Privacy Policy of SUPER CHIOCHIO

Super Love (Hangzhou) Intelligent Technology Co., Ltd. and its subsidiaries (“we”, “us” or “our”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with Personal Data processed through your use of our services, products and related mobile applications (collectively, the “Products”), including the SUPER CHIOCHIO Mobile Application and related Smart Devices. Certain functions may be enabled through SDKs, cloud platforms or other technical services provided by suppliers. Each supplier is responsible, in accordance with applicable law and its contractual obligations, for the technologies, systems and data-processing activities it provides.

·SUPER CHIOCHIO Mobile Application

Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways to execute your rights of access, update, delete or protect your Personal Data.

Please read this Policy carefully before using our Products. Where we rely on your consent to process Personal Data, we will request consent through a clear affirmative action and you may withdraw that consent as described in this Policy. Accepting this Policy confirms that you have read it; it does not constitute consent to any processing for which separate consent is required by applicable law. If you have any questions regarding this Policy, please contact us at service@superbobo.com.

Definition

In this Policy, Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.

Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collection personal sensitive data about you.

Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.

Apps refers to mobile applications developed by Super Love (Hangzhou) Intelligent Technology Co., Ltd. that enable end users to remotely control Smart Devices and connect to suppliers' IoT platforms, including through SDKs or other technical services.

What Personal Data do we collect

In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

1.Information You Voluntarily Provide Us

· Registered Account Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.

However, if the Services you request or purchase are based on your account, please go to the registration/login page for guidance.

· Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

Information based on additional functions:

In order to offer you with more convenient and higher-quality Services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:

1)Additional functions based on location information:

When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about your: a) real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Devices, or b) non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google’s Data Processing and Security Terms for more details.

You may change the Location permission for SUPER CHIOCHIO in your mobile device system settings. When disabled, we will cease collection based on that permission.

2)Additional services based on camera:

You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.

You may change the Camera permission for SUPER CHIOCHIO in your mobile device system settings.

3) Additional services for selecting and uploading pictures/videos through the system picker:

When you voluntarily choose an avatar, feedback attachment, or media in a device panel, the system photo or file picker grants the App access only to the specific file you select. We use media that you voluntarily upload to investigate a device issue or complete the function you selected. This does not give us access to your entire photo library or device storage. You may cancel the system picker at any time; no file will be uploaded, and login, pairing, and device control will remain available.

4)Additional services related to microphone-based service:

The App requests microphone permission only when you voluntarily use a supported device panel's audio recording, video recording, or voice-assistant feature. Audio from the microphone is processed only after you actively start that feature and only to complete the function you selected. The Conversation tab does not use the phone microphone. Granting microphone permission does not allow us to collect audio continuously or in the background.

You may change the Microphone permission for SUPER CHIOCHIO in your mobile device system settings.

5) Additional services for saving media and using the App's private directory:

The App does not request broad permission to read or write the device's entire storage. On Android 10 and later, when you voluntarily save an image created by the App, the file is written through the system MediaStore API. On Android 9 and earlier, the optional device-panel feature for saving to the public photo album is unavailable. Configuration and crash-diagnostic information required for operation is first stored in the App's private directory and does not require access to files belonging to you or other apps. Where the purposes and consent conditions described in this Policy are met, crash-diagnostic information may be uploaded as described under “Log Information” for troubleshooting analysis.

6)Additional services based on Notification permission:

The reason why we ask you for the permission is to send you notifications about using the Smart Devices or Services, especially if you have purchased security services and you require an alert or message so that you can capture the real-time status.

You may turn SUPER CHIOCHIO notifications on or off in your mobile device's system notification settings.

7) Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning on the permission, including controlling the Smart Devices, acquiring status of, discovering and configuring Smart Devices. In these functions, we will communicate with Smart Devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display device status on the home page and Smart Device panel; perform device control on the home page and Smart Device panel; discovering Smart Devices on the home page and the add device page, Smart Device distribution network.

You may change the Bluetooth permission for SUPER CHIOCHIO in your mobile device system settings.

Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect the previous collection and use of information based on your authorization.

2.Information We Collect Automatically

· Mobile Device Information: When you interact with our Services, in order to provide and maintain the normal operation of our Services, improve and optimize our Services, and protect your account security, we may automatically collect mobile device information such as the mobile device model, IP address, wireless connection information, operating-system type and version, application version number, push notification identifier, log files, mobile-network information and software version number.

· Usage Data: During your interaction with our websites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our websites and Services.

· Log Information: When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, language preference setting, operating system version, date or time of access, so that we can facilitate and accurately identify problems and help you solve them in timely manner.

· Voice-interaction records generated by physical hardware and displayed in the App: When you speak directly with a bound SUPER CHIOCHIO physical device, the interaction is handled by the physical device and its supporting services, which create the corresponding record. The Conversation tab only retrieves and displays existing voice-interaction records associated with that bound device in read-only form.

The Conversation tab provides no text or voice input, does not use the phone microphone, and does not send text, audio, or other user content from the phone to an AI service. The notice “AI-generated content, for reference only” describes the generated nature of device responses already present in the records; it does not mean that the App provides a way to submit content to AI.

Please note that we cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate or desensitize such information..

3.Smart Devices Related Information:

· Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

· Information collected during the process of connecting to a Smart Device: Based on the type of Smart Device you need to connect, the basic information collected includes: Wi-Fi information, device MAC address, etc.

· Information Reported by Smart Devices: Depending on the Smart Devices you connect to our Products or Services, we may collect information reported by those Smart Devices. For SUPER CHIOCHIO, this may include sensor status, current operating status and operating mode, together with physical-device interaction records such as interaction time and duration, device responses, and recognition text or labels generated as necessary to provide the relevant feature. After you sign in and bind the device, the App retrieves existing records only to display your device-use history. The actual fields processed are limited to the hardware functions you use and the content returned by the supporting service.

Purposes and legal basis for processing Personal Data

The purpose for which we may process information about you are as follows:

· Provide You with Our Services: We process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services that you have requested. The legal basis for this processing is to perform our contract with you according to user agreement.

· Improve Our Services: We process your mobile device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyze the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our user agreement.

· Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, we will also send you notifications related to the services you have purchased, such as alert services. You may manage these communications in your mobile device's system notification settings. When you turn off notifications for SUPER CHIOCHIO, the App can no longer display push notifications. The legal basis for this processing is to perform our contract with you according to our user agreement.

· Data Analysis: We may analyze use of SUPER CHIOCHIO Services or Smart Devices to maintain service stability, diagnose faults and improve the Products. Where analysis is not necessary to perform a contract or protect security and relies on your consent, we will obtain the required consent before processing. You may ask us to stop future optional analysis based on consent through Me > Feedback in the App or by emailing service@superbobo.com.

· AI Model Improvement: This release does not use voice, conversation records, generated labels, or other Personal Data that identifies or can be associated with you for model training by default. If we propose to use Personal Data for model training or algorithm improvement beyond what is necessary to provide the requested interaction, we will give you a separate, prominent notice and obtain the consent required by applicable law. You may withdraw that consent through Me > Feedback in the App or by emailing service@superbobo.com without losing account, pairing, or device-control functions.

· Personalization: Where permitted by applicable law and, when required, after your affirmative choice, we may use account data, usage data, mobile-device information or the types of Smart Devices you have connected to provide contextual suggestions or invite you to participate in surveys. This release does not provide personalized advertising. You may object to or withdraw consent for future optional personalization through Me > Feedback in the App or by emailing service@superbobo.com. Refusing or withdrawing consent will not affect basic functions.

· Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

· comply with a legal obligation, process or request;

· enforce our User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;

· protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or

· detect, prevent or otherwise address security, fraud or technical issues.

If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

Who do we Share Personal Data with?

At Super Love (Hangzhou) Intelligent Technology Co., Ltd., we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

We require third-party service providers, through applicable law, contractual safeguards, and appropriate oversight, to protect Personal Data to the same or an equivalent level as described in this Policy and to apply security measures appropriate to its sensitivity. If an App feature sends Personal Data to a third-party AI service, we will identify the data, recipient, and purpose before transmission and obtain explicit permission where required by applicable law. The current Conversation tab has no such transmission feature.

· To third-party service providers that perform business-related functions for the Products, such as infrastructure, IT services, customer support and similar services. This includes Hangzhou Tuya Information Technology Co., Ltd., which provides the Tuya Smart Life App SDK for account functions, family management, device discovery and pairing, IoT device control and status synchronization. Depending on the functions used, the SDK may process account or profile data, feedback information, family and device information, device and network information, device location information, application and operating-system information, push identifiers, log data, and de-identified SDK performance data such as MQTT and Socket connection rates. Each provider is responsible for its own technologies, systems, services and data-processing activities in accordance with applicable law and its contractual obligations.

· Components bundled with Tuya device panels: SUPER CHIOCHIO dynamically loads the Tuya device panel associated with each supported smart-toy model. The Tuya panel package statically bundles the components listed below to support voice products, third-party account authorization, and vendor-specific environments such as HONOR and Huawei devices. Static inclusion does not mean that a component has collected Personal Data. SUPER CHIOCHIO initializes the Tuya SDK only after you agree to this Policy. A panel can invoke a component only when you voluntarily open a panel that supports the corresponding capability and choose to use it. If the feature presents a separate third-party authorization screen, information within the requested scope is processed only after you complete that authorization.

QQ OpenSDK Provider: Shenzhen Tencent Computer Systems Company Limited Purpose: To provide QQ or QQ Music account authorization for supported voice-device panels, or QQ sharing when a user voluntarily selects it Scenario: When you voluntarily open a panel that supports QQ or QQ Music and select login, linking, or sharing Possible Personal Data and method: Through local SDK interfaces and encrypted network interfaces, the component may process QQ account identifiers, authorization tokens, and account data within the scope you approve, together with application, device, network, and log information necessary for authorization, compatibility, and troubleshooting. SUPER CHIOCHIO does not actively call this component when the corresponding feature is not triggered. Privacy policy: https://privacy.qq.com/policy/tencent-privacypolicy

Amazon Identity (Login with Amazon) Provider: Amazon.com, Inc. and the applicable affiliates providing the service Purpose: To provide Amazon Alexa account authorization and device linking for supported panels Scenario: When you voluntarily open a panel that supports Amazon Alexa and select login or linking Possible Personal Data and method: Through local SDK interfaces and encrypted network interfaces, the component may process an Amazon authorization result, authorization code or token, and Amazon account data within the scope you expressly approve. SUPER CHIOCHIO does not actively call this component when the corresponding feature is not triggered. Privacy policy: https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ

Tencent Yunxiaowei DMSDK Provider: Shenzhen Tencent Computer Systems Company Limited Purpose: To provide voice-platform, QQ Music account, and device-linking capabilities for supported voice-enabled smart-toy panels Scenario: When you voluntarily open a panel that supports Tencent Yunxiaowei or QQ Music and select authorization, linking, or the related service Possible Personal Data and method: Through local SDK interfaces and encrypted network interfaces, the component may process application and device information, network information, a device-linking identifier, account authorization status or token, and logs necessary to provide and troubleshoot the service. SUPER CHIOCHIO does not actively call this component when the corresponding feature is not triggered. Privacy policy: https://privacy.qq.com/policy/tencent-privacypolicy

Huawei HMS Base Provider: Huawei Software Technologies Co., Ltd. Purpose: To provide foundational compatibility for Tuya device panels and MiniApps in HONOR and Huawei device environments Scenario: When a Tuya device panel or MiniApp that needs this compatibility is opened on an HONOR, Huawei, or other applicable device Possible Personal Data and method: Through local SDK interfaces and necessary encrypted network interfaces, the component may process basic application information, device model, operating-system and system-setting information, network and IP address, and service-call results or diagnostic logs. SUPER CHIOCHIO does not actively call this component when it is not invoked by a panel or MiniApp. Privacy policy: https://developer.huawei.com/consumer/cn/doc/hmscore-common-Guides/privacy-0000001261262707

· To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our websites and Services.

· To subsidiaries or affiliates within our corporate family for purpose of regular business activities based on our instructions and in compliance with applicable law, this Policy and other appropriate confidentiality and security measures.

· To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, and choices you may have regarding your Personal Data.

· As we believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:

(a)Comply with applicable law, regulation, legal process, or lawful governmental request;

(b)Enforce our User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;

(c) Protect our operation and business systems;

(d)Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or

(e)Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.

Except for the third parties mentioned above, we only disclose your Personal Data to other third parties with your consent.

International Transfer of Information Collected

Personal Data of users served in mainland China is stored in mainland China in principle. If it must be provided outside mainland China, we will do so only as permitted by applicable law and will complete any required security assessment, certification, standard contract, notice, or separate-consent procedure. For users served outside mainland China, storage location is determined by the account service region, the services actually used, and applicable law.

Such safeguards may include an applicable adequacy decision, approved standard contractual clauses, binding corporate rules or another legally recognized transfer mechanism. We do not represent that any particular mechanism applies unless it has actually been implemented for the relevant transfer.

If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.

Your Rights Relating to Your Personal Data

We respect your rights and control over your Personal Data. You may exercise any of the following rights:

1. contact the privacy office at service@superbobo.com

2. use the Feedback entry in the App: Me > Feedback.

You do not have to pay a fee and we will aim to respond within 30 days, unless a different period is required by applicable law. If you decide to email us, please make clear what information you would like to have changed, whether you would like your Personal Data deleted, or what limitations you would like to place on our use of your Personal Data. We may ask you to verify your identity before taking further action on your request for security purposes.

You may:

· Request access to the Personal Data that we process about you by using Me > Feedback or emailing service@superbobo.com;

· Request that we correct inaccurate or incomplete Personal Data about you. To change supported account information, use Me > Settings > Account and profile > Account security. To change your nickname or other supported profile information, use Me > Settings > Account and profile > Personal information;

· Request deletion of Personal Data about you through Me > Settings > Account and profile > Account security > Delete account. Follow the on-screen instructions to submit the request;

· Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you through Me > Feedback or by emailing service@superbobo.com;

· Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated, through Me > Feedback or by emailing service@superbobo.com;

· Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:

1)For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including: location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notification settings and other related functions;

2)You may turn SUPER CHIOCHIO push notifications off in your mobile device's system notification settings;

3)For optional data analysis based on consent, you may ask us to stop future processing through Me > Feedback or by emailing service@superbobo.com;

4)For optional personalization based on consent, you may object or withdraw consent through Me > Feedback or by emailing service@superbobo.com;

5)Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected;

6)By using product with the "Try Now" mode, and not enable certain location setting for particular smart scene, we will not collect any Personal Data about you;

7)If you previously agreed to associate App account with a third-party service, such as a health platform, please unbind it on the third-party platform.

When you withdraw your consent or authorization, we may not be able to continue to provide you with certain products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.

About deletion of the account: You can submit a deletion request through Me > Settings > Account and profile > Account security > Delete account.

Security Measures

We and our suppliers use commercially reasonable physical, administrative and technical safeguards to preserve the integrity and security of Personal Data within our respective control. Measures may include access authentication and authorization, transmission encryption, data validation, audit controls and encrypted storage. Each supplier remains responsible for the security of the technologies, systems and services it provides in accordance with applicable law and its contractual obligations. If you have reason to believe that your interaction with the Products is no longer secure, please notify us at service@superbobo.com.

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data.

· For as long as you require us to fulfill the products and services you request from us as defined in the user agreement;

· Personal Data will no longer be retained when you request to remove your Personal Data, we will accordingly complete the task.

When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Children’s Privacy

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information..

The Services are not intended for independent use by children under the age of thirteen (13), or such other age at which parental or guardian consent is required under applicable law in the child’s country or region of residence. A child may use the applicable Services only with the knowledge, consent and guidance of a parent or legal guardian. Where required by applicable law, we will obtain verifiable parental or guardian consent before collecting or processing the child’s Personal Data. Please refer to the SUPER CHIOCHIO Children’s Privacy Statement for further details. If we become aware that we have collected a child’s Personal Data without the required consent, we will take steps to delete it.

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

Super Love (hangzhou) Intelligent Technology Co., Ltd

Contact Email: service@superbobo.com

Complaints and Reports: operation@superbobo.com

Contact Phone: 400-015-0718

Contact Address: Room 415-5, Building 9, No. 1818-2 Wenyi West Road, Yuhang Subdistrict, Yuhang District, Hangzhou, Zhejiang Province, China