Version release and effective date: 2024/02/26

【Special Note】
This privacy policy is applicable to the products and services provided by Shenzhen ShuYe Innovative Technology Co., Ltd. and its affiliated companies (including, but not limited to Dongguan Laifen Electronic Technology Co., Ltd., hereinafter referred to as "we" or "Laifen") and the products and services provided by them, including the Laifen APP, websites, clients, mini-programs, and various future products and services provided to you due to technological developments (hereinafter referred to as "Laifen Services"). If a specific product provided by us has a separate privacy policy or corresponding user service agreement with special provisions, the privacy policy of that product will take precedence. For content not covered by the privacy policy of that product or the user service agreement, this policy will apply. If our affiliated companies' products or services use Laifen's products or services without setting up a separate privacy policy, this privacy policy will also apply to that part of the product or service.
Please carefully read this "Privacy Policy" (especially the bold content) and make sure you understand our rules for handling your personal information. If you have any questions while reading, you can contact us using the contact information in this "Privacy Policy."
Please read and understand this "Privacy Policy" carefully before using our products or services.
Introduction
Welcome to Laifen! We highly value the privacy and protection of the personal information of our users. Through this "Privacy Policy," we aim to explain to you how we collect, use, store, share, and transfer this information when you use our products and/or services. Additionally, we will outline how we provide you with access, updates, deletion, and protection of this information.
This privacy policy will help you understand the following:
1. How we collect and use your personal information.
2. How we share, transfer, and publicly disclose your personal information.
3. How we handle the personal information of minors.
4. How your personal information is transferred globally.
5. Notifications and revisions.
6. How to contact us.

[1] How we collect and use your personal information.
1.1Personal information that we collect and use with your authorization
Personal information is collected in order to provide you with products and/or services as well as to ensure legal compliance on our part with applicable laws, regulations, and other regulatory documents. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our products or services or respond to your queries. Features and services that may need to collect your personal information include:
1.1.1 Connecting smart devices
In order to provide you with Laifen services and allow you to securely connect to and manage smart devices, we may collect your  location information, account sign-in information, and information related to your email or phone, smart devices. This information will be used to provide you with features including pairing with and connecting to smart devices, discovering nearby devices, and device management. In detail:
- Smart devices connected via Bluetooth: MAC address of Bluetooth on the device, location information and device ID.
- Mobile phone-related information: Hardware-based identifiers (MAC address, Android ID), phone model, system version, system language, country or region, App Store version, screen size and resolution, CPU, and display-related information.
- we may collect the following for Bluetooth-connected smart devices: Bluetooth information (SSID, BSSID), device MAC address, and device ID.
1.1.2 Account Registration and Login
To register for Laifen services, you are required to provide your email address or phone. In order to verify your identity, we will send an verification code to your email address or phone. Your account name will be automatically set as your default nickname. You can update your nickname information in the "Account" section of the Laifen app. 
After completing registration, you can use your Laifen account information to log in. If you do not provide this information, you will not be able to log in and use our products and/or services.
1.1.3 Smart scenes (smart device connections)
We provide support for you to configure specific rules to establish connections between devices under specific conditions, thereby creating smart scenes. To provide this feature, we may collect your location information, smart scene rule configurations, and designated device status. This allows specific device functions to be executed according to the commands you give. An example would be allowing a light to turn on whenever a sensor detects someone passing by. Please rest assured that this feature won't be turned on without your express consent and rule configurations.
1.1.4 App and smart device updates
To ensure you can continue enjoying the latest Laifen services, we may use the version information of your Laifen app and phone model in order to provide you with updates to the app. We may also collect a list of your connected smart devices and associated version information in order to provide you with smart device updates, including firmware updates.

1.2 Other Rules for Using Personal Information 
Furthermore, when you use the Laifen App, you may trigger the following device permissions. To help you manage your information more effectively, we will provide you with clear information about the purpose of each permission we ask for during the use of our product. We will also explain how your use of our service may be impacted if you choose not to enable a specific permission. You can also change authorization status at any time through the device's permission settings page or in the "My - Settings - System Permission Management" page within the Laifen app.
The details of relevant functions and permission requests are as follows: 
1. Read and Write Device Storage Permission (Android version): Used for reading and writing photos and files on the device in functions such as changing avatars and storing photos.
2. Album Permission: Used for operations such as reading, modifying, and deleting photos in the album.

If we plan to use your personal information for purposes not outlined in this privacy policy or intend to use collected information differently, we will obtain your explicit consent in advance.
For functions and scenarios not explicitly addressed in this privacy policy, we will present the relevant rules for personal information collection and use when you use that specific function or scenario and obtain your explicit consent.

1.3 Non-personally identifiable information
We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service, such as including clicks, page redirects, and browsing time. The purpose of such collection is to improve the services we provide to you.

Laifen recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Laifen makes available for you to choose to restrict the collection, use, disclosure, or processing of your personal information and control your privacy settings: Allow or deny location access and camera,  and other access permissions on your phone;
- Modify personal information such as your nickname or profile picture;
- Turn connections between smart devices on or off;
- Sign in or out of the Laifen Account.

[2] How we share, transfer, and publicly disclose your personal information
2.1 Sharing
We will not share your personal information with any company, organization, or individual outside of Laifen, except in the following cases: 
1. Sharing with Explicit Consent: After obtaining your consent, we may share your personal information with other parties. 
2. In Response to Legal Process: We may share your personal information with third parties in accordance with legal requirements, litigation, dispute resolution needs, or mandatory requests from government authorities or judicial bodies. 
3. To Protect You and Ourselves: Within the scope permitted or required by law, to protect the interests, property, or safety of Laifen, its users, or the public, we may provide your personal information to third parties. 
4. Sharing with Our Affiliated Companies: We may disclose the information we collect from you to our affiliates or subsidiaries. We will only share the necessary information, and it will be subject to the purposes stated in this privacy policy. If the affiliated companies intend to change the processing purposes of personal information, they will seek your authorization and consent once again.
5. We do not sell any personal information to third parties. To help us provide you with products and services described in this Privacy Policy, we may, where necessary, share your personal information with our third-party service providers and business partners. Laifen will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. The location-based services component of our services is provided by third party providers including AutoNavi. In order to offer you location-based services, we may provide information such as your device identifier information to any of these service providers. If we share your personal information with such third parties, we will take appropriate measures to ensure the security of the processing of your personal information, including but not limited to the encryption of your personal information. We will reasonably examine the data security environment of the companies and organizations with which we share personal information and sign data processing agreements with them. We will require third parties to take sufficient measures to protect your information and strictly abide by the relevant laws and regulations as well as regulatory requirements.

2.2 Public Disclosure
We will only disclose your personal information publicly in the following situations:
1. After obtaining your explicit consent.
2. Based on legal requirements: In cases where legal procedures, litigation, or mandatory requests from government authorities require us to disclose your personal information.

2.3 Exceptions
According to the relevant laws and regulations, in the following circumstances, we may collect, share, transfer, or publicly disclose your personal information without obtaining your authorization:
1. When it is directly related to national interests such as national security and defense
2. When it is directly related to major public interests such as public safety, public health, and public awareness.
3. When it is directly related to criminal investigation, prosecution, trial, and judgment enforcement.
4. When it is necessary to protect your or other individuals' significant lawful rights and interests, but it is difficult to obtain the person's consent.
5. When it is necessary for the signing and performance of contracts at your request.
6. When it is necessary for the safe and stable operation of the provided products or services, such as the discovery and handling of product or service malfunctions.
7. When it is necessary for conducting statistics or academic research for public interests, and when providing the results of academic research or descriptions externally, the personal information contained in the results is de-identified.
8. When it is collected from information legally disclosed to the public, such as legal news reports and government information disclosures.
9. In other circumstances as provided by laws and regulations.

2.4 Responding to Your Requests
1. To ensure security, you may need to provide a written request or other proof of your identity. We may ask you to verify your identity before processing your request. We will respond within 15 days.
2. For your reasonable requests, we generally do not charge a fee. However, for repeated or excessive requests beyond a reasonable limit, we may charge a certain cost. Requests that are unwarranted repetitions, require excessive technical efforts (such as developing new systems or fundamentally altering existing practices), pose risks to the legitimate rights of others, or are highly impractical (such as those involving information stored on backup tapes) may be refused.
3. In accordance with legal and regulatory requirements, we may not be able to respond to your requests in the following situations:
1. When directly related to national security and defense security.
2. When directly related to public safety, public health, or major public interests.
3. When directly related to criminal investigation, prosecution, trial, and judgment enforcement.
4. When there is sufficient evidence of your subjective malice or abuse of rights.
5. When responding to your request would cause serious harm to your or other individuals' or  
          organizations' legitimate rights and interests.
6. When it involves trade secrets.

2.5 Cancellation of Services or Accounts
If you wish to cancel a specific product or service, you can contact us at huanghao@laifen.net to initiate the service cancellation process. If you are sure you wish to cancel your Laifen account, please note that cancelling your Laifen account will result in the inability to use Laifen products and services.

[3] How we handle the personal information of minors
(1) Our products, websites, and services are primarily intended for adults. Minors under the age of 14 may not create their own user accounts without the consent of their parents or guardians. If you are a minor under 14 years old, before using our products and/or services, please make sure to read this policy in the presence of your guardian and ensure that you have obtained explicit consent from your guardian before using our services and providing us with your personal information.
(2) For cases where the personal information of minors is collected with the consent of parents, we will only use or disclose this information in cases allowed by law, with clear consent from parents or guardians, or in cases necessary for protecting the rights and interests of minors.
(3) If your guardian does not agree to your use of our services in accordance with this policy or providing personal information to us, please immediately cease using our services and promptly notify us.

[4] How your personal information is transferred globally
We will, in accordance with applicable laws and regulations, store personal information collected within the People's Republic of China within its territory. However, because we provide products or services through a network of global resources and servers, this means that, with your authorization, your personal information may be transferred to overseas jurisdictions in the country/region where you use the product or service or accessed from those jurisdictions.
Such jurisdictions may have different data protection laws, or they may not have relevant laws in place. In such cases, we will ensure that your personal information receives protection equivalent to that provided within the People's Republic of China. For example, we may request your consent for the cross-border transfer of personal information, or implement security measures such as data de-identification before transferring data across borders.

[5] Notifications and Revisions
1. In order to provide you with better services and to keep pace with the development of Laifen's business, this privacy policy will be updated accordingly. However, without your explicit consent, we will not reduce the rights you are entitled to under this privacy policy. We will notify you of updates by releasing updated versions on the Laifen website, and mobile application, and by reminding you of the updated content through website announcements or other appropriate means before the updates take effect. We also encourage you to visit Laifen's website to stay informed about the latest privacy policy.
2. For significant changes, we will provide more pronounced notifications. We will notify you of the specific changes to the privacy policy through methods including but not limited to email, text messages, or special notices on web pages, explaining the details of the changes.
Significant changes referred to in this privacy policy include but are not limited to:
(1) Significant changes in our service model, such as the purposes of personal information processing, types of personal information processed, and the way personal information is used.
(2) Significant changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy, mergers, and acquisitions, etc.
(3) Significant changes in the main entities with whom personal information is shared, transferred, or publicly disclosed.
(4) Significant changes in your rights and the methods for exercising them in relation to the processing of personal information.
(5) Significant changes in the department responsible for personal information security, contact information, and complaint channels.
(6) When the personal information security impact assessment report indicates a high risk.

[6] How to contact us
If you have any questions, opinions, or suggestions regarding this privacy policy, please contact us through the following means:
Data Protection Officer's Email: huanghao@laifen.net
Company Name: Shenzhen Shuye Innovation Technology Co., Ltd.
Registered Address: 1301, Office Building T7, Kerry Business Center, No. 399 Qianwan 1st Road, Qianhai Shenzhen-Hong Kong Cooperation Zone, Nanshan, Shenzhen, China
Contact Address: 1301, Office Building T7, Kerry Business Center, No. 399 Qianwan 1st Road, Qianhai Shenzhen-Hong Kong Cooperation Zone, Nanshan, Shenzhen, China
Upon receiving your feedback, we will promptly review the issues involved and respond within 15 days after successfully verifying your user identity. If you are dissatisfied with our response, especially if our handling of personal information has harmed your legitimate rights and interests, you can also file a complaint or report to regulatory authorities such as the Cyberspace Administration (CAC), Telecommunications Administration (MIIT), Public Security (PSB/PSD), and Industry and Commerce (SAIC).