Welife Privacy Policy
Last Updated: 2023.12.18
Effective Date: 2023.12.18
Version: 20231218V1
SHENZHEN TRANSSION COMMUNICATION LIMITED (hereinafter referred to as "Welife", "we", "us", "our") is the service provider and operator of Welife and its Service (hereinafter referred to as “This Application”). We fully respect your privacy and will do our utmost to protect the security of your personal information. We may collect, use or otherwise process your personal information based on your consent or in accordance with the relevant provisions of applicable laws and regulations during your use of this Application or its services (collectively, our “Service”). This Privacy Policy (hereinafter referred to as “Policy”) is meant to help you understand how we collect, use, disclose, process and protect your personal information with regard to your use of a Welife product and its Service, your rights regarding the personal information provided to us, and how we safeguard your rights. This Policy applies to all the products and services provided by Welife, including applications, mini-programs, websites, SDK for third-party websites or applications, APIs and other forms that may be available in the future.
It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties, please prudently determine whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.
We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.
Before using our products or services, providing your personal information to us or allowing us to collect your personal information, please read this Policy carefully to understand our practices regarding your personal information and access it frequently to understand the updates to this Policy. If we update this Policy, we will notify you by announcements in the product or website to let you know about the changes we made. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of the Privacy Policy for the latest update time.
If you have any questions, please feel free to contact us by the following means:
privacy@transsion.com
You can also access this Privacy Policy by the following means:
Welife >ME > About > Privacy Policy
This Privacy Policy will help you understand the following contents:
At Welife, we firmly believe that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by us, regardless of where such natural person lives.
We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.
We may collect your personal information by the following means: 1) information you provide directly to us (such as your nickname, profile picture, name and phone number you provide to us when you login to your account or take part in the promotion activity we held); 2) information we obtain automatically during your use of this Application (such as device information, service log information); 3) information we obtain from other sources.
You have the right to choose whether or not to provide the personal information when you use a Welife product and its Service or when we have requested. You are not required to provide your personal information to Welife, but in some cases, if you choose not to do so, we will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:
This application mainly provides you with online smart device management services.
2.1 To provide you with account login services
In order to facilitate your full use of the functions and services of this Application, you may: log in to our services through an independent account application (such as system account applications, etc.). We will help you jump to the corresponding account service page according to your instructions.In this scenario, we will collect information including your Open ID, nickname, profile photo, mobile phone/email address from such independent account services. We will bind your account with our Service. Your mobile phone/email will be used in family member invitation scenarios to identify your account and associate it with relevant devices. The personal information we are able to obtain ultimately will be subject to the authorization of the independent account application. You may enter the account application service page to access its privacy policy.
If you refuse to provide this information, you will not be able to register a Welife account or use relevant functions. However, your normal use of other features of this Application will not be affected. You can still browse the software in tourist mode (i.e. without being a registered user) and use its step counting function.
2.2 Binding Service for Your Smart Devices
You can bind your smart devices to and manage them through this Service. When you bind a device, we will collect the MAC address of your smart device. If you choose to bind the device by scanning a code, we will require your camera permission. If you choose to connect the device via Bluetooth scanning, we will request your permission for precise geographical location and nearby Wi-Fi devices for the scanning and connection process. Please be aware that we only require your permission for geographical location on the terminal device and do not transmit or store your location information.
If you bind your router device through this Service, you can manage your router device through this Service. You can set the name (SSID) and password of the router device through this Service, and we will store such information for you. Through this Service, you can manage devices connected to the WI-FI network, and we will record the device names and MAC addresses to facilitate your management of such devices' connections. If your router joins a Mesh network, we will record and display the associated device models and device unique identifiers within the Mesh network to facilitate you viewing the router devices in your network. You can manage functions through this Service, and we will record the on/off status of your router's functions.
If you bind your smart bracelet through this Service and enable the bracelet's functions of message push and call alerts, we will read your device notifications and call alerts. Please be aware that such information is only used to provide relevant functions for your smart bracelet device and will not be stored on our server.
If you have bound the smart TV function, when you use file casting, we will require your device's file and media permissions to read and cast relevant content.
You can turn off your permission at any time through "Welife > Application Details" or "System Settings > Application List > Welife", in which case the permission-related functions may not work properly.
If you bind your smart home devices through this Service, you can share device control permissions with your family members. When you share with family members, you can set your family name, family room information, and the room where your device is located through this Service. At this time, we will save such information and associate it with the family members' accounts, allowing them to view and manage it. Through this Service, you can view the family members' account information (profile photos, nicknames) and member management permissions, and your account information (profile photo, nickname) will be shared with the family members.
2.3 Provide You with User Feedback Services
If you encounter any problems in use, you can contact us through our user feedback channel for assistance. We may collect the feedback content and contact information (email or mobile phone number) you provide in order to contact you or help you solve problems, or record the processing plan and results of related issues. If you choose not to provide such information, we may not be able to provide this Service to you, but your use of other features of this Application will not be affected.
2.4 Provide You with Message Push Services
Based on your account information and information about your use of this Application, we may also push service notifications and other messages to you. To unsubscribe from notifications and other messages, you can go to "ME > Message Center" to withdraw your consent. The path for withdrawing may vary depending on the version.
2.5 Improve Our Products or Services
We may also acquire your additional information reasonably necessary for the improvement of our products or services, including:
(1) Device and SIM card related information: When you start using the Service of this Application, based on your specific operations in this Application and the specific permissions granted during installation and use of this Application, we will receive and record the information of the mobile device you use (including phone brand, phone model, operating system version information, unique device identifier IMEI, phone device's CPU model, phone device settings, system language, network device hardware address, IP address, information about this Application's name and version number, device environment hardware and software characteristics information), hardware device identifier GAID (Google Advertising ID), relevant information about the location of the phone device (including the country or region information of the phone you authorize, network access method), and SIM card information.
(2) Service log information: When you use the Service of this Application, we will automatically collect details of your usage of our Service and save them as service logs, including access time, number of times accessed, duration of use, and event information (errors, crashes, restarts, upgrades).
Such information will help us analyze and solve service exceptions, generate statistics to help us analyze the performance and quality of the Service of this Application, so that we can continuously optimize the service interfaces and service functions.
Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
In order to better improve our product layout and provide you with great services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take technical measures and other necessary measures to process such data, so that the data cannot be re-identified to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such processed data can be used without separately notifying you or obtaining your consent.
1. How we store your personal information
The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Currently, we may store your personal information in: India, Russia, and Frankfurt. In particular:
The personal information collected and generated during our operations in India will be stored on servers located in India.
The personal information collected and generated in our business during our operations in Russia will be stored on servers in Russia.
The personal information collected and generated in our business outside India and Russia will be stored on servers in Frankfurt.
According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.
2. How we protect your personal information
We will also take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
1. How we share your personal information
We do not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with Welife's affiliated companies. We will only share your information within Welife's affiliated companies for legitimate and explicit purposes, and only share the information necessary to provide the services, and are bound by the purposes stated in this Privacy Policy. If a purpose concerned is not included in this Policy, we will state it in the corresponding privacy policy or notice of the specific product or service.
We may share the necessary personal information with authorized third-party partners (including data storage service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. Specifically, our cloud service provider will provide us with cloud storage services to ensure the proper functioning of this Application and its Service. We will sign strict confidentiality agreements with such partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system).
In certain operating regions (excluding Russia and India), we may embed software tool development kits (SDK) or other similar applications (for which we will perform strict security checks to protect data security) from authorized partners in this Application. Specifically,
|
SDK Name |
SDK Provider |
Type of Personal Information Collected |
Purpose of Data Processing |
SDK Privacy Policy |
|
Firebase SDK |
|
Device Information and Service Log Information |
Generate Statistical Data, Analyze Service Performance, and Optimize Service Quality |
https://policies.google.com/privacy |
When we embed the third party SDK or other similar applications of authorized partners in this Application, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.
2. How we transfer your personal information
Welife will not transfer your information to any other parties, except in the following circumstances:
(1) Obtain your explicit consent.
(2) If Welife is involved in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your personal information, and any choices you may have about your personal information.
(3) In the case that has been explained in this privacy policy or notified you by other means.
3. How we disclose your personal information
According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, Welife may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
(1) Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.
(2) Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.
(3) Other third parties, for example, the disclosure of specific information with your authorization.
For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your personal information to the resources or servers stipulated in section III of this Policy for storage or processing, we may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The privacy protection laws of these countries or regions may be different, and the jurisdiction in which these global resources or servers are located may or may not protect personal information to the same standards as in your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal information, and we will follow the legal requirements of the country or region where the personal information is located to carry out the corresponding cross-border transfer and other processing of personal information.
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when Welife is legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of a Welife product and its Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”, etc.; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via “Permission Management” > “App Permissions” or contact us via privacy@transsion.com to change your decision.
You can request to cancel your account by contacting us at privacy@transsion.com. We hereby kindly remind you that, after you cancel your account, we will terminate the products and services provided based on this account. Unless otherwise required specially by applicable laws of your region, we will simultaneously delete the personal data under your account. If you sign in to this service through a third-party account, please apply for cancellation of the account with the third party.
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:
(1) Right to restriction processing. You have the right to request our restriction on the processing of your personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the compliance with applicable data protection laws, we will process your personal information under applicable circumstances in such laws and notify you before the restriction of processing is lifted.
(2) Right to automated decision-making. You have the right to refuse the processing based on automated decision-making, including profiling and other automated processing which may have legal or similar effects on you.
(3) Right to data portability. You have the right to apply for your personal information to be transmitted to another data controller in a structured and commonly used format.
We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
Welife does not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children's personal data or use children's personal information for the purposes of marketing. If you find that a child’s information has been collected to us, please send an email to privacy@transsion.com to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from Welife as soon as possible.
You may receive links to third-party websites or content and services provided by third parties other than us during your use of Welife and its Service, and some third parties’ products or services can be accessed in the form of SDKs and others. You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your personal information. Therefore, when you submit any information to a third party, please carefully review the third party’s privacy policy and take care of your personal information.
We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you of the latest Policy here (this webpage), or by sending you separate notifications. Please pay attention to this website and the notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent.
We will ask for your explicit consent again in accordance with applicable laws before we collect additional personal information from you or when we use or disclose your personal information for new purposes. Your continued use of the products and services on the website, mobile and/or any other device constitutes your agreement to the updated Privacy Policy.
The content of Welife product and its Service described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
If you have any comments, questions or concerns with respect to our Privacy Policy or practices of personal information protection, please contact us via:
Email: privacy@transsion.com (Note: This mailbox is used for receiving messages related to our Privacy Policy or our protection of personal information only)
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days (or as required by the laws of your jurisdiction) after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.
Thank you for your time to read our Privacy Policy!