Kelu Privacy Agreement

introduction

Your trust is crucial to us, and we are well aware of the importance of personal information to you. We will collect personal information from you within a reasonable and necessary range in accordance with legal and regulatory requirements. We make every effort to adopt appropriate security measures through reasonable and effective information security technologies and management processes to prevent your information from being leaked, damaged, or lost. In view of this, the service provider of the Kelu Platform (or referred to as "us") has formulated this Privacy Agreement and reminds you to pay attention to:

This agreement applies to all products and services of the Kelu Platform. Kelu Platform refers to Shenzhen Kelu Electronic Technology Co., Ltd. and its affiliated companies operating Kelu website (domain name http://www.szclou.com ）Related clients of Kelu.

It should be noted that this agreement does not apply to services provided to you by third parties, such as redirecting to third-party websites, clients, or programs through the website of Kelu Company. The personal information you provide to the third-party service provider does not apply to this agreement.

Before using various products or services on the Kelu platform, please carefully read and thoroughly understand this agreement, especially the terms marked with bold and underline. You should focus on reading them and start using them after fully understanding and agreeing to accept them. If you have any questions about this agreement, you can consult with Kelu customer service (0755-33309999) or contact us through the contact information provided on any Kelu platform.

If you are a minor under the age of 18, please read this agreement with your legal guardian and pay special attention to the terms of use for minors.
This agreement mainly explains to you:
What information do we collect from you.
How do we use your information.
Under what circumstances should we share your information.
How do we store your information.
How do we protect your information.
The rights you enjoy.
 ・ Personal information subject cancels account
How to protect minors' information.
How do you contact us
What information do we collect from you

 1.1 We collect your information based on the principles of legality, reasonableness, and necessity. When providing you with a specific service, we will clearly inform you of the information to be collected and its purpose to respond to your specific service request. Based on the service you have chosen, we may collect one or more of the following information in the following scenarios:
(1) Account information. For example, your account ID, password, name, email, phone number, country/region, etc;
(2) Personal contact information. For example, your name, email, phone number, country, city, company, position, address, etc;
(3) User experience feedback. For example, your feedback on the use of Kelu related products and services, purchase demand feedback, evaluation, satisfaction feedback, etc.

 1.2 Information obtained during your use of products and services
(1) Device information. We will collect relevant information about your devices when using Kelu products and services, such as operating system, IP address, browser type and version, and other technical information that varies depending on the product.
(2) Interactive information

√ The interaction records generated when you watch live broadcasts, click on advertisements, open or click on marketing or business notification emails we send;
When you interact with our pre-sales or after-sales service centers and other customer communication channels face-to-face, online, or through phone or email, we may record the communication process, including phone numbers, recordings, chat records, and other information;
When you participate in offline activities such as science and technology exhibitions and summits, we may collect attendance records of attendees, as well as photos, audio and video content related to offline activities;
√ When using location-based products or services, you may need to authorize us to obtain your location information;
When you use Kelu's products or services, Kelu will automatically collect and store necessary log information, such as access time, frequency, IP, events (such as successful or failed access), etc.
(3) Third party source information
If allowed by law, Kelu will also obtain information about you from public or commercial third-party sources, such as obtaining your nickname when logging into our website through third-party social media.
(4) Collection and use of non identifying data
Non identifiable data refers to data that cannot be used to determine an individual's identity. For example, Kelu will collect statistical data on website visits and other summaries. The purpose of collecting this data by Kelu is to understand how users use our website, applications, products, and services to improve service levels and user experience. Kelu may, at its discretion, collect, use, process, transfer, or disclose non identifying data for other purposes. We will do our best to isolate your personal information and non identifiable data, and use these two types of data separately. If personal information is mixed with non identifying data, it will still be considered as personal information processing.

How to use your personal information
2.1 Purpose of using personal information
The purpose of collecting and using personal information by Kelu is to provide you with a better product and service experience. Your personal information may be used for the following purposes:
(1) Authentication. When you use our products or services, you may need to provide personal information for account creation and subsequent identity verification and permission management;
(2) Contact you with your consent; Sending you information or notifications about Kelu products or services; Invite you to participate in science and technology activities, survey questionnaires, etc. If you do not want to receive the above information, you can unsubscribe or refuse at any time;
(3) When you register to participate in our online or offline marketing activities, it is used by Kelu or authorized partners to confirm your participation request, send conference information, collect questionnaire survey information, etc;
(4) With your consent, Kelu will share the hashed user ID with third-party social media to display you product or service information related to Kelu;
(5) Fulfilling contracts related to Kelu products or services, processing payments, arranging shipments, delivering and maintaining services;
(6) Provide technical support and after-sales service for Kelu products or services based on contractual agreements or at your request, including resolving issues you have raised, providing solutions or suggestions, etc;
(7) Organize and manage Kelu certification exams, online learning, training organized by Kelu or authorized partners, ICT competitions, etc;
(8) Certification and management of suppliers and partners, communication or business development with suppliers and partners;
(9) Provide you with personalized user experience and personalized content;
(10) Comply with and enforce applicable legal regulations.

2.2 Legitimacy basis for processing personal information
When Kelu processes your personal information, we will comply with applicable legal regulations and process it based on appropriate legal basis, including:
√ Process your personal information based on your consent;
√ Processing your personal information based on fulfilling the contract;
√ Process your personal information based on compliance and enforcement of legal obligations.
When logging in for the first time, you need to provide your phone number to register your account and set your account password.
After successfully registering, you can selectively fill in your personal information in the profile bar, such as your nickname, gender, birthday, address, avatar, email, feedback, and other related information. This type of information is maintained by you on your own. When using related services from Kelu, you can save on service delays caused by filling in. However, we will not force you to fill in this information. You can choose to maintain it selectively or fill it out during actual use.
When you leave a message or comment on the Kelu website, we need to collect your nickname, avatar, message, and comment content. Your messages and comments will be stored on the server, and we will anonymize your Kelu platform account and nickname before displaying them to the public. However, please note that the information you publicly publish may involve personal information or even sensitive information of yourself or others. If you choose to upload images containing personal information when commenting, please be more cautious and consider whether to share or even publicly share relevant information when using our service.
When using Kelu services, in order to provide you with more convenient and personalized information display, search, and push services that meet your needs, we will extract your preference features based on your purchase information and service log information, and generate indirect crowd portraits based on feature tags for displaying, pushing information, and possible commercial advertisements.

To help us understand the operation of the Kelu website and related apps, we will use mobile analysis software to calculate the SDK. We may record relevant information, such as your usage frequency, crash data, overall usage, performance data, etc. We will not associate the information stored in the analysis software with any of your personal information.
When you use products or services on the Kelu platform, we will automatically receive and record information from your browser and computer, such as your IP address, browser type, language used, access date and time, software and hardware feature information, and web page records of your needs.
When you use products or services on the Kelu platform, we may read information related to your location, such as the GPS signal of your device or nearby WLAN access points, information about mobile signal transmission towers, country codes, city codes, mobile network codes, community identifiers, longitude and latitude information, and language settings.
When you use the Kelu platform voice device and voice service, when you activate or wake up the smart device, we will automatically receive and record the audio, video, and other information generated by your interaction with the device terminal. And use this information to provide an intelligent recognition system with the ability to understand your expressed content. Please note that the device or program will only collect voice information after the wake-up function is turned on. If you refuse to collect the above information from us, please turn off the device's information collection function or do not wake up the device, but this will also prevent you from accessing relevant services.
It should be noted that individual device information and service log information are information that cannot identify a specific natural person. If we combine this type of non personal information with other information to identify a specific natural person, or use it in conjunction with personal information, during the combined use period, this type of non personal information will be considered personal information. Unless authorized by you or otherwise specified by laws and regulations, we will anonymize or de identify this type of information.
Obtaining your personal information from a third-party service provider. In the third-party device management business, we will cooperate with the third-party service provider, which involves us obtaining your personal information from the third-party service provider. We will obtain the following personal information of you under the condition of binding to a third-party account: the information of the third-party account, including your nickname and avatar, for display on the Kelu platform; A partial list of devices added to third-party applications for displaying devices in the "Kelu" application; Device and network information, including device identifier, MAC address, and device serial number, is used to identify the current working device and perform device security control.
If our personal information processing activities when conducting business exceed the scope of your authorization and consent when providing personal information to third-party service providers, we will obtain your explicit consent before processing such personal information. In addition, we will strictly comply with relevant laws and regulations, and require third-party service providers to ensure the legality of the information they provide. When we want to use the information for other purposes not specified in this statement, we will seek your consent in advance. When we want to use information collected for specific purposes for other purposes, we will seek your consent in advance.
In addition, we may also collect other information, such as the questionnaire response information you sent us when participating in the survey; Participate in the user experience program and provide us with information when you interact with us.
To improve the security of your use of the Kelu platform services, protect the personal and property security of you, other users, or the public from infringement, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and more accurately identify violations of laws, regulations, or Kelu platform related protocol rules, we may use or integrate your account information, device interaction information Network log information and information that we have obtained your authorization or legally shared to comprehensively assess the risks of your account and transactions, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.
If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing us with this personal information. If we use the information for other purposes not specified in this agreement, or collect information based on a specific purpose for other purposes, or if we proactively obtain your personal information from a third party, we will obtain your consent in advance.
Exceptions to obtaining authorized consent: You fully understand and agree that we do not require your authorized consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or request for information:
Related to national security and national defense security;
Related to public safety, public health, and major public interests;
Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;
For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain my consent;
• Personal information that you disclose to the public on your own;
Collecting personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels.
According to the necessary agreements or other written documents signed and fulfilled with you;
Necessary for maintaining the safe and stable operation of the provided products and/or services, such as detecting and handling malfunctions of the products and/or services;
Necessary for legitimate news reporting;
Academic research institutions conduct statistical or academic research based on the public interest, and when providing academic research or descriptive results to the public, de label the personal information contained in the results;
Other situations stipulated by laws and regulations.
Under what circumstances should we share your information
We will not share your personal information with companies, organizations, or individuals outside of Kelu, except for the following situations:
Sharing under legal circumstances: We may share your personal information externally in accordance with laws and regulations, litigation dispute resolution needs, or as required by administrative or judicial authorities in accordance with the law.
Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
Sharing with affiliated companies: In order for us to provide you with products and services, identify account abnormalities, and protect the personal and property safety of other users or the public from infringement, your personal information may be shared with our affiliated companies and/or their designated service providers. We will only share necessary personal information and are bound by the purposes stated in this agreement. If we share your sensitive personal information or if our affiliated companies change the purpose of using and processing personal information, we will seek your authorization and consent again.
Sharing with authorized partners: We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for the legitimate, legitimate, necessary, specific, and clear purposes stated in this agreement. Authorized partners can only access the information they need to perform their duties and may not use this information for any other purpose. We do not need to notify you separately and obtain your consent for the use and sharing of such processed data.

Currently, our authorized partners include the following types:
Authorized partners for advertising and analysis services. Please be aware that in order to provide you with more convenient, high-quality, personalized products and/or services, and enhance your user experience, we may entrust these partners to handle information related to advertising coverage and effectiveness, but we will not provide your personal identification information, or we will deidentify this information so that it does not identify you personally. Such partners may combine the above information with other data they lawfully obtain to execute our commissioned advertising services or decision-making recommendations.
Suppliers, service providers, and other partners. We send information to suppliers, service providers, and other partners who support our business, including technical infrastructure services commissioned by us, analysis of how our services are used, measuring the effectiveness of services, providing customer service, facilitating payment, or conducting academic research and investigations.

 We will not transfer your personal information to any company, organization, or individual, except for the following situations:
Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
In the event of a merger, acquisition, or bankruptcy liquidation of a service provider on the Kelu platform, or other situations involving merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this agreement. Otherwise, we will require the company, organization, and individual to seek authorization and consent from you again.

How do we store your information
Unless otherwise specified by law, Kelu Platform will keep your information for the following period:
During your use of the Kelu platform products or services, we will continue to save them for you, unless you voluntarily delete or cancel your Kelu account.
When you delete information or cancel your Kelu platform account, Kelu platform will stop using your personal information and delete your personal information within a certain period of time.
After anonymization and desensitization, your personal information will form usable circulating data. The Kelu platform does not need to obtain your consent for the storage and use of this data.

How do we protect your information
 We have taken reasonable and feasible security measures that comply with industry standards to protect your information from unauthorized access, public disclosure, use, modification, damage or loss. For example, when exchanging data between your browser and server, it is protected by SSL protocol encryption; We also provide HTTPS protocol secure browsing for various websites on the Kelu platform; We will use encryption technology to improve the security of personal information; We will use trusted protection mechanisms to prevent malicious attacks on personal information; We will deploy access control mechanisms to ensure that only authorized personnel can access personal information; And we will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
The Internet is not an absolutely secure environment. When using products or services on the Kelu platform, we strongly recommend that you do not use communication methods recommended by the Kelu platform to send your information. You can establish connections and share with each other through our services. When you create communication, trading, or sharing through our services, you can freely choose who to communicate, trade, or share with as a third party who can see your transaction content, contact information, exchange information, or share content and other related information.
After an unfortunate personal information security incident occurs, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will inform you of the relevant situation of the event through email, letter, phone call, push notification, etc. If it is difficult to inform the personal information subject one by one, we will take reasonable and effective measures to publish the announcement. At the same time, we will also report the handling of personal information security incidents in accordance with regulatory requirements.
・ Your rights
You have the right to manage your information, including:
・ Access your personal information:
Account Information: If you wish to access or edit personal information in your account, change your password, recipe preferences, etc., you can log in to your account and access your information through settings.
Other personal information (such as using shopping malls, after-sales, installation and repair services): For personal information generated during your use of our products or services, if you need it, you can contact us through the contact information in Chapter 9.
・ Correct your personal information
When you discover that we have made errors in processing your personal information, you have the right to request us to make corrections or supplements. You can make corrections or provide additional explanations by visiting the personal information settings page, or directly contact us.
・ Delete your personal information
In the following situations, you can contact the customer service of the Kelu platform to request the deletion of personal information:
If our handling of personal information violates laws and regulations.
If we collect and use your personal information without your explicit consent.
If our handling of personal information seriously violates our agreement with you.
If you do not need to use our products and services, or if you voluntarily cancel your Kelu account.
If we are permanently not required to provide products or services.
If we decide to respond to your deletion request, we will stop providing you with products or services and delete your personal information in accordance with applicable laws.
・ Right to withdraw consent
When we rely on your consent to process data, you have the right to withdraw that consent at any time, specifically by canceling your Kelu account.

・ Personal information subject cancels account
You can cancel your previously registered account at any time. If you need it, you can contact us through the contact information in Chapter 9 to cancel your account as an information subject.
After you cancel your account, we will stop providing you with products or services and delete your personal information according to your request.

How to protect adult information
Our products and services are mainly aimed at adults. For cases where personal information of minors is collected with the consent of the legal guardian, we will only use or publicly disclose the personal information of minors that we have lawfully collected if permitted by law, explicitly agreed by the legal guardian, or necessary to protect the minors.
If we discover that personal information of minors has been collected without the prior consent of the legal guardian, we will try to delete the relevant data as soon as possible. If the legal guardian has reason to believe that a minor submitted personal information to the Kelu platform without their prior consent, please contact us to ensure the deletion of such personal information and ensure that the minor unsubscribes from any applicable Kelu services.

How do you contact us
If you have any questions, opinions or suggestions regarding this privacy agreement, or if you wish to exercise any rights, or if you have any requirements to discuss with us, please contact our department dealing with personal information protection matters through the following methods:
Ke Lu Platform Service Provider: Shenzhen Ke Lu Electronic Technology Co., Ltd
Address: Kelu Building, Baoshen Road, Science Park North District, Nanshan District, Shenzhen, Guangdong Province

Service hotline: 0755-33309999
To ensure security, you may need to provide a written request or other means to prove your identity. Normally, we will reply within 15 days. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimate rights and interests, you can also file a complaint or report to regulatory authorities such as NetEase, Telecom, Public Security, and Municipal Supervision.
If you are not satisfied with our response, especially if you believe that our personal information processing behavior has damaged your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the defendant's residence.

Ke Lu
Updated on August 22, 2023
Effective date: August 22, 2023