ECOVACS HOME Privacy Policy

ECOVACS HOME Privacy Policy

Last Updated and Effective Date: [2025.02.21]

Chapter references

This Policy sets out:

I. How we collect and use your personal information

II. How we apply Cookie technology or Beacon technology

III. How we store and protect your personal information

IV. How we entrust, disclose, share and transfer your personal information

V. Your rights: How to access and control your personal information

VI. Security

VII. Cross-border transfer of personal information

VIII. Special Provision relating to children

IX. Scope of and amendments to this Policy

We, Ecovacs Robotics, Inc. (hereinafter referred to as “we”, “us” or “our”) respect and take measures to protect your privacy and personal information. This ECOVACS HOME Privacy Policy (hereinafter referred to as this “Policy”) explains the way we process your personal information and the rights you have under this Policy when you use the ECOVACS HOME App provided by us (hereinafter referred to as the “App”) to control and administer the robotic cleaning device(s) that are connected to your App user account (hereinafter referred to as the “Device”), as well as when you use the Device itself. The App may contain links to external websites operated by our affiliates or third parties. When you click on such a link, the website will be presented in the web browser of your smart phone and the processing of your personal information will be subject to the privacy policy of the relevant website. We act as the controller of your personal information that we obtain directly from you as the data subject when you use the App and/or Device.

If you would like more detailed information, please refer to the corresponding chapters in accordance with the index.

This Policy applies to all users of ECOVACS HOME products and services, meaning all individuals who have complete capacity according to the law and register with the App to enjoy the relevant ECOVACS HOME products and services, or use a Device (each a “user”). We do not intend to serve any users under 16 years of age (or other ages as a minor in your jurisdiction) or collect any personal information from such users.

By clicking to accept or otherwise acknowledging that you understand this Policy, you are deemed as acknowledging and consenting to this Policy with respect to your use of the App or Device. This Policy is not necessarily applicable to services, activities or products of third parties to which you may be referred and on which a different privacy policy might apply.

1. This Policy is to help you understand the type, reason to use and the collection mode of specific personal information, which is collected by certain products, services or functions of the App and Device.

2. Your usage of certain functions of the App and Device may initiate our collection of some information. Such collection and its purpose, other than being required by applicable law (hereinafter referred to as “Law”), are clearly stated in this Policy for your review. If you refuse to provide such information that is relevant to a specific function only, such function would not be available to you, but this will not affect your general access to other functions of ECOVACS HOME products and services. We may store information about you for as long as it is necessary for the purposes set out in this Privacy Policy or required or permitted by applicable Laws.

3. Generally, we do not share, disclose, or transfer your personal information to any third parties unless otherwise expressly stated in this Policy or required or permitted by relevant Law. If the sharing, disclosure, or transfer of information is necessary, we will explain the reasons/basis for such sharing, disclosure, or transfer, and, to the extent legally required, or obtain your prior consent.

4. You may have the right under applicable Law to access, correct, delete, Opt-out of sharing, limit the use of your personal information, or withdraw previous consent, insofar as the processing of your personal information is based on your consent; you may also cancel your user account registered with the App (the “App account”), file complaints or reports or apply privacy settings to control your personal information or restrict us from further processing. If the processing is based on our legitimate interests, you may also be entitled to object to the processing of data at any time. This can be done by contacting us under the contact information listed in this Policy.

5. You may at any time refer your complaints to the relevant regulator in your jurisdiction if you believe that our processing of personal information violates the Law on personal information protection.

6. If you have any questions, complaints or comments related to this Policy or our implementation of the Law on personal information protection, or would like to exercise your rights as a data subject under applicable Law, please contact us under the contact information listed in this Policy.

Contact Information of the Data Protection Officer: data-privacy@ecovacs.com

Please familiarize yourself with our privacy practices that cover how we collect, use, disclose, transfer, and store your personal information. The purpose of processing your information is to operate the App and the Device and to offer you better services and improve the quality of our products, e.g., to support the development of new products and function upgrades of existing products in order to provide you with high-quality and suitable services.

I. How we collect and use your personal information

(a) Information Type, Collection Mode and Purpose

We may process your personal information: for the purposes described in this Policy; with your consent; for compliance with our legal obligations; for the performance of a contract to which you are a party; in order to protect your vital interests; or when we have determined it is necessary for the purposes of legitimate interests pursued by us or a third party to whom it may be necessary to transmit information (please refer to the Annex below for details).

(1) Personal Information provided during the registration procedure of your App account.

An App account is necessary for you to use the App, including the functions relevant to your Device. When you register for an App account, we will collect and store your personal information, including your email address, password and Ecovacs ID. By providing your information, you are warranting that the personal information you have provided to us are complete and accurate. To facilitate our internal processing of the data related to your App account, upon the completion of your App account registration, an Ecovacs ID (which is a random character string) will be assigned to your App account. By having you bound with an App account and an Ecovacs ID, the App and we can recognize your commands and needs and differentiate you from other users, enabling us to transmit your commands correctly to your Device and to serve you on the basis of long-term understanding and perform the ECOVACS HOME User Agreement with you.

Your account registered with our e-shopping channel (if applicable) can also work as an App account or vice versa. We will recognize the accounts as owned by the same person if the same email address is provided for registration. Please note that the personal information we collect from the accounts registered by the same email address will be integrated into and used according to the respective privacy policy applying to such collection.

The above information will be used to verify your identity, match and assemble the operations made in the name of your App account, match and provide feedback on the status of your Device, facilitate our handling of transactions, customer service and after-sale requests you made to us , and send you notifications of the above, account verification, important changes and updates of service functions, and notices regarding such things as technology and safety.

We also reserve the right to use your email address to send you information about us and our products and services, i.e., direct marketing. You may unsubscribe from our email direct marketing campaigns by clicking the unsubscribe button provided in every marketing email.

(2) Personal Information collected from the App.

When you open the App for the first time, we will ask you to confirm the country/region you are in, and to select the preference of the display language. This will help the App to determine the corresponding version of the ECOVACS HOME User Agreement and the ECOVACS HOME Privacy Policy for display within the App. Your preference will also be added into your profiling if you register for an App account thereafter.

To provide the App and the App services to you and to maintain the quality of our services and the safety of your data, when you visit the App and use the App services, we may collect and record (i) the types and modes of services you requested, the operation information during your services, your operation log (including when you log in and off the account) and any other log information in connection with your services; (ii) IP address, system version, IMEI and MEID of your mobile device (use of the “unification identification code” of your mobile device is limited to referring to your historical data collected or generated on the specific mobile device, and to recognize if your App account has been logged in a strange mobile device which may imply an App account theft) ; (iii) SSID (the name of WiFi network) and the password of Wi-Fi network. This information includes your IP address and your Ecovacs ID which will be used to pair your Device with your App account and to maintain the connection.

When you utilize our customer service through the App, i.e. if you contact us, e.g., by e-mail, via a contact form or via live chat, the information you provide will be stored for the purpose of processing the request. We need the information requested in a contact form or live chat to process your request, to address you correctly and to send you a reply. We process the data as part of the provision of our contractual services. In this context, inventory data (for example, surname and first name of the contact person(s), address), contact data (for example, e-mail address, telephone number), contract data (for example, subject matter of the contract, term), payment and shipping data (if applicable, such as payment amount, payment method information, user name, billing and/or shipping address), communication records and other data collected in the context of the provision of services and/or required for the provision of services are processed, if applicable. Inquiries and customer relations are regularly stored and processed in our CRM system. To process your request, we are using Zendesk Support, provided by Zendesk, Inc., 1019 Market St, San Francisco, CA 94103, United States of America. When you make an enquiry, Zendesk Support will set a cookie to measure the amount of pending and solved enquiries as well as our response times to such response times. Such information will be used to improve our customer service. If the problem you meet would obtain a clearer description by taking a photo/screenshot, you may also consider sending to the customer service such pictures. When we use Zendesk Support, your personal information may be processed on servers located in the United States of America. Please refer to the Annex of this Policy for the details of the service provider we have engaged in conducting such collection.

The permission for “Storage” on your mobile device is indispensable for the operation of the App, its updates or upgrades, and storing any information collected from the App. To conduct the abovementioned information, the following permissions on your mobile device will be sought by the App: (i) access to “Mobile Data,” “Location” and “Wi-Fi Information” (and “Bluetooth” if the operating system on your mobile device is IOS 13.0 or above), in order to configure the connection for network matching and perform App functions that rely on network; (ii) access to “Device Information” in order to secure the use of your App account.

Occasionally, some other permissions will be requested from you to which you may object, the consequence of which will inactivate certain functions pursued by you: (i) if you choose to connect to a Wi-Fi network by scanning a QR code, access to “Photo Album” and/or “Camera” will be further required; and (ii) if you choose to have the Device broadcast real-time voice commands (only possible on a few Device models), access to “Microphone” is further required.

Our processing of such personal information is limited to:

(i) delivering the content of the App correctly, in particular to maintain the continual connection among your App account, your commands made through your App account and your Device;

(ii) processing your commands, enquiries and requests with regard to your use of the App and/or your Device, including customer service;

(iii) compiling analysis to spot potential market needs and common faults, improving our service quality and supporting the long-term viability and ongoing updates of our technology regarding information systems, Devices and mobile applications (prior to being used for this purpose, the personal information would be de-identified as much as possible);

(iv) creating and supplementing our user profiling on you, therefore optimizing and personalizing the content of the App, our or third-party advertisements (displayed among the App content, by push notification within the App or on the top banner of your mobile device), and our direct marketing campaigns (sent to your email address provided during the App account registration process) to suit such profiling; and

(v) conducting our legal obligations such as “Know Your Clients”, record keeping and network security protection, in order to provide law enforcement authorities with the information necessary to prevent, tackle or supervise data security risks.

To push advertisements and other various kinds of notifications to your App account interface, it is necessary to obtain your permission to the App on the access to “Notice” function on your mobile device, and some tools sourced from our service providers will be integrated in the App (please refer to the Annex of this Policy for details). Please check the user settings to switch off receiving the specific categories of such notices. We will distinguish advertisements with an “ad” imprint on all advertisements for your ease of identification.

During Device Sharing, if you as the Main Account Holder intend to share control with other individuals who have not been registered with the App, you are required to seek their consent prior to submitting their email addresses within the App, so that we could send them an email containing an invitation to register for an App account.

(3) Personal Information collected by the Device paired with your App account.

To maintain and secure the performance by your Device of your commands and for your Device status to be transmitted to your App account interface, and for your ease of review, some information sourcing from your Device needs to be transmitted through or stored at our servers. Among such types of information, those which may be deemed as your personal information include: (i) information of the mobile device on which you install the App (including the device model, unification identification code, operating system and its version, IP address, Mac address, and country where the device is located); (ii) the Wi-Fi network access you use for the mobile device and the Device (SSID, network layout, password of Wi-Fi network); (iii) your Device information (model and serial number); (iv) App account’s pairing status, history and obstacles (if any); (v) the operational log and status data of your Device; (vi) working environment 2D/3D map generated by your Device(if applicable); (vii) voice and audio information(if applicable), and (viii) photos/videos recorded by your Device’s vision censor in the working environment (if applicable).

(i) Under special circumstances such as where faults and bugs of the Devices are reported, we will collect the abstract layout of work areas and the operation logs of your App account and your Device to help you tackle problems including to recovery from the reported technical failures or faults.

(ii) We also use some of this information to compile analysis to spot the potential market needs and common faults, and support the long-term viability and ongoing updates of our technology regarding information systems, Devices and mobile applications. Unless otherwise specified separately, the data used for this purpose are limited to your Ecovacs ID, and some other data bound with your Ecovacs ID including your Device model, the records for commands performed, warnings and tips once happened to your Device, your Device operation logs, and the work environment map generated by your Device.

(iii) We refer to the operational logs and the work environment map on your Device to supplement our user profiling on you and to optimize and personalize the content of the App accordingly. We will also customize our advertisements or third-party advertisements (displayed among the App content, by the notification pushes within the App or on the top page of your mobile device), and our direct marketing campaigns (sent to your email address as provided during the App account registration process) to suit such profiling. Please note that for profiling purposes, we refer to the evaluation of your tastes, preferences and consumption habits related to market surveys and statistical analysis. The processing for profiling purposes could take place with automated forms of processing.

With regard to any personal information collected by the Device owing to your commands or settings within the App, we will reasonably assume that they are performed by you, or by individuals from whom you have obtained full and valid consent or other legal grounds under the Law for us to collect, use, and transmit their personal information in strict compliance with this Policy.

Please kindly note that, if you choose to share control over your Device with an App account other than yours, the data collected from your Device during the control by another App account holder will also be recorded under the name of such App account.

Please note certain models of Ecovacs Device is equipped with a vision sensor and microphone to enable some product functions or services (please refer to the product manuals to know whether your Device has such functions, how to turn on / off such functions (if applicable)). The data we actually collect depends on the context of your interactions with Ecovacs and the choices you make (including your privacy settings), the products and functions you use, your location, and applicable laws. Function-specific sections below describe data collection practices applicable to use of those product functions or services.

(4) Voice Interaction System (not applicable to lawn mower robot)

If your Device is equipped with a Voice Interaction Systems, you can instruct your Device by using your voice. To recognize your commands, the Device relies on microphones that are active anytime. However, the Voice Interaction System is only “listening” after it recognized that you said “Okay, Yiko” (the “Signal Word”) and begins to record your command. As long as you did not say the Signal Word, the Device will ignore all sounds captured by the microphone. A flashing light and an acoustic signal indicate that the recording is in progress. The Device will not store any noise recordings without indication.

The Device is able to process certain commands locally and without a connection to the internet. In the event the Device does not understand the command, it transfers an edited version of the recording furnished with your unique Ecovacs User-ID to a cloud environment operated by us (the “Ecovacs Cloud”). The Ecovacs Cloud is hosted on Servers in the United States. To process the command, we apply a speech recognition system, which automatically converts your command into written text.

We use the voice recordings to make the Device execute your commands. In particular, we will neither make the voice recordings available to any third parties, if this is not necessary to deliver the Voice Interaction System to you nor try to determine, from whom the voice command comes from or to identify you by your voice”). The recordings are furnished with a unique ID to associate the recording with the correct user account/Device. From the Ecovacs Cloud the recordings including the identifier is further transmitted to Microsoft Azure for Automatic Speech Recognition (ASR) service. For some models of device, we also use Google Dialogflow for Natural Language Processing (NLP) and Text to Speech (TTS) services. The speech recognition system translates the voice recording into text and transmits the transcript back to the Ecovacs Cloud. The Ecovacs Cloud translates the text into a command and sends the command to the Device. If the Device does not recognize the command, the process will start again. If the device still does not recognize the command, the Device asks the user questions to identify the user’s wishes. The transcripts of your command will be stored in the Evovacs Cloud. Microsoft Azure is operated by Microsoft Corporation, 920 Fourth Avenue, Suite 2900, Seattle, Washington 95104, US (“Microsoft”). To provide the ASR services, Microsoft does not need to store your voice recordings, unless you opting in the “User Experience Improvement Plan for Voice Interaction System” and consent in using and storing your data to train the AI model. In this condition, Microsoft will be entrusted to store your data to train the AI models. Google Dialogflow is operated by Google Asia Pacific Pte. Ltd., 70 Pasir Panjang Road, #03-71, Mapletree Business City II Singapore 117371 (“Google”). Google stores the recordings and your data in datacenters located in USA.

The processing described in this section is necessary to provide you with the Voice Interactions System of your Device as part of our contractual arrangements. The Voice Interaction System is turned off by default. To use the Voice Interaction System, you are required to turn it on when you set up the device or at a later stage. You can turn off the Voice Interaction System in the Device controls. When you turned off the Voice Interactions System you may no longer be able to operate your Device with voice commands.

To improve the speech recognition, you can view the transcripts and give feedback on the accuracy of the recognition of your command. For the same purpose, if you participate in the “User Experience Improvement Plan for Voice Interaction System”, your transcripts and voice recordings will be transferred to China for manual review, analysis, annotation, AI model trainings, for better understanding of the Signal Word and voice commands, reduce the possibility of false activation and provide more accurate voice recognition services. This work may be conducted by Ecovacs employees or third party service suppliers who are working on Ecovacs’ behalf. In this condition, the voice recordings will be stored in the Ecovacs local server allocated in China. To ensure that your personal information is safe, we will take necessary and reasonable data protection measures when transferring your personal data outside your jurisdiction on the premise of providing appropriate safeguards in accordance with the legal requirements in your jurisdiction. The processing described in the “User Experience Improvement Plan for Voice Interaction System” relies on your explicit consent. This function is turned off by default. You can choose to opt in or opt out of this program freely by clicking the button “Settings-Privacy-Data Authorization Settings- User Experience Improvement Plan for Voice Interaction System” within the App.

(5) Object Recognition

In case your Device is equipped with a vision sensor, it is able to recognize obstacles around and thereby decide its work route during its operation. The vision sensor monitors the work environment of the Device and compares the obstacles it encounters against the objects in the database stored on the Device. The Device can only distinguish between different types of objects (e.g., whether the obstacle is a chair or a table). It does not enable the Device to tell one person from another.

Obstacle Recognition is executed locally on the Device. The footage taken by the vision sensor is in high resolution. It possibly involves the collection and processing of your personal information and might enable identification of individuals in the work environment, depending upon what is revealed in such photos/videos. To eliminate the possibility to identify a person appearing on the Device, the Device blurs the areas of the footage, where it detects the shape of a human body.

This information is necessary to provide you with the functionalities of the improved obstacle recognition to enable the Device to find the most efficient work route and to determine the areas already worked, insofar as the footage shows you as the user of the App. If the footage shows other persons (e.g., your family members or guests), it is necessary to pursue your legitimate interests to enjoy the best work results of your Device.

When you setup your Device, object recognition is turned off by default and your App will ask you, whether you want to use this functionality. You can change your settings and turn the object recognition on or off at your discretion by referring to Device Controls. Turning off the object recognition may impair the results and efficiency of the work routines of the Device.

The data is stored on the device side only. Only if the user turns on the “User Experiences Improvement Plan” and the data transmitted to the cloud. However, the personal information (human shape/face) contained in the pictures has been blurred out beforehand. This ensures that it is not possible to identify an individual.

If object recognition is turned on and the Device is unable to recognize an object, the Device will take a picture of the object, send it to your App and ask for your consent that the image will be sent to us in the People’s Republic of China for further processing. The transmission of the image to your App takes place via WiFi. If the Device recognized that the image shows a person, the Device automatically blurs the area showing the person. If you consented to sending the picture to us, we will try to identify the object by applying artificial intelligence technologies. Before the image is transmitted to us, you may also add remarks to it to help us identifying the object. Only if the artificial intelligence is also unable to identify the object, the image may be manually reviewed by employees from one of our affiliates located in the People’s Republic of China. We will then store the image in our database to train the artificial intelligence and further improve obstacle recognition. Information captured for obstacle recognition is only transferred to us in the aforementioned cases and after your consent. The processing of the images relies on your consent. In all other cases, the information captured by the vision sensor for obstacle recognition will neither be stored on the Device nor transmitted to us and/or your App.

(6) Real-Time Video Calls

For some models of the Device, you may be able to view through the App videos and sounds taken in a real-time manner and/or their records, in this case, your Device can act as a visual monitor. To make the footage available to you, regardless whether you are at home or not, the Device streams the footage to your App via the internet.

To make persons in the surrounding aware that this function is active, a signal light mounted on the Device starts blinking and an acoustic signal sounds regularly. If you are near the Device and you do not want to be monitored by the Device, you can abort the transmission by pressing a button on the Device. In some local areas, recording third persons’ voice or making videos of them could violate the law. Before you use this function, please make yourself aware that you use the Device in accordance with the local laws applicable in your area. Please familiarize any third parties who might appear on the footage (e.g., your family members or guests) that they may be recorded by the Device and how they can abort the transmission.

The transmissions of the voice recordings and/or the images is necessary to provide you with this functionality upon your request. If the images and/or the recordings are taken from you, processing this information is necessary for the fulfillment of the contractual relationship with you and if they are taken from somebody else, it relies on pursuing your legitimate interest to monitor your home. Please note that monitoring public areas may violate local laws applicable in your country and ensure that you use the function in line with your local requirements.

The voice function described in this article (6) is not applicable to lawn mower robot.

(7) Remote Camera

When your Device is equipped with a camera sensor, you may also instruct the Device to save the images captured by the camera sensor. This function only allows you to save footage presented to you when you use the Real Time Video Call function (Regarding lawn mower robot, this function only allows you to save images when using the video module to view the surroundings of the lawn mower robot, and to save images during Multi-Spot guarding). To make the pictures accessible to you via the App, they are stored in the Ecovacs Cloud. You may also download the pictures to the smartphone on which you installed the App for your further use. The pictures stored by the remote camera function will be saved until you request us to delete them, when your storage is full or when you cancel your App account.

Storing the images is necessary to deliver the remote camera function to you. If the images and/or the recordings are taken from you, processing this information is necessary for the fulfillment of the contractual relationship with you and if they are taken from somebody else relies on pursuing your legitimate interest to monitor your home.

(8) Security Alert and Spot Guarding (applies only to lawn mower)

Depending on your model, lawn-mowing robots may notify you when somebody enters the area of operation of the Device (“Security Alert”) or a specific area designated by you (“Spot Guarding Function”). If those functions are active, the Device constantly monitors the respective area. In case the Device detects an object, it analyses, whether the object is a human being. If the Device detects, the Device will take a picture of the person and send it with a push notification to your phone via the App. The Device is not able to recognize a specific person. It is technically it is possible that the monitored area exceeds the area of operation and/or your property. According to some local laws it could be prohibited to monitor public areas. Please make sure that you use the Device in line with local requirements applicable in your area. We will not use the information obtained for any other purposes than supplying the function to you and to pursue your legitimate interests to protect your property from trespassing.

(9) 3D Maps (not applicable to lawn mower)

Some Devices use laser technology to measure your home and compile 3D Models of your home and your furniture. From the 3D Models, the Device creates 3D Maps, including the layout of your home and the size and position of your furniture. The 3D Models will not be combined with images taken by the camera sensor and does not allow us to identify persons in the surrounding of the Device. You can view the 3D Maps in your App and correct errors in the 3D Maps or determine areas, where the Device should or should not clean. We only use the 3D Maps to make the cleaning routines of the Device more efficient and to make the areas that have already been cleaned apparent to you via the App. We retain the 3D Maps until they are overwritten by a newer version, the Device recognizes that it is used in a new home or you cancel your App account. 3D Maps is active by default and is necessary to operate the Device in your home. Without 3D Maps the Device would not be able to determine, which areas already have been cleaned or still need to be cleaned.

You may also add details of your furniture. Adding furniture details is voluntarily. Not adding furniture details does not influence the performance of the Device. We use the furniture details only, to pursue our legitimate interests to make your user experience of the App more comfortable and personal.

(10) Device Sharing.

The Device allows to be used and controlled over the App by more than one user, if this is enabled by the user who paired the App with the Device for the first time (the “Main Account Holder”), activated this functionality and invites further users to control the Device through their App (the “Sub Account Holders”). Both, the Main Account Holder and the Sub Account Holder are required to hold an App Account. If Device Sharing is activated and several users share the control over the Device, the Main Account Holder and the Sub Account Holder will be presented the email addresses of each other. This processing is necessary to offer you the Device Sharing functionality and to perform an existing agreement with you. If you are the Main Account Holder, please make sure that the Sub Account Holder agrees with receiving your invitation. The invitation for Device Sharing expires one week after the receipt. If you do not accept the invitation, the information about the invitation will be deleted after the expiry of the invitation period. The Main Account Holder will be provided with a list of the Sub Account Holders, who accepted the invitation including the date of Acceptance and the Sub Account Holder’s user name. Besides that, neither the Main Account Holder may access further information from the Sub Account Holders nor may the Sub Account Holders access information from the Main Account Holder or other Sub Account Holders. If you are the Sub Account Holder, please note that the Main Account Holder can withdraw your opportunity of Device Sharing anytime. In this case, you will no longer be able to control the relevant Device anymore or access the information stored therein. To operate the Device Sharing option, we use your email address, your App Account details and an identifier that connects your App with the Device. Using this information is necessary to deliver the Device Sharing function to you upon your request.

II. How we apply Cookie technology or Beacon technology

(a) How we apply Cookie technology to automatically collect information. To facilitate your use of the App or services provided by us, we may identify you through small data files, which may assist you in avoiding repeated input of your information or determining the safety of your App account. This data may include cookies, flash cookies, or other locally stored data provided by the operating system on your mobile device (collectively, the “Cookies”). Specifically, we use Cookies to collect SSID of Wi-Fi network you once searched in the App.

(b) How we apply Beacon technology to automatically collect information. To further understand your preferences with our products and services and to improve our services, our App may also insert some digital images (namely “single-pixel GIF file” or “Web Beacon,” collectively “Beacons”), in order to record your clicks at particular locations, such as in a subpage of the App.

(c) How to refuse to apply Cookie technology or Beacon technology. You can refuse or manage the settings of Cookies or Beacons through your web browser settings. However, please note that if you disable Cookies or Beacons, you may not have access to the best service experience and certain services, which will not affect the core functionality of our products and services.

III. How we store and protect your personal information

(a) Location for storing your data. Personal information collected and generated in the jurisdiction in which you reside in the course of providing our products and services to you will be stored in servers of Ecovacs located in the United States. Notwithstanding the foregoing, your data might be transferred to other jurisdiction as described in Chapter VII.

(b) Period for storing your data. We will only store your personal information for the period necessary to fulfill the purpose outlined in this Policy or required or permitted by applicable Laws. When assessing these periods, we carefully examine our needs to collect personal information at all as revealed herein, and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by the Law.

If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal information will be routinely anonymized or deleted in accordance with the statutory provisions. Unless otherwise required under relevant laws and regulations, if we stop the provision of services or business operation, we will promptly cease to collect your personal information, and also delete or anonymize your personal information collected by us for such purpose without delay. In a case where certain categories of your personal information become unnecessary to be collected or processed to achieve all the applicable purposes specified herein, we will also stop collecting the relevant personal information and/or anonymize or delete those have been collected. We will also give notice to you individually or by publishing the relevant information on our website or within the App.

(c) Management and policies concerning data security. We undertake to maintain information safety to the level as specified by the Law. In order to keep your data safe, we commit to apply various safety technologies and associated management systems to protect your data from being disclosed, destroyed or lost. We have further established access procedures and approval mechanisms to strictly control your personal information.

(d) Account Verification. In the process of using your App account, to protect your App account security, we may undertake different verification measures to identify you. For example, if your App account is logged on for the first time on a new Device, we may identify you by using your account passcode plus a check code sent to you by ways including, but is not limited to, a verification email.

(e) Reporting mechanism for personal information safety accidents. Please understand that due to limitation of technologies or potential malicious attacks, personal information safety accidents may unfortunately occur due to factors beyond our control. If a safety accident occurs, if required by the Law, we will immediately notify you of the general facts and potential influences of the safety accident, measures we have adopted or will adopt, advice for you to protect your data and reduce risks, as well as remedial measures, etc. We will inform you of the relevant facts of the accident by email, letter and telephone or by pushing notifications as per your settings on receiving communications from us. If it is impossible or difficult for us to contact every affected user individually, we will publish notifications in a reasonable and effective manner. We will also report the result of personal information safety accident to supervisory authorities if required.

IV. How we entrust, disclose, share and transfer your personal information

(a) Delegated processing and sharing in normal situations

If it is necessary for providing you with better or satisfactory products or services, we may engage third-party service providers to process your personal information or share your personal information with our affiliates or third-party service providers.

With regard to our affiliates, please note that we are part of a global operating group of companies running the ECOVACS HOME brand, which has multiple legal entities or affiliates across different jurisdictions. To be specific, among our affiliates, the research and development team, maintenance and customer service team supporting ECOVACS HOME brand will have access to your personal information and will conduct data processing on your personal information.

With regard to third-party service providers who can obtain and/or process your personal information in connection to the App, please refer to the Annex of this Policy for details. Categories of third-party service providers include fulfilling orders for products or services, delivering packages, sending postal mail and email, analyzing data, providing data collection, review and annotation for technology improvement, providing marketing assistance, providing search results and links, processing payments, transmitting content, and providing customer service. For example, we currently contract with cloud services providers to host the App and store data, to collect information about the crash history of the App and your usage behavior and to send push notifications. We undertake to require such service providers to abide by the Law and use your personal information only for the purposes listed in this Policy.

There are also cases where we are required to provide your personal information to the competent regulatory agencies pursuant to the Law, court orders, any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies. To the extent permitted by Law, information sharing under this circumstance does not require your prior authorization or consent.

(b) Delegated processing and sharing in Digital Advertising & Analytics

We may partner with advertising networks and other advertising serving providers (“Advertising Providers”) that may push advertisements on our behalf and others within the App or to your email account. Some of these advertisements may be personalized based on your user profiling. This type of advertising is known as interest-based advertising. We will distinct advertisements with an “ad” imprint on all advertisements for your ease of identification.

We involve Advertising Providers to identify advertising that might be of interest for you and/or for products that can be used with your Device and to present them to you and to analyze the effectiveness of our advertisements and your interactions with them. This information will not be used to identify you personally, but to analyze it in a pseudonymized way. This technology enables us to pursue our legitimate interests to present you advertisements that suit your individual interests and to perform direct marketing campaigns for our products and services to our customers.

You may opt-out from such personalized advertising in the App within your account interface by opting out all recommended display. Please note that electing to opt out will not prevent advertisements from appearing in your browser or applications. However, opting out will allow the advertisements pushed to you to be irrelevant to your interests. You may also opt-out of our sharing your information for advertisement or marketing purposes as instructed in this Policy.

(c) Control Transfer

With the ongoing development of our business, we may engage in transactions, including mergers, acquisitions and assets transfers, which may involve the control transfer of your personal information to other entities. We will notify you if such were to occur, and continue to protect or cause data ‑receiving parties to protect your personal information pursuant to the Law or, in each transaction as required by the Law and with no less than the standard as stipulated under this Policy.

(d) Public Disclosure

We will not disclose your personal information to the public. If a disclosure is needed, we will notify you of the purpose of such disclosure, the type of information disclosed, and the scope of any sensitive information (if any, as defined in the Law) involved, and then only to the extent permitted by Law.

V. Your rights: How to access and control your personal information

We aim to take reasonable steps to allow you to correct, amend, delete, know and access, Opt-out of sharing or limit the use of your personal information.

(a) Access to or correct your personal information. You may refer to our contact information listed at the top of this Policy to request access or to correct your personal information which is provided to us but contains errors. Such rights will not be affected by international transfer of your personal information. Before any access or correction starts, we may require you to provide some information in order to check and verify your identity as the App account owner.

(b) You have the right to data portability. You can request to obtain a copy of your personal information in a commonly used electronic format so that you can manage and move it. You will not be permitted to examine the Personal information of any other person or entity and may be required to provide us with personal information to verify your identity prior to accessing any records containing information about you.

(c) Refuse to receive promotion notifications. You may click on the “unsubscribe” button in emails sent by us or contact us through the information provided in the Policy to refuse to receive promotion notifications. You can also apply restrictions in the user setting interface to avoid receiving promotion notifications on the App end. Furthermore, you may also opt out of targeted advertising in the App within your App account interface by choosing to opt out, thus advertisements pushed to you would be irrelevant to your interests.

(d) Withdraw your consent other than promotion notifications, or to request us to delete your personal information in our storage. You are entitled to withdraw your previous consent to our collection, use or transmission to others, without affecting the validity of the actions and situation based on your prior consent. You may contact us to request the deletion of your personal information. Please note that you may not unsubscribe or refuse to receive any emails related to your App account (e.g., App account verifications, order confirmations, changes or updates of service functions, or notices regarding technology and safety, etc.) as long as you have not cancelled your App account, and related to the fulfilment in our existing contractual relationship. And, we may not accommodate a request to delete personal information if it would violate any law or legal requirement.

(e) Cancel your App account. You may initiate cancellation of your App account in your App account setting. Before the completion of the cancellation, we may require you to provide some information to verify your identity as the App account owner. You may also reach out to customer service in the App for assistance.

(f) Opt out of sharing. You may opt out of our sharing your data with a third party, by contacting us through the information provided in the Policy.

(g) Your other rights. If the applicable Law provides for your rights other than the above, you may contact us at any time by emailing us, clearly indicating the right you wish to exercise and attach the documents required for the identification verification process. You may also file a claim with the regulatory Data Protection Authority in your country.

VI. Security

We commit to take (or have taken) all reasonable measures to our best ability to safeguard the protection of the personal information through technical safety measures such as Secure Socket Layer (SSL) encryption access and an appropriate safety policy for our employees. The personal information are stored with us, or, if applicable, with the processor of the personal information, on servers housed in third-party cloud facilities using reasonable security measures.

To make sure your personal information is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company.

VII. Cross-border transfer of personal information

In principle, the personal information as collected and produced during our provision of relevant products and services is stored in our servers located in the United States. Since we provide products or services based on our resources and servers worldwide, your personal information might be transmitted to a jurisdiction or accessed from a jurisdiction outside of the country where you reside. Such destination jurisdictions include: (i) the jurisdiction where your personal information is stored (if it is the same as where you are located (cross-border transfer does not apply); (ii) China, where our registered office, our affiliates which are involved in ECOVACS HOME products and services and most of our service providers, are located, and when our employees need to have access to your personal information for handling your issues and also conducting general analysis; (iii) the storage location of some other service providers which serve you on behalf of us through their API/SDK integrated into the App, mostly at your local jurisdictions, or at the jurisdiction where their relevant branch resides to specifically serve your local jurisdiction; and (iv) some other jurisdictions from where your App account was once logged in, provided that the data storage location for such jurisdiction differs from your domicile country. Specifically, if you send to data-privacy@ecovacs.com an email, your personal information contained in such email and its delivery will be directed to China, where our email-box server is located. All such international transfers are made in connection by and between the relevant servers housed in third-party cloud facilities and physically located in such jurisdictions, and we will require third-party cloud suppliers to adopt appropriate safeguards in compliance with the Law.

VIII. Special provision relating to children

We take the privacy protection of children very seriously. We do not intend to serve any minors nor collect any personal information from minors. Specifically, we do not seek or knowingly collect personal information from children under the age of 13 (or the age as a child in your jurisdiction) without the consent of the child's parent or guardian. If you are under 16 years old (or you are a minor pursuant to the laws and regulations of the place in which you reside), we recommend you to ask your parents or guardians to read this Policy and use our services or provide your data to us with the prior consent from your parents or guardians. If your guardians do not allow you to use our services or provide your data to us according to this Policy, please stop using our services immediately and give a notice on time so that we can react accordingly. If, due to reasons out of our control such collection occurs, we will remove such information once we are notified ecovacs will keep personal information of minors confidential and safe in accordance with the relevant laws and regulations.

IX. Scope of and amendments to this Policy

This Policy applies to all customers and users of ECOVACS HOME products and services.

We may amend this Policy from time to time. If the clauses of this Policy are changed, we will show the amended privacy policy to you in the form of push notifications when you log in the App account or update your products or services. We may also contact you via your contact information on file, for example by email, notification or some other equivalent method.

You can find this Policy in the App and read it under “Me - Setting – About – User Agreement & Privacy Policy”. We encourage you check our privacy policy whenever you access our services.

Annex: Third Party List

1. Cloud Storage – AWS Cloud

l Operating company: Amazon Web Services, Inc. located in the United States

l Functions in support: Store and transmit various data collected from all our products and services; maintain the connection between your Device and your App account and Sub Account Holders (if any).

l What type of your information is accessed: All information we collect as revealed in the Policy.

l What permissions of your mobile device is sought: None

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://aws.amazon.com/privacy/?nc1=h_ls

2. Obstacle Recognition Service – Ali Cloud Video Service（only for DEEBOT T8 AIVI\T9 AIVI\OZMO 960）

l Operating company: Alibaba Cloud Computing Ltd. located in China

l Functions in support: Analyze and classify obstructions in the working environment where your Device is located, based on the functionality of the visual censor of your Device.

l What type of your information is accessed: Photos and videos captured and recorded by your Device.

l What permissions of your mobile device are sought: None

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-privacy-policy

3. Customer service –Zendesk

l Operating company: Zendesk, Inc. located in the United States

l Functions in support: Collect your communication records with us, your contact information other than email (if needed) and some other information required for handling your customer service requests. Set a cookie to measure the amount of pending and solved enquiries as well as our response times.

l What type of your information is accessed: Photos and videos uploaded to Zendesk platform through ECOVACS.

l What permissions of your mobile device are sought: “Notification” for push to the top page of your mobile device, “Camera” for taking pictures, and “Photos” for access to and uploading photos

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://www.zendesk.com/company/agreements-and-terms/privacy-notice/?_ga=2.214252756.273093329.1710397592-1728491643.1710397592

4. Notification Push Service – Apple

l Operating company: Apple Inc. located in the United States

l Functions in support: Push various kinds of messages within the App for iOS systems.

l What type of your information is accessed: Your Ecovacs ID.

l What permissions of your mobile device are sought: “Notification” for push to the top page of your mobile device; and “Storage” for downloading and installing new versions of the App.

l How to obtain information from our products and services: The installation of the App on your mobile device of iOS system. This service is integrated in the APP’s built-in SDK/API.

l Privacy notice of the third party: https://www.apple.com/legal/privacy/

5. Notification Push Service – Google

l Operating company: Google LLC. located in the United States

l Functions in support: Push various kinds of messages within the App for Android systems

l What type of your information is accessed: Your Ecovacs ID.

l What permissions of your mobile device is sought: “Notification” for push to the top page of your mobile device; and “Storage” for downloading and installing new versions of the App.

l How to obtain information from our products and services: The installation of the App on your mobile device of Android system. This service is integrated in the APP’s built-in SDK/API.

l Privacy notice of the third party: https://policies.google.com/privacy?hl=en

6. Voice Command Transcription – Google, Microsoft

l Operating company: Google Asia Pacific Pte. Ltd. located in Singapore

Microsoft Corporation located in the United States

l Functions in support: Microsoft Azure（ASR）and Google (NLP, TTS) services perform recognition to form language slots and data, which are compared with the corpus.

l What type of your information is accessed: Your vocal message after noise reduction, language slot and data (Which can correspond to your Device or App).

l What permissions of your mobile device is sought: None.

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party:

Google: https://policies.google.com/privacy?hl=en

Microsoft: https://go.microsoft.com/fwlink/?LinkId=521839

7. Local Noise Reduction – Baidu SDK, AI Speech

l Operating company: Beijing Baidu Netcom Technology Co., Ltd. located in China; AI Speech Technology Co., Ltd. located in China

l Functions in support: Vocal message noise reduction

l What type of your information is accessed: Your vocal message.

l What permissions of your mobile device is sought: None.

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://privacy.baidu.com/policy; https://www.aispeech.com/private

8. 85-Sixty

l Operating company: 85SIXTY, Inc. located in the United States

l Functions in support: Push messages for commercial promotion to the targeted customer with certain preferences for the Product.

l What type of your information is accessed: Email, Ecovacs ID, and Device model number.

l What permissions of your mobile device is sought: None.

l How to obtain information from our products and services: The installation of the App on your mobile device. This service is integrated in the App’s built‑in SDK/API.

l Privacy notice of the third party: https://www.85sixty.com/privacy-policy/

9. Klaviyo

l Operating company: Klaviyo, Inc. located in the United States

l Functions in support: Provide data analysis to 85-Sixty for the purpose of commercial promotion to the targeted customer with certain preferences for the Product.

l What type of your information is accessed: Email, Ecovacs ID, and Device model number.

l What permissions of your mobile device is sought: None.

l How to obtain information from our products and services: The installation of the App on your mobile device. This service is integrated in the App’s built‑in SDK/API.

l Privacy notice of the third party: https://www.klaviyo.com/legal/privacy/privacy-notice

10. Data Analysis – Sensors Data SDK (iOS system)

l Operating company: Sensors Data Network Technology (Beijing) Co., Ltd. located in China

l Functions in support: Data Analysis

l What type of your information is accessed: your Ecovacs ID, device serial number, the operation logs of your App account and your Device.

l What permissions of your mobile device is sought: “Internet” for SDK to send statistics; “Location” for SDK to collect GPS data.

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://www.sensorsdata.cn/market/privacy_policy.html

11. Data Analysis – Sensors Data SDK (Android system)

l Operating company: Sensors Data Network Technology (Beijing) Co., Ltd. located in China

l Functions in support: Data Analysis

l What type of your information is accessed: Your Ecovacs ID, device serial number, the operation logs of your App account and your Device.

l What permissions of your mobile device is sought: “Internet” for SDK to send statistics; “Access_Network_State” for SDK to decide whether to send data according to network status; “Read_Phone_State” used when using in-app promotion and collection of $carrier attributes; and “Access_Wifi_State” used when using in-App promotion.

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://www.sensorsdata.cn/market/privacy_policy.html

12. Payment service – Affirm

l Operating company: Affirm, Inc. located in the United States

l Functions in support: Payment service

l What type of your information is accessed: Your transaction information (order number, payment amount, payment method information, user name, billing and/or shipping address), verification information.

l What permissions of your mobile device is sought: None.

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://www.affirm.com/privacy

13. Payment service – Adyen (if applicable)

l Operating company: Adyen Japan K.K. located in Japan (only for users in Japan) and Adyen N.V. located in the Netherlands

l Functions in support: Payment service

l What permissions of your mobile device is sought: None.

l How to obtain information from our products and services: According to your commands or upon our instructions.

l Privacy notice of the third party: https://www.adyen.com/policies-and-disclaimer/privacy-policy