Privacy agreement

Latest edition: [September 2019]

D＆O Home Collection Group Co.,LTD (hereafter “MONARCH” or “We”) respects your privacy and recognizes it as our important social responsibility to handle your personal data lawfully and properly. This Privacy and Personal Data Protection Notice (hereafter “Privacy Notice”) aims at acquainting you with the way our MONARCH Interactive Intelligent Panel (hereafter “MONARCH”) handles your personal data and how you may exercise your right of privacy.

This Privacy Notice is made in compliance with Chinese laws and regulations on data protection. The term “personal data” for the purpose of this Privacy Notice means any information recorded electronically or otherwise that can be used separately or in combination with any other information to identify a certain natural person or show the activities of a certain natural person, including without limitation name, identification number, postal address, residential address, account details, financial status, and location data. Personal data includes sensitive personal information as set out in Chinese laws and regulations on data protection.

If you have any question or doubt about how we use your personal data, please feel free to contact us at any time via the means of contact provided at the end of this Privacy Notice.

In MONARCH app store, you may download apps which may collect your personal data for purposes such as account registration. These apps will be solely responsible for their respective collection and processing of personal data, and will publish their respective rules on the collection and processing of personal data. Please review carefully the privacy policy, user agreement and other rules published by these third-party apps before downloading and using the apps. You expressly recognize and agree that MONARCH is not responsible for such collection or processing of personal data.

If you are a minor under the age of 18

We do not collect the personal data of minors under the age of 18. If you are a minor, please do not use MONARCHor submit your personal data to us through MONARCH. If you are the parent or legal guardian of a minor, you may contact us via the “Contact Us” details when you find the minor registering and using MONARCH and uploading his/her personal data through MONARCH. If we are aware that we have collected the personal data of any minor, we will delete or anonymize such personal data in compliance with applicable laws and regulations.

What personal data does MONARCH collect, and what for?

We mainly collect the following personal data about you:

· Personal data that you voluntarily provide for us

-          When you use the “Whiteboard” functionality and need to upload your personal profile, you need to log in via WeChat scan and allow us to collect your WeChat information (including your nickname, profile photo, region and sex). If you want to give us feedback on your use of the product via the “Feedback” interface in “MONARCH profile”, you will need to provide your name, contact number, product functionalities and descriptions.

-          If you want to use the “Email” functionality, you need to set up your email account in “Setting” and enter information about the sender, SMTP server, port, username and password (authorization code).

-          You may give us feedback on your use of the product via the “Feedback” functionality and apply for warranty. In the “Feedback” setting, you will be asked to provide your name, contact number, product functionalities and descriptions; in the “Warranty” setting, we need to obtain information about your geographic location so as to refer you to a nearby store. We also need to gather information about your name, address, company (optional) and phone number in order to provide warranty services for you.

· Personal data that we automatically collect

When you are using MONARCH, we may use tracking technology to automatically collect certain information from your device:

-  MONARCH is equipped with a face recognition Software Development Kit (SDK). We will collect face image data of users for the purposes of identity recognition, access control and face recognition check-in.

Generally, your personal data that we have collected will only be used for purposes that we have set out in this Privacy Notice or notified you of upon collecting your personal data. However, within the extent permitted by law, we will also use your personal data for some new purposes which are not in conflict with the purposes of which we have informed you (such as statistics).

Who will be sharing your personal data?

We may disclose your personal data to the following types of third parties:

· Our Group Company and third-party service providers and partners (such as our cloud service provider) providing data processing services for us, or any other third parties processing the data for any purposes set out in this Privacy Notice or informed of by us upon collecting your personal data.

· Law enforcement authorities, regulatory authorities, the Government, courts or other third parties as we deem necessary for the purpose of (i) complying with an applicable law or regulation; (ii) exercising, establishing or defending our lawful rights, or (iii) protecting rights and interests that are very important to you or anyone else.

· Any potential purchaser (and its agent and adviser) proposing to purchase, merge or acquire any part of our business, provided that we shall inform such purchaser of using your personal data only for the purpose of such disclosure under this Privacy Notice.

· Any other person with your consent.

Generally, we will only collect your personal data after obtaining your consent when we do need your personal data to perform the contract between us, or when we are obliged to collect, use or process your personal data as required by applicable law or for compliance with law. In some cases, we may also be legally obliged or need to collect your personal data in order to protect your or other individual’s important rights and interests.

This Privacy Notice applies to situations when we ask for your personal data in order to comply with laws and regulations or to perform the contract between us.

How does MONARCH protect your personal data?

We will use proper technology and management means to protect your personal data that we collect and process, including storing and backing up our data via encryption, as well as using access control systems such as authorization and auditing to control the access to and use of personal data. The Internet is not 100% safe, but we will do our best to ensure and protect the security of any information you provide for us. In case of any unfortunate personal data incident, we will comply with applicable laws and regulations and promptly inform you of: basic information about the incident and likely consequences, countermeasures we have taken and will be taking, advice on how you may prevent and reduce the risks, and remedies available to you. We will keep you informed of and updated on the incident in a timely manner by email, letter, phone, push notification and other means. Where it is not feasible to separately inform each personal data subject, we will make announcements via reasonable and effective means. At the same time, we will voluntarily report to competent regulatory authorities on our handling of personal data incidents.

Data storage

· Locations: we will store your personal data that we have collected in systems within the territory of China in compliance with applicable Chinese laws and regulations. We will not transfer your personal data to any other country or process your personal data in any other country.

· Storage periods: unless as otherwise provided for by laws and regulations, we will store your data for the following periods:

-            We will store your personal data that we have collected in order to meet our normal business needs (for example, providing services for you or meeting legal, tax and financial requirements).

-            When we do not have such normal business needs involving the use of your personal data or when the storage periods set out by Chinese laws and regulations have expired, we will delete or anonymize your personal data or, when deletion or anonymization is impossible (for example, when your personal data is stored in a backup), store your personal data securely and separate such personal data from other data processing.

Your right to data protection

Under Chinese laws on data protection, you have the lawful rights of a data subject, such as the right to access, amend, update and delete your personal data processed by MONARCH. You may contact us at any time via the means set out in the “Contact Us” area below. We will, as required by applicable laws and regulations on data protection, respond to any request made by a data subject to exercise its data subject rights.

For security purpose, you may be asked to submit a written request or prove your identity in any other way. We may ask you to verify your identity before processing your request. We will, as required by applicable laws and regulations on data protection, respond to any request made by a data subject to exercise its data subject rights.

We will not be able to respond to your request to exercise your rights if:

· responding to your request will make it impossible for us to fulfil our obligations under applicable laws and regulations;

· the requested data is directly related to national security and defence;

· the requested data is directly related to public security, public health and major public interests;

· the requested data is directly related to criminal investigation, prosecution, trial and judgment enforcement;

· we have reasonable evidence to prove that you have malice or is abusing your right;

· responding to your request will seriously prejudice the lawful rights and interests of you or any other individual or organization;

· the requested data concerns any business secrets.

Updates on the Privacy Notice

We will from time to time update this Privacy Notice to meet legal, technological and commercial changes. When we update this Privacy Notice, we will inform you via appropriate means according to the significance of such change. We will, as required by applicable laws and regulations on data protection, ask for your consent before making any major change to this Privacy Notice.

You may find out when this Privacy Notice is updated by referring to the “Latest edition” first above stated.

Contact Us

Please contact us at any time if you have any question or doubt about how we use your personal data:

· Company:  D＆O Home Collection Group Co.,LTD

· Address: Jiajia Industrial Park, Eastern New District,Chengdu, Sichuan Province

· TEL:  400-111-9001