1. Introduction 1.1 This Privacy Policy explains how Rakoit Technology (Shenzhen) Co., Ltd., along with its affiliates (hereinafter referred to as“we”, “us” or “Rakoit”), collects, uses, shares, transfers and protects the personal information of the user (hereinafter referred to as “you”) and the corresponding rights of the user. Personal information refers to any information related to a natural person that has been identified or is identifiable. [1] Within the meaning applicable law, we will act as a data controller when we process your personal information. 1.2 This Privacy Policy shall apply to platforms on which it is displayed, including but not limit to the Rakoit site, products, and services, and other platforms which link to this Privacy Policy. If this Privacy Policy does not cover certain specific personal information processing scenarios, we will explain it to you in the form of supplementary policies or pop-up windows. 1.3 We shall process your personal information in different scenarios based on different legal reasons, such as performing contracts and providing products and/or services to you, based on legitimate business interests or with your prior consent, as further detailed below. You will always have the right to object to the processing of your personal information on grounds relating to your particular situation. 2.Personal Information collected by Rakoit In any scenario in which you interact with us, we are likely to ask you to provide personal information. If you do not provide the relevant information, you may in certain situations not be able to achieve the specific purpose for a particular scenario. For example, you cannot purchase a Rakoit product; our call center cannot reach you and provide you with pre-sales and after-sales service; or you cannot download updated software systems and/or applications. Here are some of the scenarios where we collect your personal information: 2.1 When you register for an account and purchase a Rakoit product, you shall provide relevant personal information, such as user name, gender, phone number, email, mailing address, zip code, consignee information, method of payment and bank account information, etc. 2.2 Where permitted by law, Rakoit shall also obtain data about you from third-party sources. For example, when you use a third-party network account to register for an account in Rakoit or login to our website, Rakoit will obtain your account information from a third-party network service company. Depending on your choice of third-party network account, we may collect your WeChat account, QQ number, Alipay account, Facebook or Google account information. In such case, only the account information will be obtained. 2.3 When you activate and use a Rakoit product, we shall also collect information about your device or software, such as device name and model, device ID (such as IMEI and SN), operating system version number, language selected for the device, time zone, information of SIM card telecom operator, serious error log of system and other information. 2.4 Network information: for example, the type and version of browser used when you login to the Rakoit online store, language, OS version, resolution, website operating elements, your web IP address and web browsing information, as well as user behavior and other information collected by Rakoit through cookies and other similar technologies. 2.5 Location information: information from you or other users, including your geographic location, such as the region contained in the account information you have provided; country information displayed by the telecommunications carrier code you use. Some pre-loaded, location service-based apps such as maps, navigation and weather service apps will collect your location information with your consent. 2.6 When you call our customer service center for assistance, we shall ask for your name, phone number, product information and receiving time, and record your number of calls, date of call, problem encountered and the solution we give to you. 2.7 If you participate in one of Rakoit offline product experience events, we will also ask for information such as your name, gender, email address, and phone number. 3. How Rakoit may use Personal information Rakoit will use your personal information based on the following purposes. One or more purposes may be applied at the same time. If we use your personal information beyond the following purposes or the scope allowed by the law, we will obtain your consent again on the basis of special purpose needs. 3.1 Used for authentication, security, fraud monitoring, archiving and backup purposes to ensure the security of products and services provided to you by Rakoit. Such purposes for processing your personal information has for legal basis the respect of our legal obligation to implement appropriate technical and organizational measures to ensure a level of security of such processing. 3.2 Provide you with services such as order processing; receipt and delivery of goods; refund of payment for goods; after-sales maintenance; implementation of electronic security plans; push system upgrade information, and other similar purposes. Such purpose for processing your personal information has for legal basis the proper performance of the contract we enter with you when you purchase our products and/or services. 3.3 Contact you directly. In the process of providing products and services to you, we may contact you directly based on the contact information you have provided us. For example, if you post content on the Rakoit website indicating that you have a complaint about a Rakoit product or service, or need technical assistance from Rakoit, we will contact you to obtain further information and provide you with assistance. Such purpose for processing your personal information has the legal basis of proper performance of the contract we enter with you upon your purchase of our products and/or services. 3.4 Help Rakoit to improve products and services. For example, Rakoit will analyze and study the collected data to make user-friendly adjustments to its operating system and interface design in accordance with user characteristics. When you choose to send error details to Rakoit, Rakoit can modify the software according to the specific error information, which helps to ensure that the similar software errors will not happen again. Such purpose for processing your personal information has for legal basis our legitimate interest in improving our products and services. 4. Instructions on the use of Cookies and similar technologies 4.1 In order to ensure that the website works well, Rakoit will use cookies and similar technologies such as pixel tags and website beacons. Cookies are plain text files that are stored on a computer or mobile device by web server. The content of cookies can only be retrieved or read by the server that creates it. Each cookie is unique to your web browser or mobile app. Cookies usually contains some identifiers, commonly-used information and other details. For instance, you can reduce the number of login authentications needed and improve your experience through cookies technology when browsing different web pages of Rakoit website. Otherwise, you may not be identified as the same person and may be asked to enter the authentication information again if logging onto to Rakoit website and then be required to go to another web page of Rakoit website. 4.2 These technologies help Rakoit and third parties to better understand user behavior, tells Rakoit which section of Rakoit website you have browsed, and measure and improve the effectiveness of Rakoit’s services. Rakoit will not use cookies for any purposes other than as described in this policy. You can manage or delete cookies based on your own preferences. However, please note that some Rakoit services may be designed to require the use of cookies and disabling cookies may affect your rights to use these services or some of these features. 4.3 In addition to cookies, Rakoit also uses other similar technologies such as local storage, web beacons, and pixel tags on its website. Like local storage of HTML5, this can cache frequently-used data related to you so that such data can be rendered to you quickly when you switch between different web pages of the Rakoit website. For another example, an email sent to you may contain a click URL linked to the content of the website. If you click on the link, this click will be tracked to help Rakoit better understand your product and service preferences and improve customer service. Web beacons are usually transparent images embedded in websites or e-mails. With the help of the pixel tags in emails, Rakoit can know whether the email content is effectively served to the user. 5. How Rakoit can share personal information 5.1 We will disclose your personal information between affiliates or subsidiaries and ensure that the same level of protection is provided for your personal information between affiliates and subsidiaries. 5.2 Rakoit will disclose your personal information to its partners under certain circumstances. For example, when you purchase Rakoit products through Rakoit’s online store, Rakoit will disclose your product purchase and shipping information to our authorized logistics service provider. As another example, if you have purchased the extended warranty service of Rakoit applicable for a certain region (e.g. China), Rakoit may disclose your personal information to an insurance company when submitting a claim, as Rakoit from time to time cooperates with insurance companies for the extended warranty service. If your personal information is submitted for an insurance claim, your personal information will be used to process your claim and enable you to have your product repaired.
5.3 In addition, Rakoit shall disclose your information to public authorities with jurisdiction over the territories in which we operate to provide personal information of our users in compliance with the law or in the performance of legal procedure. 5.4 In any case of sharing your personal information with third parties, we endeavor to disclose it to such third parties only to the extent permitted by law and we require data recipients to process and protect your personal information in compliance with applicable laws and regulations. 5.5 Rakoit promises not to sell personal data to any third party and guarantees the legitimate and fair use of user information only to the extent permitted by law. 6. How you access and control your personal information 6.1 Rakoit will take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other personal information provided when using Rakoit services. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security. 6.2 You are also entitled, to restrict under certain circumstances the processing of your personal information and to request a copy of the personal information you provided us in a structured, commonly used and machine-readable format. 6.3 You can control your own personal information. For example, you can turn off the location sharing button to stop sharing your device's location information, or you can revoke prior consent for data collection and processing. However, please understand that once you make above choice, you may not be able to enjoy the related services. 6.4 Wherever required, you can contact us through contact information provided in this Privacy Policy, notably to exercise your rights detailed above. If we have a reasonable basis to believe that your request is fraudulent and/or cannot be verified, or certain personal data rights are not stipulated by law in your country and region, we will reject your request. 6.5 You shall have the right to lodge a complaint with the data protection supervisory authority of your habitual residence in case you believe that the processing of your personal information infringes any applicable regulation. 7. How Rakoit protects Personal information 7.1 Rakoit only retains your personal information for the time period necessary for the purposes described in this Privacy Policy and as required by applicable laws and regulations. 7.2 Rakoit uses various management policies (such as establishing information security system; signing a confidentiality agreements with information management employees; allowing only work-related employees to access the information collected; and other similar policies) and security techniques and procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) to prevent the loss of information, improper use, and unauthorized reading or disclosure. For example, in some services, Rakoit uses encryption technology (such as SSL) to protect the personal information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to guarantee 100% security of information, even if all efforts are made to strengthen security measures. You need to understand that the systems and communication networks you use to access Rakoit services may be subject to problems that are beyond Rakoit’s control. 7.3 If Rakoit is informed that the security of data it has acquired and stored is compromised or the user's nonpublic information is disclosed to an unrelated third party due to external acts (such as cyber-attack), Rakoit will take reasonable actions. These actions may include internal investigations, reporting and notification to law enforcement agencies, and cooperation with the law enforcement agencies, and other actions Rakoit may consider appropriate to reduce the impact of data leakage accidents on users, notwithstanding any disclaimer in this Policy. In parallel, Rakoit will take legal and reasonable steps it may deem appropriate to notify the relevant users, informing them of the information disclosed and the extent to which we are aware of such situations. 7.4 Cross-border data transfer: your personal information may be transmitted and transferred across borders (regions), and stored and processed in the target country (region). Depending on the laws in your country and region, the receiving country and region of these data may not meet the requirements. We promise that we will have the right security measures to ensure that the protection level of data can meet the full requirements of the laws and regulations of your country and region.[2] 8. Protection of minors’ personal information 8.1 Our products and services are primarily designed for adults. Anyone who is identified to be a minor customer under the laws of the country in which (s)he is located must obtain the consent of his or her parents or guardians before using our products and services upon purchase. 8.2 We value the privacy protection of minors and encourage parents to always play an active role in their child's online experience. 9. Third-party service 9.1 This Privacy Policy does not apply to products and services provided by third parties. Rakoit products and services may include products and services from third parties, as well as links to third-party websites. In general, if these products and services are not displayed or linked to Rakoit’s Privacy Policy or in other ways indicating that Rakoit is the data controller or joint data controller, the Privacy Policy of the third party should apply with respect to any personal data processed. 9.2 We are not responsible for how third parties collect, use, share, transfer and protect user's personal information, and cannot control how it is processed. 9.3 To avoid any misunderstandings, please refer to this third party's service agreement and read its privacy policy.
10. Change and modification 10.1 You may request a copy of this Privacy Policy from us using the contact details listed below. We may amend or update this Privacy Policy from time to time. You will be able to see our last updated privacy policy, along with its revision date. The revised privacy policy will take effect from the date of publication. Please check the Privacy Policy from time to time to confirm whether we have made any changes with reference to use of personal information. 10.2 If any changes to this Privacy Policy have a material impact on your rights, we will take reasonable steps to notify you of such change 11. Notification and delivery 11.1 Any notice from Rakoit will be sent to the email address, phone number, and/or mailing address left when you register for an account or purchase of Rakoit product, or pushed directly through mobile phone system. If sent via electronic methods, notice shall be deemed served when your device or the used electronic system receives the message; if sent by courier, it shall be deemed served on the third day after sending out. 11.2 If you have any questions, comments, suggestions or doubts about this Privacy Policy or our products, please feel free to give us a feedback. Our contact: i.E-mail address: privacy@Rakoit.com ii.Postal address: Room 513 Building 5 Jiuxiangling industry park Xili Nanshan Shenzhen Guang Dong Province, China . Last updated date: June 1, 2018. [1] The definition of personal information may vary from country to country. The definition of personal information in this Privacy Policy mainly refers to that in the General Data Protection Regulations (GDPR in short), which will be implemented by the European Union on May 25, 2018. If some countries or regions have different definitions on personal information, the laws of these countries or regions shall be applied according to the specific circumstances. To maximize the protection of a user's personal information, we may process some non-personal information using the same protection standards as are used with personal information. If non-personal information is mixed with personal information, we will regard non-personal information as personal information. [2] Rakoit is a company headquartered in China. When we entrust partners around the world to provide customers with our products and services, we disclose some personal information to our partners. For example, our call center services provider outside China is a US-based company, which has call centers in Philippines to serve EU and other customers. When we provide users’ personal data to our call center provider, its staff working in the US and Philippines process the users’ personal information at the same time. Rakoit online store has commissioned different partners to operate in different countries and regions. Rakoit is the data controller of all Rakoit online store. Our partners may change due to commercial needs. Consequently, the target countries of transnational transfer of personal information may also change.