users and the company from illegal infringement, the company and its affiliates or other service providers may share necessary equipment, accounts and log information.

(2) Analysis of product usage: In order to analyze the use of the company's services and improve the user experience, statistical data on product usage (crashes, flashbacks) may be shared with related parties or third parties. It is difficult for these data to identify the user's personal identity in combination with other information.

(3) Improve website functions and services: We use Google Analytics, a web page analysis service provided by Google ("Google"). Google Analytics uses cookies to help us analyze users' use of websites to edit website activity reports and provide other services related to website activity and Internet applications. We will use this information to improve website functions and services. Google Analytics will collect first party cookies, data related to devices/browsers, IP addresses and user activities in websites/applications to measure user interactions with websites and/or applications using Google Analytics and report relevant statistical information.

3.1.4 Help users to participate in marketing promotion activities

When users choose to participate in relevant marketing activities held by the company, its affiliates or other third parties, they may need to provide their name, mailing address, contact information, WeChat account and bank account information. This information is sensitive personal information. Refusing to provide it may affect users' participation in relevant activities, but it will not affect other functions. Only with the consent of the user, the company will share these information with the company's affiliates or third parties, to ensure that users can get services with consistent experience in joint activities, or entrust a third party to cash rewards to users in a timely manner.

3.2 Assignment

3.2.1 The Company will not transfer the user's personal information to any other third party unless expressly agreed by the user.

3.2.2 With the continuous development of the company's business, the company may carry out merger, acquisition and asset transfer, and the user's personal information may be transferred accordingly. In the event of the aforementioned changes, the Company will require the successor to protect the user's personal information in accordance with laws and regulations and the security standards not lower than those specified in the privacy policy, otherwise the Company will require the successor to obtain the user's authorization and consent again.

3.3 Disclosure

3.3.1 The Company will not publicly disclose the user's information unless it complies with national laws and regulations or obtains the user's consent. The company will adopt security protection measures that comply with industry standards when disclosing users' personal information publicly.

3.3.2 The Company will disclose the information of relevant accounts when making punishment announcement for illegal accounts and fraud.

3.3.3 After the user authorizes the game or applet, the avatar and nickname of the user and friends will be displayed in the ranking and related functions.

3.4 Exemption from personal information that can be shared, transferred and publicly disclosed according to law

Please understand that under the following circumstances, according to laws, regulations and national standards, the company does not need to obtain the user's authorization to share, transfer and publicly disclose the user's personal information:

3.4.1 Those directly related to national security and national defense security;

3.4.2 Those directly related to public safety, public health and major public interests;

3.4.3 It is provided according to the requirements of applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements;

3.4.4 It is difficult to obtain the consent of the user in order to protect the life, property and other major legitimate rights and interests of the user or other individuals;

3.4.5 Personal information disclosed by the user to the public or explicitly agreed or authorized by the user in advance;

3.4.6 Collect personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

3.4.7 Provided in accordance with relevant agreements signed with users (including electronic agreements signed online and corresponding platform rules) or other legal documents.

4、 How companies store personal information

4.1 Storage location

In accordance with the provisions of laws and regulations, the Company stores the personal information of users collected and generated in the domestic operation process in Hong Kong Special Administrative Region of the People's Republic of China.

4.2 Storage life

The Company will only retain the user's personal information: information, comments and other relevant information published by the user during the period necessary for the purpose of providing "Homedm" software and services. The Company will retain the user's personal information during the period when the user has not withdrawn, deleted or cancelled his/her account. After the necessary period is exceeded, the company will delete or anonymize the user's personal information, unless otherwise specified by laws and regulations.

5、 How does the company protect the security of personal information

5.1 The company attaches great importance to the security of users' personal information, and will strive to take reasonable security measures (including technical and management aspects) to protect users' personal information and prevent the personal information provided by users from being improperly used or being accessed, publicly disclosed, used, modified, damaged, lost or disclosed without authorization.

5.2 The company will use encryption technology, anonymization processing and relevant reasonable and feasible means that are no less than those of industry peers to protect users' personal information, and use security protection mechanisms to prevent users' personal information from malicious attacks.

5.3 The company will establish a special security department, security management system and data security process to ensure the security of users' personal information. The company adopts a strict data use and access system to ensure that only authorized personnel can access users' personal information, and conducts security audits on data and technology in due course.

5.4 Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that in the Internet industry, even if we try our best to strengthen the security measures, it is impossible to always guarantee the security of information 100% due to the technical restrictions and possible malicious means. The company will try its best to ensure the security of personal information provided to the company by users.

5.5 The user knows and understands that the system and communication network used by the user to access the company's services may have problems due to factors beyond the company's control. Therefore, the company strongly recommends that users take positive measures to protect the security of personal information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing the passwords of user accounts and relevant personal information to others.

5.6 The company will formulate emergency response plans and immediately launch emergency plans when user information security incidents occur, so as to prevent the impact and consequences of these security incidents from expanding. In case of user information security incidents (leakage and loss), the company will timely inform users of the basic information and possible impact of security incidents, the disposal measures taken or to be taken by the company, suggestions for users to independently prevent and reduce risks, and remedial measures for users in accordance with the requirements of laws and regulations. The company will timely inform the users of the event in the form of push notification, email, letter, SMS and other relevant forms. If it is difficult to inform one by one, the company will take a reasonable and effective way to publish an announcement. At the same time, the company will also report the disposal of user information security incidents according to the requirements of relevant regulatory authorities.

5.7 Once the user leaves the "Homedm" software and related services and browses or uses other software, services and content resources, the company will have no ability and direct obligation to protect any personal information submitted by the user in the software and website other than the "Homedm" software and related services, regardless of whether the user logs in, browses or uses the above software and website based on the link or guidance of the "Homedm" software.

6、 Manage users' personal information

The company attaches great importance to the management of users' personal information, and makes every effort to protect users' rights to query, access, modify, delete, revoke consent authorization, cancel accounts, complain and report, and set privacy functions for users' personal information, so that users can protect their privacy and information security.

6.1 Change or withdrawal of authorization scope

When a user needs to turn off specific access rights in the user's device (such as the user's location information, camera, photo album, microphone, address book and/or calendar), most mobile devices will support this requirement. For specific methods, please refer to or contact the service provider or manufacturer of the user's mobile device. When a user opens any permission, it means that the user authorizes the company to collect and use relevant information to provide corresponding services for the user. Once a user closes any permission, it means that the user cancels the authorization. The company will no longer continue to collect and use relevant information based on the corresponding permission, nor can it provide the service corresponding to the permission for the user. However, the user's decision to close the authority will not affect the information collection and use based on the user's authorization.

6.2 Accessing, deleting and correcting users' personal information

6.2.1 Accessing and modifying user account information

Users can access and modify their account information such as their avatar, nickname, and reminder settings in the "My" - "Settings" option of the "Homedm" software.

6.2.2 Query, access, change or delete user favorites, likes, comments, search history, etc

6.3 Account cancellation

If the user needs to log off the "Homedm" user account, please enter the user feedback interface through "My" - "Help and Feedback" in the "Homedm" software to apply. The company will arrange relevant staff to assist the user. Before the user logs off the account, the company will verify the user's personal identity, security status, equipment information, etc. The user knows and understands that the act of canceling the account is irreversible. When the user cancels the account, the company will delete the relevant information about the user or conduct anonymization, unless otherwise specified by laws and regulations.

6.4 Complaints

Users can make complaints or reports according to the system publicized by the company. If the user thinks that the user's personal information rights may be infringed, or finds clues to infringe the personal information rights (for example, thinks that the company collects the user's personal information in violation of legal provisions or mutual agreement), the user can enter the user feedback interface to contact the company through "My" - "Help and Feedback" in "Homedm" software. After verification, the company will timely feed back the complaints and reports of users.

6.5 Access to Privacy Policy

6.5.1 Users can view all contents of the privacy policy on the registration and login page.

6.5.2 Please understand that the "Homedm" software and related services described in the privacy policy may vary depending on the mobile phone model, system version, software application version, mobile client and other factors used by the user. The final products and services are subject to the "Homedm" software and related services used by users.

6.6 Inform the user of stopping operation

Inform users one by one in the form of delivery or announcement, and delete or anonymize the personal information of users held by them.

7、 Minor clause

7.1 If the user is a minor under the age of 18, before using Homedm software and related services, they should read and agree to the privacy policy under the supervision and guidance of the user's parents or other guardians.

7.2 The Company protects the personal information of minors in accordance with relevant national laws and regulations, and will only collect, use, store, share, transfer or disclose the personal information of minors when it is permitted by law, explicitly agreed by parents or other guardians or necessary to protect minors; If the company finds that personal information of minors has been collected without the prior consent of verifiable parents, it will try to delete relevant information as soon as possible.

7.3 If the user is the guardian of a minor, when the user has questions about the personal information of the minor under his/her supervision, please contact the company through the contact information publicized in the company's privacy policy.

8、 Amendment and notification of privacy policy

8.1 In order to provide users with better services, "Homedm" software and related services will be updated and changed from time to time, and the company will revise the privacy policy in due time