The SUBLUE ROBOT Privacy Policy



Last updated and effective date : July 1, 2023

General

This Policy will help you understand the following:

I. How we collect and use your personal information

II. How we use cookies

III. How we store and protect your personal information

IV. How we transfer your personal information to other entities

V. Your rights: How to access and control your personal information

VI. Data storage location and cross-border transfer of personal information

VII. Responsibilities

VIII. Policy Revision

IX. Severability

We, Sublue Underwater AI Co., Ltd. (hereinafter referred to as “we” or “SUBLUE”), respect and protect your privacy and personal information, and will process your personal information and rights acquired from the use of SUBLUE ROBOT App (hereinafter referred to as the “App”) to control and manage the household robot products (hereinafter referred to as the “Household Robot”) connected with the user account of the App in accordance with the stipulations in the SUBLUE ROBOT Privacy Policy (hereinafter referred to as “this Policy”). Our App may include links to external websites operated by our affiliated companies, third parties or us. If you click on these links, you may be redirected to these websites on the web browser on your mobile phone, but your personal information will be processed strictly in accordance with the privacy policy of the related website. As the operator of the App, we are the manager of your personal data and will acquire data from you, the data subject, directly.

To know more details, please read the corresponding chapter according to the above indexes:

This Policy applies to all users of SUBLUE ROBOT products and services. Specifically, this Policy applies to individuals (hereinafter referred to as the “User”) who have full capacity, registered accounts on our App and enjoy relevant SUBLUE ROBOT products and services. We do not provide services for any minors or actively collect their personal information, except in the circumstances where the personal information of any minors is collected due to the reason beyond our control. We will delete such information upon notification.

It is necessary to understand this Policy to use the App and relevant functions of the Household Robot and to become one of our users. We recommend that you carefully read and understand everything in this Policy to make a choice you consider appropriate. When using or connecting to the App, a click on “Accept” or indication that you understand this Policy will be considered as your recognition of and agreement to abide by this Policy. This Policy may not apply to third-party services, activities or products you may use;. Such services, activities or products may be subject to different privacy policies. However, if the following personal information types of third parties are involved: Country/region and mobile equipment identifier (IMEI), we will supervise and request third parties to use your personal data reasonably and legally according to our purpose, range and time of use as well as privacy policy.

1.This Policy will help you understand the type, reason for use and collection method of specific personal information that we collect for a particular product, service or function.

2.When you use some functions of the App, part of your information collected by use may be prompted. Such collection and purpose have been specified in this Policy for your reference. Refusing to provide the information concerned will make it impossible for you to use specific functions, but it will not affect normal use of other functions of the SUBLUE ROBOT product and services. When it is no longer necessary to collect or process some personal information for all applicable purposes specified herein, we will stop collecting relevant personal information and/or de-identify or delete the information collected.

3.Generally, we will not share, disclose or transfer your personal information to any third party, unless otherwise specified in this Policy or required or permitted by relevant laws. If it is necessary to share, disclose or transfer such information, we will explain the reason/basis for such sharing, disclosure or transfer and obtain your explicit consent to the extent permitted by law.

4.As long as your personal information is processed based on your consent, you can access, modify or delete your personal information or withdraw the consent; you can also cancel your user account (“App Account”) registered on the App, make a complaint or set the privacy function to realize control over personal information or limit our further use of personal information. Even if the processing of information conforms to our legitimate rights and interests, you still have the right to lodge an objection to data processing at any time and can do so by contacting us through the contact information specified in this Policy.

5.As long as your personal information is processed based on your consent or an agreement or processed automatically, it means that you have provided your personal information to us, and we will provide you with the personal information in the machine-readable form upon your request, including but not limited to your email address, password and SUBLUE ID, telephone number, account information, mobile equipment identifier (IMEI), social media accounts, location information, text messages, basic application information, application running log, equipment performance log, network information and basic information about the device for your use of the use by other service providers. You can contact us via the email ( support@sublue.com). We will reply within seven working days upon receipt of your application.

6. Whenever you believe we process personal information in violation of the General Data Protection Regulation (GDPR), you may lodge a complaint to the related regulator having jurisdiction over the related place.

7. In case of any doubt, complaint or interpretation about this Policy, our execution of the Personal Information Protection Law, implementation of the following provisions or exercise of the rights stipulated by law, you may contact us using the contact information specified in this Policy.

Contact information: support@sublue.com

Please understand our privacy rules, which cover how we collect, use, disclose, transfer and store your personal information. We promise to abide by the applicable Personal Information Protection Law to protect your privacy and data security. We also guarantee that all our staff will fulfill the above obligations. The purpose of processing your personal information is to operate the App and the Household Robot, provide you with better services and improve product quality, such as supporting research and development of new products and upgrade of existing product functions, in order to provide you with better and higher quality services more suitable for you.

I. How we collect and use personal information

(a) Type of Information, Collection Method and Purpose

Reason for processing of your personal information: Purpose described in this Policy; your permission; compliance with our legal obligation; contract performance by you as a contracting party; to protect your key interest; or necessity to conduct evaluation for the legitimate rights and interests pursued by us or to transfer information to third parties (please refer to the following appendix for details).

(1) Personal information to be provided for registration of the App Account

You shall have an App Account to use functions of the App, especially the functions related to the Household Robot. When you register an App Account, we will collect and store your personal information, including your email address, password and SUBLUE ID, telephone number, account information, mobile equipment identifier (IMEI), social media accounts, location information, text messages, basic application information, application running log, equipment performance log, network information and basic information about the device. Through the information you provide, you shall ensure that the personal information provided to us is complete and accurate. To facilitate our internal processing of the data related to your App Account, your account number will be matched with the SUBLUE ID (a series of random character strings) after you complete registration of the App Account. By binding your App Account to the SUBLUE ID, your App and we can identify your commands and requirements, distinguish you from other users, and send correct orders to your Household Robot and provide you with services based on long-term understanding and performance of the SUBLUE ROBOT User Agreement.

The above information will be used to verify your identity; match and integrate operations in your App Account; match and report on the state of your Household Robot; facilitate our processing of customer services and after-sales requests you sent to us; send you the above notices and notices on account verification, significant changes and update of service functions, technologies and security.

If you consent, we can contact you through your email address and send you interesting messages about us and our products and services, such as marketing messages. By clicking the Unsubscribe button provided in each marketing email, you can unsubscribe our email advertisement or turn off the function through “Settings - Privacy” in the App.

To better provide you with valuable product consulting information, we need to collect your personal information such as the mobile number, email address, country/region, basic information about mobile phone and information about the device purchased upon delivery of our products and services.

(2) Personal information collected by the Household Robot matched with the App Account

To maintain and protect your Household Robot to execute your commands, transmit the state of your Household Robot to the interface of your App Account and facilitate your consulting, some information about your Household Robot shall be transmitted or stored through our server. Among the above information, the following may be deemed as your personal information: (i) Service set identifier (SSID), and network layout and IP address in the Wi-Fi network access state connected to your Household Robot; (ii) model and serial number of the Household Robot; (iii) operation record and state data of the Household Robot; (iv) error and upgrade history of the Household Robot; (v) cleaning map produced by the Household Robot.

Such personal information is processed for the following purposes only:

(i) We process all personal information transmitted to and stored in our server to complete your commands until we perform the SUBLUE ROBOT User Agreement reached with you. Under special circumstances, we may share the information about your Household Robot with other users according to your commands: You can choose one or more users to use and control your Household Robot (“equipment sharing”) through the App. In this case, you are named the “sharer” and other persons invited and authorized by you to control your Household Robot through the App interface are called the “sharee”. If you are a sharee, the sharer and other sharees can view your commands to the robot shared.

(ii) We also use some of your personal information and your SUBLUE ID to analyze and detect potential market needs and common faults and to support long-term feasibility and technological updating about related information system, Household Robot and mobile application. The personal information used for that purpose is limited to the model or your Household Robot, record of commands executed by the Household Robot, warnings and suggestions on the Household Robot, cleaning log and errors as well as the clean environmental diagram generated by the Household Robot.

(iii) We look up the operating record and clean environmental diagram of your Household Robot to supplement your user data, thereby optimize and personalize the contents of your App. To adapt to such data collection, we will customize our advertisement or third-party advertisement (through the App, purchasing of notification in the App or contents displayed in the home page of your mobile device) (email address provided when registering the App Account) for marketing. Please note that for the purpose of data collection, we will conduct evaluation on likes, preferences and consumption habits related to market research and statistical analysis. Such data collection is automatic.

We will consult the operating record and clean environmental diagram of your Household Robot to supplement your user data, thereby optimize and personalize the contents of your App. For the purpose of data collection, we will conduct evaluation on likes, preferences and consumption habits related to market research and statistical analysis. Such data collection is automatic.

Please note that if you choose to share control of your Household Robot with other accounts of the App, the data collected by other sharees through your Household Robot during the control period will be recorded in the sharees’ App Accounts.

(3) Personal information collected by the App

To match your App Account with your Household Robot when you are logged in to your account and transmit commands to your Household Robots continuously, we will collect: (i) Information about the mobile device where the App is installed, including device model, operation system and version, IP address, Mac address and country and city; (ii) SSID accessed by the Wi-Fi network connected to your mobile device, status and errors of the network layout; (iii) pairing state, history and errors (if any) of your App; and (iv) login time, commands and running log generated in the App Account. We will collect the “uniform identifiers” of your mobile device, such as the international mobile equipment identifier (IMEI) and mobile equipment identifier (MEID); we will use them only for the purpose of consulting the historical data collected or generated by the particular mobile device and identifying whether your App is logged onto the unfamiliar mobile device after suspected account theft.

If you use our customer services through the App, we will collect the record of our communication, contact information (if necessary) other than the email address and other information used to process your requests. Please consult the appendix for more details about our service provider(s) participating in information collection.

The permissive license in the “storage” of your mobile device is necessary for operation, update or upgrade of the App and storage of any information collected by the App. To process the above information, the App will look for the permissive license from your mobile device for the following actions: (i) Access the “mobile data”, “location” and “Wi-Fi” information as well as “Bluetooth” so that the App functions subject to network pairing connection and depending on the network can be run normally.

Such personal information processing shall be limited to:

(i) Correctly output App contents, especially the continuous connection between your commands issued from the App account and your Household Robot to maintain your App Account;
(ii) Process relevant commands, query and request for your use of the App and/or your Household Robot, including the customer services;
(iii) Analyze and identify potential market demands and common faults to improve service quality and support long-term feasibility and technical update of relevant information system, Household Robot and mobile application;
(iv) Create and supplement your user profile to optimize and customize contents of your App, our or third-party advertisement (notifications push through the App and in the App, or the advertisement badges on your mobile device), and marketing advertisement (to the email address used for App account registration) to adapt to such information collection;
(v) Execute our legal interests, such as “know your customers”, to keep records and carry out network security protection; to provide necessary information for the law enforcement authority to prevent, process or supervise the data security risks,
To send various advertisements and other notifications to the interface of your App Account, the App will need to acquire the consent to access the “Notifications” function on your mobile device. Some of the tools provided by our service provider shall be integrated in the App (please refer to the attachment of this Policy for the details). Please turn off such notifications in specific categories from the user settings. We shall watermark all the advertisements with the symbol “Ad” for easy identification.
If you, as the sharer, want to share the Household Robot with other individual not registered in the App, you shall acquire their consent before submitting their email address to the App so that we can send them an email containing the registration invitation of the App Account.
II. How we apply cookies
(a) How we use cookies for automatic information collection. For your convenient use of the App or our services, we may identify you through small data file to help you skip the steps of repeated information input or confirming the security of your App Account. Such data shall include cookies, local shared object, or the locally stored data provided by other mobile device operation system (collectively referred to as “Cookies”). Cookies will be automatically stored for 1 month and updated dynamically. Under special circumstance, we will use SSID of Wi-Fi network searched by your App gathered by the Cookies.
(b) How to refuse to use cookies. You can refuse or manage cookies through your browser settings. However, please note that you may not enjoy the best service experience and certain services if you refuse to use cookies. However, it will not affect the core functions of our product and service. Meanwhile, the cookies saved shall be automatically deleted if you log out from the App.
III. How we store and protect your personal information
(a) Our data security management and policy. We shall be responsible for protecting the information security legally, and protect your information from inappropriate disclosure, destruction, misuse or missing. We hereby undertake that we shall take (or have taken) all the reasonable measures to make every effort to protect your personal data, and apply technical security measures, such as Security Socket Layer (SSL), AES, MD5 encrypted access, and appropriate security policy made for our staff. We shall also communicate our policy and security instructions with our staff, and strictly conduct privacy protection in our team. Moreover, we have established internal permission and approval mechanism for the access to your personal information, and selected reliable and qualified third-party cloud storage provider to store such data.
(b) Account verification. When you use your App Account, we may take different verification measures to identify you for your account security. For example, if you log in to your account on a new mobile device, we may verify your identity through your account password and a verification code to the verification email and other channels.
(c) Reporting mechanism of personal information security accident. Please understand that personal information security accident may happen due to uncontrollable factors as a result of current technical limitations or potential malicious attack. We shall immediately notify you of the general facts and potential impact, the measures taken or to be taken by us, the advice on the protection of your information and risk lowering, and remedial measures in case of such accident if required by the laws. We shall use push notification to notify you of relevant accident facts via email, mail and phone call, or the method to receive our information you set. If we cannot or experience difficulty contacting every affected customer, we shall publish the notification in reasonable and effective manner. We shall report the result of the personal information security accident to relevant regulatory department if needed.
(d) Time-limited storage of your information. We shall only store your personal information during the necessary period for realizing the purposes of the provisions hereof, the requirements or permission of the laws. We shall meticulously check our demand in collecting the personal information disclosed hereto. If we set relevant demand, we shall only store such information for the purpose of prior gathering in the shortest possible time unless the laws require longer storage period. Your personal information shall be destroyed or anonymized in irreproducible manner. We hereby undertake to immediately delete the personal information of any third party disclosed in the attachment on instructions during and after the cooperation period. If we terminate the SUBLUE ROBOT service or operation activity, we shall immediately stop collecting your personal information and immediately delete or de-identify the collected personal information. In such cases, we shall send the notification to you or publish relevant information on our website or the App.
IV. Your Rights: How to access and control your personal information
(a) How to access and revise your personal information. You may log in your APP account on the App, check “User Information” and “Settings” interface, view or revise the personal information and linked third-party account submitted, or conduct relevant privacy and security settings. However, you may be unable to revise some initial registration information you provided for registration in consideration of security and identity recognition or due to statutory provisions of the laws and regulations. If you cannot access or amend your personal information in the above ways, please contact us for assistance via the contact information shown in Article IX hereunder. We will continue to develop interface for the convenience of your own operation. Please keep an eye on the subsequent updates of the App.
(b) How to reject marketing message. If you do not want to receive any marketing message in your email, you may click “cancel subscription” in any message in question to unsubscribe. Please check the account page setting for disabling the receiving of marketing message in the App. Please note that you cannot cancel the subscription or reject message associated with your App account, such as finding the missing App account or change or update of App account & password or service function, or technical and security notice.
(c) How to ask for deletion of your information. If you find us collecting or using your personal information against the governing law or the provision between you and us, you may ask for deletion of your personal information we collected based on the illegal act via the contact information shown in Article IX hereunder.
(d) How to change the scope of your authorization and consent or revoke your consent. You may ask us to change the scope of your authorization or revoke your authorization of our continued collection of personal information by deleting personal information, prohibiting the App from accessing your mobile device, adjusting the settings of the App, etc. You can withdraw all authorization to us for continuous collection of your personal information by cancelling your App account. After you revoke your consent or authorization, we might be unable to continue the provision of corresponding services due to the lack of necessary information. Your decision to withdraw your consent or authorization will not affect the legitimacy and effectiveness of our previous processing of personal information based on your consent.
(e) How to cancel your App account. You may request for cancellation of your App account via the contact information shown in Article IX hereunder or in “App settings-account and security-cancel account”. Please note that the website account universal for your App account will be cancelled simultaneously after your App account is cancelled. You will be unable to use the account to log on the online shopping channel of the official website of Ecovacs. If you choose a third-party app user account for login, your App account will be unmatched with the third-party app user account. By then, we will delete or anonymize your personal information. After cancellation of App account, the functions of your home robot not involving App control are still available.
(f) Before we respond to your above request, for the purpose of security, we might need to first verify your identity and document. Upon successful verification, complete the processing will be conducted in fifteen (15) working days. In special cases, we will respond or provide a rational explanation on the inability of timely response within thirty (30) days at most or the term stipulated by the laws and regulations.
V. Data storage location and cross-border transfer of personal information
(a) Storage location of your personal information. The personal information collected and generated from your use of SUBLUE ROBOT products and services will be stored in the servers of third-party cloud facility. These servers are located in the United States of America (if you use it in regions beyond Europe) and France.
(b) International transfer of your personal information. As we rely on global resources and servers to provide you with products or services, your personal data might be transmitted to or accessed from other jurisdictions. Such jurisdiction includes: (i) the jurisdiction where your personal data is stored (if it is stored in your locality, cross-border transfer does not apply); (ii) China, our registered address, location of the affiliated companies for our provision of SUBLUE products and services and the majority of our service providers, and when our employees need to access your personal data to solve problems or conduct extensive analysis; (iii) the storage location of some other service providers which provide you with service in our App via integrated Api/Sdk (App interface/software development kit) on our behalf, and the jurisdiction over relevant affiliated company mainly located in your jurisdiction or specialized in serving your local jurisdiction; and (iv) The jurisdiction where you used to log on the App provided that the data storage location of such jurisdiction is different from your residence country. When you send an email to support@sublue.com, the personal information carried in your email and the sending of the email will be directly transmitted to China, namely the location of our email server. All such international transfers arise from and are performed on third-party cloud facility and relevant server actually located in such jurisdiction. We will ensure that third-party cloud service providers take proper measures by law to protect your personal information.
VI. Liabilities
We, our employees or our agent will not assume the liability for the claims for dereliction of duty, tort damage or expense in vain.
The scope of liability is not applicable to: damage arising from intentional or major negligence or violation of substantive contract obligation, namely the contract obligation on which proper executability of contract and ability of regular performance of contract party are based, and damage arising from default which might jeopardize the realization of contract purpose. If we are accountable for the dereliction of duty, the scope of liability is not applicable to damage arising from impairment on life, limbs or health. Besides, the scope of liability shall not be applicable to damage arising from lack of quality assurance or legal liability.
VII. Revision of this Policy
We may revise this Policy from time to time. In this case, we, for example, will ask for your consent after notifying you by one or multiple means below: (i) send a push notification to present the revised privacy policy when you log on App with your account or update your product or services; or (ii) contact you via the contact information stored, such as email, pop-up window or other similar approaches. If you choose to accept, the updated version will supersede this Policy and continue to form binding force upon you.
You may find the latest version of the SUBLUE ROBOT Privacy Policy via account settings in the App. We encourage you to read our privacy policy regardless of when you access our services.
VIII. Severability
If any article hereunder is deemed illegal or inexecutable, we will revise the article in question within the necessary scope to make it legal or executable. Nonetheless, as much original meaning of the article as possible will be kept.
If possible, the articles of this Policy shall be interpreted based on the effectiveness and executability of law. Nonetheless, if one or multiple articles hereunder are found partially or entirely ineffective, illegal or inexecutable, the article or the remaining part of this Policy shall remain entirely effective.
IX. Special provision on personal information of minors
We attach a high level of importance to the protection of personal data of minors. We will not collect personal information directly from minors. In case of collection of the personal information of minors with the consent of their guardians, we will only use, share, transfer or disclose such information to the extent of law, as agreed by their guardians or necessary for protection of minors. We hope the parents or guardians may instruct the minors to use our service. If you are under 14 years old or underage pursuant to your local laws and regulations. We advise you to ask your parents or guardians to read this Policy and to use our service based on the consent of your parent or guardian. Nonetheless, please avoid providing us with any personal information which may reveal your identity. If your guardian disapproves your use of our services in accordance with this Policy or you have practically provided personal information which may reveal your identity, please immediately terminate use of our services and inform us in a timely manner for us take corresponding measures pursuant to the governing laws.
X. How to contact us
1. Please contact us via the following contact information in case of any question, opinion or advice on this Policy or any matter on your personal information. SUBLUE address: 45 Muning Road, Binhai New District, Tianjin, China
Email: support@sublue.com
You may also give us feedback on the Help and Feedback page of the App to contact us.
2. Generally speaking, we will reply within fifteen (15) working days.
Attachment: List of Third-party Service Providers
*The table below presents some third-party privacy policies (you need to access third-party network environment for reading). We advise you to read the part on “personal information of end-user/terminal user” to understand their specific way to possibly use your personal information. The content below may be applicable only to the cleaning robot products of specific models of brands under SUBLUE.

Third-party product/service(s)	Information processing scenario/purpose	Type of information acquired (not all personal information)	Access to your mobile device invoked	Information processing	Name	Link
Alibaba Cloud	Storage and transmission of various data of our products and services, including the distribution network between the App and your home robot	All information we gather	None	Data is transmitted and processed merely based on our command or the automatic command of our products and services	Alibaba Cloud Computing Co. Ltd.	http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/ suit_bu1_ali_cloud201902141711_54837.html
Alibaba Cloud text message	Send verification code to your mobile phone to confirm your identity; send notification to you on the embedded user care activity and marketing information of the App	Mobile phone number	The storage permission of text messages for verification
Alibaba Cloud OSS	Analyze and classify your home robot based on the cleaning log	The cleaning log and personal portrait of your home robot	None
JPush SDK	For Android users, various push messages in the App, including but not limited to user care activity, marketing message and notification on release of new App version	Equipment information, geographic location and network information. Device information: device identifier (IMEI, IDFA, Android ID, MAC, OAID, and other relevant information), application information (App crash information, notification switch status, software list and other relevant information), device parameter and system information (device type, device model, operation system and hardware-related information).	Read and revise the storage permission of mobile device (for download and installation of new version of the App)	Use the SDK embedded in the App to make sure our message can be sent to your Ecovacs ID and displayed on your App page	Shenzhen Hexun Huagu Information Technology Co., Ltd.	https://www.jiguang.cn/license/privacy
Amazon	Storage and transmission of various data of our products and services, including the distribution network between the App and your home robot	All information we gather	None	Data is transmitted and processed merely based on our command or the automatic command of our products and services	Amazon Web Services, Inc.	https://aws.amazon.com/privacy/?nc1=h_ls
the Amazon S3	Analyze and classify your home robot based on the cleaning log	The cleaning log and personal portrait of your home robot	None
Netty	Netty is a network app framework driven by asynchronous events for the purpose of raid development of maintainable high-performance protocol server and client. Reliable long link in processed items。	Network IP address	None		The Netty project	https://netty.io/
mqtt	Intercommunication with server.	Network status	None		Eclipse Foundation.	https://www.eclipse.org/paho/
okhttp	HTTP is a modern way of network application. This is the way we exchange data and media. Effective use of HTTP can quicken your content loading speed and save bandwidth. Intercommunication with server.	Network status	None		2022 Block, Inc.	https://square.github.io/okhttp/
YYImage	For gif and image processing and loading		None	For image processing and loading	github	https://github.com/ibireme/YYImage
SnapKit	For automatic layout of control			Realize automatic layout of control through constraint	github	https://github.com/SnapKit/SnapKit