Winix Smart PRIVACY POLICY HIGHLIGHTS

WINIX Inc. [295, Gongdan1-daero, Siheung-si, Gyeonggi-do, 15078, Korea] ("We") respect your concerns about privacy. This Privacy Policy applies to your personal information we collect in connection with the services we provide, including in relation to our product Winix Smart (the “Services”).


OVERVIEW OF PRIVACY POLICY

In this Privacy Policy, we describe the types of personal information we process in relation to the Services, how we use your personal information, how long we retain your personal information, with whom we share your personal information, and the choices available to you and your rights regarding your personal information, including the right to opt out from our processing of your personal information. More information about your rights, and how to exercise them, is set out in the Your Rights section below. This Privacy Policy will also tell you how to contact us about our privacy practices. Below is a list of key topics addressed in this Privacy Policy. For more detailed information on how we process your personal information, please click on each heading or continue to read below.

1.Which Items of Personal Information We Collect
2. How We Use Your Personal Information
3. Who We Share Your Personal Information With
4. How Long Do We Keep Your Personal Information
5. Your Choices
6. Your Rights
7. How We Secure Your Personal Information
8. Personal Information of Children
9. Updates to Privacy Policy
10. Contact Us
11. For Californian Residents


 

WINIX PRIVACY POLICY

 

  1. Which Items of Personal Information We Collect
  1. Direct Collection
    • We collect basic identifying information about who our customers are. For example, we may collect information about the profile of the person creating an account (e.g., e-mail, country, registration date).
    • If you register the product, we may collect information about products (e.g., model name, installation region, place).

 

  1. Automatic Collection
    • If you log into the app, we may collect information such as smartphone details (e.g., smartphone model name, os type, os version, language setting, uuid, push token, app version, login date).
    • If the product is connected to wifi, we may collect information such as product details (e.g., product model name, mac address, firmware version, sales country, installation region/place, timezone, control button on/off status, filter life, indoor air quality, wifi pairing history, control history).
    • If you use Alexa we may collect information by technology via the Service, such as Alexa details (e.g., e-mail, AWS Cognito ID, region, registration date, control history).
    • If you use DRS, we may collect information by technology via the Service, such as DRS details (e.g., product mac address, user id, registration date, modification date, certification token, refresh token, order status, status code,, order type, order status detail, delivery status, usage status, DRS history).

 

  1. How We Use Your Personal Information

    2. In this section, we provide the legal ground on which we rely to process your personal information. For each legal ground, we explain the purposes for which we collect and use your personal information.

    To provide you with the Services based on your contractual relationship with us:

    • Provide you with the Services
    • Identify and authenticate you so you may use certain services
    • Respond to your inquiries.

    For further purposes:

    • Effectively manage our relationship with you, including by resolving technical issues, providing you with customer care support and sending you necessary information relating to our Services
    • Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities
    • Monitor use of services and use your information to help us monitor, improve and protect our products and app
    • Effectively manage our business, including by generating reports and analyzing the performance of our Services (through the use of aggregated information), auditing our business processes, using statistics to make informed business decisions.

     

    Upon your consent:

    • Place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used.

    On other occasions where we ask you for consent, we will use your personal information for the purpose which we explain to you at that time. When we rely on your consent to process your personal information, you will have the right to withdraw your consent at any time. To exercise this right, please see the “Your Rights” section below.

     

    Change in purpose:

    We will use your personal information for the purposes of collection, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose of collection. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

     

    For purposes which are required by law:

    • Comply with and enforce applicable legal requirements; or
    • Respond to requests from government or law enforcement.

 

  1. Who We Share Your Personal Information With

    2. We may disclose your personal information in relation to the Services as described below:

    • Affiliates and subsidiaries. Your information may be shared among our affiliates and subsidiaries for the purposes described in this Privacy Policy. The term “affiliates and subsidiaries” refers to companies related to WINIX by common ownership or control. Our affiliates may include companies with the WINIX name or other companies under common ownership or control.
    • Service providers. We may disclose your information to carefully selected companies that provide system development and operation services on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing services for us.
    • Business Partners. Partners who we work together with to provide you with the Services you have requested or bought. For example, we may work with amazon so that you can use Alexa and DRS Services to make more comfortable. These business partners control and manage your personal information.
    • Business Advisors: For example, our lawyers, accountants, business consultants, insurers, auditors, other entities to the extent necessary for them to provide with their services.
    • Other parties if required by law or necessary to protect our Services. There may be instances when we disclose your information to a third party:
    • to comply with the law or respond to compulsory legal processes (such as a search warrant or other court order);
    • to verify or enforce compliance with the policies governing our Services; and
    • to protect the rights, property, or safety of us, our users, or any other individual, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.
    • Other parties to transactions. We may disclose your information to a third party (e.g., the successor or potential successor organization, as well as their professional advisors during the transition) as part of a merger or transfer, acquisition or sale related to our business, or in the event of bankruptcy.
    • Other parties with your consent or pursuant to your request. In addition to the disclosures described in this Privacy Policy, we may disclose your information to third parties when you separately consent to or request such disclosure of your information.
    • Google Analytics / FireBase. We may collect personal information about your online activities on the app. We may use third-party analytics services, such as Google Analytics and Firebase. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Service and to help administer the app. To learn more about Google Analytics, please visit “How Google uses data when you use our partners' sites or apps,” (located at https://www.google.com/policies/privacy/partners/), “Safeguarding your Data” (located at https://support.google.com/analytics/answer/6004245#zippy=) and “Google Analytics Opt-out Browser Add-on” (located at https://tools.google.com/dlpage/gaoptout).

 

  1. How Long We Keep Your Personal Information

    2. We will take appropriate measures to ensure that we only process and retain your information for the duration as required:

    • to provide you with the Services;
    • under law or contract, including, for example, with regard to our statutory obligations under tax laws; or
    • for the purposes for which it was collected and is processed (or longer if required under any contract, by applicable law), or for statistical purposes, in anonymized form, subject to appropriate safeguards.

      • When we no longer need to use your personal information, it will be removed from our systems and records or anonymized so that you can no longer be identified from it.

       

  1. Your Choices

    2. We offer you certain choices in connection with the personal information we collect about you. To limit communications you receive from us, or submit a request, please contact us at privacy@winix.com.

     

  1. Your Rights

    2. Your personal information belongs to you. To the extent provided by applicable law, you can request us to provide details about what we have collected and request for deletion and/or correction of your personal information. You can also request for restriction or limitation to processing, sharing, or transfer of your personal information, as well as for access to your personal information that we have collected so you can use it for your own purposes. However, requesting for deletion of your personal information may also result in a loss of access to Services we provide. We will not be deleting personal information that we are required by law to retain. To make a request concerning your rights or to make an inquiry, contact us at privacy@winix.com.

 

  1. How We Secure Your Personal Information

    2. We take protection of your information seriously and maintain safeguards designed to protect the information we collect in connection with the Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

 

  1. Personal Information of Children

    2. While our Services are designed for a general audience, they are not directed towards children. We do not knowingly collect or solicit information from anyone under the age of 18 or knowingly allow such persons to use our Services. If we discover that we have processed personal information of someone who is under 18, we will take reasonable steps to promptly remove that person’s personal information from our records. If you believe we are processing personal information of a person who is under the age of 18, please contact us at privacy@winix.com.

 

  1. Updates to this Privacy Policy

    2. This Privacy Policy may be updated to reflect changes in our personal information practices with respect to the Services, or changes in the applicable law. We will post a notice on our Services to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice the dates on which it was most recently updated.

 

  1. Contact Us

    2. If you have any queries in relation to this Privacy Policy or to exercise your rights in relation to your personal information, please contact us at privacy@winix.com or via post at WINIX Inc. [295, Gongdan1-daero, Siheung-si, Gyeonggi-do, 15078, Korea]. In addition, the Data Protection Officer can be contacted at dpo@winix.com. You can also contact the competent data protection authority that is the responsible supervisory authority.

 

  1. For Californian Residents

    2. This section supplements the WINIX Privacy Policy and applies solely to Californian residents; that is, if you are protected by the California Consumer Privacy Act (the “CCPA“), the below section will apply to you. In case there is conflict between the above general text of the Privacy Policy and this section, this section will prevail if you are protected by the CCPA.

 

During the 12-month period prior to the effective date of our Privacy Policy, we may have:

  1. Collected the following categories of personal information about you:
    • If you create an account, we may collect basic identifying information(e.g., e-mail, country, registration date).
    • If you log into the app, we may collect information such as smartphone details (e.g., smartphone model name, os type, os version, language setting, uuid, push token, app version, login date).
    • If you register the product and the product is connected to wifi, we may collect information such as product details (e.g., product model name, mac address, firmware version, sales country, installation region/place, timezone, control button on/off status, filter life, indoor air quality, wifi pairing history, control history).
    • If you use Alexa we may collect information by technology via the Service, such as Alexa details (e.g., e-mail, AWS Cognito ID, region, registration date, control history).
    • If you use DRS, we may collect information by technology via the Service, such as DRS details (e.g., product mac address, user id, registration date, modification date, certification token, refresh token, order status, status code,, order type, order status detail, delivery status, usage status, DRS history).

 

  1. Collected personal information about you from the following categories of sources:
    • from your smartphone or your product, for example, through your use of the Services.

 

  1. Collected personal information about you for the following business or commercial purposes (in addition to the purposes listed above in the WINIX Privacy Policy:
    • performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services;
    • auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
    • short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
    • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
    • debugging to identify and repair errors that impair existing intended functionality;
    • undertaking internal research for technological development and demonstration; and
    • undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

 

  1. Shared your personal information with the following categories of third parties:
    • our affiliates, subsidiaries and business partners;
    • vendors who provide services on our behalf;
    • professional services organizations, such as auditors and law firms;
    • a third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy;
    • other third parties when you separately consent to or request such sharing; and
    • government entities, including law enforcement.

 

  1. Sold the following items of your personal information:
  • None

    • (We do not sell your personal information.)

 

  1. Disclosed for a business purpose the following categories of personal information about you:
    • Identifiers such as e-mail, country, registration date, login date.
    • smartphone information such as smartphone model name, os type, os version, language setting, uuid, push token, app version.
    • product information such as product model name, mac address, firmware version, sales country, installation region/place, timezone, control button on/off status, filter life, indoor air quality, wifi pairing history, control history.
    • When interfacing with Alexa and DRS, information such as AWS Cognito ID.

Californian Residents’ Privacy Rights

You may have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

  • categories and specific pieces of personal information we have collected about you;
  • categories of sources from which we collected the personal information;
  • business or commercial purpose for which we collected or sold the personal information;
  • categories of third parties with whom we shared the personal information; and
  • categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. In addition, you have the right to request that we delete the personal information we have collected from you. We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise these rights.

To submit an access or deletion request, click here or contact us as specified in the How To Contact Us section of this Privacy Policy. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.