Privacy Agreement

Privacy Agreement
Version update date: January 3, 2025
Version effective date: January 3, 2025

1. Introduction
Your personal information protection is very important for TWS Technology (Guangzhou) Limited and its subsidiaries and branches (hereinafter referred to as "us"/"the company"). This privacy policy outlines the types of personal information we collect when using the APP and how we use and protect this personal information. We will process these personal information in accordance with the relevant laws and regulations of the People's Republic of China on personal information protection, especially the Personal Information Protection Law, Cybersecurity Law, and Data Security Law.
For the purposes stated in Section 2.1 of this Privacy Policy, we need to collect, use, transmit, store, and/or otherwise process your personal information. These individuals include the personal information about you contained in various forms and documents of this system, as well as any other personal information you provide, we own, we obtain, have collected or are currently collecting. If you do not wish us to use your personal information in accordance with the provisions of this privacy policy, please do not provide us with your personal information. However, please note that in this situation, you may not be able to use our related services, you may not be able to access and/or use certain functions of this system and related apps, and you may not be able to manage your battery devices. After carefully reading and understanding the entire content of this privacy policy, please decide whether to authorize us to process your personal information and agree to assume the relevant rights, obligations, consequences, and responsibilities arising therefrom.
Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy shall have the following meanings:
Personal information: Various information related to identified or identifiable natural persons recorded electronically or in other ways, excluding anonymized information.
Sensitive personal information: Personal information that, once leaked or illegally used, can easily lead to the infringement of a natural person's personal dignity or endanger their personal and property safety, including biometric, religious beliefs, specific identities, medical and health information, financial accounts, whereabouts, and personal information of minors under the age of fourteen.
The functional scope of this system may continue to expand and adjust based on technological advancements and the development of the company's business.
Affiliated companies refer to companies, enterprises, and other economic organizations that have one of the following relationships with the company: (1) direct or indirect ownership or control relationships in terms of funds, operations, purchases, and sales; (2) Directly or indirectly owned or controlled by a third party; (3) There is a significant influential relationship between the two parties.

2. How do we collect and use your personal information
We will follow the principles of legitimacy, legality, and necessity to collect and use various personal information provided by you voluntarily or by third parties authorized by you when using the various functions of this system, as well as personal information automatically generated by this system, for the purposes described in this policy. If we want to use your personal information for other purposes not specified in this privacy policy, we will inform you in a reasonable manner and obtain your consent again.
2.1 We will collect and use your personal information in the following business scenarios.
When you register and log in to your personal account, you provide us with an email account so that we can provide you with support and services related to the APP when necessary.
In order to manage user login behavior, we need to record your login information, including everyone, login name, and password.
We do not require you to provide us with any other personal information or sensitive personal information unless specifically required by law in certain circumstances. If you voluntarily provide us or our partners with other personal information or sensitive personal information through this system by uploading document materials, image materials, video materials, etc., it means that you hereby expressly agree to collect and process these data in accordance with this privacy policy and relevant information.
2.2 Ways We Collect Personal Information
We mainly obtain your personal information directly through this system. If you decide to provide us with your personal information by filling in documents and forms of this system, or by providing us with your personal information through your electronic communication terminal or Internet browser, we will directly or indirectly obtain your personal information. Some personal information may also be automatically generated from this system, such as the user ID used to create a user for you. If you entrust your installer or distributor to create an account on your behalf, we will obtain your account information, such as username, email, country/region, time zone, and password, through the installer or distributor authorized by you. We ensure that your personal information is processed in accordance with the processing purposes specified in Article 2.1 of this Privacy Policy, and within the necessary scope to achieve the processing purposes.

3. The legal basis for our processing of personal information
In most cases, we obtain your consent before conducting personal information processing activities. However, in the following situations, we may process your personal information without your prior consent:
Necessary for the conclusion and performance of contracts to which individuals are a party, or for the implementation of human resource management in accordance with legally established labor regulations and collective contracts signed in accordance with the law;
Necessary for fulfilling legal duties or obligations;
Necessary for responding to sudden public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;
Implementing news reporting, public opinion supervision, and other behaviors for the public interest, and processing personal information within a reasonable range;
Other circumstances stipulated by laws and administrative regulations.

4. Personal Information Policy for Minors
Our services are aimed at both minors and adults.

5. Storage and Term of Personal Information
We strive to take appropriate technical and organizational measures to minimize the risks associated with the processing of personal information, particularly accidental or illegal destruction, loss, alteration, unauthorized disclosure or access, transmission, storage, or other processing of personal information.
However, no system is absolutely secure, please understand that there are no "perfect security measures" on information networks. Even if we make great efforts, it is still possible that we may not be able to prevent illegal access to your personal information. In addition, due to the inability to determine the truthfulness of others' statements, we may be misled by unreliable, misleading, or illegal information. Once such an event unfortunately occurs, we will also notify you of the event and its possible impact in accordance with relevant laws and regulations, and provide you with information on measures that can be taken when necessary.
Unless required by laws, regulations, and regulatory requirements or allowed for longer storage periods, we will only retain your personal information for the necessary period to achieve the purposes stated in this privacy policy (including the requirements for litigation or audit procedures). Once we no longer need your personal information, we will immediately delete it. In some cases, we may irreversibly anonymize your personal information so that it is no longer associated with you. In such cases, we may use such personal information without further notice to you.
We use the following criteria to determine whether your personal information needs to be stored:
Achieve service objectives related to you, maintain corresponding service and business records, and respond to your possible business needs;
Ensure the safety and quality of the services we provide to you;
Do you agree to a longer retention period;
Are there any other special agreements or legal provisions regarding retention periods.

6. How do we share, transfer, and publicly disclose your personal information
6.1 Sharing or Authorized Access to Personal Information
We will only share your personal information with our affiliated companies or partners, third-party service providers, or authorize them to access it in the following situations:
Based on the needs of company operation and management activities, conducting related business, and fulfilling the contract with you, we share or authorize access to your personal information with our affiliated companies.
Share with the client to provide corresponding services, such as providing your personal information to cloud storage service providers for data storage services.
We may need to disclose your personal information in accordance with legal regulations, legal procedures, litigation, and/or requirements from your location and foreign public and government agencies.
In addition, in order to protect our rights, seek available remedies, enforce our user agreement, investigate fraud, or protect our business and users, we may also disclose your personal information if we honestly determine that disclosure is reasonable and necessary.
If we share or authorize access to your personal information with third parties for purposes other than those mentioned above, we will obtain your separate consent. You can choose to refuse not to provide your personal information to third parties.

6.2 Transfer of Personal Information
We will not transfer your personal information to any third-party companies, organizations, or individuals unless:
Obtain your explicit consent. Transfer your personal information to the recipient after being informed in accordance with the law and obtaining your explicit consent.
If personal information transfer is involved due to company merger, division, dissolution, bankruptcy liquidation or other reasons, we will inform and require the recipient to continue to comply with this privacy policy in accordance with the law. Otherwise, we will request the recipient to obtain your consent again.

6.3 Public Disclosure of Personal Information
In principle, we will not publicly disclose your personal information unless one of the following conditions is met:
Obtain your separate consent.
Fulfill legal obligations or comply with regulatory requirements: If there are mandatory requirements from laws, regulations, or regulatory authorities, we may publicly disclose your personal information.

7．How to transfer your personal information across borders
In general, we will process your personal information within China, but we may also transfer (or share, authorize access to) necessary personal information related to your personal information covered by this privacy policy to our legal entities located outside of China or other countries/regions where our authorized partners are located based on business needs. We may also transfer (or share, authorize access to) your personal information to other countries/regions as necessary for the performance of labor contracts/service contracts (or other contracts to which you are a party), or with your prior separate consent, or due to government regulation, judicial assistance requirements, etc. The personal information protection laws in these countries/regions may vary.
No matter where these personal information are processed, we will fulfill our legal obligations for cross-border transmission of personal information and take all reasonable and necessary measures to ensure the security of your personal information. We will take appropriate measures to ensure that the protection of personal information by overseas recipients meets the same standards as in China. For example, we will enter into contracts with overseas recipients in accordance with Chinese laws, regulations, and relevant standards, and conduct security assessments organized by the national cyberspace administration when conditions are met.

8．System permissions and permission management
You understand and agree that during the use of the system, we will apply for access to your system as necessary (specific permissions may vary depending on the device model and system version you are using), which involves the collection and use of personal information. The specific permissions are as follows: After you agree to enable camera permissions, you can use this app to scan QR codes to connect to the battery's Bluetooth and obtain operational data of the battery product.. After you agree to enable file management permissions, you can use this app to save the operational data and log files of TWS brand battery products on your phone's file system. After you agree to enable Bluetooth permission, you can use this app to connect TWS brand battery products via Bluetooth and obtain operational data of the battery products through Bluetooth communication. Before granting permission, we will inform you of the purpose of granting permission and seek your consent. If you do not agree, we will not grant the relevant permission and will not be able to provide you with the services corresponding to that permission. You can disable specific system permissions in the relevant options under system settings or disable specific feature permissions on your device. However, your decision to disable permissions will not affect the collection and use of personal information previously conducted based on your authorization. If we want to use your personal information for other purposes not specified in this privacy policy or collect additional personal information not mentioned, we will obtain your consent through page prompts, pop ups, or other means in accordance with the law.

9. Your rights and exercise methods
9.1 Your Rights and Interests
As a personal information subject, you have the right to be informed and make decisions regarding the processing of your personal information. You have the right to restrict or refuse the processing of personal information by others, access and copy your personal information, transfer your personal information to the personal information processor designated by you, and correct, supplement, or delete your personal information. If you have any questions about our privacy policy, you can also request an explanation from us.
9.2 Ways of exercising rights
You can contact us through the contact information disclosed in this privacy policy or through the "Feedback" function, and we will provide you with feedback on the processing results within 15 days.
If you are not satisfied with our response, especially when our personal information processing behavior damages your legitimate rights and interests, you can also file a lawsuit or file a complaint with relevant regulatory authorities through external channels for resolution.
To ensure safety, you need to provide a written request or prove your identity in other ways. We usually process your request after you have verified your identity.

10. Cookies and similar technologies
10.1 What is a cookie?
Cookie, Identifier and related technologies are widely used in the Internet industry. We or our third-party partners may collect your personal information by placing secure cookies, identifiers, and related technologies in order to provide you with a better user experience and service. We will not use cookies for any purposes other than those stated in this Privacy Policy and the Cookie Policy of our system.

10.2 Classification and Purpose of Cookies We Use
Absolutely necessary cookies: These cookies enable our website to function properly and help us provide services related to website operation. This type of cookie can be automatically placed without your consent, and you can set your device to block the use of these cookies, but some features of the website will not work.
Analytical cookies: These cookies collect information about how users participate and interact with web pages. If you disable such cookies, we will not be able to know how you interact with web pages or applications, and therefore cannot optimize the user service experience of our system.
Privacy preference cookies: These cookies are used to remember your cookie settings when you visit our website. If you disable such cookies, our website or application will not remember your privacy settings and you may be asked to provide your privacy preferences again.

10.3 What cookies do we use?
The cookies we use are as follows:
Admin Token: As a credential for users during access, it prevents the leakage of user information, avoids duplicate logins, reduces the number of times usernames and passwords are transmitted, and is an absolutely necessary cookie.
_gid, _ ga： Used to understand how users interact with the website during their visit, it helps provide information on indicators such as visitor numbers, bounce rates, traffic sources, etc. It belongs to the analysis category of cookies.
cc_cookie, gdpr cookie： Used to save privacy preference configurations, it belongs to privacy preference cookies.

11．Third party SDK
This app does not use third-party SDKs.

12. How do we protect personal information
We adopt reasonable and feasible physical, electronic, and management measures to protect the security of personal information and prevent unauthorized access or improper use of personal information.
We strive to ensure the security of any personal information you send to us. If the physical, technological, or management protective facilities of the company are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of personal information, we will promptly implement measures such as reporting, repairing, and notifying; If it causes damage to your legitimate interests, we will actively assist the competent authorities in investigating and safeguarding your legitimate rights and interests.
After the unfortunate occurrence of personal information leakage, tampering, loss and other security incidents, we will promptly inform you in accordance with relevant laws and regulations of the reasons for the security incident, the types of personal information involved, the potential harm, the remedial measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and the remedial measures for you. We will promptly inform you of the relevant situation of the event through email, letter, phone, push notifications, etc. If it is difficult to inform you one by one, we will adopt a reasonable and effective way to issue an announcement. At the same time, we will proactively report the handling of personal information security incidents in accordance with regulatory requirements.

13．Contact Us
TWS Technology (Guangzhou) Limited is the processor of your personal information collected through this system.
You can contact us through the following ways:
TWS Technology (Guangzhou) Limited
Address: 39 Nan Yun San Road, Science Park, Guangzhou, Guangdong 510663, PRC，
Contact email: TEC_SW@TWS.COM
Contact email for personnel responsible for personal information protection: TEC_SW@TWS.COM

14. Update to this Privacy Policy
We may revise or update our privacy policy from time to time. The update of the privacy policy will take effect at the same time as the revised version is released. If you continue to use our services through mobile applications or web pages, it constitutes your consent to the updated content. If we make changes that we consider important, we may make reasonable efforts to notify you and, if necessary, request your consent.
If you have any questions or requests regarding this privacy policy, please consult us through the contact information provided in this privacy policy.