Our Privacy Policy was updated on may 25, 2018. We have revised our Privacy Policy so that, beginning from this date, this Privacy Policy will be able to provide details about how we manage the personal information you disclose when using Xparkle products and services. This excludes Xparkle products or services for which a separate privacy policy is provided.
Please take some time to familiarize yourself with our privacy practices, and let us know if you have any questions.
This Privacy Policy describes how SkyRC Technology Co.,LTD. and its affiliates (hereinafter referred to as "Xparkle" or "We") collects, uses, discloses, processes, and safeguards the information you provide to us through the Xparkle app when using our products or services. If We ask you to provide certain information in order to verify your identity when using Xparkle products or services, We will use this information in strict accordance with this Privacy Policy and/or our User Terms and Conditions.
This Privacy Policy was developed with full consideration of your needs taken into account. It is important that you fully understand our personal data collection and usage practices and feel confident in your ability to control the personal information you provide to Xparkle.
In this Privacy Policy, "personal information" refers to data, either derived from information itself or from other related personal information that Xparkle is able to access, that can distinguish a specific individual. This type of personal information may include your name, phone number, or email address.
By using Xparkle products and services, you acknowledge that you have read, agreed to and accepted all of the terms included in this Privacy Policy, including any changes We make at any time. We are committed to protecting the privacy, confidentiality, and the security of your personal information in compliance with applicable law (including data protection law in your area), and we guarantee that all of our employees and agents will fulfill these obligations.
Finally, We want to bring the best experience to our users. If you have any questions about the data processing practices outlined in this Privacy Policy, please contact our Support Officer at
[email protected] so that We can best see to your needs. We are very happy to directly address any questions or issues you may have.
What information is collected, and how is it used?
(1). Types of information collected
When providing you with services, We will ask you for personal information that is necessary for us to successfully provide those services. If you do not provide us with this personal information, We may not be able to provide our products or services to you.
We collect the following types of information (regardless of whether or not they are considered to be personal information):
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Information you provide to us or upload: We may collect personal information you provide to us including your name, phone number, email address, account information (e.g. security-related information such as name, birthday, and sex), information or data that is synchronized with the device you use to access the Xparkle portal, information used to create your account or related to your account setup on the Xparkle portal, devices you add or information that you send, and feedback.
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Information related to the handheld device terminal or your SIM card: information related to the operation of the Xparkle handheld device terminal. This includes, for example, IMEI number, IMSI number, the version of your operating system, manufacturing information about your device, model name, and network operator.
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Device information: information about the device associated with your account. For example: MAC address, DID, network status of the device (IP/network signal), and the version of your firmware.
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Information We designate that is about you: We may collect and use content such as information related to your account.
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Location information (only for specific services/features): a variety of different kinds of information related to your location. For example, country code, city code, mobile network code, district name, information about latitude and longitude, and language settings.
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Login information: information related to your use of certain features and devices. Information includes, for example, cookie and other anonymous labeling and marking technology, IP address, temporary messaging history, and standard system logs.
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Other information: Environmental Feature Value (ECV) (for device-bound accounts (email and phone number), account number and password for connected Wi-Fi accounts)
We may also collect other kinds of anonymous information that is not related to an individual. For example, when using a specific service, a user's device, device model number, and the version number of the user's firmware may all be collected. The type and amount of information collected depends on how you use, join, or participate in our products and/or services.
(2). How this personal information is used
The purpose of collecting personal information is to provide you with products and/or services while also ensuring that We comply with applicable law. You hereby agree to our processing of personal information in accordance with the purposes stipulated by this Privacy Policy, and you agree to disclose personal information to our affiliates (these may include communications, social media, technology, or cloud services) and to third-party service providers (as defined below). We may use your personal information for the following purposes:
- Provider services, processing, maintenance, improvement, development of the products and/or services We provide you, and services provided through your device or by Xparkle.
- Communication with you regarding your device, services, or any other common queries (including updates, device firmawer/software updates, customer support, related information, and notifications).
- Analysis and development of statistical information related to the use of our products and services that is used to further improve our products and services.
- Storage and maintenance of your information, to be used in our business operations or to fulfill legal obligations.
More details on how We use your information (including personal information) are provided below:
- Creating your account. The personal information that is collected when an account is created on a mobile device is used to create a user's personal account and information pages.
- Providing location-based services. When using Xparkle devices, We may use information about your location to determine the time zone of the device. This will ensure that the device accurately displays the correct time and login service area. It will also optimize user experience by providing services such as advance activation of the corresponding device at a time set by the user. You can turn off this feature at any time by going to device settings or by discontinuing your use of this application.
- Accessing devices. The authenticity of devices that are operated through the app must be verified. We therefore need to confirm the legal identity of the device by consulting the factory MAC and DID information. In addition, in order to connect the device to the network, it will need to be configured through the app. During configuration, you must enter the corresponding Wi-Fi name and password. This information will only be used to connect the device to the network. The Wi-Fi and password data you enter will be encrypted and stored locally on your device; it will not be uploaded to the server. In addition, you can access the device and delete this information at any time. We also need to analyze the device's IP and network signal in order to determine the optimal network connection method. This will ensure the stability of the device network.
- Display of device status. This allows you to view the status of the device remotely that you can check at any time whether or not the device is running.
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Providing push services. Account numbers and IMEO Numbers will also be used for the Xparkle push service, which sends device notifications to the user. You can turn off this feature at any time by changing the preferences listed under "Message Settings."
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Collecting user feedback. The feedback you choose to provide is extremely valuable, as it helps us improve the services provided by Xparkle. In order to track your feedback, Xparkle may use the personal information you provide to contact you and to keep records.
- Sending notifications. We may occasionally use your personal information to send important notifications, for example, notifications about the status of device malfunctions; your customized device push notifications (which depend on what additional equipment you have purchased); and changes to our terms, conditions, and policies.
We may use your name, phone number, email address, account number, or IMEI number to provide you with promotional information related to products and services provided by SkyRC Technology Co.,LTD. or by its partners (who provide web and mobile applications and cloud-related products and services). We strictly abide by local data protection law and require your independent and explicit permission. This means that We will only use your personal information after We have obtained your consent or after you express that you have no objections. You also have the right to stop our planned use of your personal data for direct marketing purposes.
Access third-party software development kit (SDK)
In order to adapt to the use of Xparkle mobile application and third-party platform services on different mobile devices, to achieve your mobile device identity authentication, mobile device security, receive information pushes, log in to third-party platform accounts, and share information through third-party platforms. The Xparkle mobile application is connected to a third-party SDK. The aforementioned third-party SDK providers include mobile phone device manufacturers, social platforms and communication operators. Some third-party SDKs may call your device permissions and obtain your related information so that you can use the corresponding functions normally on different mobile devices or third-party platforms. Different third-party SDKs may call different types of device permissions and information obtained, which may include obtaining your location information, reading/writing your external memory card, reading your mobile phone status and identity, viewing WLAN connection, and searching Running application/Bluetooth. Regarding the specific types of device permissions called by the third-party SDK and how to collect and use your personal information, it is recommended that you refer to the relevant service agreement and privacy policy of the third-party SDK. The following is a detailed description of the third-party SDK:
SDK: Tencent Bugly
Operator: Tencent Technology Co., Ltd.
Website:
http://bugly.qq.com/v2/contract Intention: To improve the stability of the service, it is convenient for the related service
to quickly and accurately locate the problem after the crash.
Privacy practices: Crash environment (Crash information and thread stack, ROM/RAM/SD card
capacity, network/language status App information: package name, version, process name), device
information, device manufacturer, device name, operating system Version, operator code, App
operating status, crash, freeze, network information, log information.
SDK: Umeng
Operator: Umeng Technology(Bei jing) Co., Ltd.
Website:
https://www.umeng.com/page/policy?spm=a211eg.10560647.0.0.547034dcbzinI9 Intention: Data analysis and message push notification
Privacy practices: Networking information, MAC address, Unique Device Identification Code
(IMEI/Android ID/IDFA/OPENUDID/GUID, bssid, IMSI information of SIM card), IP address, location
information.
SDK Wechat
Operator: Tencent Technology(Shen Zhen) Co., Ltd.
Website:
https://privacy.qq.com/ Intention: Login via Wechat
Privacy practices: Networking information, MAC address, Device information.
SDK: Tuyasmart
Operator: Hangzhou Tuya Information Technology Co., Ltd.
Website:
https://auth.tuya.com/privacy Intention: Control and monitor devices by Tuya
Privacy practices: Networking information, MAC address, Device information.
Who do We share your information with?
We will never sell any of your personal information to a third party.
At times, We may disclose your personal information to a third party (as defined below) in order to provide products or services that you have requested.
We may disclose information to the third-party service providers and affiliates listed at the end of the section. In any of the various situations described at the end of the section, you can rest assured that Xparkle will only share the personal information that you have authorized. Please understand that if, in any of the situations described below, Xparkle shares your information with a third-party service provider, Xparkle will abide by applicable local data protection law by specifying what the third party's practices and obligations are in its contract. Xparkle guarantees that it will contractually obligate third-party service providers to comply with all applicable privacy standards in your jurisdiction.
(1). Sharing information with our group and with third-party service provider
In order to operate successfully and provide you with the full functionality of our products and services, We may occasionally disclose your personal information to other Xparkle affiliates (these may include communications, social media, technology, or cloud services) or with our third-party service providers (our mailing centers, delivery services providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and promotional service providers, and agents representing Xparkle) [affiliated companies and/or other third parties] (collectively referred to as "third-party service providers"). These kinds of third-party service providers may process your personal information as a representative of Xparkle, or they may fall into one of the categories listed above. When using certain mobile applications on our devices, We may share your IP address with third parties in order to provide certain services you have requested. If you would no longer like us to share this information, please contact us by sending an email to
[email protected]
(2). The sharing of information with others
Xparkle may disclose your personal information to others without further consent when it is required by law.
(3). Information that does not require consent
We may share anonymous information in aggregate form with third parties (such as advertisers on our website) for commercial purposes. We may share trends in common usage of our services, for example, the number of customers in a particular group who purchase certain products or engage in certain transactions.
In order to avoid any suspicion, Xparkle may collect, use, or disclose your personal information without your consent if and only if expressly permitted by local data protection law (to, for example, comply with a subpoena). We may also disclose your information without your consent if We believe in good faith that it must be disclosed in order to protect our rights, your safety, or the safety of others; investigate fraud; or respond to government requests.
(1). Xparkle's security measures
We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure, or other similar breaches, We have implemented physical, electronic, and management-related measures to protect the information We collect from you during your use of the Xparkle app. We will take all appropriate measures to protect your personal information.。
For example, When you send information to our server from your Xparkle device or receive information through the same channel, We make sure that it is encrypted using a number of protocols.
All of your personal information is stored on secure servers and protected in controlled facilities. We also guarantee that employees and third-party service providers who provide products and services to you by accessing this information will be held under strict contractual confidentiality obligations. If these obligations are not filled, they will be subject to disciplinary action or contract termination. Similarly, We have established dedicated access control measures for cloud-based data storage. In summary, We regularly review our information collection, storage, and processing practices, including physical security measures taken in order to prevent any unauthorized access and use.
We will take all measures possible to protect your personal information. You should, however, be aware that the Internet is not always secure. Because of this, We cannot guarantee the security or integrity of any personal information when it is being transmitted online in either direction.
You can ensure that your personal information remains protected by not revealing your login password or account information to anyone (unless it is a person you have officially authorized). When you log into Xparkle as a account user, no matter when, and especially if you are using another person's computer or a public Internet portal, you should always log out at the end of the session.
Xparkle is not responsible for security oversights caused by third parties accessing your personal information that are the result of your inability to ensure the privacy of your own personal information. Notwithstanding the foregoing, you must immediately notify us if any online users access your account without permission or if any other security breaches occur.
Your assistance will help us better protect your personal information.
We retain information We collect about you as long as it is still needed for the purposes We obtained it or as long as it is needed to comply with applicable legal requirements or permissions. As long as We can reasonably infer that this retention of personal information cannot lead to the collecting of personal information, and as long as We no longer need to retain this information for legal reasons, dispute resolution, enforcement of our agreements, or any other business related purposes, We will not retain personal information, or We will eliminate any ways in which this personal information can be connected to specific individuals.
Accessing other features on your device
Our application may need to access certain features on your device, for example, Wi-Fi network status. This information is necessary for these applications to be able to run on your device and for you to be able to interact with them. You can close the application on your device at any time, or you can contact us at
[email protected] to revoke your consent.
You can submit a request by sending an email to
[email protected], in which you can request to withdraw your consent for us to collect, use and/or disclose any of your personal information that We hold or control. We will process your submission within a reasonable amount time, after which, We will abide by your request and no longer collect, use, and/or disclose your personal information.
Please note that your revocation of consent may result in some legal consequences. Based on the extent to which you decide to revoke consent for us to process your personal information, you may no longer be able to enjoy the use of Xparkle products or services.
The transfer of personal information to areas outside your jurisdiction
If We need to transfer personal information outside your jurisdiction, whether it is transferred to our affiliates (these may include communications, social media, technology, or cloud services) or to third-party service providers, We will always comply with applicable law. In particular, in order to ensure that all such transfers comply with applicable local data protection law, We will implement appropriate security safeguards. For example, if you choose to use other third-party services available for this product or service (such as Amazon Alexa, Google Assistant, etc.), those third parties may be able to read information about you, information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.
We believe that it is the responsibility of parents to supervise their children when using our products and services. Our policy, however, does not require us to obtain the personal information of minors or to send any promotional materials to these kinds of people.
Xparkle will not seek or attempt to seek out any way to obtain personal information from a minor. If parents or guardians have reason to believe that a minor has submitted personal information to Xparkle without their prior consent, they should contact us to ensure that such personal information is removed and that subscriptions the minor may have for any applicable Xparkle services are canceled.
If you agree to an applicable user agreement, and if there is any inconsistency between the user agreement and this Privacy Policy, the user agreement will prevail.
(3). Privacy Policy updates
We periodically review our Privacy Policy, and We may update it to reflect changes in our information practices. If We make a substantial change to this Privacy Policy, We will notify you by email (using the email address specified in your account), by releasing a notice in the Xparkle app, or by contacting you via your mobile device. This will allow you to understand what information We collect and how We use it. These kinds of changes to this Privacy Policy will be effective starting on the date specified in the notice or on the website. We recommend that you visit this page regularly for the latest information on our privacy practices. Your continued use of products and of website, cell phone and/or any other device-based services will be deemed as your acceptance of the updated Privacy Policy. If We collect additional personal information from you, or if We wish to use or reveal your personal information for a new purpose, We will once again seek your consent.
(4). Do I have to agree to all terms and conditions of third parties?
Our Privacy Policy does not apply to products and services provided by third parties. Xparkle Products and services may include third party products and services, as well as links to third-party websites. When you use these products or services, they may also collect your information. Because of this, we strongly urge you to spend time reading the privacy policies of these third parties, just as you have read ours. We do not take any responsibility for the way in which third parties use the personal information they collect from you, nor do We have any control over how they use it. Our Privacy Policy does not apply to other websites whose links can be accessed through our services.
Depending on your jurisdiction, you may be able to log into our website using login services provided by Facebook Connect or by Open ID. These services will verify your identity and allow you to choose whether or not you want to share certain personal information (such as your name and email address) with us to populate our registration form. Services like Facebook Connect allow you to choose whether or not you want to share information about your personal activity from their site on your profile page so that it can be shared with other people in your network.
If you have any questions or feedback regarding this Privacy Policy, or if you have any questions regarding Xparkle's collection, use, or disclosure of your personal information, please contact our Data Protection Officer at the address listed below and mention that your message is in reference to the "Privacy Policy":
SkyRC Technology Co., Ltd.
Floor 4,Bldg 4,Meitai Technology Park,Guanguang Rd,Guanlan,Shenzhen
Email:
[email protected]
Thank you for taking the time to familiarize yourself with our Privacy Policy!