SmartCool Element Cooler Privacy Policy

SmartCool Element Cooler (hereinafter referred to as "this APP") respects and protects the personal privacy of all users who use the services of this APP. Except as otherwise provided in this Privacy Policy, we will not disclose or provide this information to third parties without your prior permission. If necessary, we will update this Privacy Policy in a timely manner. By agreeing to the Network Service Use Agreement of this APP, you are deemed to have agreed to the entire content of this Privacy Policy. This Privacy Policy is an integral part of the Network Service Use Agreement of this APP. Before using this APP, please carefully read the "SmartCool Element Cooler Privacy Policy".

I. Situations Where You Must Authorize Us to Collect and Use Your Personal Information

Personal information refers to all kinds of information recorded electronically or by other means that can identify a specific natural person's identity or reflect a specific natural person's activities, either alone or in combination with other information.

SmartCool Element Cooler is a smart hardware control tool product. In order to provide you with the basic and additional functions of our products and services, you may choose to authorize us to collect, store, and use the following information related to you. If you refuse to provide such information, you will not be able to use the relevant additional functions normally or achieve the functional effects we intend, but it will not affect your normal use of our basic functions. This information mainly includes:

(1) Our product integrates the Umeng+ SDK. The Umeng+ SDK needs to collect your device's Mac address, unique device identifier (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information), and log information to provide statistical analysis services, and to calibrate report data accuracy through geographic location and provide basic anti-cheating capabilities. For details, please refer to the Umeng+ Privacy Policy. (2) During the use of our application products, we need to obtain the list of software installed on your mobile device. This APP needs to obtain the list of software installed on your mobile device, so that when you customize the RGB lighting effect scheme of the cooler, you can choose to link it with installed games or applications for scene linkage (for example, automatically switching the lighting effect mode when starting a certain game), simplifying the operation process. (3) The application obtains your device's Mac address, unique device identifier IMEI information, manufacturer information, and device model information in the background state. As a Bluetooth smart device assistant tool APP, we still perform necessary information and status interactions with the already paired cooler device (such as temperature reporting, battery monitoring) in the background state. This process involves mobile phone compatibility issues. We will record mobile devices that perform abnormally with the APP and later improve compatibility.

II. How We Use Your Personal Information

1. To provide you with services

(1) For archiving and backup purposes when we provide services, to ensure the security of the products and services we provide to you; (2) Through information data analysis, help us design new services and improve our existing services; (3) To better understand how you use our services, so as to meet your personalized needs, such as lighting effect settings, temperature alert thresholds, personalized help services and instructions; (4) Software certification or management of software upgrades (such as cooler firmware OTA upgrade); (5) Allow you to participate in surveys concerning our products and services; (6) Other situations where you authorize us to provide personal information.

2. After collecting your personal information, we will de-identify the data through technical means, and the de-identified information will no longer be able to identify the individual. You understand and agree that in this case we have the right to use the de-identified information; and under the premise of complying with relevant laws and regulations, we have the right to conduct overall analysis and utilization of user data, including your personal information.

3. When we intend to use the information for other purposes not specified in this policy, we will obtain your prior consent.

4. You fully understand that we may use personal information without obtaining your authorization in the following circumstances:

(1) Related to national security or national defense security; (2) Related to public safety, public health, or major public interests; (3) Related to criminal investigations, prosecutions, trials, and enforcement of judgments; (4) In order to protect the life, property, or other major legitimate rights and interests of the data subject or other individuals, but it is difficult to obtain the consent of the individual; (5) The personal information collected is publicly disclosed by the data subject themselves; (6) The personal information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure channels; (7) Necessary for signing a contract at your request; (8) Necessary for maintaining the safe and stable operation of the provided products and/or services, such as detecting and handling faults in the products and/or services; (9) Necessary for legal news reporting; (10) Necessary for academic research institutions to conduct statistics or academic research based on public interests, and when providing the results of academic research or descriptions externally, the personal information contained in the results is de-identified; (11) Other circumstances stipulated by laws and regulations.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

1. Sharing

We will not share your personal information with any company, organization, or individual outside SmartCool Element Cooler, except in the following cases:

(1) Sharing with your explicit consent: After obtaining your explicit consent, we will share your personal information with other parties. (2) We may share your personal information externally in accordance with legal regulations or mandatory requirements of competent government authorities. (3) Sharing with our affiliated companies: Your personal information may be shared with our affiliated companies. We will only share necessary personal information, subject to the purposes stated in the user privacy policy. If affiliated companies change the purpose of processing personal information, they will seek your authorization again. Our affiliated companies include any company or institution now or in the future controlled by, controlling, or under common control with SmartCool Element Cooler, as well as the legal successors of the above companies or institutions. (4) Sharing with authorized partners: Solely for the purposes stated in this policy, some of our services will be provided by authorized partners. With your explicit consent, we may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legitimate, proper, necessary, specific, and clear purposes, and will only share personal information necessary to provide the service. Our partners have no right to use the shared personal information for any other purpose.

2. Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

(1) Transfer with your explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties; (2) In the event of a merger, acquisition, or bankruptcy liquidation, if personal information is transferred, we will require the new company or organization holding your personal information to continue to be bound by this user privacy policy; otherwise, we will require that company or organization to seek your authorization again.

3. Public Disclosure

We will only publicly disclose your personal information in the following cases:

(1) After obtaining your explicit consent; (2) Disclosure based on law: In cases where disclosure is required by law, legal proceedings, litigation, or mandatory requirements of government authorities, we may publicly disclose your personal information.

IV. How We Protect Your Personal Information

1. We will strictly comply with relevant local laws and regulations, establish an information security assurance system, and take technical and other necessary measures to protect the security of your personal information.

2. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless a longer retention period is required or permitted by law.

3. Please understand that the Internet environment is not 100% secure. We will try our best to ensure the security of any information you send to us. However, due to technical limitations and various possible malicious means, it is impossible to guarantee 100% information security even with our best efforts. In the unfortunate event of a personal information security incident, we will notify you in a timely manner in accordance with legal requirements: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, and remedies for you. We will timely inform you of the incident by email, letter, phone, push notification, etc. When it is difficult to inform individual data subjects one by one, we will take reasonable and effective measures to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents to regulatory authorities as required.

V. Your Rights

1. You can request us to delete your personal information in the following circumstances:

(1) Our processing of personal information violates laws and regulations; (2) We collect and use your personal information without your consent; (3) Our processing of personal information violates the agreement with you; (4) You no longer use our products or services, or you cancel your account; (5) We no longer provide products or services to you.

After you delete information from our services, we may not immediately delete the corresponding information from our backup systems, but we will delete it when the backup is updated.

2. After you cancel your account, we will stop providing products or services to you and delete your personal information as requested, unless otherwise provided by laws and regulations.

VI. How This Policy is Updated

Our user privacy policy may change.

Without your explicit consent, we will not reduce your rights under the user privacy policy. We will publish any changes to this policy by announcement. In such case, if you continue to use our services, you agree to be bound by the revised privacy policy.

VII. App Permissions

1. "android.permission.ACCESS_NETWORK_STATE"

Permission description: View network status

Reason: The APP requires internet access to determine whether the device is in a network environment.

2. "android.permission.ACCESS_WIFI_STATE"

Permission description: View Wi-Fi status

Reason: The APP needs good network conditions and checks the current network signal.

3. "android.permission.READ_PHONE_STATE"

Permission description: Read phone status and identity

Reason: Reads the phone status for device deduplication and statistical analysis.

4. "android.permission.INTERNET"

Permission description: Access the internet

Reason: Download firmware upgrade packages, upload device logs, and obtain official cooler information.

5. "android.permission.WRITE_EXTERNAL_STORAGE"

Permission description: Modify/delete SD card contents

Reason: Required when downloading cooler firmware upgrade packages.

6. "android.permission.BLUETOOTH"

Permission description: Bluetooth scan, connect, communicate

Reason: Used to connect to SmartCool Element Cooler devices, adjust fan speed, read temperature and battery level.

7. "android.permission.MANAGE_EXTERNAL_STORAGE"

Permission description: Android 11+, modify/delete SD card contents

Reason: Required for downloading firmware upgrade packages on Android 11+.

8. "android.permission.QUERY_ALL_PACKAGES"

Permission description: Get list of installed apps on your device

Reason: This APP needs to obtain the list of installed apps so that when you set smart lighting effect linkage, you can choose to link with installed games or apps for automatic scene switching.

9. "android.permission.ACCESS_FINE_LOCATION"

Permission description: Precise location permission

Reason: Bluetooth scanning requires location permission (Android system requirement).

10. "android.permission.ACCESS_COARSE_LOCATION"

Permission description: Approximate location permission

Reason: Bluetooth scanning requires location permission.

11. "android.permission.BLUETOOTH_SCAN"

Permission description: Bluetooth scan permission (Android 12+)

Reason: Used to scan for nearby SmartCool Element Cooler devices.

12. "android.permission.BLUETOOTH_CONNECT"

Permission description: Bluetooth connect permission (Android 12+)

Reason: Used to connect and control the cooler device.

13. "android.permission.POST_NOTIFICATIONS"

Permission description: Send notifications permission (Android 13+)

Reason: Used to push device over-temperature alerts, firmware upgrade completion messages, etc.

14. "android.permission.WAKE_LOCK"

Permission description: Prevent phone from sleeping

Reason: Prevents the phone from automatically turning off the screen during firmware upgrades, which could interrupt the process.

VIII. How to Contact Us

If you have any complaints or report requests regarding our personal information processing activities, you can contact us by email at jimmyli0621@163.com. We will respond to your request within 5 working days after verifying your identity and do our best to resolve the issue. Phone: 18165725008 Company Name: Shenzhen Zhiwan Innovation Technology Co., Ltd. Company Address: Room 1602, Runchuang Building, Xin'an Street, Bao'an District, Shenzhen, Guangdong Province Effective Date: May 11, 2026