Privacy Agreement

Introduction

Thanks for usingthe cleaning robot (hereinafter referred to as “the robot”) independently developed and manufactured by Shanghai Gaussian Automation Technology Development Co., Ltd. (hereinafter referred to as “we”). We are keenly aware of the significance of your personal information in the process of product use. Therefore, we formulate Gaussian User Privacy Policy (hereinafter referred to as “the Policy”) in accordance with Cybersecurity Law of the People’s Republic of China, Information Security Technology – Personal Information Security Specification (GB/T 35273-2017), other relevant laws, regulations and technical specifications.

The Policy is closely related to our product used by you and/or other relevant services. When you use our product and/or relevant services, wewillnotify you how Gaussian gathers, uses and stores your personal information and what rights you have, and process and protect your personal information according to the Policy. Therefore, we sincerely hope that you can carefully read and comprehensively understand the Policy, and make the choice as you think appropriate under the guidance of thePrivacy Policyas needed. We endeavor to explain relevant technical terms mentioned herein concisely. The aforementioned clauses shall be in bold and highlighted so as to draw your special attention.

You shall choose whether to agree on the contents of the Policy after carefully reading and comprehensively understanding the Policy. Your disagreement on the Policy may cause the failure of partial product services, or the non-fulfillment of the proposed performance. If you finish registering the Gaussian account, or actually use our services and products, it shall be deemed your consent to the gathering, use and storage of your relevant information in accordance with the Privacy Policy.

Before you read the Policy, we hereby undertake to you:

(1) When you use our product, or we offer services to you, we will gather some of your sensitive information after acquiring your explicit authorization, unless such information must be gathered according to the requirements of relevant laws and regulations. If you refuse to provide such information, you shall solely be prevented from using certain functions, and you shall still be able to normally use the core functions of our products and services. We shall not proactively disclose your personal information externally or offer your personal information to any third party. If such information should be shared with third party or your personal information should be transferred, we shall explain the reason and obtain your explicit consent, or such third party and the App (or the App affiliated company) shall separately or jointly offer services to you, and such access to all the information, including the information accessible previously, shall be forbidden after the service ends.

(2) You may access, correct and delete your personal information in the methods or on the channels prescribed herein, or cancel the agreement, deregister the account, complain and set the privacy functions so as to control your personal information.

(3) We shall gather, store, use and share your information so as to offer better services to you and improve the product quality (i.e. Support the new product development, improve existing product functions, offer and recommend better or appropriate services to you) .

(4) If you have any questions or other relevant inquires when reading the Policy, we have provided multiple feedback channels for you. Please refer to the Section “Contact us” for the details. Our data protection specialist shall process your special demands in time. We are pleased to directly process your questions and meet your demands.

The Gaussian User Privacy Policy shall inform you of the following contents

I. How we gather and use your personal information

II. How we use Cookie and Beacon technologies

III. How we store and protect the personal information

IV. How we entrust, share, transfer and publicly disclose your personal information

V. How to access and control your personal information

VI. Statement on third party liability

VII. Special provision on the minor’s privacy right

VIII. Application and revision of the Policy

IX. Keyword description of the Policy

X. Contact us

I. How we gather and use your personal information

1. The information provided by you for the registration of Gaussian account. When you register Gaussian account, and use Gaussian products and services through your Gaussian account, we will gather and store your personal information, including your email address, user name and password, user account for third-party software, nickname and profile icon, delivery address, billing information and phone number. We gather and use such information so as to offer products and services to you, process the orders and deliver, offer customer services and directly communicate with you, such as sending email of new product introduction, account verification, order confirmation, and major changes and update of service functions, technical and security notice to you. You may reject such emails or push notification through relevant email settings. Moreover, we may also gather other information so as to offer service to you and improve the service quality, such as relevant information provided by you during the communication with our customer service team, and the questionnaire answers sent to us for your participation in the questionnaire survey. If you refuse to provide such information, the general functions of Gaussian services shall not be affected, but the service quality may be affected.

2.The information gathered by us from the registered robot device. If you register online on the App and link to the robot, we shall gather your location information, terminal information (i.e. Device ID, serial No. or product code, and IP address), and we may also gather the robot cleanable contour and relevant activity status so as to assist you in handling the faults and error report under special situation.

3. The information gathered by use from the website and mobile device client. To guarantee the service quality and your information security, when you visit Gaussian website or Gaussian mobile device client, and use Gaussian services, we may record the type, method, operation information of the services you use and other log information related to the services, such as your IP address, version used on mobile device, device identification code, device identifier, and your location. 

You hereby acknowledge and agree that pursuant to applicable laws and regulations, court order, other legal procedure, administrative or judicial statutory requirements, we may provide your personal information for corresponding competent authority without obtaining your consent.

II. How we use Cookie and Beacon technologies

1. How we use Cookie technology to automatically gather information. To provide more convenient access experience for you, when you visit Gaussian website or use Gaussian services, we may identify you with small data file so as to leave out the procedure of repeated registration information input, or help judge the account security status. The data file may be Cookie, Flash Cookie, or other local storage provided by your browser or associated applications (collectively referred to as “Cookie”). The system may automatically gather the following information with Cookie:

Device or software information, such as configuration information provided by your mobile device, webpage browser or other application for access to our service, your IP address, version on the mobile device, and device identification code;

The search or browse information during the use of our service, such as the webpage search word used by you, accessed webpage URL address, and other information and content details browsed or provided during your use of our services.

2. How we use Beacon or other technology to automatically gather information. To further understand your product and service preferences and improve our service for you, electronic images (referred to as “single-pixel GIF file” or “network Beacon”) have been embedded on our website to gather the information of your webpage view, such as the webpage address viewed by you, the address of the citation page viewed previously, and your browse environment and display settings.

3. Third-party Cookies or Beacon probably existing in our products and services. The Cookies and Beacon set by the advertiser or other partners may exist in our products and services. Such Cookies and Beaconmay gather your non-identification information so as to analyze how the user uses such service, send the advertisement you would be interested in, or assess the performance of the advertisement service. Such information gathering and use by third-party Cookies and Beacon is restricted not by the Policy but by the privacy policy of relevant user. We shall not undertake the responsibilities for third-party Cookies and Beacon.

4. How to reject the information gathering by us with the technologies, including Cookies and Beacon. You may reject or manage Cookies or Beacon in browser settings. Please be informed that if you disable cookies or Beacon, you may not be able to enjoy the optimal service experience, and some services may not be available.

III. How we store and protect the personal information

1. The location of the information stored by us. The personal information gathered and generated in China shall be stored by us in China. If we need to transmit relevant personal information gathered in China to overseas institution due to business needs, we shall execute in accordance with the laws, administrative regulations, and the provisions of relevant regulatory department, and take effective measures, such as agreement signing and inspection. We shall inform you of the purpose of information overseas transmission, recipient, security measures and security risks, and require the overseas institution to keep the personal information that it acquires confidential. If you choose to deregister your account, we shall delete your information or conduct anonymous processing, unless relevant laws and regulations prescribe that certain information must be stored for certain period. As for the aforementioned information that must be stored, we shall delete or conduct anonymous processing after the expiry of the storage period prescribed in laws and regulations.

2. Our data security capacity and policy. We hereby undertake that our information security protection reaches the level prescribed in the laws and regulations. We shall take security measures up to industry standard to protect your personal information and prevent the data from unauthorized access, public disclosure, use, revision, damage or loss. We shall take advanced technical protective measures. The technical means that we apply shall include but not limited to firewall, encryption (i.e. SSL), de-identification or anonymous processing, and access control measures. Moreover, we shall continuously enhance the security capacity of the software installed on your device. For instance, we shall conduct local partial information encryption on your device so as to solidify secure transmission; we shall learn the installed application information and operated process information for your device so as to prevent malware, such as virus and Trojan. We have established specialized management system, procedure and organization for the protection of personal information security. For instance, we strictly restrict the scope of the persons with access to the information, require such persons to fulfill the obligation of confidentiality, and audit. The persons breaching the obligation shall be punished in accordance with the provisions. We shall also audit the management system, procedure and organization so as to prevent the unauthorized persons from arbitrary access, use or disclosure of the users’ information.

We hereby recommend that you should be fully aware of the personal information protection while using the products and services. We shall also provide multiple security functions to assist you in protecting the personal information security.

3. Our reporting mechanism of personal information security incident. You should acknowledge that based on the restriction of technical level and potential malicious means, personal information security incident may unfortunately happen due to the factor beyond our control. If security incident happens, the emergency response plan shall be activated so as to prevent the aggravation of the security incident. We shall inform you of the followings in time according to the requirements of the laws and regulations: General condition of security incident and potential influence, the measures taken or to be taken by us, the advice on your autonomous prevention and risk lowering, and remedial measures for you. We shall inform you of the incident conditions via email, letter, phone call or push notification in time. If it is difficult to notify everyone, we shall publish the announcement in reasonable and effective mode. Meanwhile, we shall proactively report the processing of the personal information security incident according to the requirements of the regulatory department.

4. Our deletion of your information. If we terminates provision ofthe service to you or terminates the operation, we shall stop gathering your personal information in time, inform you in individual notice of operation termination or the announcement, and delete your information stored by us or conduct anonymous processing.

IV. How we entrust, share, transfer and publicly disclose your personal information

(I) Entrust the processing

To offer better or the required products or services to you, we may entrust third-party service provider to analyze and process your personal information. The aforementioned third-party service provider shall analyze and process your personal information on behalf of Gaussian. Some third-party service providersmay gather the data generated when you use the product with the software in the product, such as xiaoneng and umeng. Such third parties may gather your IP address, webpage access record, online customer service consultation data, problem feedback data, App statistical data, etc. so as to servethe purposes of software and product optimization, customer data management and enhancement, customer service, assessment of your interest in our products and services, pushing of customized advertisement to you, customer survey or customer satisfaction survey.

Gaussian hereby undertakes that we shall meet the following requirements when we entrust third party to process the personal information:

1. We shall not analyze and process the information beyond the scope authorized by you.

2. We shall assess the data security capacity of third-party service provider in advance so as to guarantee that it holds the data security capacity required in the laws and regulations;

3. We shall bind the third-party service providers with the responsibilities and obligations through contract so as to let such providers comply with all the applicable laws and regulations in your attributed judicial jurisdiction, industry rules and standards, enterprise specifications and code of conduct, and require such providers to fulfill the obligations for you in the standard not superior to ours.

4. We shall accurately record and store the condition of personal information entrusted for processing, and guarantee your information security and the effective access and control of your information.

5. If we cancel the entrustment relationship, we shall require the third-party service provider to delete your personal information and destroy all the data copies.

(II) Share and transfer

In principle, we shall not share or transfer your personal information with/to any company, organization and individual. In the following exceptional cases, we shall share your personal information for legal, adequate and necessary purposes. The third party accepting the data shall not be entitled to use the personal information shared or transferred by us for other purposes than these prescribed herein.

1. It is necessary for the product or service provision to you and explicit consent is obtained from you in advance

You hereby acknowledge and agree that to offer better or the required products or services to you, Gaussian may share or transfer your personal information with/to the affiliated companies or other third-party service providers under the premise that your explicit consent is obtained. For instance, when you purchase goods on Gaussian website, we may share your transaction information with the bank or your transaction counterparty so as to prove the authenticity of the transaction and protect your legal rights and interests. Meanwhile, we must share your address information with the logistics service provider so as to arrange the delivery. Gaussian may also entrust the third-party data analysis company to analyze ad process your personal information, and so on.

Gaussian hereby undertakes that we shall meet the following requirements when we share or transfer your personal information with/to the aforementioned third party:

(1) We shall assess the personal information security influence in advance, and take effective measures to protect the personal information subject according to the assessment result;

(2) We shall accurately record and store the condition of your personal information sharing and transfer, including but not limited to the date, scale and purpose of sharing and transfer, and profile of data recipient, so as to help you to learn the storage and use of your information by the data recipient;

(3) We shall protect your information security and the effective access and control of your information, such as access, correction, deletion, and account deregistration.

2. Information transfer at the time of changes, such as acquisition, merger, and restructuring

With the continuous development of our business, we may conduct the transactions, including merger, acquisition, and asset transfer. We shall inform you of relevant situation, and continue protecting or require the data recipient to continue protecting your personal information in the standard not superior to that prescribed herein in accordance with the laws and regulations.

3. Personal information sharing according to the statutory requirements of the laws, regulations and regulatory authority

We may provide your personal information for corresponding competent authority pursuant to applicable laws and regulations, court order, other legal procedure, administrative or judicial statutory requirements, and your consent may not be obtained for the information sharing in such scenario.

(III) Public disclosure 

We shall not publicly disclose your personal information. In case of compulsory public disclosure, we shall inform you of the purpose of such public disclosure, type of disclosed information, and sensitive information probably involved, and obtain your explicit consent.

V. How to access and control your personal information

1. How to access and revise your personal information. You may access your Gaussian account on Gaussian official website, click “Account Management”, or access your Gaussian account on mobile phone client, click “Profile” to view or revise your profile or arrange relevant privacy and security settings; however, in consideration of security and identity verification, or pursuant to statutory provision of the laws and regulations, you may not be able to revise some initial registration information provided by you at the time of registration.

2. How to reject the marketing notices. You may reject the marketing notices pushed by us to you through clicking the “Cancel subscription” button in any email sent by us. Please be informed that you cannot cancel the subscription of or reject the information related to your account, such as account verification, order confirmation, change or update of service functions, or technical and security notification.

3. How to delete your personal information. If you find that our gathering and use of your personal information violates the laws, regulations, or the agreement with you, you may contact [http://www.gs-robot.com] or online customer service to request the deletion of your personal information gathered in connection with such violation.

4. How to correct your personal information. If you find that your personal information gathered and stored by us is incorrect, regulations, you may contact [http://www.gs-robot.com] or online customer service to request the correction.

5. Before we respond to your requirements prescribed in preceding item 3 and 4, we shall first verify your identification and credential information for the purpose of security. After you pass the verification, the requirement shall be accomplished within five (5) working days; in special cases, we shall respond or give the reasonable explanation on no timely response within thirty (30) days or the period prescribed in the laws and regulations. Moreover, we shall notify any third party receiving your information according to Section 4 to respond to your requirements prescribed in item 3 and 4.

6. How to deregister your Gaussian account. You may contact [http://www.gs-robot.com] or online customer service to request the deregistration of your Gaussian account. Please be informed that after your account is deregistered, we shall delete your personal information or conduct anonymous processing.

7. Notwithstanding the foregoing, we may share, transfer, or publicly disclose your personal information without winning your prior consent according to the requirements of the laws and regulations under the following situations:

(1) The state security and national defense security are directly involved;

(2) The public security, public health, and major public interests are directly involved;

(3) The criminal investigation, prosecution, trial and judgment execution are directly involved;

(4) We hold adequate evidence proving that you have subjective malice or abuse the rights;

(5) The response to your request will cause serious damages to your, other individuals’ or organizations’s legal rights and interests;

(6) Business secret is involved;

(7)The personal information gathered is autonomously disclosed by the personal information subject to the public;

(8)Your personal information is gathered from the legal and publicly disclosed information, such as legal news report and government information publicity.

VI. Statement on third party liability

Please be informed that the third-party website operator accessed by you during the use of our products and services, third-party services accessed from us, and third party receiving your personal information from Gaussian may have their own privacy policy. When you view the webpage created by third party or use the application developed by the third party, such third party may gather and use your personal information. We do not directly participate in the data gathering and use of the aforementioned third party. The data gathering and use of such third party is not bound by the Policy, but the privacy policy of relevant gatherer or user. We shall not undertake the responsibilities for the aforementioned data gathering and use of such third party. We shall take reasonable business efforts to require such entities to take protective measure for your personal information, but we cannot guarantee that such entities will take protective measures at our request. Please directly contact them or view the privacy policy published from time to time on such third-party official website for more information. If you find that the webpage created or the application developed by such third party is at risk, it is suggested that you should terminate relevant operation so as to protect your legal rights and interests.

VII. Special provision on the minor’s privacy right

Gaussian shall protect the confidentiality and security of minors’ personal information in accordance with relevant national law and regulations. We anticipate that the parents or guardian can guide the minors to use our service. If you are under 18 years of age, or you are a minor in accordance with the laws and regulations in your locality, it is suggested that you should read the Policy with your parents or guardian, and use our service or provide your information for us with the consent of your parents or guardian. If your guardian does not agree on your use of our service or the provision of your information for us according to the Policy, you shall immediately terminate using our service and notify us in time so that we can take corresponding measures.

We shall solely use, externally provide or publicly disclose such information with the permission of the laws and regulations, explicit consent of the minor’s guardian, or for the purpose of protecting the minor.

If you are the guardian of the minor, you are kindly required to find out whether the minor under your guardianship uses Gaussian services with your consent. If you have any doubt about the personal information of the minor under your guardianship, please contact us according to the contact information stated in Section X.

VIII. Application and revision of the Policy

The Policy shall be applicable to all the Gaussian products and services.

We may revise the Policy as appropriate. If the terms of the Policy change, we shall present the revised Privacy Policy to you in the form of push notification and state the effective date when you log in and at the time of version update. Please be informed that only if you click the button of agree, shall we gather, use and store your personal information in accordance with the updated Privacy Policy. Please carefully read the updated Privacy Policy. Your continued use of Gaussian shall be deemed your consent to our processing of your personal information according to the updated Privacy Policy.

You may view the Policy at the bottom of our official website homepage, or in “About - Privacy Policy” on Gaussian mobile client. We encourage you to view our privacy policy whenever you access our service.

IX. Keyword description of the Policy

“Gaussian affiliated companies” herein refer to any company and legal institution currently controlled or to be controlled by Gaussian Robotics in the future, controlling Gaussian currently or in the future, or under the joint control with Gaussian, and the legal successors of the aforementioned companies and legal institutions.

X. Contact us

You may contact us on [http://www.gs-robot.com] or through online customer service.

Thank you for taking the time to learn our privacy policy! We shall make every effort to protect your personal information and legal rights and interests. We appreciate your trust!