PRIVACY POLICY

Effective 15 December 2022: Please take a moment to familiarize yourself with our new privacy policy. This Privacy Policy can provide privacy details on how we manage your personal information for Xiaomi Kids software and services provided by Xiaomi.

OUR COMMITMENT TO YOU

This Privacy Policy sets out how Xiaomi Inc. and its affiliated companies within the Xiaomi Inc. ("Xiaomi", "we", "our" or "us") collect, use, disclose, process and protect any information that you give us when you use Xiaomi Kids software and services. Should we ask you to provide certain information by which you can be identified when using Xiaomi Kids software and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to Xiaomi.

In this Privacy Policy, "personal information" means information that can be used to identify an individual, either from that information alone or from that information combined with other information Xiaomi has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, device information, etc.

By using Xiaomi Kids software and services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation, we will specifically seek prior explicit consent to the particular processing (e.g. automated individual decision-making) of special categories of personal data. We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact our Data Protection Officer at https://privacy.mi.com/support to address your specific concerns. We will be happy to address them directly.

This privacy policy will help you understand the following:

1. What information is collected and how we can use it

2. With whom we share your information

3. Security safeguards

4. Retention policy

5. Accessing other features on your device

6. You have control over your information!

7. Transfer of personal information outside of your jurisdiction

8. Miscellaneous

9. Do I have to agree to any third party terms and conditions?

10. Contact us

WHAT INFORMATION IS COLLECTED AND HOW WE CAN USE IT

TYPES OF INFORMATION COLLECTED

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

· Mobile terminal information of connected devices: When your child's device is bound to mobile terminals such as mobile phones (hereinafter referred to as "mobile terminals" or "mobile phones"), we will collect information related to the mobile terminals, including device model, device name, system version number, Android id, and IDFA.

· Access to mobile phone storage permission: When you use group chat or private chat to insert photos in your mobile phone album and access your mobile phone album when you modify your watch head image, we need to obtain mobile phone storage permission to access your mobile phone album; At the same time, we will use this permission to store photos after setting the security area.

· Basic information of children: basic personal information about your children provided by you, including nickname, head portrait, height and weight.

· Device information: information related to your child's device, including watch IMEI number, watch serial number (SN), watch MAC address, watch Bluetooth MAC address, watch power, firmware version number, and application version number.

· Network information: the current connection mode of the device to Wi Fi (LAN mode, remote mode), the IP address assigned by the device, the name of the connected Wi Fi, the strength of the Wi Fi signal, the strength index of the received Wi Fi signal (i.e. device RSSI), the name of the connected Bluetooth, the strength of the Bluetooth signal, the MAC address of the router, and the Wi Fi account and password that you or your children actively provide to us. For your or your child's Wi Fi password, we will encrypt it and then store and transmit it. If you and your children do not provide such information, it will affect your children's use of Wi Fi related functions, but will not affect the use of other functions.

· Device setting information: the setting information of your child when using the device, including positioning mode, sleep period, timing boot time, class anti disturbance function setting information, automatic answering setting, alarm clock setting, reminder mode setting, clock format setting, firmware setting (including firmware automatic update switch setting, firmware update switch setting under WiFi), screen brightness setting, and screen lighting time setting.

· Voice information: When your children use the intelligent voice interaction function, we may collect voice command information by recording audio through hardware.

· Communication and call related information: we will collect the network operator, SIM card number (watch number), IMSI number, watch mobile signal value, mobile phone call status, mobile phone call number, address book ("family member list", including friends' nicknames, watch numbers, friends list), call log, white list switch Chat message (voice, text, expression, picture, video of communication between mobile phone and device), SMS white list switch. Please rest assured that your chat information will be encrypted and stored in the server; We will not read your chat messages.

· Photo information: We will collect the photos and videos taken by your children using the device, the time of shooting, and save them locally for viewing at any time.

· Location information: We will collect the current geographic location information of devices and mobile terminals, as well as the specific location and scope of the security area (home and school).

· Feedback information: we may collect the types of problems encountered in use, problem logs, contact information and feedback content provided by your children.

· Other information: We may also collect other types of information which are not directly or indirectly linked to an individual and which is aggregated, anonymized or de-identified. For example, the device model and system version number of the user’s Xiaomi device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

HOW THE PERSONAL INFORMATION IS USED

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies, Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

· Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.

· Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices.

· Analyzing and developing statistical information on use of our products and services to better improve our products and services.

· Optimizing the performance of your device.

· Storing and maintaining information about you for our business operations or legal obligations.

· Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information):

· Verify the uniqueness of the device: When you bind the watch for the first time, the device unique ID and firmware version of the hardware will be used to verify the uniqueness of the device. The above information will also be used to update the system or software, restore factory settings.

· Judge whether the mobile terminal can run with the app: At present, the Xiaomi Kids application can only run on specific operating systems and specific mobile terminals. To do this, we need to detect your mobile terminal information.

· Provide location-based services: When you use location-based program services or functions, we will collect the geographic location information of your children's devices and/or mobile phones to view your children's current location and footprints online or in real time (report every 20 seconds); You can view the distance between your current location and the device location, and also initiate navigation; The geographical location information can also show you the current weather on the device. When your children come in and out of the safe area you set, we will send you a notice to protect your children's safety. The Wi Fi information you provide will also be used to improve the positioning accuracy of the watch.

· Providing communication and call functions: We collect information about communication and call to provide communication and call related functions for you and your children. For example, you can call your child by dialing the SIM card number of the device; You can also set up a white list to protect your children's safety; We collect your chat content, address book information, nicknames, and avatars to provide you with a device to phone chat service. Please rest assured that your chat information will be encrypted and stored in the server; We will not read your chat messages.

· Add friends function: your children can add watch friends, for which we will collect their watch nickname and SIM card number information.

· Step counting function: we collect step counting information to show you the sports details of you and your children. You can view them in daily view or weekly view; You can also view your child's step ranking. To do this, we need to collect step count information, children's height and weight (used to calculate calories).

· Collect user feedback: The feedback you choose to provide is extremely valuable to help improve our service. In order to track the feedback you choose to provide, Xiaomi may use the personal information you provide to contact you and keep records.

WITH WHOM WE SHARE YOUR INFORMATION

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that Xiaomi will only share your personal information in accordance with your consent. Your consent to Xiaomi will engage sub-processors for the processing of your personal information. You should know that when Xiaomi shares your personal information with a Third Party Service Provider under any circumstance described in this section, Xiaomi will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Xiaomi will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

SHARING WITH OUR GROUP AND THIRD PARTY SERVICE PROVIDERS

In order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other Xiaomi affiliated companies, or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, and Xiaomi’s representatives. Such Third Party Service Providers would be processing your personal information on Xiaomi’s behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this information, please contact us at https://privacy.mi.com/support.

After-sales, push, troubleshooting and other service provider: After-sales, push, troubleshooting and other services for the product are provided by Xiaomi .

SHARING WITH OTHERS

Xiaomi may disclose your personal information without further consent when required under applicable law.

INFORMATION NOT REQUIRING CONSENT

We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

For the avoidance of doubt, Xiaomi may collect, use or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws. Such disclosure may be brought about by the necessity to protect our rights, ensure the safety of you and other people, and comply with the requirements of the local government to facilitate the investigations of illegal activities.

SECURITY SAFEGUARDS

XIAOMI’S SECURITY MEASURES

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect from your using of Xiaomi products and services and on Xiaomi websites. We will use all reasonable efforts to safeguard your personal information.

For example, when you access your Mi Account, you can choose to use our two-step verification process for better security. When you send or receive data from your Xiaomi device to our servers, we make sure they are encrypted using Secure Sockets Layer ("SSL") and other algorithms.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

WHAT YOU CAN DO

· You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you. Whenever you log in as a Mi Account user on Xiaomi websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.

· Xiaomi cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.

· Your assistance will help us protect the privacy of your personal information.

RETENTION POLICY

Personal information will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by Xiaomi even if the further processing is incompatible with original purposes.

All the personal information on the device will be erased when you reset your device to factory default settings. To implement a hard-reset function, you can click "My - Watch management - Unpair" in Xiaomi Kids app. Beware that hard-reset can’t be undo, so you have to make sure that you don’t need the information any more.

ACCESSING OTHER FEATURES ON YOUR DEVICE

Our applications may need access to certain features on your device such as Wi-Fi network status. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at https://privacy.mi.com/support.

YOU HAVE CONTROL OVER YOUR INFORMATION!

CONTROLLING SETTINGS

Xiaomi recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Xiaomi makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

· On the app Locate page, click the "Locate" button at the bottom left corner to turn on/off the location access function of the mobile terminal;

· Click "Path" in the lower right corner of the app Locate to view historical footprints;

· Click "My Baby Information" on the app to query and modify basic information such as nickname, avatar, height and weight;

· Click "My - Watch management - Location mode" on the app to select the frequency of the device reporting the geographical location;

· Click "My - Watch Management - Unpair" on the app to unbind the device and delete all your data locally and stored on our server. When you or we assist you in deleting relevant information, because of applicable laws and security technologies, we may not be able to delete the corresponding information from the backup system immediately. We will safely store your and your children's personal information and isolate it from any further processing until the backup can be cleared or anonymous;

· Click "My - About/More - Permission management" on the app to authorize/revoke watch&mobile phone permissions. When you revoke the corresponding permission, app&Watch cannot use the corresponding function;

· Click "My - About - Watch legal information - Privacy Policy" on the app to view the privacy policy of your bound watch;

· Click "My - More - App legal information - Privacy Policy" on the app to view the app privacy policy;

· Click "My - About - Watch legal information - Privacy Policy" on the app, and click "Third Party data sharing instructions" in the document to view the third party data sharing instructions.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or submitting a request to https://privacy.mi.com/support.

ACCESSING, UPDATING, CORRECTING OR ERASING YOUR PERSONAL INFORMATION

· You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

· A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

· If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please submit a request to https://privacy.mi.com/support.

· For details relating to the personal information in your Mi Account, you may also access and change them at https://account.mi.com or by logging into your account on your device.

· You may also log in to Mi Account (https://www.mi.com/global/) and enter “privacy” module, where you could delete the data generated by web apps and services as well as permanently delete your account along with the data associated with it. If you would like to delete the data generated by smart device, please submit a request to https://privacy.mi.com/support.

WITHDRAWAL OF CONSENT

You may withdraw your consent for the collection, use and/or disclosure of your personal information in our possession or control by submitting a request to https://privacy.mi.com/support. In the Xiaomi Kids app, you could also go to "My - More - App legal information - Withdraw consent to Xiaomi Kids app Privacy Policy" to revoke authorization. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.

Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy Xiaomi Kids software and services.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF YOUR JURISDICTION

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by Xiaomi for this transfer of your personal information

Xiaomi may use overseas facilities operated and controlled by Xiaomi to process or back up your personal information. Currently, Xiaomi has data centers in Singapore and Russia. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. We may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

In particular,

Personal information collected and generated in our Russian operations will be processed and stored in a data center located in Russia, except for cross-border transmission permitted by Russian law.

If we need to transfer personal information outside your jurisdiction, whether it is our affiliates or third-party service providers, we will comply with relevant applicable laws. We ensure that all such transmissions comply with applicable local data protection laws by implementing uniform safeguards. You can contact us at [ https://privacy.mi.com/support ] to learn about our existing safeguards.

MISCELLANEOUS

ORDER OF PRECEDENCE

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

UPDATES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the Xiaomi websites or through our software, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products and services offered by a third party. Xiaomi products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to Xiaomi's collection, use, or disclosure of your personal information, please contact us via https://privacy.mi.com/support or at the address below. When we receive privacy or personal information requests about accessing or downloading personal information, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information.

If you are not satisfied with the response you received from us in relation to your personal information, you can hand over the complaint to the relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.

Xiaomi Communications Co., Ltd. #019, 9th Floor, Building 6, 33 Xi'erqi Middle Road, Haidian District, Beijing, China 100085

Xiaomi Singapore Pte. Ltd. 20 Cross Street, China Court #02-12 Singapore 048422

For users in India:

Xiaomi Technology India Private Limited Building Orchid, Block E, Embassy Tech Village, Outer Ring Road, Devarabisanahalli, Bengaluru, Karnataka - 560103, India

Any discrepancies and grievances with respect to processing of sensitive personal data or information shall be informed to the designated Grievance Officer as mentioned below:

Name: Vishwanath C

Telephone: 080 6885 6286, Mon-Sat: 9 AM to 6 PM

Email: grievance.officer@xiaomi.com

For users in the European Economic Area (EEA):

Xiaomi Technology Netherlands B.V. Prinses Beatrixlaan 582, The Hague 2595BM Netherlands

Thank you for taking the time to read our Privacy Policy!