Privacy Policy
MOTTO Electronics (hereinafter referred to as “we” or “the Company”) acknowledges the importance of personal information security, and will take corresponding security protection measures to protect your personal information and privacy as per applicable laws and regulations. Therefore, we formulate Privacy Policy of Motto Electronics (hereinafter referred to as “Privacy Policy”) and remind you that: before you submit your personal information for obtaining “Motto Electronics Children’s Watch” software and related services, you must carefully read and fully understand this Privacy Policy. Only when you agree can you start to use related product and services. Your use of “Motto Electronics Children’s Watch” software and related services shall be deemed that you have accepted and recognized this Privacy Policy.
We attaches great importance to the protection of the user’s personal information and will treat such information with a high degree of diligence and prudence. When you download, start, browse, register, log in and use (hereinafter collectively referred to as “use”) “Motto Electronics Children’s Watch” software and related services, we will collect, save, use, share, disclose and protect your personal information according to this Privacy Policy. We need introduce you the way of processing your personal information by means of this Privacy Policy. For this reason, we suggest you to carefully read through all terms stipulated herein again. However, Exemptions or Limitation of Liabilities will be written in bold to arouse your attention. Please read them carefully.
“Motto Electronics Children’s Watch” software and related services mentioned herein may vary according to your mobile phone model, system version and software application program version. Ultimate product and services are subject to your use.
If you disagree this Privacy Policy, “Motto Electronics Children’s Watch” software and related services will be unavailable, and we will not provide you with complete product and services. Your use of “Motto Electronics Children’s Watch” software and related services will be completely deemed that you have fully understood and agreed this Privacy Policy.
Whether you obtain “Motto Electronics Children’s Watch” software and related services via computer, mobile device or other terminal devices, Privacy Policy shall be applied to all products and services we provide.
For the purpose of this Privacy Policy:
This Privacy Policy will guide you to understand the following content:
I. The application scope of Privacy Policy
II. Scope and Method of Collecting Personal Information
III. Storage of Personal Information
IV. Use of Cookie and Similar Technology
V. Possible Usage Mode of Personal Information
VI. Possible Sharing Mode of Personal Information
VII. Personal Information Security Protection
VIII. Personal Information Management
IX. Terms of Use for Minors
X. Changes of Privacy Policy
XI. Dispute Settlement
XII. Others
I. The application scope of Privacy Policy
Unless otherwise specified herein, all terms mentioned in Privacy Policy shall have the same definition with those adopted in User Service Agreement.
(1) Collecting and using your personal information by means of the third-party services (including any third-party application and website) accessed via “Motto Electronics Children’s Watch” software and related services;
(2) Collecting and using your personal information by means of other third parties providing the advertising service via “Motto Electronics Children’s Watch” software and related services.
2. “Motto Electronics Children’s Watch” software and related services may include or link to any third-party information or services (including website). Such third-party service may be operated by the related third party. If you use such third-party service (including your provision of any personal information to the third party), you must obey the third party’s service terms and privacy policy (rather than our Privacy Policy). You need read their terms very carefully. Please properly protect your own personal information and do not disclose it to others when it’s not necessary. This Privacy Policy only applies to our collection, storage, use, sharing and disclosure of information, and shall not apply to any third party’s services or information use rules. For any third party’s use of the information provided by you, we shall not burden any liabilities.
II. Scope and Method of Collecting Personal Information
You shall understand and agree that, when you’re using “Motto Electronics Children’s Watch” software and related services, we may collect, store and use the following data related to your personal information. Such information can facilitate your registration, login, account binding, password retrieve through receiving corresponding verification code. If you refuse providing related information, you cannot complete corresponding registration and become our user, or enjoy certain services provided by us, or achieve what you want through our service.
According to applicable laws and regulations prevailing in the People’s Republic of China, you may need provide us your true identity information while using “Motto Electronics Children’s Watch” software and related services, and we will assist you to complete the real-name authentication in an appropriate way based on your identity properties. If you only need browsing, searching and other basic functions, you are required to neither register “Motto Electronics Children’s Watch” account, nor provide any related information.
When you register, log in or use “Motto Electronics Children’s Watch” software and related services, we will collect your nickname, profile picture and mobile phone number (or E-mail) from the information you filled in and/or provided so as to help you complete the account registration and protect your account. Mobile phone number is sensitive personal information which is collected to satisfy the network real name system requirements stipulated in applicable laws and regulations. Your refusal may cause the failure in normally using our services.
(1) Log Information: During your use of “Motto Electronics Children’s Watch” software and related services, we will automatically collect your specific use of our service and store such information as the network log, including the bound device model, system version, network and abnormal information etc..
(2) Device or Application Information: Some mobile devices or applications contain the sole application program number, including the configuration information, device version number and device identification code provided by your mobile device, browser or other programs accessing “Motto Electronics Children’s Watch” software and related services. In order to present you with better services and improve your experience, “Motto Electronics Children’s Watch” software and related services may record related software and hardware data, such as hardware model, operating system version number, IMEI and network device hardware address (MAC).
(3) Location Information: When you enable the device positioning function and use related services provided under “Motto Electronics Children’s Watch” software and related services based on the location, we will locate by using various information as permitted by you and you can enjoy related services without manually inputting your own geographical coordinates. Such information include iP address, GPS signal and other sensor information containing related location information (if possible, the information of nearby device, WLAN access point and base station are required). We will collect the location information from the mobile terminal and bound watch to enable the basic positioning, School Guard, Vacation Guard and water flooding alarm function. By disabling the positioning function, you can stop providing “Motto Electronics Children’s Watch” software and related services with your geographical location information. As we know, most mobile devices will permit your request for disabling the positioning service (for specific product or service). Please contact your mobile device service provider or manufacturer to know more details.
(4) Phone Book Information: When you enable Recommending Friends based on Phone Book, we will merely collect your phone book information subject to the irreversible encryption to verify whether any person in your phone book has bound the watch and help your children add the person as a friend after your express content is obtained. The above information are sensitive, and your refusal will only result in the failure in enabling the above function without influencing your normal use of “Motto Electronics Children’s Watch” software and related services. Besides, you can disable related functions at any time.
(5)Watch’s Call Function: When you use the watch’s call function, we will obtain the bound watch’s call records to enable the function of refusing strangers’ calls, and related call refusing records in watch will be synchronized to the client terminal of “Motto Electronics Children’s Watch” after your express consent is obtained. The above information are sensitive, and your refusal will only result in the failure in enabling the above function without influencing your normal use of “Motto Electronics Children’s Watch” software and related services. Besides, you can disable related functions at any time.
(6) Step Count Information: When you use the watch’s sports function, we need collect your step count information and compare your step count with your watch friends’. The above information are sensitive, and your refusal will only result in the failure in enabling Parents’ Steps and Watch Friends’ Steps without influencing your normal use of other “Motto Electronics Children’s Watch” software functions.
(7) Micro Chatting Information: When you use Micro Chatting Voice Input, Conversion between Voice and Text and Translation Function, we will collect your voice content, voice or text information to be converted and text to be translated because such collection is essential for realizing the above functions. After our real-time processing, we will return corresponding results without storing your data.
(8) Picture Information: When you enable Micro Chatting Picture and Remote Photo function, your pictures will be sent to the counter-party’s APP via the third party or our Company’s server. After our real-time processing, we will return corresponding results without storing your data.
3. When you use the search service of “Motto Electronics Children’s Watch”, we will collect key words information and device information. In order to provide the high-efficient search service, partial above-mentioned information will be temporarily stored in your local storage device. You understand and agree that, if your personal identity cannot be recognized by separately using key words or combining other information, it shall not belong to legally personal information. In this case, we can use it for other purposes; only when your personal identity could be recognized by separately using key words or combining other information, we will regard such key words entered by you as your personal information, and they will be treated and protected according to this Privacy Policy together with your search history.
4. When you participate in various marketing activities held by us, we may collect your name, mailing address, contact number and bank account information as needed so that you could receive the money transferred by us or corresponding gifts. If you refuse providing these information, we cannot transfer money or send gifts to you.
III. Storage of Personal Information
1.Place of Information Storage
Pursuant to applicable laws and regulations, your personal information collected and generated during the operation in China will be stored within the territory of the People’s Republic of China.
2. Storage Period
We will retain your personal information only during the required period of providing “Motto Electronics Children’s Watch” software and related services, unless otherwise specified in relevant laws and regulations.
IV. Use of Cookie and Similar Technology
1. You understand and agree that, when you use “Motto Electronics Children’s Watch” software and related services, in order to guarantee your easier access experience, we may apply various techniques to collect and store information, during which period, we may send one or several Cookie or anonymous ID to your device.
2. When you use “Motto Electronics Children’s Watch” software and related services, we may use Cookie or similar technology to collect your information so as to know your preference and using habit, provide consultation service or conduct data analysis, improve our service and user experience, enhance the advertising effect, spot and prevent security risk and present you with better service.
3. Except the purpose mentioned in this Privacy Policy, we will not use Cookie for other purposes. You can retain or delete Cookie or clear all Cookies stored in software or web page as needed.
V. Possible Usage Mode of Personal Information
1. In order to realize various functions of “Motto Electronics Children’s Watch” software and related services, we will use corresponding personal information collected according to Privacy Policy. If applied for any other purposes, we will obtain your consent in advance. Specifically, we will collect your personal information for the following purposes:
(1) Provide you with customized high-quality services by means of “Motto Electronics Children’s Watch” software and related services;
(2) Provide you with more related services, replacing traditional advertisements;
(3) Perform ID verification, customer service, security protection, fraud monitoring, filing and backup and guarantee the safety of products and services we provide (if required during our provision of services);
(4) Know more about the way of your access and use of our services through data analysis and accordingly satisfy your personalized needs, including Language Setting, Location Setting and Personalized Help and Instructions etc..
2. In order to maximally guarantee the security of our service and help us better know the operation of “Motto Electronics Children’s Watch” software and related services, we may record the information data about your use of “Motto Electronics Children’s Watch” software and related services, including use frequency, breakdown data, overall usage and performance data etc..
3. For the purpose of bettering your experience, improving our services or for the purpose of using your personal information as agreed, we may summarize corresponding information data collected and then use them to support other services in a personalized way. For example, the information we collect from your use of one service may be applied to provide you with any specific content in another service or display specific information specially related to you. If we provide corresponding options in related services, you can authorize us to apply the information provided and stored via the service to other services.
4. After your personal information is collected, we will technologically erase corresponding data identity so as to reduce the risk of being recognized by other organizations or individuals via the processed personal information. Besides, various technical and management measures will be taken to separately store the processed data and the information applied to recover the identification of personal information. In this case, you shall understand and acknowledge that, we have the right to use the information whose identity is erased, analyze the user data and apply such data for commercial purpose without disclosing your personal information.
5. It shall be noted that, unless you cancel or refuse our data collection and usage through system settings, you shall continuously license us to use all personal information you provide during the use of “Motto Electronics Children’s Watch” software and related services for the purpose specified in this Privacy Policy. After you cease using the service account, we will stop providing “Motto Electronics Children’s Watch” software and related services, and delete your personal information or resort to the anonymization processing as required, unless otherwise specified in applicable laws and regulations.
6. We will summarize the specific usage of “Motto Electronics Children’s Watch” software and related services and may share corresponding statistical data with the public or any third party to demonstrate the overall usage trend of our software and related services, but your personal information are not included.
VI. Possible Sharing Mode of Personal Information
1. We will treat your information with a high degree of diligence. After your express consent is obtained, we may share your personal information with the third party. In addition, we may disclose your personal information to related third parties as per applicable laws and regulations or mandatory government requirements or judicial decisions.
2. After your consent is obtained, we may share your personal information with our affiliated parties. Restricted by the personal information usage mode and purpose you agree in this Privacy Policy, we will only share necessary personal information with our affiliated parties. If affiliated parties indeed require the use of your personal information for the benefit of business beyond the above-mentioned scope of authorization, we need ask for your authorization again.
3. In order to realize some purposes stated in Privacy Policy, some services will be provided by authorized third parties. In this case, we may share some of your personal information with such authorized third parties so as to provide better customer service and user experience. However, we will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share the part of personal information required by the provision of corresponding service. Authorized third parties shall have no right to apply such shared personal information for any other purposes.
4. You shall agree that we could share your personal information with the following third parties:
(1) Software Service Provider, Intelligent Service Provider or System Service Provider. When the third-party software, device and system cooperate with “Motto Electronics Children’s Watch” software and related services to provide you with location-based services, we may collect your location information and related device information (including hardware model, operating system version no., IMEI, network device hardware address (MAC)) based on your authorization and settings of system positioning and share them with the above providers. In special cases, additional information filled in by you will be included as well. If you refuse such information’s collection and usage, you can adjust corresponding system settings or disable the service-providing software.
(2) Advertising Service Provider. Without your authorization, we will not share your personal information with the advertising service provider, but it may be difficult for us to recognize your personal user portrait tag and share it with the advertising service provider to improve the advertising’s effective service rate without recognizing your personal identity. For example, only when the advertisers agree to obey our advertising release regulations can we tell them the advertising’s effect or how many users have watched their advertising or installed their APP, or provide these partners with statistical information (like Female, between the age 25 and 29, in Beijing) that cannot be applied to recognize personal identity for the purpose of helping them know their audiences or customers.
(3) For the third parties sharing your personal information, we will investigate their data security capacity and environment, sign strict confidentiality agreement with them and require them to treat your personal information as agreed by you according to this Privacy Policy and any other related confidentiality and security measures.
(4) As the continuous development of our business, we may conduct M&A, purchasing, asset transfer or similar transactions, and your personal information may be transferred as a part of the transaction. Before your personal information is transferred, we will inform you of corresponding situation and continue to protect or require new controller of your personal information to continue to protect your personal information as per applicable laws and regulations and according to the safety standards stipulated in this Privacy Policy.
5. Without your consent in advance, we will not share your personal information with any third party except the Company and its affiliated parties, unless:
(1)Your express authorization and consent are obtained in advance;
(2)You personally share it with the third party;
(3) It is directly related to national security, national defense security, public security, public health and public interest;
(4) The disclosure or provision of your personal information is required by applicable laws and regulations and mandatory administrative and judicial regulations, or directly related to criminal investigation, prosecution and execution of judgement. According to relevant laws and regulations, when we are required to disclose your personal information, we will ask the counter party to issue corresponding legal documents including summons or inquiry letter. Accordingly, we will prudently review all requests to guarantee their legal basis and only provide the data which can be legally accessed by the administrative and judicial department for a specific purpose;
(5) As permitted by applicable laws and regulations, the disclosure is necessary for safeguarding the life, properties and other legitimate rights and interests of other users, company and its affiliated parties or the safe and stable operation of services, including discovering, preventing and managing frauds and other illegal activities and reducing corresponding credit risks (excluding the disclosure or provision of personal information for the sake of profit by violating this Privacy Policy);
(6) Personal information is collected from the legally publicized information via legal news report, government information publicity and other channels;
(7) Other situations in conformity with applicable laws and regulations.
VII. Personal Information Security Protection
1. Great importance will be attached to the security of your personal information, and we will take various reasonable (technical and management) safety measures consistent with industrial standards to protect your personal information, prevent your personal information from being abused or accessed, publicized, disclosed, used, revised, damaged, lost or revealed without authorization.
2. We will resort to encryption techniques, anonymization processing and other reasonably practicable means to protect your personal information and adopt the reliable protection mechanism to protect your personal information from hostile attack.
3. We will set up the specialized security department, safety management system and data security procedures to safeguard your personal information. We will adopt the strict data use and access system, under which, only authorized personnel can access your personal information. Meanwhile, we will timely carry out the safety audit for corresponding data and technology.
4. You shall understand that, although we have taken the above-mentioned reasonable and effective measures and met various requirements and standards stipulated in applicable laws and regulations, it is still impossible for us to completely guarantee the security of your personal information in the field of Internet due to various technical restrictions and malicious means. We will try our best to safeguard your personal information. You shall understand and acknowledge that, the system and communication network you use to access our service may go wrong due to factors beyond our control. Therefore, we strongly suggest you to take active measures to protect your personal information, including but not limited to using complicated password, changing your password on a regular basis and refusing disclosing your account, password and other personal information to others.
5. We will formulate corresponding Emergency Plan which will be immediately executed if any user information security incident occurs so as to control the resulting consequence and deterioration. In case of any user information security incident (disclosure or loss), we will timely inform you of the basic information and possible impact of such security incident, various measures we’ve taken or we will take, suggestions about independent prevention and risk reduction and measures adopted to compensate your loss according to relevant laws and regulations. We will detail the incident to you by means of notice, E-mail, letter and SMS; if it’s impossible to notify everyone, we will publish an announcement in a reasonable and effective way. In the meantime, we will report the disposal of such user information security incident to the competent supervision department as required.
6. We hereby remind you that, various personal information protection measures stipulated in this Privacy Policy only apply to “Motto Electronics Children’s Watch” software and related services. If you quit from “Motto Electronics Children’s Watch” software and related services and turn to browse or use other websites, services and content resources, we are unable and not obliged to protect any personal information you provided in other APP and websites except “Motto Electronics Children’s Watch” software and related services. Whether your login or browse of the above-mentioned software and website is based on the link or guidance of “Motto Electronics”, we shall not burden any legal liabilities.
VIII. Personal Information Management
We attach great importance to the management of your personal information and will maximally protect your access, revision (update or correction), deletion and withdrawal of consent rights so that you are fully capable of protecting your privacy and security.
(1) related to national security and national defense security;
(2) related to public security, public health and major public interest;
(3) related to criminal investigation, prosecution and execution of judgement;
(4) sufficient evidences prove that you are subjectively malicious or abuse your rights;
(5) response to your request will result in the serious damage to legitimate rights and interests of yours or others and relevant organizations’;
(6) any business secret is involved;
(7) Other situations in conformity with applicable laws and regulations.
IX. Terms of Use for Minors
If you are minor under 18 years old, you shall read and agree this Privacy Policy under the supervision and guidance of your parents or other guardians before you use “Motto Electronics Children’s Watch” software and related services. The Company will protect the minors’ personal information as per applicable laws and regulations and collect, use or disclose the minors’ personal information to the public as permitted by laws or with the express consent from parents or other guardians or for the purpose of protecting children; if we collect the minors’ personal information without obtaining parents’ consent in advance, we will delete relevant data as soon as possible.
X. Changes of Privacy Policy
In order to provide you with better service, “Motto Electronics Children’s Watch” software and related services are subject to update and changes from time to time, and we will timely revise this Privacy Policy. However, such revision shall constitute a part of Privacy Policy and have the same force with Privacy Policy. Without your express consent, we will not weaken your due rights stipulated in existing Privacy Policy. After this Privacy Policy is updated, we will release the updated version via “Motto Electronics” platform (including the mobile application program client terminal and official website) and inform you of updated content in an appropriate way before the updated contents come into effect so that you can know the latest version of Privacy Policy in time.
For significant changes, we will send more effective notice (for example, we will send E-mail, SMS, private message or issue special tips on the browse page to inform you of the specific changes in Privacy Policy).
Significant Changes mentioned in this Privacy Policy include but not limited to major changes in our service mode (the purpose of processing personal information, the type of processed personal information and the usage of personal information), major changes in the ownership structure and organizational structure (all changes caused by business adjustment and bankruptcy and M&A, changes of the object of personal information sharing, transfer or public disclosure), major changes in your right of personal information processing and the exercise of such right, change of the department in charge of processing personal information, corresponding contact information and complaint channels, and changes made when the personal information security impact report is subject to high risk.
XI. Dispute Settlement
Interpretation of Privacy Policy and the settlement of all disputes shall be governed by applicable laws prevailing in the mainland of the People’s Republic of China. When any dispute over the execution of Privacy Policy arises between you and the Company, both parties shall firstly resort to friendly negotiation; if such negotiation fails, you agree to submit such dispute to Futian District People’s Court, Shenzhen for possible solutions as per User Agreement of Motto Electronics.
XII. Others
1. All titles in this Privacy Policy are only for convenient reading and shall not influence the definition or interpretation of any provision stated in Privacy Policy.
2. If you have any comment or suggestion about Privacy Policy or the collection, storage, use, sharing, disclosure and protection of your personal information, you can send your feedback or complaint on “Motto Electronics” function page or by means of “Motto Electronics” user feedback channel. Upon received, we will give you our reply as soon as possible.
3. The copyright of Privacy Policy is owned by the Company; the Company shall retain the right to make ultimate explanations and revisions as permitted by applicable laws.
