Privacy Policy

Preamble

"ToWell" (hereinafter referred to as the "App" or "Application") is a hardware and software integrated product provided by Houwei Technology (Hong Kong) Limited (hereinafter referred to as "we", "us", or "our Company").

Smart hardware devices refer to devices that can be controlled and managed within the App after being bound to it (hereinafter referred to as "Device(s)" or "Hardware").

We take user privacy very seriously. When you use our products and services, we may collect and use your relevant information. We hope this Privacy Policy explains how we collect, use, store, and protect this information when you use our services, as well as the methods we provide for you to access, update, control, and protect this information.

This Privacy Policy is highly relevant to the services you use from our Company. Please read it carefully before using the APP, and only use our products and services after confirming your full understanding and agreement.

1. How We Collect and Use Your Information

1.1 Information You Provide to Us

We will collect and use your personal information in accordance with this policy. For example, when you register an account, we will ask you to provide personal information such as your email address and phone number, which will be stored under your account. If you wish to fully utilize the various third-party sharing or login functions we provide, we may also need to obtain some information allowed by your third-party accounts, including third-party account IDs and avatars. Other information such as log information, local storage information, capturing photos/videos/audio, WiFi information, reading or modifying storage, etc., the specific purposes and uses for collecting and using this information are described below. We will use compliant technology to encrypt and store the information you explicitly consent to, protecting the security of your personal information.

1.2 Purpose and Use of Information We Obtain During Your Use of Services

We collect information about the services you use. The purpose and use of such information include:

Log Information
When you use our services, we automatically collect certain information and store it in server logs or write it to the phone's external storage. This information includes:
- When errors or exceptions occur while the application is using the service.
- When the application crashes during operation, we write error logs to external storage, and users can choose whether to send them to us.
Local Storage
- Screenshots and video recordings taken by the user are stored on the phone's external storage.
- Data caching during application operation and user data are stored in a database for local storage.
Location Information
- Obtain the list of WiFi networks at your location.
- To enable the smart hardware device to connect to the WiFi network you select.
Reroute Outgoing Calls
- Some special devices can call the mobile phone (user) to initiate a video call request. At this time, the application needs to perceive the incoming and outgoing call status of the phone, and hang up the external video call request when there is an incoming or outgoing call.
Audio Recording
- When the application receives a video call request from another device, it needs to send data collected by the microphone to the device.
Read, Modify, or Delete USB Storage Contents
- When viewing camera data, the application allows users to capture images and save them in the phone's storage medium, and view the saved content within the application.
View Network Connections, Change Network Connections, and Full Network Access Permissions, Read Phone WiFi SSID, BSSID
- The application needs to read network information when configuring the network for the camera to connect the camera to the WiFi.
Software Installation List
- Check if third-party sharing or payment applications are installed, and launch the third-party application when the user uses functions like video sharing or payment.
Device MAC Address Information, Network IP Address Information, Device OAID, AndroidID
- Determine if the smart hardware and the phone are on the same local area network, and for device uniqueness identification.
Phone IMEI, CPU Architecture, Phone Model, System Version Information, Device Serial Number (SN)
- When you contact us with feedback or questions, we may obtain this type of information to help quickly locate and resolve your issue.
- Diagnose and resolve device compatibility issues.

1.3 Device Startup Instructions

Self-startup Instructions
- To ensure that the scheduled notifications and reminder functions you set can be executed normally after the device restarts, this application needs to register for the system boot completion broadcast. When you agree to this Privacy Policy and use the notification function, the application will self-start upon device boot to restore all preset scheduled notifications.
- You can turn off the self-start permission for this application at any time in the device's [Settings] - [App Management] - [Self-start], but this will cause all scheduled notifications to fail after the device restarts.

Associated Startup Instructions
- This application manages background tasks through the WorkManager framework and may associate and start related service processes in specific scenarios to ensure the accuracy of scheduled notifications.

1.4 Details of Device Permission Calls

Device Permission	Corresponding Business Function	Purpose of Permission Call	Requested?	User Can Disable?
Location Permission	Add Device function, assists in binding between App and smart hardware	Obtain the list of WiFi networks at your location to enable the smart hardware device to connect to the WiFi network you select	Yes	Yes
Storage Permission	Recording, screenshot, playback download functions on the monitoring interface	Local storage on the phone of videos and images captured by the smart hardware device	Yes	Yes
Camera Permission	QR code scanning in Add Device, Share with Friends function, assists in binding App and smart hardware	Add and share smart hardware devices by scanning QR codes	Yes	Yes
Microphone Permission	Intercom function on the monitoring interface	Intercom calls	Yes	Yes

2. How We Store Your Personal Information

We only retain your personal information for the period necessary for the purposes described in this Privacy Policy and as required by laws and regulations. We use various security technologies and procedures to prevent loss, improper use, unauthorized access, or disclosure of information. For example, in some services, we use encryption technology (e.g., SSL) to protect the personal information you provide. However, please understand that due to technical limitations and potential malicious means, it is impossible to always guarantee 100% security of information in the internet industry, even with our best efforts to strengthen security measures.

3. How We Share, Transfer, and Disclose Your Personal Information

3.1 Sharing

We do not share your personal information with any company, organization, or individual, except in the following circumstances:
1. With your explicit consent, we may share your personal information with others.
2. We may share your personal information as required by laws and regulations, for litigation dispute resolution, or as requested by administrative or judicial authorities according to law.
3. To the extent permitted by laws and regulations, where necessary to protect the interests, property, or safety of ToWell's affiliates or partners, you or other users, or the public from damage.
4. Sharing among affiliated companies: When our affiliates provide services to you or us, we may share your personal information with our affiliates. However, we only share necessary personal information, and the processing of your information by affiliates is subject to this policy. If an affiliate wishes to change the purpose of processing your information, it will seek your authorization and consent again.
5. Sharing with partners: We will only share necessary personal information (or the SMS or call numbers you report), or aggregated information, anonymized information, or other information that does not identify you personally (for example, we may inform application developers how many people have installed their applications) with our suppliers, service providers, advisors, agents, third-party advertisers, application developers, open platforms, or other partners for legitimate, proper, necessary, specific, clear purposes as stated in this policy and with your explicit authorization and consent, in order to provide better customer service and user experience. These suppliers, service providers, advisors, and agents may provide us with technical infrastructure services, analyze how our services are used, measure the effectiveness of advertisements and services, provide customer service and payment services, conduct academic research and surveys, or provide legal, financial, and technical advisory services. For example, we may occasionally invite you to participate in lucky draws. If you are lucky enough to win, we need to provide your personal information to logistics service providers to send you prizes or arrange for partners to provide services. All our partners are not authorized to use the shared personal information for purposes unrelated to the product or service.
For companies, organizations, and individuals with whom we share personal information, we sign strict data protection agreements requiring them to process personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.
Third-party SDK Partners and Shared Information Description
To ensure the realization of application-related functions and the stable and secure operation of the application, we may integrate software development kits (SDKs) provided by third parties to achieve related purposes.

Third-Party Name	SDK Name	Purpose of Use	Function Type	Personal Information Involved	Privacy Policy Link
WeChat Open Platform	WeChat Open Platform SDK	Provide third-party login and sharing services, provide third-party payment services	Payment, Quick Login, Sharing	None	Link10
Alipay Open Platform	Alipay Open Platform SDK	Provide third-party payment services	Payment	None	Link13
Xiaomi Push	Xiaomi Push SDK	Provide message push service	Alarm Message Push	The SDK will collect your device identifier OAID and encrypted Android ID, as well as application information such as application package name, version number, and running status of the application using the push service, to provide timely alarm message push services.	Link14
Huawei Push	Huawei Push SDK	Provide message push service	Push	Unique device identification code	Link2
Hangzhou Admobile Information Service Co., Ltd.	ADmobile Suyiad SDK	1. Use ADmobile's ad aggregation service to aggregate multiple ad platforms for monetization. 2. Ad delivery cooperation	Advertising	1. [Device Information]: System version name, system version number, device model, resolution, screen DPI, device manufacturer, network type, system language, timezone, timestamp, User Agent information, screen orientation; 2. [Application Information]: Current application package name, application version name, application version information. 3. [Device Identifier Information]: Device ID (android_id), IMEI (collected with user authorization), IMSI (collected with user authorization), OAID, Mac address, IDFA. 4. Geographic location information (collected with user authorization), advertising interaction data.	Link3
Beijing Jutui Engine Network Technology Co., Ltd.	Pangle	Ad delivery cooperation	1. Adjust ad delivery strategy based on user device information; 2. Analyze ad behavior (such as ad loading, display, clicks, etc.) based on user device information.	[Required Information] (Information necessary for your cooperation with Pangle.) Device Information: [Android]: Device brand, model, software system version related information, OAID, device ID (android_id), resolution, screen DPI, device manufacturer, network type, system language, timezone, timestamp, User Agent information, screen orientation, sensor information and other basic information. [iOS] Device brand, model, software system version related information, phone system reboot time, total disk memory space, number of CPUs, system language, timezone, timestamp, User Agent information, screen orientation, network type, IDFA, IDFV, sensor information and other basic information. Application Information: Developer application name, application package name, version information. Other Information: Carrier information, device timezone. [Optional Information] [Android] Wireless network SSID name, WiFi router MAC address (BSSID), device MAC, device IMEI, IMSI, device geographic location. - Only applicable to iOS versions below 2800: Clipboard calls: OpenUDID optional information acquisition (obtained by calling the clipboard and used for ad delivery and anti-fraud). App crash monitoring (implemented by calling the clipboard, used to monitor whether the SDK causes APP instability or other abnormal running states). The above calls are only used for necessary scenarios related to ad delivery and anti-fraud, and will not obtain private information. - Only applicable to iOS versions below 3200. [iOS] Wireless network SSID name, WiFi router MAC address, device MAC address.	Link15
Shenzhen Tencent Computer Systems Co., Ltd.	Tencent Gromore (优量汇)	Ad delivery cooperation	1. Adjust ad delivery strategy based on user device information; 2. Analyze ad behavior (such as ad loading, display, clicks, etc.) based on user device information.	1. [Device Information]: System version name, system version number, device model, resolution, screen DPI, device manufacturer, network type, system language, timezone, timestamp, User Agent information, screen orientation, sensor information and other basic information; 2. [Application Information]: Current application package name, application version name, application version information. 3. [Device Identifier Information]: Device ID (android_id), IMEI (collected with user authorization), OAID, Mac address, IDFA. 4. Geographic location information, advertising delivery data.	Link11
Guangzhou Guomen Information Technology Co., Ltd.	Unad	Ad delivery cooperation	1. Adjust ad delivery strategy based on user device information; 2. Analyze ad behavior (such as ad loading, display, clicks, etc.) based on user device information.	1. [Precise Location] and [Approximate Location]: If the user authorizes location permission, we will collect location information for ad delivery and monitoring attribution. Media can disable SDK location permission collection via API. 2. [Device ID Device ID]: When the application is granted ad tracking permission by the user, Unad will obtain OAID/GAID/IDFA/IDFV for ad attribution and tracking.	Link4
Tencent Bugly	Bugly SDK	Record APP crash logs to facilitate troubleshooting of hidden bugs in the APP	Troubleshoot crash issues, help improve APP stability	Android system collection: Phone model, phone brand, Android system version, Android system API level, manufacturer system version, CPU architecture type, whether the device is rooted, disk space usage, SD card space usage, memory space usage, network type, process name and PID currently running by the application, device hardware serial number, IMEI, IMSI, MAC address, Android ID. iOS system collection: Device model, operating system version, operating system internal build number, WiFi status, CPU attributes, free memory space, disk space/free disk space, runtime phone status (memory occupied by processes, virtual memory, etc.), IDFV, whether jailbroken, region code, device serial number.
Tencent QQ Connect	QQ Connect SDK	QQ Quick Login	QQ Quick Login function	Please refer to the QQ Connect Privacy Policy.	Link7
China Academy of Information and Communications Technology	Mobile Security Alliance OAID	Obtain OAID	Mobile Security	SDK collects locally, does not involve data sharing.	Link16
Shanghai Beizi Network Technology Co., Ltd.	BeiZi	Ad delivery cooperation	1. Adjust ad delivery strategy based on user device information; 2. Analyze ad behavior (such as ad loading, display, clicks, etc.) based on user device information.	[Information Common to Android and iOS] Device brand, device model, device timezone, device language, system version, developer application name, application version number, application package name, network type, UserAgent information, network status, crash information, performance data, screen height and width, screen orientation, screen DPI information, system update time, boot time, approximate location (collected with user authorization), precise location (collected with user authorization), battery level, USB debugging mode, number of base stations, carrier, CPU. [Android Specific Information] Device ID (OAID, GAID) (IMEI collected with user authorization). [iOS Specific Information] Device ID (IDFA collected with user authorization), IDFV. Information Accessed (But Not Collected) Sensor information (e.g., gravity sensor, acceleration sensor, orientation sensor, gyroscope, light sensor, pressure sensor, gravity sensor, linear acceleration sensor, etc.), swipe gesture content. Permissions Requested [Android] Access the internet, network status, phone WiFi status, install applications. [iOS] Network permissions, device information (IDFA).	Link17
Youmeng Tongxin (Beijing) Technology Co., Ltd. (Umeng+)	Umeng SDK	Statistical Analysis	Statistical Analysis	Device information (phone SN code/ICCID/IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/IP address/SIM card IMSI information, etc.), location information, network information.	Link12
Vivo Mobile Communication Co., Ltd.	VIVO Push SDK	Provide message push service	Push	Device identifier information (such as IMEI, EmmCID, UFSID, ANDROIDID, GUID, GAID, OPENID, VAID, OAID, RegID, encrypted Android ID).	Link1
Guangdong Heytap Technology Co., Ltd.	OPPO Push SDK	Provide message push service	Push	Device identifier information (such as IMEI, EmmCID, UFSID, ANDROIDID, GUID, GAID, OPENID, VAID, OAID, RegID, encrypted Android ID).	Link5
Youmeng Tongxin (Beijing) Technology Co., Ltd. (Umeng+)	Umeng Push SDK	Provide message push service	Push	Device identifier information (such as IMEI, EmmCID, UFSID, ANDROIDID, GUID, GAID, OPENID, VAID, OAID, RegID, encrypted Android ID).	Link12
Beijing Zhangshang Leyou Co., Ltd.	Fusion SDK	Ad delivery cooperation	1. Adjust ad delivery strategy based on user device information; 2. Analyze ad behavior (such as ad loading, display, clicks, etc.) based on user device information.	Enable wireless data: You can connect to a wireless network or enable cellular data to achieve the internet connection function required by this software; Read phone information: Read hardware serial number, device MAC address, unique device identifier (IMEI, OAID, AndroidID, IDFA, IDFV, UUID, SIM card IMSI information), sensor information, etc., for precise ad delivery and anti-fraud; Access local storage: Enable local storage permission to cache advertising materials; Access GPS permission: Obtain location for precise ad delivery;	http://ag.wanzjhb.com/OcrPrivacy.html
Beijing Meishu Information Technology Co., Ltd.	Meishu Information Technology SDK	Ad delivery cooperation	Advertising Promotion	Basic information such as device brand, model, software system version, screen density, screen resolution, device language, device timezone, available storage space size, etc., phone system reboot time, total disk space, total system memory space 【Android only】CPU information 【iOS only】IDFV 【Android only】AndroidID, OAID, wireless network SSID name, WiFi router MAC address (BSSID), device MAC address, device identifiers (such as IMEI, IMSI, GAID (GMS service only), MEID, specific fields may vary depending on hardware and software version) 【iOS only】Device identifiers (such as IDFA, specific fields may vary depending on hardware and software version) IP address, carrier information, Wi-Fi status Application package name, version number, application foreground/background status Software list information	https://wwww.atdplus.cn/html/privacy-policy/Meishu-Privacy-Policy.html

3.2 Transfer

We will not transfer your personal information to any other company, organization, or individual, except in the following circumstances:
1. As our company's business develops, we and our affiliated companies may undergo mergers, acquisitions, asset transfers, or other similar transactions. If such transactions involve the transfer of your personal information, we will require the new holder of your personal information to continue to be bound by this policy. Otherwise, we will require that company, organization, or individual to re-obtain your authorization and consent.
2. To comply with the requirements of laws and regulations, legal procedures, mandatory government requirements, or judicial rulings.
3. Transfer with your explicit consent, meaning that after obtaining your explicit consent, we will transfer your personal information that we have already obtained to other parties.

3.3 Disclosure

We will only publicly disclose your personal information under the following circumstances:
1. We have obtained your explicit consent.
2. Where required by law, legal proceedings, litigation, or mandatory requirements of government authorities, we may disclose your personal information.
3. To the extent permitted by laws and regulations, where necessary to protect the interests, property, or safety of ToWell (Hopeway)'s affiliates or partners, you or other users, or the public from damage.
4. Other circumstances stipulated by laws and regulations.
According to legal provisions, sharing or transferring de-identified personal information, and ensuring that the data recipient cannot restore and re-identify the personal information subject, does not constitute sharing, transferring, or public disclosure of personal information. The storage and processing of such data will not require separate notification to you or your consent.

4. Your Rights to Manage Your Personal Information

4.1 Access and Correct Your Personal Information

You can access and correct your account information, including account password, nickname, etc., by visiting the account information section within the application.

4.2 Delete Your Personal Information

You have the right to request that we delete your personal information under the following circumstances:

1. We collected your personal information without seeking your explicit consent.
2. Our processing of your personal information violates legal and regulatory requirements.
3. We violated our agreement with you in using and processing your personal information.
4. You have deregistered your account, uninstalled, or no longer use our products (or services).
5. We have stopped providing services to you.

You can contact us using the methods provided in this Privacy Policy to request the deletion of your personal information. We will respond within 15 working days. After we delete your personal information from our servers, we may not immediately delete the corresponding data from the backup system, but will delete this information when the backup system is updated.

4.3 Deregister Your Personal Account

Please log in to our APP to deregister your account and delete your personal account information. The operation path is as follows: 【Me】-【Avatar】-【Deregister Account】
After receiving your account deregistration (deletion) request, our system will complete the account deregistration process within 7 working days. After that, you will not be able to log in using the deregistered account, and the information associated with your account will be deleted.

5. How We Handle Minors' Personal Information

We attach great importance to the protection of minors' personal information. We do not use age recognition as a prerequisite for providing products or services to users, but the nature of our products and/or services requires you to be an adult with full civil capacity. If you are a child or another minor under the age of 18, we require you to ask your parents or other guardians to read this Privacy Policy carefully and to use our services or provide information to us only with the consent and under the supervision of your parents or guardians. If you collect or submit minors' personal information to us through our products and/or services for purposes such as interacting with children, you must ensure that you have obtained prior authorization and consent from their legal guardians.

6. Changes and Revisions to the Privacy Policy

Our Privacy Policy may change. We will not restrict the rights you are entitled to under this Privacy Policy without your explicit consent.

For major changes to this Privacy Policy, we will also provide prominent notice (for example, by displaying a pop-up when the APP is updated or upgraded, or when you log in again).

Major changes referred to in this policy include but are not limited to:

1. Major changes in our service model. Such as the purpose of processing personal information, the types of personal information processed, and the manner of using personal information.
2. Major changes in our control, etc., such as changes in ownership due to mergers, acquisitions, or restructuring.
3. Changes in the main parties with whom personal information is shared, transferred, or publicly disclosed.
4. Major changes in your rights regarding the processing of personal information and how you can exercise them.
5. Changes in the department responsible for the security of personal information processing, contact methods, and complaint channels.
6. When a personal information security impact assessment report indicates high risks.

7. How to Contact Us

If you have any questions, comments, suggestions, or complaints regarding our Privacy Policy or the processing of your personal information, please contact us through the following methods.

Contact Email: ms-user@houwei-tech.com

Under normal circumstances, we will respond to your request within 5 working days.

8. Effectiveness of the Privacy Policy

This policy version was updated on September 8, 2021, and will take effect on September 8, 2021.