Privacy Policy

Last modified: March 22, 2024

Introduction

This Privacy Policy for Vesync describes how L&H Y Trading Inc. and its subsidiaries and affiliates, including but not limited to Vesync Corporation, Arovast Corporation, Etekcity Corporation, and Vesync (Singapore) Pte., Ltd (collectively, "Vesync", "our", "us" or "we") collect, use, share, and store information. Our goal is to provide you with a positive experience when using our Websites, App, products, and services, while at the same time keeping your personal information secure.

This policy applies to information we collect:

  • when you register with, access, or use Cosori, Levoit, or Etekcity websites (“Websites”), and our services;
  • when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;
  • when you subscribe to our newsletters, promotions or other marketing initiatives; and
  • when you contact or interact with us, for example, in email, text, and other electronic messages between you and our Websites or our Customer Service team.

Some of our products are Internet-enabled, or may be operated through a Vesync mobile application. In the event that you use such smart products via Vesync mobile app, we advise that you refer to the applicable Vesync Privacy Policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, or do not want us to collect the information, do not register with, or use the Websites. By registering with or using the Websites or services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of our Websites or services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We May Collect and How We Collect It
Information we may collect

When You Use Our Websites, or related services, We May Collect the Following Information:

  • Profile Data, such as your username, password, email address, and region.
  • Logistics Data, such as receiver’s name, phone number, delivery address, postal code, and related product information.
  • Financial Data, before placing orders, you'll be asked to provide financial data, including card numbers, card expiration dates, CVC codes, account holder name, and billing addresses. Importantly, we do not store this information. Instead, it is securely processed by our credit card payment service providers, such as PayPal or Stripe.
  • Technical Data, such as your mobile device data, smart device data and internet connection data, including mobile phone model, mobile phone brand, operating system version, browser type, language, region, Android S/N, smart device cid, smart device MAC address, smart device IP address, Wi-Fi name and its passwords, Wi-Fi MAC address, Wi-Fi signal quality, network operator, network type, network quality, and session information.
  • Usage Data, such as details of your use of any of the Websites, , including, but not limited to, session information and history of operation of devices, the Websites, traffic data, logs, page response times, errors, length of visits to certain pages, page interaction information, browsing history, history of logging in, your schedule settings, input records, search queries, and methods used to browse away from the page.
  • Consumer Preference Data, such as products purchased, motivation for purchase, your preferences in receiving marketing from us and third parties, your responses to surveys, and other purchasing behavior and preferences.
  • Communications Data, such as your communication preferences, your contact information, the audio recordings of calls when you call the Customer Service team, and records and copies of your correspondence (including email addresses and phone numbers), if you contact us. The correspondence may include information like proof of identification, gender, employment, medical information, or health insurance information when needed for Customer Service team to provide related support.
  • Location Data, such as your precise location disclosed by GPS technology and other similar technologies.
  • Content Data, such as the content you post on the Websites. The content data that you post on public areas of the Websites may be transmitted to other users of the Websites or third parties at your own risk. Therefore, we cannot and do not guarantee that your content data will not be viewed by unauthorized persons.
  • Aggregated Data, We may store and use any anonymized or aggregated data such as statistical or demographic data that incorporates or is derived from your personal information, which is not itself personal information (“Aggregated Data”); however, we will not do so in a way that identifies you personally. For example, we may aggregate users’ behavioral data to calculate the percentage of users accessing a specific App feature, as well as facilitate and measure the effectiveness of advertisements. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Cookies and Similar Technology

The Technologies We Use for Automatic Information Collection May Include:

  • Cookies (or browser cookies).
  • Web Beacons.
  • Flash Cookies.
  • Click-through URL.
  • And other similar technologies.

When you visit or log in to Websites, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may include personal information. It helps us to improve our Websites or App and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Websites according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Websites.
  • Most websites will prompt you before accepting cookies. You may also change your cookies settings in your browser. Note, depending on your device or browser, it may not be possible to disable all tracking mechanisms. Also, if you set your browser to reject all cookies, parts of this Website may not work for you.

For more information, please see our Cookie Policy, which is incorporated herein by reference

Categories of Personal Information We Collected

Our Websites has collected the following categories of personal information from consumers within the last 12 months:

Category Examples Collected
Identifiers. Profile Data, Logistics Data, Technical Data, or Communication Data. YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Profile Data, Logistics Data, Financial Data, or Communication Data. YES
Protected classification characteristics under California or federal law. Communication Data. YES, only when needed in conversation with Customer Service for related support.
Commercial information. Logistics Data, or Consumer Preference Data. YES
Internet or other similar network activity. Usage Data. YES
Geolocation data. Location Data. YES
Sensory data. Communication Data. YES
Professional or employment-related information. Communication Data. YES, only when needed in conversation with Customer Service for related support.
Inferences drawn from other personal information. Consumer Preference Data. YES
How We Use the Collected Information

We use information that we collect about you or that you provide to us, including any personal data, generally based on the following purposes:

Types of Data Specific Purpose Legal Basis for Processing under GDPR (for EEA and UK Users)
Profile Data To allow you to register and log in to your account.

To enable you to place orders.

To investigate and prevent fraud.

To enable you to personalize your profile and provide you with region-available services.
Your consent 

Performance of a contract with you 

Necessary for our legitimate interests (for developing our products/services, running and growing our business, to prevent fraud) 

  

Logistics Data To fulfil your orders and deliver products to you.

To process warranty, returns and/or repairs.
You consent 

Performance of a contract with you 

Necessary for our legitimate interests (to keep records updated and to analyze how customers use our products/ services) 

Financial Data To process payments.

To detect and prevent fraud.
You consent 

Performance of a contract with you 

Necessary for our legitimate interests (to prevent fraud) 
Technical Data To operate, maintain, and provide you with the features and functionalities.

To identify your device for diagnostic purposes and fraud prevention.

To improve or develop our products and new technologies via analytics.

To personalize the product functionalities and services and improve our marketing strategies.
Necessary for our legitimate interests (for developing our products/services, running and growing our business, provision of administration and IT services, network security) 
Usage Data To operate, maintain, and provide to you the features and functionalities, to identify your device for diagnostic purposes and fraud prevention, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies.

To enable you to manually input and track your wellness data, tailor available features to your particularized needs, and provide you with personalized recommendations, product offerings and promotions.

To provide personalized recommended services.

To provide customer services, such as dealing with any enquiries and complaints.
Your consent 

Necessary for our legitimate interests (for developing our products/services, running and growing our business, provision of administration and IT services, network security)  
Consumer Preference Data To provide personalized recommended content and services which you can turn off through visiting account setting in the App.

To develop new products and features available through our service or otherwise improve our service.
You consent 

Necessary for our legitimate interests (for developing our products/services, running and growing our business) 
Communication Data To communicate with you.

To provide customer services, such as dealing with any inquiries and complaints.

To provide new promotions to you and to provide you with information on new products and/or services.
You consent 

Necessary for our legitimate interests (for developing our products/services, running and growing our business) 

  

Location Data To operate, maintain, and provide to you the features and functionalities, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies. You consent 

Necessary for our legitimate interests (for developing our products/services, running and growing our business, provision of administration and IT services, network security) 

Content Data To operate, maintain, and provide to you the features and functionalities, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies. You consent 

Necessary for our legitimate interests (for developing our products/services, running and growing our business) 

Wellness Data To operate, maintain, and provide to you the features and functionalities, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies.

To enable you to manually input and track your wellness data, tailor available features to your particularized needs, and provide you with personalized recommendations, product offerings and promotions.
You consent 

Necessary for our legitimate interests (for developing our products/services, running and growing our business) 

Personal Information Sharing and Disclosures

We may disclose personal information that we collect or you provide in the following ways:

  • Sharing with consent: with your consent or at your request, we will share your personal data within the scope of your consent/request with specific third parties or categories of third parties authorized or designated by you.
  • Sharing with Vesync’s corporate group: we may share your personal information with our subsidiaries, parents, affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services. For example, we verify the global uniqueness of accounts before allowing them to be registered.
  • Sharing with service providers: we also may disclose your information to contractors, service providers, or third parties we use to support our business. They usually perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, marketing, analytics, and other similar services. These service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.
  • Sharing with business partners: some products and/or services are provided to you directly by our partners. When you use third party products and/or services, we may share your information with them to provide you with the products and/or services you request. These third-party services are offered by independent data controllers and their use of your personal data is subject to their respective privacy policies. You should carefully review their policies to determine how they will treat your information.
  • Sharing for complying with the law or legal process: we may be required to respond to a subpoena, court order, search warrant, administrative or judicial process, requests by law enforcement agencies, or other requests that we must respond to under applicable law. We may disclose your personal information in response to any of these requirements.
  • Sharing for protection of our legal rights and/or those of others: we may disclose your personal information to preserve the security of our mobile applications, website, or social media accounts; resolve disputes; or assess any possible wrongdoing.
  • Sharing during asset transfer: to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our App users is among the assets transferred.
  • To enforce our rights arising from any contracts entered into between you and us, including the Terms of Use, and for billing and collection.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.

We will ensure that the lawfulness of this sharing and, if applicable, sign stringent non-disclosure agreements (NDAs) and/or data processing agreements/clauses with the companies, organizations, and individuals with whom personal data is shared, requiring them to comply with this policy and take appropriate confidentiality and security measures when processing personal information.

We may also share Aggregate Data collected about the application and device usage, as long as the data does not identify any specific individuals, to analyze trends about home networking and utility use, to show third parties how their products could work with our products and to generally improve our products and services.

In the preceding twelve (12) months, the Company has shared personal information with the categories of third parties indicated in the chart below.

Disclosure of "Sale" of Personal Data defined in Applicable States in the U.S.

While we don't sell your information for money, it's important to note that the use of cookies or sharing information with advertisers for cross-context behavioral advertising may be considered a "sale" of information in certain states.  In this specific context, we are considered to be "selling" information by making personal information available to third parties through third-party website cookies.   You have the option to decline these cookies through our cookie banner.

Personal Information Category Category of Third-Party Recipients
Business Purpose Disclosures Sales
Identifiers. Affiliates, Parent, subsidiary organizations or service providers/processors. Internet cookie data recipients like Google Analytics. See Cookie Policy.
California Customer Records personal information categories. Affiliates, Parent, subsidiary organizations or service providers/processors. For identifiers, we use Internet cookie data recipients like Google Analytics.  See Cookie Policy
For Financial Data, none.  Our Websites collect payment card or banking information to complete product purchases, but we do not store such information. All payments are processed by our payment service providers, PayPal and Stripe.
Protected classification characteristics under California or federal law. Affiliates, Parent, subsidiary organizations or service providers/processors. None
Commercial information. Affiliates, Parent, subsidiary organizations or service providers/processors. Internet cookie data recipients like Google Analytics. See Cookie Policy.
Internet or other similar network activity. Affiliates, Parent, subsidiary organizations or service providers/processors. Internet cookie data recipients like Google Analytics.  See Cookie Policy.
Geolocation data. Affiliates, Parent, subsidiary organizations or service providers/processors. Internet cookie data recipients like Google Analytics.  See Cookie Policy.
Sensory data. Affiliates, Parent, subsidiary organizations or service providers/processors. None
Professional or employment-related information. Affiliates, Parent, subsidiary organizations or service providers/processors. None
Non-public education information. Affiliates, Parent, subsidiary organizations or service providers/processors. None
Inferences drawn from other personal information. Affiliates, Parent, subsidiary organizations or service providers/processors. Internet cookie data recipients like Google Analytics.  See Cookie Policy.
Retention of Personal Information

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

This (Section 5) does not apply to deidentified or Aggregated Data.

How We Secure Personal Information

Vesync implements reasonable and appropriate industry-standard security controls to protect personal information in its possession. Vesync’s administrative, physical, and technical safeguards:

  • Provide assurances of the integrity and confidentiality of personal information covered by this policy.
  • Protect against reasonably anticipated threats or hazards to the security or integrity of personal information, and unauthorized uses or disclosures of such personal information; and
  • Facilitate compliance with legal frameworks of requirements under applicable data protection laws.

To this end, we take the following measures:

  • We take reasonable and feasible measures to ensure that the personal information collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal information for no longer than is necessary for the purposes stated in this policy and privacy notice of specific product or service, unless extending the retention period is required or permitted by law.
  • We use a range of technologies such as cryptographic technologies to ensure the confidentiality of information in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks.
  • We deploy access control mechanisms to ensure that only authorized personnel can access your personal information. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels.
  • We strictly select business partners and service providers and incorporate personal information protection requirements into commercial contracts, audits, and appraisal activities that are at least as stringent as the ones Vesync itself uses, consistent with this policy.
  • We hold security and privacy protection training courses or other equivalent publicity activities to raise employees' personal information protection awareness.

The safety and security of your data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out data in public areas of the App like Forum. The information you share in public areas may be viewed by any user of the App.

Although we do our best to protect your personal information, unfortunately, no security measures can provide absolute protection. To cope with possible risks, such as personal information leakage, damage, and loss, we have procedures in place to deal with suspected data security breaches. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with Contact Information below.

How We Protect Children's Personal Information

The Websites and services are not intended for children under the age of 18 or the equivalent age as specified by law in your jurisdiction. We do not knowingly collect personal information from children for purposes of marketing or sales. We also do not collect any personal information from children under the age of 18 without their parent’s or guardian’s consent. If we learn we have collected or received personal information from a child without parental consent, we will take steps to delete that information as soon as possible. If you believe that we have unknowingly collected information about a child in connection with our marketing or sales operations, please contact us using one of the methods in the Contact Information below for us to delete it.

Your Rights and Choices
Right to Know, Correct and Data Portability

You can access, correct, or modify the information you provided to us by editing your profile and adjusting your account settings.

You can also contact us to submit your right to access, correct, or modify your information.

To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with a deletion, portability, or other related request. We may, in certain situations, reject your request for access, correction, or portability, for example, we may reject access where you are unable to verify your identity.

Right to Delete

You can also contact us to submit your right to delete your information.   Please note that if you request deletion of your personal information, or if you delete your account, we may retain your personal information for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Also, because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Right to Opt-Out

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, please see our Cookie Policy.
  • Promotional Offers from the Vesync. You may utilize the unsubscribe function in each promotional email. You may also submit your request to opt-out by sending us an email stating your request to privacy@vesync.com.

This opt-out does not apply to information provided to us as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Right to Request a List of Third Parties

If applicable under states’ law or other regulations, you may have the right to request a list of third parties whom we have shared your personal information with.

Right to Appeal a Refusal

If we can't confirm your identity or authority to make a request, or if the information is legally required to be retained, we may not be able to honor your request.  If your request is denied, like in cases where we can't verify your identity, you can appeal our decision by contacting us.

Non-Discrimination

We won't treat you differently for exercising your rights and choices. However, please note that some features or functionality on our Websites may change or become unavailable to you based on the information you provide.

If you are a user in the EEA or in the UK, you may have additional rights

Right to restriction of processing

For users in the EEA or the UK, you have the right to restrict the processing of your personal data in accordance with applicable laws.

Withdraw consent

For users in the EEA or the UK, you have the right to withdraw consent at any time when we are relying on consent to process your personal data. However, this may not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

You can exercise your rights by contacting us. You can also lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by us.

Links to Other Parties’ Websites, Products, and Services

The Websites and services may contain links to third-party websites, products, and services of interest. All links to third-party websites, products, and services are provided for users' convenience only. You need to determine your interaction with such links on your own. We cannot be responsible for the protection and privacy of any information which you provide while visiting or using such third-party websites, products, and/or services and they are not governed by this policy. You should exercise caution and look at the privacy statement applicable in question.

Data Transfer Outside EEA Countries and UK

Where personal data originated in the EEA, this will involve transferring your data outside the EEA.

Whenever we transfer personal data to countries outside of the EEA, we will ensure that the data is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection. Our commitment includes ensuring that an equivalent level of protection is afforded to it by ensuring appropriate safeguards are implemented in the form of specific contracts approved by the European Commission.

Please contact us if you want further information on the transfer of personal data outside of the EEA.

With regard to Do Not Track (DNT), we currently don’t respond to DNT signals in browsers because no DNT standard has been adopted.

Do Not Track Disclosures

With regard to Do Not Track (DNT), we currently don’t respond to DNT signals in browsers because no DNT standard has been adopted.

Entire Privacy Policy

We may provide you with separate privacy notices for specific products and services, and such privacy notices are incorporated into herein by reference. If there is any inconsistency between privacy notices and this Privacy Policy, the privacy notice shall prevail.

Changes to Our Privacy Policy

Our business changes constantly, and our privacy policy and the terms of use will also change accordingly. We may email periodic reminders of our policy and terms, but you should check our applications of legal & policy frequently to see the most recent changes. Unless stated otherwise, our current privacy policy applies to all data that we have about you and your account(s).

We stand behind the promises we make and will never materially change our policies and practices to make them materially less protective of user information collected in the past without the consent of affected users. However, we may amend this policy from time to time. We will make amendments to the policy by displaying an amended copy on our Websites and App, and, if necessary, by sending a notice to you by email. Your continued use of our applications after the revision will constitute your approval of the revised version.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically checking our application and this privacy policy for any changes.

Contact Information

Please direct all requests for assistance, questions, or complaints about our privacy practices to our privacy team by email, postal mail, or phone at the following contact data:

Attention:  Privacy Team

Email:  privacy@vesync.com

Postal Address:  1202 North Miller Street, Suite A, Anaheim, CA 92806 US

If you are EEA and UK users, please contact us via the following address:

Legal representative in EEA: ETEKCITY GmbH

Postal Address at Vossbarg 1,25524 Itzehoe, Germany

Legal representative in the UK: Vesync (UK) Co., Ltd

Postal Address: Unit G2 Havebside Industrial Estate, Fishtoft Road, Boston, PE21 0AH, United Kingdom

If you have any concerns or complaints about Vesync’s privacy policies or practices, please provide information relevant to your complaint. Our privacy team will evaluate your concern or complaint based on the information you provide and send you a response. We may need to ask you for additional information to evaluate your concern or complaint. We will promptly investigate and respond to your communications about a complaint. You may have other rights under the law and the right to contact the privacy regulator in your local jurisdiction about your concern or complaint.

 

We're here to help

Get advice or help from our experts Monday - Friday 9am to 5pm PST.

 - cosori-support-img