User Privacy Policy

This "User Privacy Policy" (hereinafter referred to as "this Policy") is formulated by WIMA Technology (Guangdong) Co., Ltd. (hereinafter referred to as "WIMA Technology"). It outlines how WIMA Technology will process your personal information and private information, declares WIMA Technology's commitment to privacy protection, and acknowledges that WIMA Technology may update or modify this Policy periodically based on information processing scenarios in the future.

This Policy applies to all products or services provided by WIMA Technology and its affiliated companies. It does not apply to services provided by other third parties, nor to products or services that have separately established independent privacy policies.

Before using any services or products provided by WIMA Technology, or submitting personal information or private information to WIMA Technology, please carefully read, understand, and agree to this Policy and any supplementary policies. Only after confirming full understanding and agreement should you use the relevant products or services. If you disagree with any content of this Privacy Policy, you must immediately cease using WIMA Technology's services. Once you begin using any products or services provided by WIMA Technology, it signifies that you have fully understood and agreed to this Policy.

This Privacy Policy will help you understand:

1. We will collect and use your information in accordance with this Privacy Policy, but we will not mandatorily bundle or collect personal information solely based on your consent to this Policy.
2. When you use or activate specific features or services, we will collect and use necessary information to enable those functionalities. Unless it is essential information required for basic business functions or mandated by laws and regulations, you may refuse to provide such information without affecting other features or services. We will explicitly specify which items constitute essential information in this Privacy Policy.
3. Precise geographic location and Bluetooth permissions will not be enabled by default. They will only be utilized for specific features or services after obtaining your explicit authorization, which you may revoke at any time. Notably, even if authorized, we will not collect your information when the relevant features or services do not require these sensitive permissions.
This Privacy Policy applies to your access and use of our products and services through this application, official website, our Software Development Kit (SDK), and Application Programming Interfaces (APIs) provided for third-party websites and applications.

1. How We Collect and Use Your Personal Information

1.1 Information You Need to Authorize Us to Collect and Use

1. Account Information. The account used to log into this APP is created for you by your company administrator in the corresponding system back end. Creating account information requires a login name and mobile phone number. You may contact your company administrator to confirm details such as the login name, mobile phone number, and login password before accessing the account. If your company administrator has not created an account for you in this application, you will be unable to use our services.
2. Additional Information. When you use additional business features of this application, we may require you to provide further information including but not limited to personal identity information, location information, and other data necessary to deliver the products and services to you, in addition to your account information. If you do not use such additional business features or specific products/services, providing this information is not required (details will be elaborated below).
3. Location Information. When you enable the device positioning feature and use our location-based services, we will collect information about your location. This information is classified as sensitive. We advise you to carefully consider whether to disclose such sensitive information. Refusal to provide this information will only restrict your access to location-related functionalities but will not affect your use of other features.

1.2 Information You Voluntarily Authorize Us to Collect

1. Geographic Location

   Purpose: With your authorization, we collect your geographic location information to enable Bluetooth connectivity with IOT Locks (Bluetooth keys) for unlocking operations. Refusal to provide this information will only restrict your access to location-related functionalities but will not affect your normal use of other service features within the APP.

   Information Description: Location data sources include IP addresses, GPS, and sensor information from WLAN access points (e.g., Wi-Fi), Bluetooth, and cellular towers that can provide relevant details.

2. Bluetooth

   Purpose: When using your mobile device to connect to smart Bluetooth keys or Bluetooth-enabled locks, Bluetooth permission must be enabled. Refusal to enable this permission will prevent you from using the aforementioned services but will not affect your ability to choose alternative unlocking methods.

   Information Description: We only collect relevant information when you use Bluetooth permissions, such as during intelligent unlocking operations via Bluetooth.

1.3 Exceptions Requiring Prior Authorization Exemption

In accordance with relevant laws and regulations, your personal information may be collected without prior authorization under the following circumstances:

1. When involving national security, defense security, public security, state interests, or societal public interests;
2. When related to criminal investigations, prosecution, trial, execution, or similar legal proceedings;
3. When necessary to protect the life or property safety of you or others in emergencies where obtaining timely authorization is impractical;
4. When collected from other legally public and legitimate sources;
5. When the personal information has been voluntarily disclosed to the public by yourself;
6. When essential for executing contracts at your request;
7. When necessary to maintain the secure and stable operation of products or services, including detecting and resolving technical failures;
8. Other circumstances prescribed by laws and regulations.

2. How WIMA Technology Uses Your Personal Information

We will use your personal information for the following purposes:

1. To assist your company administrator in completing your account registration.
2. To deliver products or services to you.
3. To authenticate identities, provide customer support, implement security protections, monitor fraudulent activities, archive data, and create backups when delivering services – ensuring the security of our offerings.
4. To conduct internal audits, data analysis, and research for improving our products, services, and user communication.

3. How We Use Cookies

3.1 Cookies

When you use our services, we store small data files called Cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and alphanumeric characters. We use this information to verify registered user logins, enhance service/product quality, and optimize user experience. If you do not wish to store personal information in Cookies, you may configure your browser to disable Cookies. Disabling Cookies may affect your access to WIMA Technology's website or limit your ability to fully utilize our services.

WIMA Technology will not use Cookies for purposes beyond those stated in this Policy. You may manage or delete Cookies based on your preferences. You can clear all Cookies stored on your computer. Most web browsers provide functionality to block Cookies.

3.2 Device Permission Access

During service provision, WIMA Technology may require you to enable certain device permissions, such as access to notifications, photo gallery, camera, Bluetooth, etc. You may revoke part or all permissions through your device settings at any time, thereby restricting WIMA Technology from collecting corresponding personal information. The display and deactivation methods for permissions may vary across devices. Please refer to instructions provided by your device manufacturer or operating system developer.

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

4.1 Sharing

WIMA Technology will not provide your personal information to third parties without your consent or authorization. However, we may share your personal information under the following circumstances.

We will rigorously evaluate third parties' purposes for using shared information, conduct comprehensive assessments of their security capabilities, and require compliance through legal agreements. We implement strict security monitoring on partners' Software Development Kits (SDKs) and Application Programming Interfaces (APIs) to ensure data protection.

1. Sharing with Explicit Consent: WIMA Technology will share your personal information with third parties only after obtaining your explicit consent.
2. Sharing with Affiliated Companies: Within the scope of purposes declared in this Policy, your personal information may be shared with WIMA Technology's affiliated companies. As a policy, we only share necessary personal information. Should affiliated companies intend to alter the purposes of processing, your authorization will be re-solicited.
3. Sharing with Authorized Partners: Certain services are provided by authorized partners to fulfill objectives stated in this Policy. WIMA Technology may share specific personal information with partners to enhance customer service and user experience.
4. Sharing with Other Users: To improve service quality and user experience, WIMA Technology may share certain personal information with other users.
5. Sharing Under Legal Obligations: We may disclose your personal information in compliance with legal/regulatory requirements, judicial proceedings, or lawful requests from administrative/judicial authorities.
6. Other Circumstances: Sharing of de-identified information where the third-party recipient cannot re-identify individuals; sharing based on legitimate business practices; academic research usage; scenarios where sharing is essential to enable core functionalities of our products/services, fulfill your service requirements, or resolve disputes; and sharing with third parties to protect you, other users, employees, WIMA Technology, or public interests, property, or safety (e.g., fraud or credit risks).

4.2 Transfer

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

1. Transfer with Explicit Consent: We will transfer your personal information to other parties only after obtaining your explicit consent;
2. During mergers, acquisitions, reorganizations, divisions, bankruptcy, asset transfers, or similar transactions, if such transactions involve the transfer of personal information, we will require the new entity holding your information to remain bound by this Privacy Policy. Otherwise, we will demand the entity to re-obtain your authorization;
3. Other circumstances stipulated by laws and regulations.

4.3 Public Disclosure

We will publicly disclose your personal information only under the following circumstances, while implementing security measures compliant with legal and industry standards:

1. Upon obtaining your explicit consent;
2. When required by laws, legal proceedings, or mandatory requirements from government authorities. However, we ensure that upon receiving such disclosure requests, we will require the requesting party to present corresponding legal documentation, provided this complies with applicable laws and regulations.

4.4 Exemptions from Prior Authorization for Sharing, Transferring, or Publicly Disclosing Personal Information

Prior authorization is not required for sharing, transferring, or publicly disclosing personal information in the following circumstances:

1. Directly related to national security or defense security;
2. Directly related to public safety, public health, or significant public interests;
3. Directly related to criminal investigations, prosecution, trial, or execution of judgments;
4. Necessary to protect significant legitimate rights/interests (e.g., life, property) of the data subject or others when immediate consent cannot be obtained;
5. Personal information voluntarily disclosed by yourself to the public;
6. Collected from legally public sources such as legitimate news reports or government disclosures;
7. Essential for executing agreements or legal documents signed with you;
8. Other circumstances prescribed by laws and regulations.

5. How to Manage Your Personal Information

You may access and manage your personal information through the following methods:

5.1 Access, Modify, or Supplement Your Personal Information

1. You may access, correct, and supplement your personal information via the "Personal Settings" page in accordance with WIMA Technology's policies and guidelines.
2. Your company administrator may also access, correct, and supplement your personal information through the software backend.

5.2 Delete Your Personal Information

You may request deletion of personal information through your company administrator under the following circumstances:

1. If your company's processing of personal information violates laws or regulations;
2. If your company collects or uses your personal information without obtaining your explicit consent;
3. If we process your personal information in material breach of agreements with you;
4. If your company ceases using our products/services, or your company administrator proactively deletes your account via the software backend;

5.3 Account Deletion/Deactivation

1. Your account may be deactivated or deleted in accordance with the terms of the User Service Agreement and applicable national laws and regulations. Upon account deactivation/deletion, all associated data and information will be permanently erased or anonymized.
2. Note: Your account is created by your company administrator through the software backend. To request account deletion, contact your company administrator. The administrator may delete your account via: "Log into back end with admin account" → "User Management" → "[Your Name]'s Account" → "Delete". Account deletion is irreversible and takes immediate effect. All personal information will be permanently removed. We recommend backing up data prior to deletion.

5.4 Modifying Authorization Scope

While certain information is essential for service delivery, most data provision is voluntary. You may adjust authorization scope by: Deleting specific information / Disabling device features. Withdrawing consent does not affect the lawfulness of information processing activities conducted prior to withdrawal.

For reasonable requests, we generally do not charge fees. However, for repetitive or excessive requests beyond reasonable limits, we reserve the right to impose a cost-based fee. Requests that are manifestly unfounded, require disproportionate technical efforts (e.g., developing new systems or fundamentally altering existing practices), pose risks to others' legitimate rights, or are impractical may be rejected.

Under the following circumstances, we may be unable to fulfill your requests to access, modify, supplement, delete, deactivate accounts, or modify authorizations as required by laws:

1. Directly related to national security or defense security;
2. Directly related to public safety, public health, or significant public interests;
3. Directly related to criminal investigations, prosecution, trial, or execution of judgments;
4. Substantial evidence indicating your subjective malicious intent or abuse of rights;
5. Fulfillment would severely harm legitimate rights/interests of you or others;
6. Involving trade secrets;
7. Other circumstances prescribed by laws and regulations.

6. How We Protect and Retain Your Personal Information

WIMA Technology prioritizes the security of personal information. We implement internet industry-standard practices to protect your personal information against unauthorized access, disclosure, use, modification, damage, or loss. We will take all reasonably feasible measures to safeguard your personal information.

We adopt all reasonably feasible measures to ensure that no personal information unrelated to the services provided by WIMA Technology is collected. While we endeavor to protect your personal information comprehensively, please understand that absolute security cannot be guaranteed in the internet industry due to technological limitations and potential malicious activities. You acknowledge that the systems and communication networks used to access our services may encounter issues beyond our control. Please exercise caution when voluntarily sharing or publicly disclosing information through our services, as such actions may involve personal or sensitive information of yourself or others.

In the event of a personal information security incident, we will promptly notify you in compliance with legal requirements, including: Basic details and potential impact of the incident ; Measures taken or to be taken for mitigation; Recommendations for self-protection and risk reduction; Available remedial actions. Notifications will be delivered via email, postal mail, phone calls, push notifications, or other appropriate channels. Where individual notification is impractical, we will issue public announcements through effective means. Additionally, we will proactively report incident handling to regulatory authorities as mandated.

Personal information collected and generated within the territory of the People's Republic of China will be stored domestically. We retain your personal information only for the duration necessary to achieve the purposes stated in this Policy. However, retention periods may be appropriately extended to comply with applicable laws, court rulings, governmental requirements, or to safeguard public interests.

7. Third-Party Providers and Their Services

To ensure seamless browsing experiences, you may encounter content or hyperlinks from third parties external to WIMA Technology and its partners (hereinafter "Third Parties"). WIMA Technology exercises no control over such Third Parties. You may choose whether to access their links, content, products, or services.

WIMA Technology cannot govern Third Parties' privacy and data protection policies, which are not bound by this Policy. Before submitting personal information to any Third Party, ensure you have read and acknowledged their respective privacy policies.

8. How WIMA Technology Handles Minors' Personal Information

We encourage parents or guardians to guide minors under the age of eighteen in using our services. We recommend that minors' parents or guardians read this Policy and advise minors to seek parental/guardian consent and guidance before using our services or submitting personal information. If we identify personal information submitted by minors without verifiable parental/guardian consent, we will promptly delete such data.

9. Policy Updates and Scope of Application

This Policy constitutes an integral part of the Software License and Service Agreement. WIMA Technology reserves the right to update or modify this Policy periodically. We will notify you of changes through various channels, including but not limited to official website announcements, emails/SMS/in-app messages. Your rights under this Privacy Policy will not be restricted without your explicit consent. For material changes that substantially reduce your rights under this Policy, we will provide more prominent notices (e.g., platform banners or pop-up notifications).

If you disagree with the modified Privacy Policy, you have the right and obligation to immediately cease using WIMA Technology's services. Continued use of services after modifications constitutes acceptance of the revised terms.

This Policy applies to all WIMA Technology services. However, certain services may have specific privacy policies that elaborate on how we handle your information within those services. In case of conflict between this Policy and service-specific policies, the latter shall prevail.

10. Miscellaneous

1. The interpretation and dispute resolution of this "User Privacy Policy" shall be governed by the laws of Mainland China. Any disputes arising from the conclusion or performance of this Policy shall first be resolved through good-faith negotiations. If no resolution is reached, either party may file a lawsuit with the people's court having jurisdiction over the domicile of WIMA Technology.
2. The headings in this "User Privacy Policy" are for convenience and readability only, and shall not affect the interpretation of any provisions herein.

11. Contact Us

For cybersecurity complaints, or any questions/feedback regarding this Privacy Policy, our privacy practices, or personal information handling, please contact us via email at: info@r-wima.com.

Generally, we will respond within five (5) working days after verifying your identity. If unsatisfied with our response, you may lodge complaints with consumer rights protection authorities or file a lawsuit with the competent court in the domicile of WIMA Technology (Guangdong) Co., Ltd. (Zhuhai High-tech Zone, Guangdong Province).

WIMA Technology (Guangdong) Co., Ltd.