1.Subject of this Privacy Policy
LEPRO and subsidiaries ("we", "us", "our", "LEPRO") are committed to protecting your privacy. This Privacy Policy ("Policy") describes our information privacy practices in connection with the Personal Data, as defined herein, that is generated through your individual use of the services identified herein provided by us via our mobile applications and/or our Smart Devices (collectively, the "Products"):
If you do not want to provide your Personal Data when you use any of the Products, you may use the App without creating and logging into an account. You may still use certain LEPRO services, such as searching and browsing any features on the Services. As described in Paragraph 4.1 below, we do not presently collect Personal Data relating to an account or profile. The collected data will be limited to that which you have authorized to be collected for purpose of using the additional functions of the App and/or the Smart Devices, as well as corresponding usage information. However, if the services you request or purchase are based on your account, please go to the registration/login page for guidance.
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 this Policy you will also find ways to manage your rights to access, update, delete or protect your Personal Data.
When you accept this Policy when you register with your Personal Data, or otherwise signify assent to this Policy through other means, we will consider that you fully understand and agree with this Policy.
2. Name and address of the controller
LEPRO INNOVATION INC.
3651 Lindell Road, Suite D1048, Las Vegas, NV, 89103, USA
If you wish to object to the collection, processing, or use of your Personal Data by us, according to these provisions on data protection as a whole or for individual measures, you can address your objection to the controller.
3. Collection of Personal Data related to our Products
In order to operate our Products and provide our services to you, we collect and process the categories of Personal Data as described in the following sections. Please note that some features of our Products may not be available if you chose to not provide your Personal Data.
3.1 Account registration
When you register an account for our Product, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials.
During your further use of our Products, we may also collect your nickname, profile picture, country code, language preference or time zone information in relation to your account, where you provide us with such information.
If you do not want to provide your profile data when you start to use any of the Products, you may use the App without login or registration of an account, while being able to use certain features of our Products, such as searching and browsing any features on the services. In such case, the collected data will be limited to those you have authorized to be collected for purpose of using the additional features of the App and/or the Smart Device (see below), as well as automatically collected information. Note that some of our Products require registration of an account, as set out in more detail on the relevant registration/login page.
3.2 Feedback
When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content, as provided by you, to respond to your query, to address your problems and solve device failures on a timely basis.
3.3 Additional features
In order to offer you with more convenient and high-quality services and options for an optimized user experiences, we may collect and use certain information if you chose to use additional features in the App. Please note that use of such additional features is optional. If you do not provide Personal Data related to the use of such features, 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 features may include the following.
a)Location-based features: 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 real-time precise or non-precise geolocation when you use certain Smart Devices or the Services, such as weather service. Based on your consent, when you enable the geofence feature, your location information will be generated and shared with Google Maps services. Please note that Google acts as separate controller of personal data, as further described in Google’s privacy notices, see https://policies.google.com/privacy and https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the services, upon which we will cease to collect and use your location information.
b)Camera features: our Services or your local device will collect video and images from your cameras in accordance with your camera storage settings, which may include images or videos of individuals. While captured photos or recorded videos are stored locally on your device and will therefore not be shared with us, we may obtain information when you actively use the camera.Where you want to use the camera on your device (e.g. to scan the code to pair with a Smart Device or for video recordings), you need to turn on the camera permissions.
c)Person Detection Information: If you have enabled the person detection feature for your camera and set the planned identified individual actively, then the Services analyze the video to help detect the presence of a person in that video (without trying to identify that person). We use this person detection information solely to provide and improve this feature. For most users, this person detection information is stored for a limited period of time in accordance with your video storage settings. However, if you voluntarily submit a video to help improve our Services. The collected biometric information will be coded and anonymized instead of individual photoes.
d)Facial emotional recognition: Some of our Products provide for a facial emotional recognition ("FER") feature that allow to recognize and interpret emotions on basis of photos/pictures of individuals (especially by analyzing facial expressions). This feature depends on the camara feature and therefore requires that you activate the camera permissions on your device. We will ask you for your prior consent before you activate and use a FER feature. Our FER features are built in accordance with the principles of privacy by design and by default. This means, for example, that any video recording are stored locally on your device. Further, we will not collect or store biometric identifiers when you use a FER feature.
e)Access to picture/video library: If you want to use features in order to upload your photos/pictures/videos, (e.g. in order to upload a profile picture or to report device usage problems by providing illustrative photos), you need to activate the photo/video album permission on your device. In such case, we may process the photos or videos that you upload to our services. Normally, we will not take knowledge of any of the uploaded photos or videos. However, when you report a device usage problem, we may use the photos/pictures that you upload to analyze the technical issue for user support purposes.
f)Audio-recording and voice recognition features: When turning on the microphone permission on your device, you can use the microphone for audio-recording features and voice recognition features (if available for the Product). When you use voice recognition features, we process your voice information (recorded voice clips and transcripts) to recognize and process your voice command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you activate the microphone in the App. Our Products provide for an offline mode which ensures that voice recordings are stored solely on the device and will not be shared with us. We will ask you for your separate consent by which you may allow us to use transcripts of your voice commands in order to improve the accuracy and quality of the voice recognition features of our Products and the voice information will be coded and anonymized.
Note that some of the above features may involve the processing of special categories of Personal Data. All of the personal data will be coded and anonymized to maximize protect your data security even in some critical case. (e.g. voice recordings or photos/videos revealing information about your health), depending on the Product and your use of our Product. Before we collect special categories of Personal Data from you, we will ask you for your prior explicit consent. You may withdraw your consent any time with effect for the future.
3.4 Automatically collected information
Depending on your use of our Products and services, we may automatically collect the following information, which may include Personal Data:
Device information and log files: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information. When you connect your Smart Devices with our Products or 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. This information is necessary in order to operate our Products and provide our services to you. We process log files for the optimization of our Products and services and data security based on our overriding legitimate interest to identify malfunctions, ensure the security of our systems and detect and respond to any attempts of unauthorized access.
Usage data: During your interaction with our Products and services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Products and services.
Unless we have obtained your consent or unless otherwise permitted by data protection laws and regulations, we will anonymize any of the above information.
4. Purposes and legal basis for processing Personal Data
We may process information about you for the following purposes:
·Provision of Our Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased, pursuant to our Terms of Use with you.
·Improvement of Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and 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 Terms of Use.
·Non-marketing Communication: We process your Personal Data in order 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 can check the [App Notification] in the App to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such purpose. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
·Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of the Services. If you do not allow us to process your Personal Data for personalization, you may opt out when using the App, or by changing your preferences in [Privacy Settings] in the App. The legal basis for this processing is your consent.
·Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate:
(a) to comply with applicable laws and regulations;
(b) to comply with legal process;
(c) to respond to requests from public and government authorities;
(d) to enforce our terms and conditions;
(e) to protect our operations, business and systems;
(f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and
(g) to allow us to pursue available remedies or limit the damages that we may sustain.
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.
Legal basis
LEPRO will comply with applicable data localization requirements in corresponding jurisdictions with respect to storage of data. To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence.
5. Erasure of data and duration of storage
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy 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 destroy our records of your Personal Data. 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.
6. Security of your data
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. LEPRO provides various security strategies to effectively ensure data security of user and device. As for device access, LEPRO proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing .
7. Children’s Privacy
Protecting the privacy of 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 anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have inadvertently collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information.
8. Share of personal data
At LEPRO, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:
·To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
·To our third-party partners who provide you, directly or indirectly, Smart Devices, and/or networks and systems through which you access and use our Sites and Services.
·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, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.
To subsidiaries or affiliates within our corporate family, to carry out regular business activities.
We will also share Personal Data, as we believe to be necessary or appropriate:
(a) to comply with applicable laws and regulations;
(b) to comply with legal process;
(c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
(d) to enforce our terms and conditions;
(e) to protect our operations, business and systems;
(f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and
(g) to allow us to pursue available remedies or limit the damages that we may sustain.
·Except for the third parties described above, we will share Personal Data with third parties only with your consent.
9. Your rights as data subject
We respect your rights and control over your Personal Data, you may exercise any of the following rights without fear of retaliation:
Email Address: cs@lepro.com
Website: https://www.lepro.com
You do not have to pay a fee, and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that 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;
·Request that we correct inaccurate or incomplete Personal Data about you;
·Request deletion of Personal Data about you;
·Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
·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; and
·Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.
California Residents are covered by the California Consumer Privacy Act which may provide additional or alternate rights and remedies regarding the use of Personal Data. See www.oag.ca.gov/privacy/ccpa
•Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:
1) Modification of Permissions: For privacy permissions acquired through device system settings, your consent can be withdrawn by you modifying device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notifications and other related functions;
2) Unsubscribe: In the marketing communications that you agree to, the information we send to you contains instructions that allow you to withdraw your consent in accordance with the "unsubscribe" method described in the information;
3) Unbind: Unbind the Smart Device through the app, and the information related to the Smart Device will not be collected;
4) Visitor Mode: By using product with the visitor mode, we will not collect any personal data about you;
When you withdraw your consent or authorization, we may not be able to continue to provide you with the 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.
5) Deletion of Account: The App enables the account deletion when you click "Delete Account" in Account and Security.
10. Validity of the Privacy Policy and updates
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.