Privacy Policy

CGSmartHome Mobile Application Privacy Policy

Effective as of: October06, 2021

 

CGSmartHome mobile application Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data (as hereinafter defined) we process through your use of our services (for instance, products, the CGSmartHomeMobile Application (the “App”) (collectively, the “Services”).

Before you start using the Services, please carefully read this Policy which details our purposes for collecting and processing your Personal Data, as well as how we use, store, share and transfer your Personal Data. In this Policy you will also find ways to exercise your rights of access, update, delete or protect your Personal Data.

If you have any question regarding this Policy, please do not hesitate to contact us via:

CG Privacy Office: iot@chaudharygroup.com      

You are not obliged to provide to us your Personal Data (as defined below). However, we may be unable to provide you with certain products and/or Services if you decline to provide such data.

By submitting your personal data to us you will be treated as having given permission –where necessary and appropriate –for disclosures refer in this policy. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THIS SITE, THE APPLICATION OR THE SERVICES.

The Privacy Policy may be updated and changed from time to time. CGSmartHome reserve the right to make changes to this Privacy Policy as required.

 

 

WHAT PERSONAL DATA DO WE COLLECT?

To provide the Services to you, we will ask you to provide necessary Personal Data that is required to provide those Services. If you do not provide your Personal Data, we may not be able to provide you with the Services. The personal data collected from you shall be kept confidential and will not be shared with third party without your consent.

However, if the Services you request or purchase are based on your account, please go to the registration/login page for guidance.

 

1. INFORMATION YOU VOLUNTARILY PROVIDE TO US

Account Data: When you register an account with us, we may collect your account name and contact details, such as your email address, phone number, username, and login credentials. During your interaction with the Services, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.

We collect and stores the personally identifiable information such as your name, address, telephone number, email address, or company name, that you voluntarily provided to us when you register with our Site or App or when you contact us or when you participate on various schemes, sales promos or various activities related to the site like chatbots and message boards

We may collect non-personally identifiable information such as your IP address, your browser type, your operating system, your access times and the pages you have viewed directly before or after accessing the Site or it can be demographic information, such as your age, location, gender or interests, when you access our Site or application.

 

Feedback: When using feedback and suggestion features in the Services, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

 

Information based on additional functions:

To offer you with more convenient and higher-quality Services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:

a)            Additional functions based on location information:

When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Device, or b) non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details. You may disable the collection and use of your location information by managing the device level settings, upon which we will cease to collect and use your location information. 

 

b)            Additional services based on camera:

You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.

 

c)            Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):

You can use this function to upload your photos/pictures/videos after turning on the photo album permission, to realize functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.

 

d) Additional services related to microphone-based service:

You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognize your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App.

 

e) Additional services based on storage permissions:

The purpose is to ensure the stable operation of the App by utilizing the storage permission. After you give or indicate the permission to read/write your mobile device’s storage, we will access pictures, files, crash log information and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.

Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect previous collection and use of information based on your authorization.

 

2. INFORMATION WE COLLECT AUTOMATICALLY

Mobile Device Information: When you interact with our Services, in order to provide and maintain the common operation of our services, improve and optimize our service, and protect your account security as well, we automatically collect device information, such as mobile device model number, IP address, wireless connection information, operating system type and version, mobile hardware serial number (a unique mobile identifier, which is a string representing the device manufacturer coded in the mobile device), Android ID, application version number, push notification identifier, log files, and mobile network information.

 

Usage Data: During your interaction with CGSmartHome or and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our websites and Services.

 

Log Information: When you use the App, the system and exception log may be uploaded.

 

Please note that one cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate and desensitize such information.

 

3. SMART DEVICES RELATED INFORMATION:

Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

 

Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with the Services, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or videos captured by it. Particularly, when you proactively consent to the Services connecting with third party Health platform to enable the fundamental feature for you (such as Apple Health, Google Fit, Fitbit, etc.), we will share your health data (exclusively to your BMI, height, weight, and body fat%) with them for the sole purpose of measuring and analyzing heath related indicators about you. We will not disclose such health data to any other third party. You may disconnect the Services with third party Health platform at any time by managing your health settings on your mobile device.  

 

PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

The purpose for which we may process information about you are as follows:

 

Provide You Services: We process your account data, device information, usage data, location information, and Smart Device related information to provide you with the Services and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our User Agreement. Your right to privacy ensured under the Constitution of Nepal shall be respected and shall not be shared with any third party without your consent.

 

Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our User Agreement.

 

Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, we will also send you notifications related to the services you have purchased, such as alert services. You can check the “App Notification” in the App (“Me > Settings on the upper right corner > App Notification > Notification Setting”) to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such purpose. The legal basis for this processing is to perform our contract with you according to our User Agreement.

 

Data Analysis: In order to analyze the usage of the products we provide and improve your user experience, we will analyze the data you provide us, a) we need to check your problems when you encounter any malfunctions during the usage of the product, under such circumstance, you may not able to opt-out because it is highly relate to your functionalities and quality of using our product and service, and b) analyze data about how you interface with the product or under particular scenarios so that you can better enjoy the convenience brought by our Services, under such circumstance, if you do not agree to data analysis of your data, you can enter the privacy settings of CGSmartHomeApp (“My > Settings at the upper right corner > Privacy Settings > Data Analysis”) to opt-out your selection. The legal basis for such processing is based on your consent.

 

Personalization: We may process your account data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of the Services. If you do not allow us to process your Personal Data for personalization, you may opt out when you enter the App, or by changing your preferences in “Privacy Settings” (“Me> Settings at the upper right corner > Privacy Settings > Personalization” in the App. The legal basis for this processing is your consent.

 

Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on the Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. If you do not agree to CGSmartHome sending you marketing communications, you may opt out when you enter the App, or by changing your preferences in [Privacy Settings] of the App. The legal basis for this processing is your consent.

 

Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to complies with a legal obligation, process, or request enforces our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof protects the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or detects, prevent, or otherwise address security, fraud, or technical issues.

 

If there is any change in the purposes for processing your Personal Data, we will inform such change to you with a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

               

WHO DO WE SHARE PERSONAL DATA WITH?

At CGSmartHome, we only share Personal Data in ways that we tell you about obtaining your consent. We do not sell your Personal Data to third parties. Without your consent, we will not disclose your Personal Data to third-party companies, organizations, or individuals except in the following cases:

 

•   To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us. If you purchase or download an item from a site, we may share your data in order to provide the item to you. In addition, if you email us a question, we may use your email address to process your request and respond to your question. In addition, if you purchase a product via the Sites, we may need to share your data with third parties in order to have that product delivered to you and installed as you requested. Also, if you are entering a competition or prize draw, we may use your data in order to fulfill the terms of that promotion.

•   To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the data for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Sites will have access to users' data, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any Personally Identifiable Information to us. If you choose to make a purchase on the Sites, we may forward you to our affiliates and sister concerns

  • To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our websites and Services.
  • To subsidiaries or affiliates within our corporate family for purpose of regular business activities based on our instructions and in compliance with applicable law, this Privacy Policy and other appropriate confidentiality and security measures.
  • To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, and choices you may have regarding your Personal Data.

As we believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:

(a)     Comply with applicable law, regulation, legal process, or lawful governmental request.

(b)    Enforce our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof.

(c)     Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.

(d)    Perform risk management, screening and checks for unlawful, fraudulent, deceptive, or malicious activities.

 

DATA TRANSFER

Personal Data may be transferred, stored, and processed outside of the country or region where it was initially collected. Also, the applicable laws in the countries and regions where we operate may differ from the laws applicable to your country of residence. Under the Personal Data protection framework and to facilitate our operation, we may transfer, store, and process your Personal Data in jurisdictions other than where you live.

If you would like further details on the safeguards, we have in place under the data transfer, you can contact us directly as described in this Privacy Policy.

 

DATA SUBJECT RIGHTS

We respect your rights and control over your Personal Data. You may exercise any of the following rights:

Via the “Me > Settings > Account and Security” or via “Me > FAQ&Feedback” in the Services or by emailing us at iot@chaudharygroup.com

If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may:

  • Request access to the Personal Data that we process about you.
  • Request that we correct inaccurate or incomplete Personal Data about you.
  • Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you.
  • Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated.
  • Object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:

1)    For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notification settings and other related functions.

2)    You may opt-out the data analysis features through “Me > Settings at the upper right corner > Privacy Settings”.

3)    You may opt-out the Personalization feature through “Me > Settings at the upper right corner > Privacy Settings > Personalization”.

4)    Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected.

When you withdraw your consent or authorization, we may not be able to continue to provide you with certain products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.

 

About Deletion of the Account: You can find the Delete function through “Me > Settings at the upper right corner > Account and Security > Delete Account”.

SECURITY MEASURES

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. CGSmartHome provides various security strategies to effectively ensure data security of user and device.

As for device access, CGSmartHome proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization.

As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported.

As for data processing, strict data filtering is applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing iot@chaudharygroup.com.

 

DATA RETENTION

We process your Personal Data for the minimum period necessary for the purposes set out in this Policy unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we may destruct your Personal Data.

 

DISPUTE RESOLUTION

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please write us at iot@chaudharygroup.com.

 

No indemnification

We shall have no obligation to indemnify any person in connection with any matter related to or arising out of this Policy or the subject matter of this Policy except for any willful misconduct adjudicated by the competent court.

 

CHILDREN’S PRIVACY

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of Eighteen (18) (or such other age provided by applicable law in Nepal), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information.

 

CHANGES TO THIS POLICY

We may update this Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes, we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

 

 

CONTACT US

If you have any questions about our practices or this Policy, please contact us as follows:

 

CG Impex Pvt. Ltd.

IOT/IT Department for CGSmartHome

Postal Mailing Address: Chandragiri Municipality – 10/11, Kathmandu, Nepal

Email: iot@chaudharygroup.com.